Order in Respect of Vandana Securities Pvt. Ltd. and Anr

WTM/RKA/IVD/NRO/151/2014
BEFORE THE SECURITIES AND EXCHANGE BOARD OF INDIA

ORDER
UNDER SECTION 11(1), 11(4) (b) AND 11B OF THE SECURITIES AND EXCHANGE
BOARD OF INDIA ACT, 1992 IN RESPECT OF VANDANA SECURITIES PVT. LTD.
AND ITS DIRECTOR MR. I. C. JINDAL
IN THE MATTER OF SHAMKEN MULTIFAB LIMITED.
1. Securities and Exchange Board of India (hereinafter referred to as SEBI) investigated into the
unusual price movement in the scrip of Shamken Multifab Limited (hereinafter referred to as
SML or the company) following an unusual sharp rise in price from 6/- on February 23,
2000 to 25.55/- on July 20, 2000 accompanied with an unusual rise in net traded quantity, from
average traded volume of 9,800 shares in the period May-June 2000 to 92,400 shares during the
period June 21, 2000 to July 18, 2000.
2. The investigation inter alia revealed that
(a). There was a price movement in the share price of SML from 6/- on February 23, 2000
to 25.55/- on July 20, 2000. The analysis of trading has been carried out in two
different trading periods, i.e., February 23, 2000 to June 20, 2000 and June 21, 2000 to
July 18, 2000.
(b). Trading in the scrip of SML was largely concentrated with two stock brokers, namely,
Maheshwari Technical & Financial Services Ltd. (hereinafter referred to as
Maheshwari) and Adroit Financial Services Ltd. (hereinafter referred to as Adroit)
who had entered into large number of cross and structured deals. These brokers were
mainly trading for a common client namely Vandana Securities Ltd. (hereinafter referred
to as Vandana), who was acting as unregistered sub-broker. Adroit had also traded for
its clients, namely, Ms. Sonali Bansal, M/s Shiv Vani Associates and Mr. Moti Ram. The
affairs of firm M/s Shiv Vani Associates and trades of Ms. Sonali Bansal were handled
by one Mr. Amit Bansal (husband of Ms. Sonali Bansal and brother of Mr. Manish
Bansal).
(c). Vandana was mainly trading for Prasneeta and M/s. Dhanvarsha Investments
(hereinafter referred to as Dhanvarsha). Prasneta and Dhanvarsha were linked to each
other. The proprietor of Dhanvarsha, namely, Mr. Jeev Narain Mishra is an employee of
director of Prasneeta. Both Dhanvarsha and Prasneeta had admitted that they were
Order in respect of Vandana Securities Pvt. Ltd. and Anr.
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Page 1 of 11
trading for SML group. They have also stated that they were introduced to SML group
by Mr. P. K. Agarwal who is a Chartered Accountant and also a friend of Mr. Praveen
Juneja, director of SML.
(d). Mr. P. K. Agarwal reportedly played an instrumental role in managing the share price
manipulation for SML. It has been contended by Mr. I. C. Jindal of Vandana that Mr. P.
K.. Agarwal used to place orders on behalf of Dhanvarsha and Prasneeta.
(e). The entire trading in the shares by these clients was for various promoter group
concerns of SML. SML has admitted that their promoter group concerns had acquired
shares from Dhanvarsha. Fund flow trail has also shown that Dhanvarsha and Prasneeta
had received money from SML group concerns for the purpose of trading in the scrip of
SML. SML had also given funds to these entities for acquiring its own shares. It is clear
that SML attempted to influence price rise of its scrip by trading effected through front
entities. Dhanvarsha, Prasneeta and Vandana who did not have certificate of registration
from SEBI to deal in securities.
(f). Further, by creating false market in the scrip, the entities, i.e., stock brokers/Vandana/
Dhanvarsha/Prasneeta/Mr. P. K. Agarwal/SML and its group concerns also apparently
have attempted to induce general public to deal in the scrip. Probably, the motive could
be to exit from the scrip (after booking profit) once general public had been lured into it.
3. In view of the above, a common show cause notice ("SCN") dated August 31, 2004 was issued
under section 11B of the Securities and Exchange Board of India Act, 1992 ("SEBI Act") read
with regulation 12 of the Securities and Exchange Board of India (Prohibition of Fraudulent and
Unfair Trade Practices relating to Securities Market) Regulations, 1995 ("the PFUTP
Regulations, 1995") read with regulation 11 of the Securities and Exchange Board of India
(Prohibition of Fraudulent and Unfair Trade Practices relating to Securities Market) Regulations,
2003 ("the PFUTP Regulations, 2003") by SEBI to Vandana and Mr. I.C. Jindal (hereinafter
collectively referred to as the noticees or by individually by their respective names) calling
upon them to show cause as to why directions under section 11B of the SEBI Act, 1992
including, inter-alia, directions of restraining him from accessing the securities market and
prohibiting them from buying, selling and dealing in securities, should not be issued against him.
In the SCN issued to the noticees it was, inter alia, alleged that
(a). Two brokers of NSE namely Maheshwari and Adroit accounted for approximately 95% of
the total net traded quantity during the relevant period and that both the aforesaid brokers
had mainly traded on behalf of their common client, namely, Vandana.
(b). Vandana acting in the capacity of an unregistered sub-broker had traded on behalf of
Dhanvarsha and Prasneeta. The proprietor/directors of both these entities were linked to
Page 2 of 11
one Mr. P. K. Agarwal, Chartered Accountant, who is admittedly a close friend of Mr. Pravin
Juneja, Director of SML.
(c). The promoter group companies of SML were the final clients and had purchased the shares
through Dhanvarsha and Prasneeta, apparently with a view to create artificial market and rig
the share price.
(d). The flow of transactions that created the artificial market and made possible the sharp rise in
price in SML were as under:
Maheshwari
SML group
P K Agarwal group
Vandana
Adroit
(e). SML group consists of SML and its group companies, namely, Shamken Multifab Ltd., Lotus
Garments P Ltd., Right Credit and Sec Pvt. Ltd., Shamken Spinners Ltd., Kotwan Traders P.
Ltd., Angel Textiles P. Ltd. and Sohit Investments P. Ltd.
(f). The P. K. Aggarwal group consists of Dhanvarsha (Proprietor Mr. Jeev Narain Mishra) and
Prasneeta.
(g). Vandana has traded mainly for the following clients during the period February 23, 2000to
June 20, 2000.
Name of client
Buy
Sell
Gross
Net
Dhanvarsha
Prasneeta
105000
590200
1300
225700
106300
815900
103700
364500
Total
695200
227000
922200
468200
(h). The gross buying by these clients of Vandana was 6,95,200 shares, which was 53.08% of the
total buying of 13,09,600 shares of SML at NSE. The net buying by them was 4,68,200
shares, which was 68.50% of the net total buying of 6,83,500 shares of SML at NSE.
(i). Vandana further informed that during the period from June 21, 2000 to July 18, 2000, all the
trading was done for Dhanvarsh, which had purchased 3,39,000 shares and sold 2,28,800
shares resulting in net buy of 1,10,200 shares. The gross buying by Dhanvarsha through
Vandana was 89.30% of the total trading of 3,79,600 shares.
(j). The director of Vandana, Mr. I. C. Jindal, in his statements recorded on October 18, 2001,
November 28, 2001 and July 09, 2003 stated that Mr. P. K. Agarwal, used to place all the
orders for purchase and sales of SML shares on behalf of these entities. Mr. I. C. Jindal
however stated that no contract notes/bills were issued to clients, only a statement of
Page 3 of 11
(k).
(l).
(m).
(n).
account was used to settle account with clients.

One of the clients of Adroit was Mr. Moti Ram who was introduced by Mr. I. C. Jindal. The
letter sent by SEBI to the available address of Mr. Moti Ram was returned undelivered.
When Mr. I.C. Jindal was asked to explain the trading by Mr. Moti Ram, he stated that a buy
order for 10,200 shares was actually placed by him but wrongly shown in the name of Mr.
Moti Ram by the broker, Adroit. Mr. I.C. Jindal also claimed that payment for this purchase
had been made by him.
Mr. I.C. Jindal's contention that Mr. Moti Ram was wrongly shown as a client by Adroit is
apparently not acceptable as the broker has no incentive for creation of a fresh account in
the name of Mr. Moti Ram. Moreover, as per Adroit, Mr. Moti Ram had executed only one
trade which was placed by Mr. I.C. Jindal and delivery was also taken by him. However, Mr.
I.C. Jindal had an incentive to camouflage his trading. Incidentally, as informed by Mr. Ajay
Gupta of Adroit, Mr. Moti Ram is the brother of Mr. I.C. Jindal. It seems that the name of
Mr. Moti Ram was misused by Mr. I.C. Jindal.
The other clients of Adroit dealing in the scrip of SML, namely, Ms. Sonali Bansal and M/s.
Shiv Vani Associates (Proprietor Mr. Manish Bansal) were introduced to Adroit by Mr. I.
C. Jindal. Mr. Amit Bansal, who is husband of Ms. Sonali Bansal and brother of Mr. Manish
Bansal, was placing orders and receiving deliveries for Ms. Sonali Bansal and M/s. Shiv Vani
Associates.
As admitted by Mr. Manish Bansal, the orders in SML were received from Mr. I. C. Jindal.
Numerous structured deals and cross deals placed by Vandana through two brokers
corroborate the suspicion that it was indulging in creation of false market.
Sett. No.
No. of cross deals
Quantity
shares
of Market Gross
% of cross deals
to Market Gross
Cross Deals through Maheshwari

2000027N
52
2000028N
120
22000
51900
213600
211600
10.00
24.53
2000029N
22400
278200
8.05
46
Cross Deals through Adroit

2000027N
2000028N
62
89
34100
45100
213600
211600
15.96
21.31
2000029N
65
44200
278200
15.89
(o). Some of the instances of cross deals done by Vandana are given below:
Page 4 of 11
Some instances of cross deals through Maheshwari

Date
Trade No.
Price
Quantity
Buying
and Buying and
selling broker
selling client
()
30/06/2000 200006300410402
03/07/2000 200007030029830
03/07/2000 200007030409624
18.75
18.40
19.85
1500
100
500
Maheshwari
Maheshwari
Maheshwari
Vandana
Vandana
Vandana
04/07/2000 200007040201646
05/07/2000 200007050288853
19.85
20.10
500
1200
Maheshwari
Maheshwari
Vandana
Vandana
06/07/2000 200007060301855
20.30
1000
Maheshwari
Vandana
Some instances of Cross deals through Adroit

Date
Trade No.
Price
Quantity
29/06/2000 200006290174079
29/06/2000 200006290251515
()
18.55
19.00
Buying
and Buying and
selling broker
selling client
200
1000
Adroit
Adroit
Vandana
Vandana
03/07/2000 200007030153843
03/07/2000 200007030434711
19.35
19.75
800
2900
Adroit
Adroit
Vandana
Vandana
03/07/2000 200007050557398
20.65
2500
Adroit
Vandana
(p). The settlement wise details of synchronized trades are show below:Sett. No.
No. Average Quantity of Buying member Selling Member Market

of
traded
shares
Gross
Deals price
% to
Market
Gross
()
2000026N
2000027N
7
23
32
18.90
18.53
19.04
4800
6300
24200
Adroit
Maheshwari
Adroit
Maheshwari
Adroit
Maheshwari
2000028N
67
63
19.43
19.41
34000
37600
Maheshwari
Adroit
Adroit
Maheshwari
2000029N
50
42
20.26
23.19
28400
32300
Maheshwari
Adroit
Adroit
Maheshwari
50200
217800
Maheshwari
Adroit
Total
79 21.41
363
55800
213600
8.60
11.29
11.33
211600
15.92
17.77
278200
13.42
11.61
18.04
Page 5 of 11
(q). It emerges from the above that Vandana had apart from dealing as unregistered sub-broker
also actively participated in price manipulation of the scrip.
(r). By being instrumental in attempt to create artificial market in the scrip, influencing the price,
misusing the name of Mr. Moti Ram for dealing in securities, executing numerous cross deals
and structured deals through the aforesaid two brokers, it was alleged that the noticees have
violated provisions of regulation 4(a), (b) and (c) of the PFUTP Regulations, 1995 read with
regulation 4(2)(a) and (e) of the PFUTP Regulations, 2003. Further, by dealing as
unregistered sub-broker, Vandana has also violated rule 3 of the Securities and Exchange
Board of India (Stock Brokers and Sub-Brokers) Rules, 1992 (the Stock Brokers Rules) (since
rescinded) read with section 12(1) of the SEBI Act, 1992.
4. Vide its letter dated September 14, 2004, the noticees filed their reply to the SCN whereby they,
inter alia, made the following submissions:
(a). Vandana is the company making purchase/sale of securities and Mr. I.C. Jindal look after all
sale/purchase transactions of the company.
(b). Mr. P. K. Agarwal approached Mr. I.C. Jindal and asked for purchase/sale of shares of SML
and offered to pay brokerage on such transactions.
(c). The said offer of Mr. P K Agarwal was accepted so that the noticees earn some brokerage.
(d). The noticees were not aware that prior to starting such transactions, a certificate of
registration is required to be obtained from SEBI.
(e). Mr. I.C. Jindal was working with Adroit and Maheshwari as a client.
(f). As soon as Mr. I.C. Jindal came to know about this fact he applied to SEBI for registration
as sub-broker, but his application was rejected.
(g). As the noticees were working with both Adroit and Maheshwari as a client, during the
course of transactions, the noticees innocently executed the work of Mr. P. K. Agarwal, as a
result both the stock brokers discontinued business with the noticees when they came to
know of this fact.
(h). Mr. P. K. Agarwal never disclosed the identity of Mr. Pravin Juneja to the noticees.
(i). The noticees were unaware of this fact that the promoter group companies of SML were the
final clients behind these purchases.
(j). The noticees never assessed that such purchase/sale in the shares was with a view to create
any artificial market or to rig share price as mentioned in the SCN.
(k). Mr. P K Agarwal used to place orders for purchase and sale of SML and a statement of
account was used to be given to settle account with him.
(l). The noticees never intended to manipulate the prices of shares. The noticees used to place
orders to the above said stock brokers as and when instructed by Mr. P. K. Agarwal with the
Page 6 of 11
(m).
(n).
(o).
(p).
(q).
(r).
(s).
(t).
(u).
intention to earn the brokerage only.

All the transaction entered in the name of Mr. Moti Ram belongs to the noticees. Mr. Moti
Ram might have placed some order on behalf of the noticees and told his name to them at
the time of confirmation of sauda. Adroit has opened a separate account in the name of Mr.
Moti Ram and later on transfer the account in the account of the noticees.
The noticees and not Mr. Moti Ram had purchased 10200 shares of SML from Adroit as the
shares were ordered and paid by the noticees. Further, the noticees had taken delivery of the
said shares.
Mr. Moti Ram is the brother of Mr. I.C. Jindal and he had never lived in Delhi or traded in
the capital market. The noticees never misused the name of Mr. Moti Ram.
Mr. I.C Jindal introduced Ms. Sonali Bansal and M/s. Shiv Vani Associates to Adroit during
the course of business. Mr. I.C. Jindal had known Ms. Sonali Bansal and Mr. Manish Bansal
and they wanted to deal in shares.
Mr. I.C. Jindal had introduced Ms. Sonali Bansal and Mr. Manish Bansal in the normal
course of business to Adroit. M/s. Shiv Vani Associates dealt in number of shares, other
than SML with Adroit during the period of business with them.
The noticees do not have any knowledge of cross deals and structured deals as has been
alleged in the SCN. The noticees have placed the orders as and when ordered by Mr. P. K.
Agarwal on the terminals of any of the above said stock brokers available at that particular
time.
Mr. I.C. Jindal had placed all the orders on telephone to Adroit. All confirmations received
from Adroit as well as Maheshwari were being duly confirmed to Mr. P. K. Agarwal.
The noticees never intended to create any false market or to rig price or to cheat public.
The share price of SML remained stable at almost at its highest rates for a long time even
after the noticees discontinued trading in this share.
5. An opportunity of personal hearing was granted to the noticees before the then Whole Time
Member of SEBI on November 7, 2008 and December 12, 2008. Vandana had appeared on
December 12, 2008. However, no order was passed in the matter. Following the principles of
natural justice further opportunities were granted to them before me. However, the notices
issued in this regard were returned undelivered from the last known address of the noticees. The
notices were, therefore, uploaded on SEBI website. However, no response of the Noticees have
been received.
6. I have considered the SCN and other material on record. I note that the Noticees have made
their written submissions but have not utilized the opportunities given for personal hearing. I
conclude that they do not have to submit anything beyond what has been submitted by them in
Page 7 of 11
their written submissions. I, therefore, proceed to decide the matter on merits considering such
written submissions made by the Noticees.
7. Before dealing with allegations and charges, I deem it necessary to refer to the provisions alleged
to have been violated by the Noticees in this case. Those provisions are reproduced as under:SEBI (Prohibition of Fraudulent and Unfair Trade Practices relating to Securities
Market) Regulations, 1995
" 4. No person shall (a) effect, take part in, or enter into, either directly or indirectly, transactions in securities,with the intention of
artificially raising or depressing the prices of securities and thereby inducing the sale or purchase of securities by any
person;
(b) indulge in any act, which is calculated to create a false or misleading appearance oftrading on the securities
market;
(c) indulge in any act which results in reflection of prices of securities based on transactions that are not genuine
trade transactions; "
SEBI (Prohibition of Fraudulent and Unfair Trade Practices relating to Securities
Market) Regulations, 2003
" 4. Prohibition of manipulative, fraudulent and unfair trade practices
(2) Dealing in securities shall be deemed to be a fraudulent or an unfair trade practice if it involves fraud and may
include all or any of the following, namely:(a) indulging in an act which creates false or misleading appearance of trading in the securities market;
......................................................
......................................................
(e) any act or omission amounting to manipulation of the price of a security;"
SEBI Act, 1992
"12. (1) No stock broker, sub-broker, share transfer agent, banker to an issue, trustee of trust deed, registrar to
an issue, merchant banker, underwriter, portfolio manager, investment adviser and such other intermediary who
may be associated with securities market shall buy, sell or deal in securities except under, and in accordance with,
the conditions of a certificate of registration obtained from the Board in accordance with the regulations made
under this Act."
SEBI (Stock Brokers and Sub-Brokers) Rules, 1992
"3. No stock-broker or sub-broker shall buy, sell, deal in securities, unless he holds a certificate granted by the
Board under the Regulations:
Page 8 of 11
Provided that such person may continue to buy, sell or deal in securities if he has made an application for such
registration till the disposal of such application."
8. In this case, it is noted from the SCNs that there was a price rise in the scrip of SML from 6/on February 23, 2000 to 25.55/- on July 20, 2000. Two stock brokers, viz., Maheshwari and
Adroit had entered into cross deals and structured deals in the scrip of SML and through such
transactions they had directly/indirectly influenced the price of the scrip. I further note that
SML and its group concerns including Shamken Spinners Ltd. were the ultimate clients of the
said brokers. These two stock brokers were mainly trading for a common client viz., Vandana,
who was mainly trading for Dhanvarsha and Prasneeta. Gross buying and net buying by these
two clients constituted 53.08% and 35.75% respectively of the total buying at NSE. It is further
noted that clients of Adroit were Vandana, Ms. Sonali Bansal, Shiv Vani Associates and Mr.
Moti Ram. Mr. I. C. Jindal had introduced Ms. Sonali Bansal, Shiv Vani Associates and Mr.
Moti Ram for dealing in the shares of SML. Mr. I.C. Jindal is brother-in-law of Mr. Amit Bansal,
the brother of Mr. Manish Bansal (husband of Ms. Sonali Bansal).
9. I note that cross deals through Maheshwari and Adroit constituted 13.69% and 17.11% of the
gross traded quantity for the market in the scrip of SML. Further, during the period from June
21, 2000 to July 18, 2000, 363 structured deals amounting to 2,17,800 shares were executed by
Maheshwari and Adroit on behalf of Vandana which constituted 28.69% of the gross traded
quantity at NSE in SML shares.
10. The noticees have submitted that shares of SML were purchased/sold for Mr. P. K. Agarwal so
as to earn some brokerage. I note that payments were received by Vandana from Dhanvarsha.
Vandana also received cheques from SML and its directors on behalf of Prasneeta. I further note
Vandana had received cheques from Shamken Spinners Ltd. duly signed by Mr. Pravin Juneja.
Hence, the contention of the noticees that they innocently executed the work of Mr. P. K.
Agarwal who never disclosed the identity of Mr. Pravin Juneja and that they were unaware of
this fact that the promoter group companies of SML were the final clients behind these
purchases does not hold true.
11. I note that several payments have been made by Shamken Spinners Ltd. to Prasneeta,
Dhanvarsha and Vandana. Further, Shamken Spinners Ltd. has bought 2,66,920 shares of SML
from Prasneeta who had purchased through Vandana during March-May 2000. In this regard,
Shamken Spinners Ltd. had made a payment of 49.21 lacs to Prasneeta. Similarly, Shamken
Spinners Ltd. had made payments to Vandana at the instance of Dhanvarsha. In view of these
facts and circumstances, I find that the noticees had traded through the stock brokers
Page 9 of 11
Maheshwari and Adroit on behalf of Dhanvarsha and Prasneeta who were, in turn, trading on
behalf of SML group. Further, these trades of the noticees had resulted in cross deals and
structured deals and had directly / indirectly influenced the share price of SML. Such
transactions executed by the noticees are not genuine and were meant to create artificial volumes
in the market transactions, as held by the Hon'ble Securities Appellate Tribunal (the Honble
SAT) in its order dated August 05, 2011 in Appeal no. 113/2011 - in the matter of GIR
Marketing & Trading Co. Pvt. Ltd. vs SEBI as under:
......As already observed, the seven appellants had a common broker and, therefore, the trades executed by
them were cross deals. Cross deals per se are not illegal but the common broker executing the buy and sell
orders is not expected to match those orders by putting in orders for the same quantity, at the same price and
at the same time. The learned counsel appearing for the respondent Board has placed before us a chart
depicting the trades executed by the appellants on the Calcutta Stock Exchange. We find from the chart that
in most of the cases the buy and sell orders had been put into the system for the same price, same quantity and
at the same time. In other words, it was the common broker who by manipulation was matching the trades on
behalf of the appellants and did not allow the price order mechanism of the exchange to match the trades.
Proceedings were initiated against the broker as well and a statement of its representative was recorded. He
stated that the buy and sell orders had been placed on the specific instructions of the clients who were the
appellants. Having regard to the trading pattern of the appellants and the manner in which the trades had
been matched, we are satisfied that the trades executed by them were non genuine which were meant to create
artificial volumes in the market. We are also satisfied that the appellants have violated Regulations 3 and 4
of the aforesaid Regulations which prohibit persons from directly or indirectly buying, selling or otherwise
dealing in securities in a fraudulent manner. These regulations also prohibit persons from indulging in
fraudulent or unfair trade practices in securities. In this view of the matter, no fault can be found with the
findings recorded by the adjudicating officer.
12. The other clients Mr. Moti Ram, M/s. ShivVani Associates, Ms. Sonali Bansal / Mr. Amit
Bansal, Mr. Kalu Ram Agarwal and Mr. Pavan Mishra were name lenders and were used by Mr.
I. C. Jindal. Shamken Multifab Ltd. and its group concerns including Shamken Spinners Ltd.
were the ultimate clients of the said brokers.
13. Considering the above facts and circumstances of this case, I do not find any material to differ
from the allegations and charges leveled in the SCN and find that the noticees were instrumental
in creating artificial market in the scrip, influencing the price, misusing the name of Mr. Moti
Ram for dealing in securities, executing numerous cross deals and structured deals through
Maheshwari and Adroit and thereby have violated the provisions of regulation 4(a), (b) and (c)
of the SEBI (Prohibition of Fraudulent and Unfair Trade Practices relating to Securities Market)
Page 10 of 11
Regulations, 1995 read with Regulation 4 (2) (a) and (e) of the SEBI (Prohibition of Fraudulent
and Unfair Trade Practices relating to Securities Market) Regulations, 2003. Further, by dealing
as unregistered sub-broker, Vandana has violated rule 3 of the SEBI (Stock Brokers and SubBrokers) Rules, 1992 read with section 12(1) of the SEBI Act, 1992.
14. I am of the considered view that such fraudulent activities pose prudential threat to the market
integrity and orderly development of securities market. I, however, note that the transaction in
question had taken place long back in the year 2000. Further, the SCN that had been issued in
the year 2004 does not clearly bring out the magnitude of contribution of Noticees in the
alleged price and market manipulation in the scrip of SML.
15. Considering the fact and circumstances of this case and the abovementioned mitigating factors,
I, in exercise of powers conferred upon me under section 19 read with section 11(4) and 11B of
the Securities and Exchange Board of India Act, 1992, regulation 11 of the Securities and
Exchange Board of India (Prohibition of Fraudulent and Unfair Trade Practices relating to
Securities Market) Regulations, 1995 read with regulation 13 of the Securities and Exchange
Board of India (Prohibition of Fraudulent and Unfair Trade Practices relating to Securities
Market) Regulations, 2003 hereby restrain Vandana Securities Pvt. Ltd. and its director Mr. I.C.
Jindal from accessing the securities market and prohibit them from buying, selling or otherwise
dealing in securities, directly or indirectly, in any manner, whatsoever, for a period of one year
from the date of this order.
16. This order shall come into force with immediate effect. A copy of the order shall be served on
the Noticees and the stock exchanges for ensuring due compliance with the above directions.
Sd/DATE: DECEMBER 9th, 2014

PLACE: MUMBAI
RAJEEV KUMAR AGARWAL

WHOLE TIME MEMBER
SECURITIES AND EXCHANGE BOARD OF INDIA
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WTM/RKA/IVD/NRO/151/2014

BEFORE THE SECURITIES AND EXCHANGE BOARD OF INDIA

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