Interim Order in The Matter of Radford Global Ltd.

WTM/RKA/ ISD/ 162 /2014
SECURITIES AND EXCHANGE BOARD OF INDIA
EX-PARTE AD- INTERIM ORDER

UNDER SECTIONS 11(1), 11(4) AND 11B OF THE SECURITIES AND EXCHANGE
BOARD OF INDIA ACT, 1992 IN THE MATTER OF FIRST FINANCIAL
SERVICES LTD..
1. Securities and Exchange Board of India ("SEBI") conducted a preliminary inquiry in the
dealings in the scrip pursuant to detection of a huge rise in the traded volumes and price of
the shares of First Financial Services Ltd. {hereinafter referred to as "First Financial"} on the
Bombay Stock Exchange Ltd. ('BSE") during the period from May 15, 2012 to March 31,
2014 (hereinafter referred to as "Examination Period").
2. It was noticed that during the period from May 15, 2012 to February 08, 2013 ("Patch 1"),
the price of the scrip of First Financial rose from 5/- to 263/, i.e. an increase of 5160%
(53 times) in 115 trading days. From February 11, 2013 to December 12, 2013 ("Patch 2"),
the price of the scrip increased from 268 to 296 till July 23, 2013 i.e. an increase of 10%
in 113 trading days and thereafter decreased to 178 as on December 12, 2013 (i.e. a
decrease of 40% in 96 trading days). Subsequently, on December 13, 2013, the equity shares
of First Financial were split in the ratio of 1:10 and thereafter, the price of the scrip fell from
17.7 (effective price as a result of Stock split) to as low as 7 with huge increase in trading
volume during December 13, 2013 to March 31, 2014 ("Patch 3"). An illustration of the
price/volume movement in the scrip of First Financial during the Examination Period and
afterwards is given below:
Chart - I : Price-volume movement in the scrip of First Financial
Total Volume
35
30
25
20
15
10
5
0
Order in the matter of First Financial Services Ltd

Brought to you by http://StockViz.biz
Close Price
5000000
4500000
4000000
3500000
3000000
2500000
2000000
1500000
1000000
500000
0
Page 1 of 29
3. First Financial had a share capital of 37,47,600 comprising 3,74,760 equity shares of
10/- each as on September 30, 2011. On December 08, 2011, First Financial made a
preferential allotment of 54,50,000 equity shares at the price of 20/- per share
(hereinafter referred to as the "1st preferential allotment"). Thereafter on April 28, 2012, it
made another preferential allotment of 24,50,000 equity shares at the price of 20/- per
share (hereinafter referred to as the "2nd preferential allotment"). Thus, in total, First
Financial allotted 77,00,000 equity shares to 83 persons/entities. The equity shares allotted
on preferential basis to aforesaid allottees were locked-in for a period of one year i.e. up to
December 07, 2012 and April 27, 2013 respectively in the instant case in terms of Securities
and Exchange Board of India (Issue of Capital And Disclosure Requirements) Regulations,
2009. Thus, these shares held by the said 83 allottees pursuant to preferential allotment
were not tradable till December 07, 2012 and April 28, 2013 respectively. Subsequently, on
December 13, 2013, the equity shares of First Financial were split in the ratio of 1:10.
Consequent to these actions, paid up share capital of First Financial increased to
80,74,76,000 comprising 8,07,47,600 shares (i.e. an increase of 7,70,00,000 shares) as on
December 31, 2013.
4. From the Annual Reports of First Financial for FY 2011-12 and FY 2012-2013, it was
observed that it is in the business of financing and investment activities and it had earned
a profit of 32,22,148/- during 2011-12 and 47,93,621 during FY 2012-13 respectively.
From the Annual Report of First Financial for the FY 2012-2013 it is observed that for the
FY ended 2012 the earning per shares ("EPS") of First Financial was 0.41/- and for the
FY ended March 31, 2013, EPS was 0.61/-. During the Examination Period there was
no material corporate announcement made by First Financial which could support such
price rise in its scrip. Thus, the sharp rise in the price of the scrip of First Financial during
the Examination Period was not supported by its fundamentals or any other genuine
factor. It is interesting to note that the shares of First Financial were suspended from June,
2000 to July, 2011. Between July, 2011 and May 15, 2012, the scrip of First Financial was
traded only on July 8, 2011 and November 16, 2011. The closing price on these days was
7.12/- and 5.10/- respectively. Strangely, in spite of such fundamentals and tarnished
track record of long period of suspension of trading and below par market price, First
Financial was able to garner funds aggregating to 15,40,00,000/- from aforesaid 83
entities at a premium of 10/- per share within a short span of five months of revocation
of suspension. Investment in a company having such poor and meagre fundamentals
cannot prima facie be termed as a rational investment behaviour. Such investments, as in this
case, normally could be made if the allottees had a nexus with First Financial and its

Page 2 of 29
directors/promoters and the issue of these shares was under a prior arrangement between
them.
5. As a part of the inquiry, SEBI advised BSE to conduct surprise inspection at the registered
office of First Financial to determine inter alia, the following:
a. Whether the company exists at the registered office/corporate office;
b. Whether any operations of the company are conducted at the said address.
6. Accordingly, BSE, on October 31, 2014, conducted a surprise inspection at the registered
office of First Financial (i.e. Old no. 24, 2nd Floor, New no. 45, Venkata Maistry Street,
Mannady, Chennai, Tamil Nadu 600 001) when it was revealed that the said premise was
occupied by another firm in the name of M/s Carewell Enterprises and no
officials/employees of First Financial were available at the time of the said inspection. On
further inquiry, it was learnt that First Financial had recently shifted its base to Mumbai.
On November 07, 2014 BSE also conducted an inspection of the corporate office of First
Financial (i.e. 1513 & 1514, Maker Chamber V, 221, Nariman Point, Mumbai 400 021)
but no employee/official of First Financial was available there nor any operations of First
Financial were being carried out from the said address. It was aloe noticed that on
November 2 and November 4, 2014 First Financial had made two disclosures about shift of
corporate office within Mumbai. However, from visits to all the aforementioned sites it
was revealed that First Financial does not exist at the registered and corporate office
addresses available as per BSEs record, where it is listed.
7. It was observed that within a short period after the 2nd preferential allotment, a significant
increase in the price of the scrip took place which continued during the period of lock in
on the shares allotted to the preferential allotees. Considering the fact that prior to the
preferential allotments, trading occurred in the scrip of First Financial on two occasions
only, the increase in the traded volume in the period after preferential allotment was found
to be substantial. In light of the above, in order to observe the price volume behaviour of
the scrip, the trading in the scrip was analysed in two Patches with a focus on the
following: The trading frequency;
The volume generated;
Contribution to price rise;
Buying behaviour as observed from Last Traded Price ("LTP") data
8. On analysis of trading activity in the Scrip, it was observed that, during the Examination
Period, two sets /groups of entities were mainly involved. While one group of entities was

Page 3 of 29
primarily involved in pushing the price up during Patch-1 (when the shares allotted in
preferential allotments were under lock-in) by contributing to positive LTP through first
trades with negligible order quantity, the other group of entities was acting as buyers in
Patch-2 in order to provide exit to preferential allottees and in the process creating artificial
volume. The role of these two groups is discussed in subsequent paragraphs.
9. During Patch 1 (May 15, 2012 to February 08, 2013), on May 15, 2012, the scrip price
opened at 5.35 and closed at 263.45 on February 08, 2013. During this period, the
scrip was traded with an average volume of 23 shares per day and total volume of 2653
shares in 115 trading days with an average of 1 trade per day. It was observed that price of
the scrip was influenced by certain entities primarily through first trades during this period. It
was noticed that these entities by putting 1 or 2 trades per day with negligible/ very less
quantity of buy order contributed significantly to the price rise. From LTP analysis, it was
observed that price of the scrip increased from 5.35 to 263.45 mainly through first
trades in 115 instances.
10. It was observed that in Patch 1, out of a total of 115 instances of trades establishing new
high price in the scrip, top four entities namely, Prem Lata Nahar, Shyam Kanheyalal Vyas,
Bharat Bagri Bagri and Sumitra Devi Agrawal established new high price on 69 instances.
The contribution of these four entities in establishing new high price was 185/- out of
total price rise of 258/-, which constitutes 72% of the total new high price. The details of
contribution to price rise by these four entities during Patch 1 are as under:
Table I : Contribution to price rise in Patch 1 by top four entities.
Pos
Pos LTP
Contribut Tot Pos
Contribution
ion (in
Contribution of the Client
Client PAN
Client Name
%)
in Securities as a buyer
Prem Lata
AFAPN8764M Nahar
29.01
258.35
74.94
Shyam
ACTPV2787Q Kanheyalal Vyas
19.04
258.35
49.2
Bharat Bagri
AADHB8488A Bagri
12.74
258.35
32.91
Sumitra Devi
ABLPA9728M Agrawal
10.88
258.35
28.1
Total
71.67
258.35
185.15
Count
of LTP
34
16
12
7
69
11. Inquiry also revealed that these aforementioned entities had also traded and were
instrumental in contributing to the price rise of other stocks. Further, Prem Lata Nahar,

Page 4 of 29
Shyam Kanheyalal Vyas and Sumitra Devi Agrawal are also related /connected to Shilpa
Stock Broker Pvt. Ltd. and Bharat Bagri Bagri to BCB Brokerage through whom they have
traded. The details of connection are as follows.
Table II-Basis of connection amongst the entities who established new high prices in
Patch I
Name
Prem Lata Nahar
Shyam Kanheyalal Vyas
Sumitra Agrawal
Bharat Bagri Bagri
Particulars
Prem Lata Nahar is the Mother of Rakesh Nahar who is the
owner/director of Shilpa Stock Broker Pvt. Ltd.
Client of Shilpa Stock Broker Pvt. Ltd. Also huge debit balance
in the client ledger shows that it has been funded by the
broker.
Sumitra Agrawal is the client of Shilpa Stock Broker Pvt. Ltd
and director of Rajat Stock Broking
Promoter/ director of BCB Brokerage Pvt Ltd and share
common address with BCB brokerage.
12. The selection of scrips for trading, the trading pattern and connectivity with brokers cast
doubt on the intent of these entities while trading in the securities market. The sheer number
of scrips with track records of such dubious price and volume rise in which the said entities
and their connected brokers are involved also cast doubt on their conduct in the securities
market. This suspicion gains strength from the fact that when these entities were buying
during Patch-1, shares were being supplied by B.P JhunJhunwala who was connected to First
Financial and was the top net seller during the said period. It was also observed that B.P
JhunJhunwala and his family was the ultimate buyer of the shares sold by the promoters of
First Financial prior to the increase in the price of the scrip. It was noted that P Natarajan, N
Nithya and N Jayanthi sold 80093, 3360 and 570 shares, respectively which were ultimately
bought by B.P JhunJhunwala and his family namely Ruhi Jhujhunwala and Mala
Jhunjhunwala. This prima facie indicates that First Financial, its connected entity and brokers
acting in connivance under a pre-planned arrangement had artificially increased the price
during the lock-in period.
13. During Patch 2 (February 11, 2013 to December 12, 2013), the price of the scrip of First
Financial opened at 263.45 on February 11, 2013 and closed at 178.45 on December 12,
2013. The scrip touched a high of 300 on June 06, 2013. During this period, the scrip was
traded with an average volume of 41,252 shares per day and total volume of 86,21,776 shares
in 209 trading days. As compared to Patch 1, in Patch 2 the average volume increased by
179256% (1793 times) and average price increased by 193 %.

Page 5 of 29
14. On analysis of trading activity during Patch 2, certain entities related/connected to First
Financial were found to be the net buyers to the preferential allottees and thereby created
artificial demand for the supply of shares from preferential allottees. Their interrelationship/connection were noted from the Know Your Client (KYC) details, their bank
statements, off-market transactions amongst them and the information available on the
Ministry of Corporate Affairs ("MCA") website. Considering the large number of these
related/connected entities, it was deemed necessary to shortlist those who were closely
connected to First Financial and/or were instrumental in the price rise and/or contributed in
volume of First Financial during Patch 2 of the Examination Period. These entities were
shortlisted on the basis of following parameters:
a) Top entities based on gross buy/trade quantity;
b) Any other entity who has traded in the scrip and directly or indirectly connected to the
company/ its directors/ entities mentioned in point above
15. The particulars of the above mentioned shortlisted group (hereinafter referred to as the "First
Financial group") and the basis of relationship / connection amongst them are under:
Table -III: Particulars of the shortlisted entities and the basis of connection amongst
them
Sr.
No
1
Name
PAN
Basis of Connection
GLOBAL INFRATECH &

FINANCE LTD.
AABCA4255H
DYNAMIC PORTFOLIO
MANAGEMENT &
SERVICES LTD
AAACD9125E
PADMA IMPEX PRIVATE

LTD.
AAACL4269P
RANISATI DEALER PVT

LTD
RITESH COMMERCIAL
HOLDINGS LTD.
AADCR7368C
RITESH PROJECTS
PRIVATE LTD
AADCR6224M
3
4
5
6
AABCR1974J

Ashok Bothra was the common director

in Global Infratech & Finance Ltd ,
Dynamic Portfolio Management &
Services Ltd , Blue circle Services Ltd and
First financial Services Ltd.
S Krishna Rao was also the director in
First Financial Services Ltd and Global
Infratech & Finance Ltd.
Fund transfer between Global Infratech
& Finance Ltd. and First Financial
Services Ltd.
The shareholder of Padma Impex Pvt Ltd
is Bina hemanshu Mehta with whom First
Financial has huge fund transfer.
Ranisati dealer is the shareholder in
Padma Impex Pvt Ltd among others.
Ranisati Dealer has also appeared in the
bank statement of Comfort Fincap Ltd.
Ritesh commercial and Ritesh Projects are
promoters
of
Dynamic
Portfolio
Page 6 of 29
BURLINGTON FINANCE
LTD.
AABCB2575P
BLUE CIRCLE SERVICES

LTD.
AAACB2131L
MANIMUDRA VINCOM
PRIVATE LTD.
AADCM4316K
10
AMRIT SALES
PROMOTION PVT LTD.
AACCA3220D
11
SYMPHONY MERCHANT
PVT LTD
AADCS5411K
12
BAZIGAR TRADING
PRIVATE LTD.
AABCB3052B
13
PINE ANIMATION LTD.
AAECM0267A
14
FOREVER FLOURISHING
FINANCE &
INVESTMENT PVT LTD
ASTABHUJA
CONSTRUCTION
PRIVATE LTD.
NAVDURGA
INVESTMENT
CONSULTANTS PRIVATE
LTD.
AAACF4311Q
NITYADHARA PLAZA
PRIVATE LTD.
AACCN9567A
15
16
17
AADCN9427C
AACCK2399D

Management & Services Ltd

Fund transfer between Blue Circle
Services Ltd, Pine animation Ltd and
Amrit sales Promotion Pvt Ltd
Panna Lal Maloo is the common director
of Manimudra Vincom Private Ltd.,
Amrit Sales Promotion Pvt Ltd. and
Symphony Merchant Pvt Ltd. Also Fund
transfer between Symphony Merchant
Pvt and Amrit Sales Promotion Pvt Ltd..
Director of Burlington Finance Ltd is
Rabi Paul who is also director in Amrit
Sales Promotion Pvt Ltd.
Bazigar Trading Pvt Ltd has common ph
no with Amrit Sales promotion and
common address with Manimudra
Vincom Pvt Ltd
Fund
transfer
between
Forever
Flourishing Finance and Pine animation
Common
e-mail
id
maloo.kol@gmail.com
The directors of these companies are

common namely Narendra Joshi and
Ratan Pandit.
Ratan Pandit and Anita Jhunjhunwala are
directors in Ruby Traders exporters Ltd
Anita Jhunjhunwala is director as well
shareholder of Subham Communication
in which S Krishna Rao is also a
shareholder
As S Krishna Rao was director of First
Financial Services during the Examination
Period, thus the counterparties are
connected to the company.
S Krishna Rao and Jhunjhunwala group
/family are closely connected as they are
directors as well as shareholders of
various private companies namely
Onesource idea Pvt ltd, Onesource tech
media Pvt ltd, Subham communication ,
Radhasoami securities, Nandlal Vyapaar
Pvt Ltd , Chiraag suppliers Pvt Ltd , LRG
Properties, BPJ Holding etc who have
fund transaction with the company during
Page 7 of 29
18
JAIHANUMAN MULTI
AGENCIES PRIVATE
LTD.
AABCJ6667L
19
MASTER SECURITIES/
MASTER
INFRASTRUCTURE AND
REAL ESTATE
DEVELOPERS LTD
AAHFM8098F
20
DHANLAKSHMI
BROKERS PRIVATE LTD.
AAECD4759L
21
HS TRADECOM PRIVATE
LTD.
AACCH8988B
22
JAYINE TRADECOM PVT

LTD
AACCJ8342D
23
SWARNA PUSHPA
VANIJYA PRIVATE LTD.
HARI OM SUPPLIERS
PRIVATE LTD.
GOLDSTAR TRACOM
PRIVATE LTD.
KALAKAR COMMERCIAL
PRIVATE LTD.
SWARNAPRIYA VANIJYA
AAJCS0597G
24
25
26
27

AABCH2251E
AADCG8045K
AADCK9346B
AAJCS0595E
the Examination Period.

As per the KYC submitted by the trading
member Comfort Securities Pvt Ltd for
its
client
Navdurga
Investment
Consultants Private Ltd. has common
director with that of the company Blue
Circle Services Ltd viz, Dhruvnarayan
Jha.
e-mail id given in the annual report of
Astabhuja Construction Private Ltd. is
dhruvonarayan.jha@rediffmail.com
Directors of Jaihanuman Multi Agencies
Private Ltd. , Gokul Securities pvt ltd and
Rutron International Ltd are same
namely Ashok Hargovindas Soni, Hitesh
Jaswantrai Pandya, Chhaya Ashok Soni
Gokul securities Pvt Ltd is also the
preferential Allottee of First Financial
Services Ltd
Directors of Master Infrastructure And
Real Estate Developers Ltd And Master
Trust are Same Namely Harjeet Singh
Arora, Rajinder Kumar Singhania, Pavan
Kumar
Chhabra,Puneet
Singhania,,Jashanjyot Singh
Master trsut and their directors are also
the preferential allottee in First financial
Ltd
Rakesh
Srivastava
(director
of
Dhanlakshmi) & Punita Srivastava
(Director of HS Tradecom) share
common address i.e 354, Jessore Road,,
Dum dum, Nagar Bazar,, Kolkata,
700074, West Bengal.
Jayine Tradecom and Hs Tradecom have
common
e-mail
id
shefali.khandelwal89@gmail.com
As observed from MCA website, all these
private companies have common director
namely Bishwanath Agarwal & Uttam
Banerjee . Further there have o ff-market
transfer of shares among themselves .
As observed from KYC details they have
common phone no and e-mail id i.e
9830041787 & bishwanath1951 @
Page 8 of 29
28
29
30
31
32
33
34
PRIVATE LTD.
SURBHIKA VYAPAAR
PRIVATE LTD.
NANDAN KANAN IRON
AND STEEL PRIVATE
LTD.
ANCHAL VYAPAAR
PRIVATE LTD.
BNA COMMERCE
PRIVATE LTD.
SANCHAY TRADECOMM
PRIVATE LTD.
SANCHAY TREXIM
PRIVATE LTD.
STARDOX VINIMOY
PRIVATE LTD.
AAJCS0680C
AABCN8968J
AAFCA2480C
AABCB0727D
AAPCS2005M
AAPCS1999E
AAECS0352C
35
R C SUPPLIERS PRIVATE
LTD.
AABCR2904A
36
RAINA VYAPAAR
PRIVATE LTD
AABCR3482R
37
USHITA TRADING AND

AGENCIES LTD.
AAACU3269L
38
WALTARE INVESTMENT
PVT LTD
AAACW2314A
39
BIMAL KUMAR DROLIA
AABCG9640C
40
PARMANAND DROLIA
AABCC0603M
41
ROSHAN KUMAR
DROLIA
AAACF4335Q
42
GRD ENCLAVE PVT LTD
AABCG9641D
43
LIFE LINE MARKETING

PVT LTD.
AAACL5973G
43
LINTON
CONSULTANTANTS
PRIVATE LTD.
BSR FINANCE &
CONSULTANTS PRIVATE
LTD.
AAACL5784F
44

gmail.com
Most of these companies are Shareholders
of Surbhika vyapaar pvt Ltd. Among
others Ritesh Enclave Pvt Ltd and Ritesh
Properties Pvt Ltd are shareholder of
Surbhika Vyapaar who are also promoter
of Dynamic Portfolio Management &
Services Ltd
As observed from MCA website, all these

private companies have common director
namely Biswanath Basak and Swarup
Kumar Dey
Off-market transfer of shares among the

clients
Life line marketing pvt ltd share common
address with Waltare Investment pvt ltd
GRD Securities have acted as broker to all
these clients while dealing in the shares of
First financial. GRD Securities is a group
company of Drolia family.
Parmanand Drolia is the shareholder of
GRD Securities and GRD Securities had
acted as brokers to all these clients.
GRD Enclave is a group company of
GRD Securities in which the directors are
same that is Pramod Drolia, Bimal drolia.
Common director as Dilip das and share

common phone no and common address
AABCB0636K
Page 9 of 29
45
PREFER ABASAN
PRIVATE LTD.
AAECP2470J
46
KRIPA SECURITIES
AACCK2399D
47
PRIDE DISTILLERY
PRIVATE LTD
AACCM6582E
48
SANTOSH KUMAR SHAH
ALGPS0859J
49
MADSAN AGENCIES (P)

LTD.
AACCM0579K
50
MOTOREX FINANCE
PVT. LTD.
AACCM1042R
51
MIDNIGHT AGENCIES
PVT LTD
AABCM6864G
52
EAST INDIA SECURITIES

LTD.
VALUE AND WORTH
AABCE2412N
SHREE SUDHARSHAN
CASTINGS PVT LT
MINIMUM SHARES AND
SECURITIES PRIVATE
LTD.
AADCS9429B
53
54
55
Fund transaction with Comfort Intech who is

connected or related to First Financial as
described in the order
Off-market transfer with Globe Capital
Market and Globe capital Market appears
in the bank statement of Comfort Intech.
Kripa commodities is appearing under the
head unsecured loan of Goldstar Tracom
Private Ltd.
Jagdish purohit is the shareholder of mc
pride distillery as well as of JMD sound
who is a subsidiary of JMD telefilms
industries. JMD sound is also a
shareholder of Onesource techmedia Ltd
in which S Krishna Rao, director of First
Financial is also shareholder.
Santosh Kumar Shah is connected to
Madsan Agencies through off-market
Madsan agencies is connected to East

India Securities and others through offmarket
Vinayshah0004@yahoo.co.in
is
the
common e-mail id for santosh kumar
shah, madsan agencies and shree
sudarshan castings . Further they share
common address
All these clients had bought huge number

of shares of First financial through
Narayan Securities. The Director of
Narayan securities namely Amit Saraf was
the Preferential allottee of First Financial
during the Examination Period.
Further another preferential allottee
namely Pawan kumar Bajaj is also
connected to Amit Saraf as they are
common director in Avyaan Capital
private Ltd.
These entities also share a common
address.
Rajani Investment Pvt. Ltd. And R. K.
AAFFV5756K
AAGCM0970Q
56
RAJANI INVESTMENT
PRIVATE LTD.
AABCR2457G
57
R K INVESTMENT
PRIVATE LTD.
AABCR2488R

Page 10 of 29
58
TOPLIGHT
COMMERCIALS /TARA
CHAND AGARWAL
59
VEENA MOHANLAL
CHANDIRAMANI
NIRMAL KUMAR
MALHOTRA
KIRIT VASUDEO DAVE
60
61
AABCT1134Q
AAWPC3158M
AAUPM6284E
AHKPD0543J
Investment Pvt. Ltd. Are also the

shareholders of Minimum Shares and
Securities Pvt. Ltd.
ISG trader is shareholder of Toplight
commercial among others and also
appearing in the bank statement of
Comfort Intech.
All these clients have traded through
comfort securities who is a connected
entity to First Financial
All these entities have received money
from similar entities namely Keshav
Madhav Enterprises and Madanji
Enterprises who have also provided funds
to Astabhuja Construction, Nityadhara
plaza etc.
16. It is observed that during Patch 2, the preferential allottees were net sellers and entities
forming part of the First Financial group were net buyers, a snapshot of which is given below:Table IV - Exit provided by First Financial Group to Preferential allottees
Gross
Gross sell as
% of Market
Gross
Buy
Gross Buy as % of
Market Gross
6995530
64.65
6065202
56
sell
Preferential
Allottees
First Financial
Group
17. As it can be observed from Table IV, most of the trades took place between the allottees and
the entities of First Financial Group. During the same period, the allottees were found to be
selling and in the process making a huge profit/gain. It is observed that 80 allottees made a
collective profit of a 172.21 Crore on a collective investment of 14.50 Crore, a whopping
return of approximately 1087 % on their investment in a period of 20-24 months (including
the lock in period of the shares allotted in the preferential allotment). This profit was
obtained in a stock where the fundamentals/financials of the company do not justify the
price. It is evident from the above analysis of Patch 2 that the entities of First Financial Group
provided a hugely profitable exit to the allottees. The profit/gain earned by the allottees
during Patch 2 is given below:-

Page 11 of 29
Table: V- Profit made by the preferential allotees

Shares Shares Cost
Allotte sold
price of Gross Sell
Name
d
shares
Value
sold
Sr.
No
1
2
MASTER COMMODITY
SERVICES LTD.
GIRIRAJ PRASAD MANIHAR
3
4
Profit
(in )
75000
25000
240000
25000
1500000
500000
58790800
7318400
57290800
6818400
KRISHAN KUMAR DAGA

N K AGARWAL &SONS
50000
100000
50000
100000
1000000
2000000
14531750
29379910
13531750
27379910
5
6
7
RAMESH KUMAR DAGA

NARESH GARG
SANGEETA GARG
50000
250000
200000
50000
120100
178000
1000000
5000000
4000000
14512000
34696990
50261750
13512000
29696990
46261750
8
9
TUSHAR DHIRAJLAL MEHTA

MASTER TRUST LTD.
50000
75000
50000
85000
1000000
1500000
13973771
17624650
12973771
16124650
10
HASHMUKHBHAI B PATEL
HUF
375000
35000
7500000
10071508
2571508
11
H N PARWAL
50000
50000
1000000
14688550
13688550
12
13
SANJAY DAGA
KETAN DHIRAJLAL KAPASI
50000
75000
50000
75000
1000000
1500000
14528000
22073918
13528000
20573918
14
15
DRAKE PROPERTIES
PRIVATE LTD.
ANIL AGRAWAL HUF
50000
250000
50000
249900
1000000
5000000
14534250
72540759
13534250
67540759
BITTHAL DAS PARWAL

NAVRATANMAL JEETMAL
GANNA
50000
50000
1000000
14705000
13705000
50000
50000
1000000
14022850
13022850
VIMAL KUMAR MANTRI

DHIRAJLAL MAGANLAL
MEHTA
25000
25000
500000
7364800
6864800
50000
50000
1000000
14326875
13326875
75000
75000
1500000
21984438
20484438
21
BHARAT RAMJIBHAI MANEK

CHETAN RAMJIBHAI
MANEK
75000
75000
1500000
21984612
20484612
22
GOKUL SECURITIES
PRIVATE LTD.
300000
300000
6000000
81397817
75397817
23
MUKESH ATAL MUKESH
50000
50000
1000000
14702000
13702000
16
17
18
19
20

Page 12 of 29
ATAL (HUF)
24
25
27
AASHISH V AGGARWAL
BAL KISHAN & SONS HUF
AMIT HASMUKHBHAI
PATEL
RAJENDRAKUMAR
AGARWAL HUF
28
29
RAJNI ATAL
RAJESH ATAL
26
50000
50000
40000
50000
1000000
1000000
11807946
14693300
10807946
13693300
375000
625000
7500000
55706489
48206489
75000
75000
1500000
21902905
20402905
50000
50000
50000
50000
1000000
1000000
14728900
14718580
13728900
13718580
100000
100000
2000000
24963016
22963016
50000
50000
1000000
13993425
12993425
50000
50000
1000000
13943850
12943850
200000
200000
4000000
58291100
54291100
32
SYNCOM FORMULATIONS
(INDIA) LTD.
JINESHNAVRATANMALGAN
NA
VIKASNAVRATANMALGAN
NA
33
DEVSHIBHAI
PARSHOTTAMBHAI
DUNGRANI
34
AMIT SARAF
50000
50000
1000000
14755240
13755240
35
36
PAWAN KUMAR BAJAJ

GIRISHBHAI PATEL HUF
50000
50000
50000
50000
1000000
1000000
14718000
12578951
13718000
11578951
37
38
RITESH AGARWAL HUF

HARJEET SINGH ARORA
75000
50000
75000
50000
1500000
1000000
21931343
14184180
20431343
13184180
39
40
41
SARLA DHIRAJLAL MEHTA

SAMIR HARSHADRAI DOSHI
KAMAL KHEMKA
50000
50000
250000
50000
50000
66030
1000000
1000000
5000000
14307762
14728680
19106304
13307762
13728680
14106304
42
50000
50000
1000000
14753670
13753670
43
KULBIR SINGH
BHARATBHAI NATHABHAI
BUHA
50000
50000
1000000
14703371
13703371
44
45
SUNDER SOMANI
KARUNA ATAL
75000
50000
75000
50000
1500000
1000000
20512201
14718700
19012201
13718700
50000
52500
1000000
15495975
14495975
50000
50000
50000
50000
1000000
1000000
14683020
14736600
13683020
13736600
30
31
46
47
48
DHEERAJ KRISHNA
AGARWAL
RAJINDER KUMAR
SINGHANIA
PARVEEN PARVEEN

Page 13 of 29
SINGHANIA
49
50
SURESH KUMAR
KHANDELIA
MANJU KHANDELIA
112500
100000
112500
100000
2250000
2000000
31245539
27897219
28995539
25897219
51
52
PREM JAIN
HARNEESH KAUR ARORA
125000
50000
125000
50000
2500000
1000000
36623649
14524450
34123649
13524450
53
54
55
GAURAV JAIN
SUNITA CHAUDHARY
SANJIV CHAUDHRY
125000
150000
150000
125000
150000
150000
2500000
3000000
3000000
36310325
40657450
40755752
33810325
37657450
37755752
56
GOPALBHAI
PARSHOTAMBHAI
DUNGARANI
200000
200000
4000000
58319451
54319451
57
58
NANDITA BHAVESH
MADIYAR
SANTOSH MANIHAR
50000
25000
50000
25000
1000000
500000
14744850
7355600
13744850
6855600
59
60
VINAL ARVIND KAPASI

SURESH KUMAR KALANI
75000
100000
75000
100000
1500000
2000000
22067915
29456462
20567915
27456462
61
ASHOKBHAI NATHABHAI
BUHA
50000
50000
1000000
14590648
13590648
62
BRIJ BHUSHAN SINGAL
225000
225000
4500000
65749627
61249627
63
64
NARAYAN PRASAD
MUNDHRA
SHILPA AGARWAL
100000
75000
100000
75000
2000000
1500000
28845604
21843585
26845604
20343585
65
66
PRIYANKA GANNA
SHILPA GANNA
50000
50000
50000
50000
1000000
1000000
13949708
13965480
12949708
12965480
67
50000
50000
1000000
13844535
12844535
68
RUPAL TUSHAR MEHTA

MANJUDEVI N MUNDRA
MUNDRA
100000
100000
2000000
28869249
26869249
69
70
CHAMPAKBHAI MANUBHAI
SOPARIWALA
BHARATI BHARAT MANEK
50000
75000
50000
75000
1000000
1500000
14245180
22022488
13245180
20522488
71
72
ANSHUL JAIN JAIN

NEERAJ SINGAL
50000
225000
50000
225000
1000000
4500000
14597500
64835211
13597500
60335211
73
UMA SONGAL
RAJKUMAR TEJBAHADUR
SINGH
75000
75000
1500000
22178900
20678900
50000
52000
1000000
15349975
14349975
74

Page 14 of 29
75
PUNEET SINGHANIA
50000
50000
1000000
14546735
13546735
76
77
AAMIR NAWAB MEHJABEEN

MALIK
JASHANJYOT SINGH
87500
50000
87500
50000
1750000
1000000
25605054
14687586
23855054
13687586
78
79
HIMANSHU C SOPARIWALA
HARSHITA MAHESHWARI
50000
25000
50000
27000
1000000
500000
14426965
7927996
13426965
7427996
80
ANJALI DAGA
50000
50000
1000000
TOTAL
14378300 13378300
186709788 172209788
7250000 6995530 145000000
9
9
18. The transactions wherein the entities of First Financial group bought most of the shares sold
by the allottees cannot be just a coincidence particularly when sellers have nexus with First
Financial and its promoters/directors and buyers are the entities connected with First
Financial and its promoters /directors. From the analysis presented for Patch 1, it was
established that the shares of First Financial were not in demand by the general investors of
the market and saw very low volume on most of the trading days and hence could not have
commanded the price as observed in Patch 2. In any market, a sudden supply if not
matched by similar demand leads to price fall. Considering the same, any rational investor
would not have dumped a large number of shares without facing the risk of a significant
price fall until and unless he was sure of the demand side absorbing the supply. In this
peculiar case, the entities of First Financial Group created the demand against the supply
from the preferential allottees. In the whole process, the principle of price discovery was
kept aside and the market lost its purpose. It is evident from the above analysis that the
Financial group entities provided a hugely profitable exit to the allottees. This could be only
possible if the allottees, First Financial entities and First Financial and its promoter/ directors
were hand in glove with each other. The said finding is also corroborated by the fact that in
few instances/ cases, it is observed that the buyers are related /connected entities of
preferential allottees.
19. During Patch-3 (December 13, 2013 to March 31, 2014) i.e pursuant to the stock split,
price of the scrip opened at 17.7 on December 13, 2013 and fell to as low as 7 as on
March 31, 2014. During this period, it was noticed that the scrip was traded with an
average volume of 8,02,667 shares per day and total volume of 6,01,90,286 shares in 75
trading days. On analysis of trading activity during Patch-3, it was noticed that the top
buyers among others include Minimum Shares And Securities Private Ltd., Rajani
Investment Private Ltd., R K Investment Private Ltd, Pride Distillery Pvt Ltd, Veena

Page 15 of 29
Mohanlal Chandramani, Kirit Vasudeo Dave and Nirmal Kumar Malhotra who had bought
in total 2,43,93,430 shares comprising of 41% of gross buy to the market gross buy volume
during the said period. These clients have traded through Narayan securities and Comfort
securities that are related / connected to the Preferential allottees and company First
Financial respectively in the manner as described in the table above (basis of connection).
20. Thereafter, the trading volume in the scrip decreased in the quarter ending June 2014 and
again started increasing from August 2014 onwards. It was also noticed that the price of
the scrip increased from 9 to a high of 24 during August, 2014 to October 2014 and
the total trading volume also increased to 50,28,803 which is 1.6 times higher than the
trading volume of 31,00158 shares during April to June 2014. From the trade data it is
prima facie observed that connected /related clients namely Kripa securities Pvt. ltd, Padma
Impex Private Ltd , Atash transport Pvt. Ltd, Pride Distillery are found to be top net
sellers among others during this period August, 2014 to October 2014. It is pertinent to
mention that Kripa securities Pvt. ltd, Padma Impex Private Ltd and Pride Distillery were
buyers during Patch II, whereas, directors of Atash transport Pvt. Ltd were preferential
allotees of the shares of First Financial and there were fund transactions between Atash
transport Pvt. Ltd and First Financial during the Examination Period.
USE OF FUNDS RECEIVED THROUGH PREFERENTIAL ALLOTMENT
AND CONNECTION BETWEEN PREFERENTIAL ALLOTEES AND FIRST
FINANCIAL
21. From the copies of the special resolutions dated August 25, 2011 and March 12, 2012,
passed under section 81(1A) of the Companies Act, 1956 as available on BSE website it is
noted that First Financial had disclosed to its shareholders and public that the purpose of
aforesaid fund raising through preferential allotment was to meet following requirements
To expand the segment of Corporate Advisory Service like exploring refinancing

alternatives of the clients and advising better sources of funds available.
To enter in to the spectrum of Loan / Debt Syndication, which is the need of the hour
for all corporate and to provide a comprehensive suite of advisory services packaged
with resource raising.
To enter in to segment of arranging Equity Placement / Strategic partners for corporate

clients.

Page 16 of 29
To expand the geographies of the company by penetrating to the major clients such as
Mumbai and Delhi by opening the branches therein.
22. From an examination of the P&L account for the period 2011-12 and 2012-13 it is
observed that there is no receipt of advisory fee. Which implies that the company did not
enter into any fee based activities which it had stated in the resolution for approval of
preferential allotment by shareholders. Further, from an examination of the balance sheet
of First Financial for the FY 2011-12 and 2012-13 it is observed that the company has no
fixed assets and no capital work in progress. As far as expansion of geography by opening
branches in Mumbai and Delhi is concerned, it is already discussed above that company is
unavailable both at its corporate office as well as Registered office. Further the annual
report indicates that company during the Examination Period is basically into trading or
investment activities of its related/connected companies which is again not supported by
the above resolution of arranging equity placement, Loan /Debt syndication etc. This prima
facie indicate that the purpose mentioned by the company to raise funds through
preferential allotment is just an eye-wash to the investor in general and was never done
with an real intent.
23. During preliminary inquiry it was observed from the bank statement of First Financial that
money received through two preferential allotments of equity shares was immediately
transferred to the following entities as shown below:Table : VI: Transfer of money after the preferential allotment
1st Preferential Allotment
Entities
First Financial (other bank A/c)
Bina Hemanshu Mehta
Parikh Group (Chetan S Parikh HUF, Pankaj S Parikh,
Vinod S Parikh, Kajal P Parikh, Dhara V Parikh, Dipal C
Parikh, Megha P Parikh)
Marsh Steel Trading
Vision Steel Ltd
Noble Express Services Pvt. Ltd
Values (approx.)
1,20,00,000
2,42,00,000
4,36,80,000
1,00,00,000
50,00,000
5,00,000
Comfort Group comprising Comfort Fincap Ltd, Comfort

Intech Ltd, Comfort Securities.
2nd Preferential Allotment
1,30,00,000
Comfort Group (Comfort Fincap Ltd, Comfort Intech
2,48,36,757

Page 17 of 29
Ltd, Comfort Securities)

Tirupati Developers Pvt. Ltd
Advent Developers Pvt. Ltd
Kuber Kamana Marbles
Chiraag Suppliers Pvt. Ltd
5,00,000
40,00,000
1,05,00,000
50,00,000
24. From the fund statement analysis, it is observed that funds received as proceeds of
preferential allotment were immediately transferred to various entities on the same day or
next day and was never retained in the company for expansion of its business or execute its
future plans as envisaged in the special resolution passed under section 81(1A) of the
Companies Act, 1956. The whole system of fund transfer looks as if the transferor and
transferee are pre-determined and funds are being routed through various channels before
reaching the end users who are basically the buyers in Patch-2 that provided exit to the
preferential allottees. It is also pertinent to mention that several preferential allottees such
a those belonging to the Singal family, namely Brij Bhushan Singal, Neeraj Singal, Ritu
Singal and Uma Singal (who were allotted 7,50,000 shares by First Financial at a cost price
of 1.5 crore) indirectly received the funds back from First Financial in the name of
investment by First Financial or otherwise.. One such instance (mentioned in the above Table)
is where 1.5 crore have been transferred to Marsh Steel Trading Ltd and Vision Steel
Ltd for the purpose of investment as indicated in Annual Report of FY 2011-12 whose
promoters are Singal family. Thus the above events prima facie indicates that money
received through preferential allotment were again routed to the same source i.e. Singal
family. Inquiry also revealed that members of Singal family have been preferential allottees
in such type of companies which have a history similar to that of First Financial . From the
above facts, it prima facie emerges that a number of entities who were the preferential
allotees in the present case, were regularly investing in companies for namesake and the
money invested by them in these companies was being returned to them indirectly.
25. It was noticed that the entities who had received funds from First Financial after the
preferential allotment had later transferred funds to First Financial. Again these funds were
further transferred from First Financial to various entities and majorly to Comfort Group. It
was further observed from the bank statement that an approximate amount of 11 crore
has been transferred to Comfort Group whereas only 4.10 crore received during the
Examination Period. Other events occurred during the Examination Period that
substantiate the relationship between First Financial and Comfort group is as follows:

Page 18 of 29
Table : VII: Relationship between First Financial and Comfort group

Name
Anil Agrawal HUF
Jugal Chandrakant
Thacker
Lakshya Global
Logistics
BLC Trading
Agencies
Suresh Khandelia
and Manju
Khandelia
A. K Nevatia
Ranisati Dealer Pvt
Ltd and Prefer
Abasan pvt Ltd
Transaction details
Director of Comfort Group as well as the preferential allotee
of First Financial
Director of Comfort group and had received 15 lac from
First Financial during Examination Period.
Directors of Lakshya Global Logistics are Preferential allotee
of First Financial
Transfer of Fund between Lakshya Global Logistics and First
Financial and transfer of fund between Lakshya Global
Logistics with Comfort Intech
Company had fund transfer with First Financial as well as with
Comfort Intech
Promoter of Comfort Fincap Ltd as well as preferential
allottee of First Financial
A. K Nevatia is the director of Comfort Group and also the

director of Splash Media Infra Ltd in which First Financial has
invested during the Examination Period.
Both the entities are counterparties as buyers to preferential
allottees and have also appeared in the bank statement of
Comfort Fincap Ltd / Comfort Intech Ltd.
26. This prima facie indicates that Comfort group and its directors share a close relationship
with First Financial which cannot be termed as mere commercial/business relationship.
Further on analysis, it is observed that comfort securities had been broker to majority of
the top buyers during Patch-2 which again cannot be a mere coincidence. Thus the above
findings prima facie indicate that Comfort group has played a key role in the whole process
of preferential allotment that has resulted into huge profitable exit to the preferential
allottees of such a stock that has hardly any intrinsic value.
27. It was also observed that the entities, to whom funds were transferred by First Financial,
included two private companies namely, Chiraag Suppliers Pvt. Ltd and Nandlal Vyapaar
Pvt. Ltd who were related/connected to First Financial and to whom 1 crore of was
transferred during the Examination Period. It was observed from MCA database that
among others, S Krishna Rao and Stanley Gilbert Mekhasingh, who were also directors of
First Financial , held shares in these two companies at that point of time.
28. From the analysis of bank statements and financial statements, it is observed that funds
received as proceeds of preferential allotment were immediately transferred to various

Page 19 of 29
entities on the same day or next day and was never retained in the company for expansion
of its business or execute its future plans as envisaged in the special resolution passed
under section 81(1A) of the Companies Act, 1956. The company representative/ company
also could not satisfactorily explain the nature of conduct of its business and the final
purpose for which the funds were actually utilised. The fund movement, therefore,
indicates routing of money through various channels before it reaches the end users to
provide exit to the preferential allottees.
29. On analysis of bank statement of few top buyers, it is observed that these entities bank
accounts had huge inflow of funds from different entities and the outflow is primarily to
the trading member towards purchase of shares. It was also observed that entities from
whom funds have been received are similar in cases of top buyers whose accounts are
analysed. This shows that all the top buyers are related to each other.
30. A similar fund flow pattern was observed across all the First Financial group of entities who
were found to be trading in Patch 2. It was observed that all of the First Financial group
entities providing an exit to the allottees, received funds from various sources and the
money received was transferred to their trading member towards purchase of shares of
First Financial. Most of the First Financial Group entities are private Ltd. companies, engaged
in various kind of businesses. However, the analysis of bank account statement reveals that
they are only indulged in routing of funds. On most of the instances, the funds received by
them were immediately transferred to a trading member or to another entity. It was
observed that there was a significant layering by way of funds transfers hiding the true
identity of ultimate owner.
31. From the above examination and factors as discussed hereinabove, I note that the allottees,
First Financial and First Financial group entities are connected to each other. In this regard, I
note that Hon'ble SAT has, in many cases such as Classic Credit Ltd. vs. SEBI (SAT Appeal
no. 68/2003, Order dated December 8, 2006), Classic Credit Ltd. vs. SEBI (SAT Appeal no.
76/ 2003, Order dated January 9, 2007) and Veronica Financial Services Ltd. vs. SEBI (SAT
Order dated August 24, 2012), held that connection/relations can be established on the
basis of factors including the common addresses, common directors/ shareholders, etc.
32. It is pertinent to mention that the key to the scheme of operations employed by the First
Financial Group lies in the preferential allotment of shares made by First Financial. Due to a
lock-in of one year on shares any gains made on the sale of such shares makes them
eligible for long term capital gains. From the observations of preliminary inquiry it is inter
alia noted that :-

Page 20 of 29
a) the fund brought in by way of preferential allotment was utilised for purposes other
than those disclosed and extended by way of purported loans to companies through
informal arrangements;
b) even when substantial number of shares i.e. 77 lakh shares were locked-in and non
transferable / tradable, price of the scrip increased substantially to the extent of 5160%
with small chunk of volume / purchases by certain entities;
c) After the expiry of the lock-in period (i.e. in Patch 2), the average volume increased
astronomically to the extent of 179256% (1793 times) and average price increased by
197%. Such increase in volume was mainly on account of matched trading amongst
First Financial group entities and allottees
d) 80 out of the 83 preferential allottees sold total 6995530 shares allotted to them by First
Financial at the price increased on account of the aforesaid manipulative trading in
Patch 1;
e) The funds required for purchase of shares by the First Financial group entities had been
provided to them through layering of fund transfers.
33. From the above facts and circumstances it can reasonably be inferred that the preferential
allottees acting in concert with First Financial group have misused the stock exchange system
to generate fictitious long term capital gains ("LTCG") so as to convert their unaccounted
income into accounted one with no payment of taxes as LTCG is tax exempt. I prima facie
find that the above modus operandi helped the concerned entities to pay a lower rate of tax
on account of LTCG and helped them to show the source of this income to be from
legitimate source i.e. stock market.
34. Considering the above, I am of the view that the preferential allotment was used as a tool
for implementation of the dubious plan, device and artifice of First Financial group and
allottees. One could argue that in the order to make LTCG , the preferential allottees in
question could have bought in secondary market and waited for a year before selling the
shares. In the instant case, probably the preferential allotment route was preferred over
secondary market route because the share capital of First Financial prior to preferential
allotment was very small i.e. 3,74,760 equity shares (face value 10) to accommodate the
required fictitious LTCG of 172 crore approximately. As such the capital expansion
through preferential allotment and sock split provided much bigger source to the persons
involved in terms of volume and price manipulation to facilitate the whole operation.
35. Since prior to the trading in its scrip during the Examination Period, First Financial did not
have any business or financial standing in the securities market, in my view, the only way it
could have increased its share value is by way of market manipulation. In this case, it is

Page 21 of 29
noted that the traded volume and price of the scrip increased substantially only after First
Financial group and allottees started trading in the scrip. The average volume increased by
179256% (1793 times) during the Examination Period i.e. from 23 shares per day to 41,252
shares per day & the price increased by 5160% (53 times) during the Examination Period,
i.e. 5 to 263. First Financial group entities were trading in the scrip above the LTP and
their trades resulted into artificial increase in price. Thus these group of entities
manipulated the price of the scrip during the Examination Period. I further note that, First
Financial group entities and allottees traded amongst themselves as substantiated by their
matching contribution to net buy and net sell in Patch 2. There was no change in the
beneficial ownership of the substantial number of traded shares as the buyers and sellers
both were part of the common group and were acting in league/concert to provide LTCG
benefits to the allottees. I prima facie find that First Financial group and allottees used
securities market system to artificially increase volume and price of the scrip for making
illegal gains to and to convert ill-gotten gains into genuine one.
36. I am of the considered view that the schemes, plan, device and artifice employed in this
case, apart from being a possible case of money laundering or tax evasion which could be
seen by the concerned law enforcement agencies separately, is prima facie also a fraud in the
securities market in as much as it involves manipulative transactions in securities and
misuse of the securities market. The manipulation in the traded volume and price of the
scrip by a group of connected entities has the potential to induce gullible and genuine
investors to trade in the scrip and harm them. As such the acts and omissions of First
Financial group and allottees are fraudulent as defined under regulation 2(1)(c) of the SEBI
(Prohibition of Fraudulent and Unfair Trade Practices relating to Securities Market)
Regulations, 2003 (PFUTP Regulations) and are in contravention of the provisions of
Regulations 3(a), (b), (c) and (d) and 4(1), 4(2)(a), (b), (e) and (g) thereof and section 12A(a),
(b) and (c) of the Securities and Exchange Board of India Act, 1992. The said provisions
are reproduced hereunder:SEBI ACT
Prohibition of manipulative and deceptive devices, insider trading and
substantial acquisition of securities or control.
"12A. No person shall directly or indirectly
(a) use or employ, in connection with the issue, purchase or sale of any securities listed or proposed to be
listed on a recognized stock exchange, any manipulative or deceptive device or contrivance in
contravention of the provisions of this Act or the rules or the regulations made thereunder;

Page 22 of 29
(b) employ any device, scheme or artifice to defraud in connection with issue or dealing in securities
which are listed or proposed to be listed on a recognised stock exchange;
(c) engage in any act, practice, course of business which operates or would operate as fraud or deceit upon
any person, in connection with the issue, dealing in securities which are listed or proposed to be listed on
a recognised stock exchange, in contravention of the provisions of this Act or the rules or the regulations
made thereunder;"
PFUTP Regulations
"3. Prohibition of certain dealings in securities
No person shall directly or indirectly
(a) buy, sell or otherwise deal in securities in a fraudulent manner;
(b) use or employ, in connection with issue, purchase or sale of any security listed or proposed to be listed
in a recognized stock exchange, any manipulative or deceptive device or contrivance in contravention of
the provisions of the Act or the rules or the regulations made there under;
(c) employ any device, scheme or artifice to defraud in connection with dealing in or issue of securities
which are listed or proposed to be listed on a recognized stock exchange;
(d) engage in any act, practice, course of business which operates or would operate as fraud or deceit upon
any person in connection with any dealing in or issue of securities which are listed or proposed to be listed
on a recognized stock exchange in contravention of the provisions of the Act or the rules and the
regulations made there under.
4. Prohibition of manipulative, fraudulent and unfair trade practices
(1) Without prejudice to the provisions of regulation 3, no person shall indulge in a fraudulent or an
unfair trade practice in securities.
(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;
(b) dealing in a security not intended to effect transfer of beneficial ownership but intended to operate only
as a device to inflate, depress or cause fluctuations in the price of such security for wrongful gain or
avoidance of loss;
.
(e) any act or omission amounting to manipulation of the price of a security;
.
(g) entering into a transaction in securities without intention of performing it or without intention of
change of ownership of such security;"
37. I note that the directors of First Financial during the relevant time (i.e. S Krishna Rao,
Stanley Gilbert Felix Melkhasingh and Sambasivaiyer Swaminathan), being in control of

Page 23 of 29
the day to day affairs of First Financial, had the knowledge of its acts and omissions. They
were also under an obligation to ensure that the acts and transactions of First Financial were
not in violation of any of the applicable provisions of SEBI Regulations or other applicable
laws. I, therefore, prima facie find that S Krishna Rao, Stanley Gilbert Felix Melkhasingh,
Nirmal Singh Mertia and Sambasivaiyer Swaminathan were responsible for First Financial 's
acts and omissions in this case.
38. I am of the opinion that a detailed investigation of the entire scheme employed in this case
is necessary to find out the role of any other entity therein, connection amongst the
concerned entities and the ultimate owners of funds used for manipulating the price of the
scrip. Therefore, while SEBI would investigate into the probable violations of the securities
laws, the matter may also be referred to other law enforcement agencies such as Income
Tax Department, Enforcement Directorate and Financial Intelligence Unit for necessary
action at their end as may be deemed appropriate by them.
39. SEBI strives to safeguard the interests of a genuine investor in the Indian securities market.
The acts of artificially increasing the price of scrip misleads investors and the fundamental
tenets of market integrity get violated with impunity due for such acts. Under the facts and
circumstances of this case, I prima facie find that the acts and omissions of First Financial
group and allottees as described above is inimical to the interests of participants in the
securities market. Therefore, allowing the entities that are prima facie found to be involved
in such fraudulent, unfair and manipulative transactions to continue to operate in the
market would shake the confidence of the investors in the securities market.
40. In this case it is noted that as on December 01, 2014 the allottees are still holding
65,98,810 shares of First Financial that were allotted to them in the aforesaid preferential
allotments. Further, the entities that were buyers in Patch-2 and Patch-3 have gradually
started selling shares after the price rise from August 2014 onwards i.e. from 9 to 23
almost 155% increase. The price of the scrip is currently around 23 per share and the
holders including preferential allottees and buyers (exit providers), who are holding around
7,70,00,000 shares (post split), may potentially gain around 177 crore. Unless prevented
they may use the stock exchange mechanism in the same manner as discussed hereinabove
for the purposes of their dubious plans as prima facie found in this case. In my view, the
stock exchange system cannot be permitted to be used for any unlawful/forbidden
activities. Considering these facts and the indulgence of a listed company in such a
fraudulent scheme, plan, device and artifice as prima facie found in this case, I am
convinced that this is a fit case where, pending investigation, effective and expeditious

Page 24 of 29
preventive and remedial action is required to be taken by way of ad interim ex -parte in order
to protect the interests of investors and preserve the safety and integrity of the market.
41. In view of the foregoing, in order to protect the interest of the investors and the integrity
of the securities market, I, in exercise of the powers conferred upon me in terms of section
19 read with section 11(1), section 11 (4) and section 11B of SEBI Act, 1992, pending
inquiry/investigation and passing of final order in the matter, hereby restrain the following
persons/entities from accessing the securities market and buying, selling or dealing in
securities, either directly or indirectly, in any manner, till further directions:S.
NO. NAME OF THE ENTITY
COMPANY
1 FIRST FINANCIAL SERVICES LTD
PROMOTERS AND DIRECTORS OF FIRST FINANCIAL
2 PONUSWAMMY NATARAJAN
3 N NITHYA
4 N JAYANTHI
5 S KRISHNA RAO
6 STANLEY GILBERT FELIX MELKHASINGH
7 SAMBASIVAIYER SWAMINATHAN
8 NIRMAL SINGH MERTIA
PREFERENTIAL ALLOTTEES
9 MASTER COMMODITY SERVICES LTD
10 GIRIRAJ PRASAD MANIHAR
11 KRISHAN KUMAR DAGA
12 N K AGARWAL &SONS
13 RAMESH KUMAR DAGA
14 NARESH GARG
15 SANGEETA GARG
16 TUSHAR DHIRAJLAL MEHTA
17 MASTER TRUST LTD.
18 HASHMUKHBHAI B PATEL HUF
19 H N PARWAL
20 SANJAY DAGA
21 KETAN DHIRAJLAL KAPASI
22 DRAKE PROPERTIES PRIVATE LTD.
23 ANIL AGRAWAL HUF
24 BITTHAL DAS PARWAL
25 NAVRATANMAL JEETMAL GANNA

PAN
AAACF1145J
AAAPN9499G
AKWPN5092R
AACPJ1012F
AGWPR3410R
AAMPF5456D
AABPS1434P
AKHPM8437G
AAACE3600M
AAAHG6195E
AAAHK5685D
AAAHN5067J
AAAHR7973K
AAAPG1524B
AAAPG5628E
AAAPM8897P
AABCM5833B
AABHH5224A
AABHH6685K
AABHS1744Q
AABPK6452F
AACCD4639H
AACHA9591E
AACHB8343P
AACHN5142C
Page 25 of 29
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
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62
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64
65
VIMAL KUMAR MANTRI

DHIRAJLAL MAGANLAL MEHTA
BHARAT RAMJIBHAI MANEK
CHETAN RAMJIBHAI MANEK
GOKUL SECURITIES PRIVATE LTD.
MUKESH ATAL MUKESH ATAL (HUF)
AASHISH V AGGARWAL
BAL KISHAN & SONS HUF
AMIT HASMUKHBHAI PATEL
RAJENDRAKUMAR AGARWAL HUF
RAJNI ATAL
RAJESH ATAL
SYNCOM FORMULATIONS (INDIA) LTD.
JINESHNAVRATANMALGANNA
VIKASNAVRATANMALGANNA
DEVSHIBHAI PARSHOTTAMBHAI DUNGRANI
AMIT SARAF
PAWAN KUMAR BAJAJ
GIRISHBHAI PATEL HUF
RITESH AGARWAL HUF
HARJEET SINGH ARORA
SARLA DHIRAJLAL MEHTA
SAMIR HARSHADRAI DOSHI
KAMAL KHEMKA
KULBIR SINGH
BHARATBHAI NATHABHAI BUHA
SUNDER SOMANI
KARUNA ATAL
DHEERAJ KRISHNA AGARWAL
RAJINDER KUMAR SINGHANIA
PARVEEN SINGHANIA
SURESH KUMAR KHANDELIA
MANJU KHANDELIA
PREM JAIN
HARNEESH KAUR ARORA
GAURAV JAIN
SUNITA CHAUDHARY
SANJIV CHAUDHRY
GOPALBHAI PARSHOTAMBHAI DUNGARANI
NANDITA BHAVESH MADIYAR

AACHV0973P
AACPM3147N
AACPM3397G
AACPM3398K
AADCG7372B
AADHM9088H
AADPA5357P
AAEFB0727D
AAEHA4171N
AAEHR7685G
AAEPA0263F
AAEPA0264C
AAFCS6794R
AAFHJ7950P
AAHHV1011R
AAIPD7191D
AAJHA6325F
AAKHP1145F
AALHP0436L
AAMHR6805C
AAMPA0474C
AANPM7722Q
AAQPD2202F
AAQPK0916R
AATPS8757M
AAWPB3665Q
AAWPS1022L
ABHPA0900D
ABHPA9593N
ABRPS7928R
ABRPS7929Q
ABSPK3417A
ABSPK3421A
ABZPJ4150C
ACJPA6923B
ACKPJ4330N
ACLPC7278D
ACLPC7284P
ACOPD6501F
ACOPM4635R
Page 26 of 29
66 SANTOSH MANIHAR
67 VINAL ARVIND KAPASI
68 SURESH KUMAR KALANI
69 ASHOKBHAI NATHABHAI BUHA
70 BRIJ BHUSHAN SINGAL
71 NARAYAN PRASAD MUNDHRA
72 SHILPA AGARWAL
73 PRIYANKA GANNA
74 SHILPA GANNA
75 RUPAL TUSHAR MEHTA
76 MANJUDEVI N MUNDRA MUNDRA
77 CHAMPAKBHAI MANUBHAI SOPARIWALA
78 BHARATI BHARAT MANEK
79 ANSHUL JAIN
80 NEERAJ SINGAL
81 UMA SINGAL
82 RAJKUMAR TEJBAHADUR SINGH
83 PUNEET SINGHANIA
84 AAMIR NAWAB MEHJABEEN MALIK
85 JASHANJYOT SINGH
86 HIMANSHU C SOPARIWALA
87 HARSHITA MAHESHWARI
88 ANJALI DAGA
FIRST FINANCIAL GROUP
89 ASTABHUJA CONSTRUCTION PRIVATE LTD.
90 DHANLAKSHMI BROKERS PRIVATE LTD.
91 MASTER SECURITIES
92 PADMA IMPEX PRIVATE LTD.
93 JAYINE TRADECOM PRIVATE LTD.
94 JAIHANUMAN MULTI AGENCIES PRIVATE LTD.
95 HS TRADECOM PRIVATE LTD.
96 NITYADHARA PLAZA PRIVATE LTD.
97 KRIPA SECURITIES PVT. LTD
98 PREFER ABASAN PRIVATE LTD.
99 STARDOX VINIMOY PRIVATE LTD.
100 RAINA VYAPAAR PRIVATE LTD
101 KALAKAR COMMERCIAL PRIVATE LTD.
102 SWARNA PUSHPA VANIJYA PRIVATE LTD.
103 SURBHIKA VYAPAAR PRIVATE LTD.
104 HARI OM SUPPLIERS PVT. LTD.
105 RANISATI DEALER PRIVATE LTD.

ACSPM8149E
ADQPK1014P
ADRPK7629M
AECPB5885J
AEFPS6298M
AENPM3873N
AERPJ3347N
AFQPJ7537N
AFRPJ6563K
AGWPM9589L
AHDPM7706M
AHPPS8032G
AHTPM1266G
ALGPJ9222L
ANRPS7986B
ANRPS7987A
ANTPS3913J
AROPS8175R
ATAPM4926A
AUPPS9752A
AVZPS5235M
AZWPM4747P
BFRPD1515E
AAKCA4137B
AAECD4759L
AAHFM8098F
AAACL4269P
AACCJ8342D
AABCJ6667L
AACCH8988B
AADCN9427C
AACCK2399D
AAECP2470J
AAECS0352C
AABCR3482R
AADCK9346B
AAJCS0597G
AAJCS0680C
AABCH2251E
AADCR7368C
Page 27 of 29
106
107
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112
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115
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129
PINE ANIMATION LTD.

GOLDSTAR TRACOM PRIVATE LTD.
SWARNAPRIYA VANIJYA PRIVATE LTD.
BAZIGAR TRADING PRIVATE LTD.
ROSHAN DROLIA
GLOBAL INFRATECH & FINANCE LTD.
LIFE LINE MARKETING PVT LTD.
SHREE SUDHARSHAN CASTINGS PVT LTD
BSR FINANCE & CONSULTANTS PRIVATE LTD.
WALTARE INVESTMENT PVT LTD
BIMAL KUMAR DROLIA
PARMANAND DROLIA
PRIDE DISTILLERY PRIVATE LTD
R C SUPPLIERS PRIVATE LTD.
USHITA TRADING AND AGENCIES LTD.
GRD ENCLAVE PRIVATE LTD
LINTON CONSULTANTS PRIVATE LTD
SANTOSH KUMAR SHAH
MADSAN AGENCIES (P) LTD.
MOTOREX FINANCE PVT. LTD.
MIDNIGHT AGENCIES PVT LTD/VIJAY KUMAR SHAH
EAST INDIA SECURITIES LTD.
VALUE AND WORTH
MINIMUM SHARES AND SECURITIES PVT LTD
AAECM0267A
AADCG8045K
AAJCS0595E
AABCB3052B
AAACF4335Q
AABCA4255H
AAACL5973G
AADCS9429B
AABCB0636K
AAACW2314A
AABCG9640C
AABCC0603M
AACCM6582E
AABCR2904A
AAACU3269L
AABCG9641D
AAACL5784F
ALGPS0859J
AACCM0579K
AACCM1042R
AABCM6864G
AABCE2412N
AAFFV5756K
AGCM0970Q
130 RAJANI INVESTMENT PRIVATE LTD.
AABCR2457G
131 R K INVESTMENT PRIVATE LTD.
AABCR2488R
AAACD9125E
132 DYNAMIC PORTFOLIO MANAGEMENT & SERVICES LTD

133
134
135
136
137
138
139
140
RITESH COMMERCIAL HOLDINGS LIMITED

RITESH PROJECTS PRIVATE LTD
BURLINGTON FINANCE LIMITED
BLUE CIRCLE SERVICES LIMITED
MANIMUDRA VINCOM PRIVATE LIMITED
AMRIT SALES PROMOTION PVT LIMITED
SYMPHONY MERCHANT PVT LTD
FOREVER FLOURISHING FINANCE & INVESTMENT PVT
LTD
141 NAVDURGA INVESTMENT CONSULTANTS PVT LTD
142 TOPLIGHT COMMERCIALS /TARA CHAND AGARWAL
143 NIRMAL KUMAR MALHOTRA
144 KIRIT VASUDEO DAVE
145 VEENA MOHANLAL CHANDIRAMANI
OTHER

AABCR1974J
AADCR6224M
AABCB2575P
AAACB2131L
AADCM4316K
AACCA3220D
AADCS5411K
AAACF4311Q
AACCN9567A
AABCT1134Q
AAUPM6284E
AHKPD0543J
AAWPC3158M
Page 28 of 29
146
147
148
149
150
151
152
COMFORT FINCAP LTD

COMFORT SECURITIES LTD
COMFORT INTECH LTD
PREM LATA NAHAR
SHYAM KANHEYALAL VYAS
BHARAT BAGRI BAGRI
SUMITRA DEVI AGRAWAL
AABCP4792J
AABCC9625R
AAACC5567H
AFAPN8764M
ACTPV2787Q
AADHB8488A
ABLPA9728M
42. This order shall come into force with immediate effect. The Stock exchanges and the
depositories are directed to ensure that all the above directions are strictly enforced.
43. This order is without prejudice to the right of SEBI to take any other action that may be
initiated against the aforementioned entities in accordance with law. The persons/entities
against whom this Order is passed may file their objections, if any, within twenty one days
from the date of this order and, if they so desire, avail themselves of an opportunity of
personal hearing before the Securities and Exchange Board of India, on a date and time to
be fixed on a specific request, received from the said persons/entities.
DATE:DECEMBER 19, 2014

PLACE: MUMBAI

Sd/RAJEEV KUMAR AGARWAL

WHOLE TIME MEMBER
SECURITIES AND EXCHANGE BOARD OF INDIA
Page 29 of 29

Interim Order in The Matter of Radford Global Ltd.

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Interim Order in The Matter of Radford Global Ltd.

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WTM/RKA/ ISD/ 162 /2014

SECURITIES AND EXCHANGE BOARD OF INDIA

EX-PARTE AD- INTERIM ORDER

Order in the matter of First Financial Services Ltd

Order in the matter of First Financial Services Ltd

Order in the matter of First Financial Services Ltd

Order in the matter of First Financial Services Ltd

Order in the matter of First Financial Services Ltd

GLOBAL INFRATECH &

PADMA IMPEX PRIVATE

RANISATI DEALER PVT

Order in the matter of First Financial Services Ltd

Ashok Bothra was the common director

BLUE CIRCLE SERVICES

PINE ANIMATION LTD.

Order in the matter of First Financial Services Ltd

Management & Services Ltd

The directors of these companies are

JAYINE TRADECOM PVT

Order in the matter of First Financial Services Ltd

the Examination Period.

USHITA TRADING AND

BIMAL KUMAR DROLIA

GRD ENCLAVE PVT LTD

LIFE LINE MARKETING

Order in the matter of First Financial Services Ltd

As observed from MCA website, all these

Off-market transfer of shares among the

Common director as Dilip das and share

SANTOSH KUMAR SHAH

MADSAN AGENCIES (P)

EAST INDIA SECURITIES

Fund transaction with Comfort Intech who is

Madsan agencies is connected to East

All these clients had bought huge number

Order in the matter of First Financial Services Ltd

Investment Pvt. Ltd. Are also the

Order in the matter of First Financial Services Ltd

Table: V- Profit made by the preferential allotees

KRISHAN KUMAR DAGA

RAMESH KUMAR DAGA

TUSHAR DHIRAJLAL MEHTA

BITTHAL DAS PARWAL

VIMAL KUMAR MANTRI

BHARAT RAMJIBHAI MANEK

MUKESH ATAL MUKESH

Order in the matter of First Financial Services Ltd

PAWAN KUMAR BAJAJ

RITESH AGARWAL HUF

SARLA DHIRAJLAL MEHTA

Order in the matter of First Financial Services Ltd

VINAL ARVIND KAPASI

BRIJ BHUSHAN SINGAL

RUPAL TUSHAR MEHTA

ANSHUL JAIN JAIN

Order in the matter of First Financial Services Ltd

AAMIR NAWAB MEHJABEEN

Order in the matter of First Financial Services Ltd

To expand the segment of Corporate Advisory Service like exploring refinancing

To enter in to segment of arranging Equity Placement / Strategic partners for corporate

Order in the matter of First Financial Services Ltd

Comfort Group comprising Comfort Fincap Ltd, Comfort