BEFORE THE ADJUDICATING OFFICER

SECURITIES AND EXCHANGE BOARD OF INDIA

[ADJUDICATION ORDER NO. AO/AS/5/2015]
___________________________________________________________________________
UNDER SECTION 15-I OF SECURITIES AND EXCHANGE BOARD OF INDIA ACT, 1992 READ
WITH RULE 5 OF SEBI (PROCEDURE FOR HOLDING INQUIRY AND IMPOSING PENALTIES BY
ADJUDICATING OFFICER) RULES, 1995.
In respect of
Ruchiraj Share & Stock Brokers Private Limited
Broker of BSE (SEBI Registration no. INB010982132)
(PAN: Not Available)
In the matter M/s. Gujarat Arth Ltd
___________________________________________________________________________
FACTS OF THE CASE IN BRIEF
1.

Securities and Exchange Board of India (hereinafter referred to as SEBI) conducted

an investigation into the alleged irregularity in the trading in the shares of Gujarat
Arth Limited (hereinafter referred to as GAL) and into the possible violations of the
provisions of the Securities and Exchange Board of India Act, 1992 (hereinafter
referred to as Act) and various Rules and Regulations made thereunder for the
period from October 06, 2003 to January 28, 2004 (hereinafter referred to as
"investigation period").

2.

The Investigation revealed that the Ruchiraj Share & Stock Brokers Private Ltd
(hereinafter referred to as "Noticee") placed large buy orders and intentionally kept
on regularly updating the buy order which were subsequently deleted and created
artificial market which allured the gullible investor to invest in the scrip thus aided
and abetted the client in manipulation and failed to exercise due and diligence.

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3.

SEBI has therefore, initiated adjudication proceedings under the provisions of the
SEBI Act against the Noticees to inquire and adjudge the alleged violations of
provisions of Regulations 4 (1) read with 4 (2) (a,b,e) of the SEBI (Prohibition of
Fraudulent and Unfair trade Practices Relating to Securities Market) Regulations,
2003 (hereinafter referred to as the PFUTP Regulations) and Regulation 7 read
with Clause A (1), (2), (3), (4) and (5) of Code of Conduct specified under Schedule II
of the SEBI (Stock Brokers & Sub Brokers) Regulations, 1992 (hereinafter referred to
as the Broker Regulations).

APPOINTMENT OF ADJUDICATING OFFICER

4.

The undersigned was appointed as Adjudicating Officer, vide order dated April 02,
2009 under section 15-I of Securities and Exchange Board of India Act, 1992
(hereinafter referred to as SEBI Act) and rule 3 of SEBI (Procedure for Holding
Inquiry and Imposing Penalties by Adjudicating Officer) Rules, 1995 (hereinafter
referred to as Adjudicating Rules) to enquire into and adjudge under section 15HA
and 15HB of the SEBI Act 1992 for the alleged violations.

SHOW CAUSE NOTICE, REPLY AND HEARING

5.

Show Cause Notice no. ADJ/GAL/AS/194491/2010 dated February 10, 2010

(hereinafter referred to as SCN) was issued to the Noticee under Rule 4 of
Adjudicating Rules to the Noticee to show cause as to why an inquiry should not be
held against him and penalty be not imposed under Sections 15 HA and 15HB of the
SEBI Act, for its alleged violation of the provisions of Regulation 4 (1) read with 4 (2)
(a,b,e) of PFUTP Regulations and Regulation 7 read with Clause A (1), (2), (3), (4) and
(5) of Code of Conduct as specified under Schedule II of the Broker Regulations.

6.

It is observed that noticee bought 11,27,121 shares (13.89%) and sold 13,93,467
shares (17.17%). Noticee bought 1,11,633 shares and sold 6,10,246 shares for
Cavalior Securities Ltd; bought 9,01,738 shares and sold 7,69,471 shares for Basant
Adjudication Order in respect of Ruchiraj Share and Stock Brokers Private Ltd in the matter of M/s Gujarat Arth Ltd.

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Malpani. The allegations against the Noticees were that on January 19, 2004,
noticee for its client CSL placed two orders during the day. The first order was
originally placed for 50,000 shares @ Rs.15.06 i.e. upper circuit price of the day and
was regularly updated throughout the day and most of the time the buy order
quantity was higher than the previous one. The said order was updated for 35 times
during the day and eventually the order increased to buy order for 5,00,000 shares
at the end of the day. The second buy order was placed for 5,00,000 shares at
Rs.15.06 at end of the day at 3:46:20 p.m. It is apparent that the order was just
placed to show that at the end of day also there were buyers for 5,00,000 shares in
the system which remained unexecuted. Thus noticee placed 2 buy orders for total
1,33,55,457 shares out of which order for 1,23,14,500 shares were amendments and
490957 shares were deletion. Noticee placed large buy orders and intentionally
updated kept on regularly updating the buy order so that the order loses its time
priority and other orders placed after this order move up in the system and get
executed. Noticee on net basis sold 1,82,957 shares on January 19, 2004 CSL. Further
since this orders were visible in the system throughout the day; it created an illusion
of large buying interest in the scrip. These orders along with the fabricated results by
the company mislead the investors. The act of the broker is in violation of SEBI
(PFUTP) Regulations, 2003 as it aided in creating misleading appearance of trading in
the market and did not exercise due care and diligence.
7.

The Noticees vide its letter letters dated March 23, 2010, inter-alia, submitted that:
a) Noticee have done trades for its clients and that these trades have been settled
by delivery and payment. Noticee further submitted that the trades undertaken
by then were within the price band of the day. Noticee further stated and
submitted that trades, which was traded by the other persons/entities nor does
it have any corresponding relevance to the statistical ratio derived by SEBI. It is
therefore, submitted that the said allegation / finding is meaningless and
incapable of any meaningful response. It is further submitted that the stock
exchange has put in place an automated price and order matching mechanism of
blind system to ensure perfect transparency in the trading system. Noticee
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submitted that it only executed the trades of our clients. Noticee further
submitted that it is impossible, impracticable and unfeasible for Noticee as a
broker to detect and perceive the intentions and objectives of clients. Noticee we
further submit that there was insignificant amount of proprietary trades in the
shares of GAL. Noticee further submitted that the trades were entered into by us
for the sole purpose of earning brokerage.
8.

The undersigned granted an opportunity of personal hearing to the Noticee. The

Noticee appeared before me through his representative Shri Bhavesh Muni, Shri
Rajesh Omnanarayan Khandelwal and M/s Poonam Dipen Gadkari. The Noticee
reiterated the submissions made by noticee vide his letter dated March 23, 2010
which were again indicated in their letter dated August 4, 2010.

Consideration of Issues, Evidence and Findings

9.

I have carefully examined the charges made against the Noticees as mentioned in
the SCN, Oral and written submissions and the documents as available on record. In
the instant matter the following issues arise for consideration and determination:
a. Whether the Noticee has violated Regulations 4 (1) read with 4 (2) (a,b,e) of the
PFUTP Regulations 2003 and Regulation 7 read with Clause A (1), (2), (3), (4)
and (5) of Code of Conduct specified under Schedule II of the SEBI (Stock
Brokers & Sub Brokers) Regulations, 1992.
b. Whether the Noticee is liable for monetary penalty prescribed under Section
15HA and 15HB of the SEBI Act for the aforesaid violation?
c. What quantum of monetary penalty should be imposed on the Noticee taking
into consideration the factors mentioned in section 15J of SEBI Act?

10.

Before proceeding, I would like to refer to the relevant provisions of the PFUTP,
Takeover Regulations and Insider Trading Regulations which reads as under:
PFUTP Regulations
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.

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(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 security not intended to effect transfer of beneficial ownership but
intended to operate only as a device to inflate , depress or cause fluctuation 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;
CODE OF CONDUCT FOR STOCK BROKERS - Regulation 7
A. General.
(1) Integrity: A stock-broker, shall maintain high standards of integrity,
promptitude and fairness in the conduct of all his business.
(2) Exercise of due skill and care: A stock-broker shall act with due skill, care and
diligence in the conduct of all his business.
(3) Manipulation: A stock-broker shall not indulge in manipulative, fraudulent or
deceptive transactions or schemes or spread rumours with a view to distorting
market equilibrium or making personal gains.
(4) Malpractices: A stock-broker shall not create false market either singly or in
concert with others or indulge in any act detrimental to the investors interest or
which leads to interference with the fair and smooth functioning of the market. A
stockbroker shall not involve himself in excessive speculative business in the market
beyond reasonable levels not commensurate with his financial soundness.
(5) Compliance with statutory requirements: A stock-broker shall abide by all the
provisions of the Act and the rules, regulations issued by the Government, the
Board and the Stock Exchange from time to time as may be applicable to him.
Issue a) Whether the Noticee has violated Regulations 4 (1) read with 4 (2) (a,b,e)
of the PFUTP Regulations 2003 and Regulation 7 read with Clause A (1), (2), (3),
(4) and (5) of Code of Conduct specified under Schedule II of the SEBI (Stock
Brokers & Sub Brokers) Regulations, 1992.
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11.

I find from the records that the price of the scrip increased from opening price of Rs.
9.5 on October 6, 2003 to closing high price of Rs.26.45 on November 11, 2003
accompanied by high volumes. The results for quarter ended September 2003 were
declared on November 7, 2003. Thereafter from opening price of Rs. 27.75 on
November 12, 2003 the price of the scrip fell and reduced to Rs. 10.12 on December
18, 2003 amidst comparatively low volumes. The results for quarter ended
December 2003 were declared on January 14, 2004. During this period the scrip
recorded very large volumes especially on 15th, 16th and 19th January 2004. The
price hit the lower circuit of 5% thereafter and closed at Rs.11.10 on January 28,
2004. The volumes in the scrip were as low as 143 shares on October 6, 2003 and
was as high as 8, 04,675 shares on January 16, 2004.

12.

I find that following corporate announcements were made by GAL:

Date

News text (gist)

November
1, 2003

Informed BSE that it has acquired the business and

undertaking of Poonam Industries Ltd along with their
registered Trade Marks on going concern basis and have
entered into an agreement on October 25, 2003.
December
Informed BSE that the EGM of the members would be
22, 2003
held on January 12, 2004 to seek approval- to increase
the Authorized Share capital of the company from Rs.55
million to Rs. 260 million and to issue and allot in one or
more lots on preferential or Rights Issue basis not
exceeding 20.80 million equity shares of Rs 10/- for
value not exceeding Rs 208 million at a price in
accordance with the SEBI Guidelines
January 16, Informed BSE that at the EGM held on January 12, 2004
2004
the shareholders approved the increase in authorized
share capital from Rs. 55 million to Rs.260 million and
the issue and allotment on preferential or as Rights issue
basis upto 2,08,00,000 equity shares of Rs.10/- at a price
determined as per SEBI guidelines, but not less than Rs.
10/-

13.

Impact
on
price/volume
Next 7 days
price went up
from Rs 21.55
to Rs 26.45.
Marginal rise in
price.

Price
fell,
accompanied
by
huge
volumes.

GAL declared the results for quarter ended September 2003 on November 7, 2003
and following observations were made:a. The Sales of GAL were Rs.2351.68 lakhs and net profit of Rs.237.19 lakhs as
against total sales of Rs.15 lakhs and net loss of Rs.0.44 lakhs for the quarter
ended September 30, 2002.

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b. In the notes below the results of September 2003 the company announced that
by an agreement dated 25th October, 2003 it acquired w.e.f. 1st July, 2003 the
business and undertaking of Poonam Industries Ltd. alongwith trade mark
Poonam Sarees having annual turnover of about Rs.100 crores.
14.

GAL declared the results for quarter ended December 2003 on January 14, 2004 and
it is observed from the same that:a. The sales of GAL were Rs.2615.33 lakhs and net profit of Rs.259.29 lakhs as
against the sales of 0.15 lakhs and net profit of Rs.0.43 lakhs for the quarter
ended December 2002.
b. The Board of Directors recommended a dividend of 40% alongwith the results.

15.

I further find from the investigation report that noticee bought 11,27,121 shares
(13.89%) and sold 13,93,467 shares (17.17%). Noticee bought 1,11,633 shares and
sold 6,10,246 shares for Cavalior Securities Ltd; bought 9,01,738 shares and sold
7,69,471 shares for Basant Malpani. The allegations against the Noticees were that
on January 19, 2004, noticee for its client CSL placed two orders during the day. The
first order was originally placed for 50,000 shares @ Rs.15.06 i.e. upper circuit price
of the day and was regularly updated throughout the day and most of the time the
buy order quantity was higher than the previous one. The said order was updated for
35 times during the day and eventually the order increased to buy order for 5,00,000
shares at the end of the day. The second buy order was placed for 5,00,000 shares at
Rs.15.06 at end of the day at 3:46:20 p.m. It is apparent that the order was just
placed to show that at the end of day also there were buyers for 5,00,000 shares in
the system which remained unexecuted. Thus noticee placed 2 buy orders for total
1,33,55,457 shares out of which order for 1,23,14,500 shares were amendments and
490957 shares were deletion. Noticee placed large buy orders and intentionally
updated kept on regularly updating the buy order so that the order loses its time
priority and other orders placed after this order move up in the system and get
executed. Noticee on net basis sold 1,82,957 shares on January 19, 2004 CSL. Further
since this orders were visible in the system throughout the day; it created an illusion
of large buying interest in the scrip. These orders along with the fabricated results by

Adjudication Order in respect of Ruchiraj Share and Stock Brokers Private Ltd in the matter of M/s Gujarat Arth Ltd.
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March 02, 2015

the company mislead the investors. The act of the broker is in violation of SEBI
(PFUTP) Regulations, 2003 as it aided in creating misleading appearance of trading in
the market and did not exercise due care and diligence.
16.

I find from the investigation report that the Noticee has placed the orders in
following manner. Extract of buy orders of Ruchiraj Shares & Stock Brokers on
January 19, 2004. Ruchiraj placed large quantity buy orders in the scrip which were
updated several times during the period which are given below:

ordid

Memb trdid S type Qty

Avqty

rate

time

aud date

err client

38000100000093195

380

1B L

50000

50000 15.06 10:00:27 A

19/01/04

0 57090

38000100000093195

380

1B L

100

50100 15.06 10:12:38 U

19/01/04

0 57090

38000100000093195

380

1B L

99900 150000 15.06 10:20:06 U

19/01/04

0 57090

38000100000093195

380

1B L

1000 151000 15.06 10:31:49 U

19/01/04

0 57090

38000100000093195

380

1B L

-1000 150000 15.06 10:42:03 U

19/01/04

0 57090

38000100000093195

380

1B L

20000 170000 15.06 10:53:05 U

19/01/04

0 57090

38000100000093195

380

1B L

-1000 169000 15.06 11:04:12 U

19/01/04

0 57090

38000100000093195

380

1B L

1000 170000 15.06 11:25:58 U

19/01/04

0 57090

38000100000093195

380

1B L

1000 171000 15.06 12:13:23 U

19/01/04

0 57090

38000100000093195

380

1B L

-1000 170000 15.06 12:32:15 U

19/01/04

0 57090

38000100000093195

380

1B L

20000 190000 15.06 12:45:00 U

19/01/04

0 57090

38000100000093195

380

1B L

10000 200000 15.06 12:58:14 U

19/01/04

0 57090

38000100000093195

380

1B L

25000 225000 15.06 13:31:48 U

19/01/04

0 57090

38000100000093195

380

1B L

25000 250000 15.06 14:00:05 U

19/01/04

0 57090

38000100000093195

380

1B L

75000 325000 15.06 14:43:30 U

19/01/04

0 57090

38000100000093195

380

1B L

25000 350000 15.06 14:52:14 U

19/01/04

0 57090

38000100000093195

380

1B L

25000 375000 15.06 14:57:27 U

19/01/04

0 57090

38000100000093195

380

1B L

-100 374900 15.06 15:02:01 U

19/01/04

0 57090

38000100000093195

380

1B L

50100 425000 15.06 15:04:39 U

19/01/04

0 57090

38000100000093195

380

1B L

-2810 420000 15.06 15:11:25 U

19/01/04

0 57090

38000100000093195

380

1B L

40000 460000 15.06 15:12:08 U

19/01/04

0 57090

38000100000093195

380

1B L

100 460100 15.06 15:13:00 U

19/01/04

0 57090

38000100000093195

380

1B L

-100 460000 15.06 15:13:43 U

19/01/04

0 57090

38000100000093195

380

1B L

15000 475000 15.06 15:14:37 U

19/01/04

0 57090

38000100000093195

380

1B L

-1000 474000 15.06 15:15:24 U

19/01/04

0 57090

38000100000093195

380

1B L

26000 500000 15.06 15:15:59 U

19/01/04

0 57090

38000100000093195

380

1B L

-1000 499000 15.06 15:16:44 U

19/01/04

0 57090

38000100000093195

380

1B L

1000 500000 15.06 15:17:56 U

19/01/04

0 57090

38000100000093195

380

1B L

100 500100 15.06 15:19:51 U

19/01/04

0 57090

38000100000093195

380

1B L

-100 500000 15.06 15:20:31 U

19/01/04

0 57090

38000100000093195

380

1B L

100 500100 15.06 15:20:59 U

19/01/04

0 57090

38000100000093195

380

1B L

-100 500000 15.06 15:21:53 U

19/01/04

0 57090

38000100000093195

380

1B L

100 500100 15.06 15:22:39 U

19/01/04

0 57090

38000100000093195

380

1B L

-100 500000 15.06 15:23:38 U

19/01/04

0 57090

38000100000093195

380

1B L

100 500100 15.06 15:26:04 U

19/01/04

0 57090

38000100000093195

380

1B L

-100 500000 15.06 15:27:46 U

19/01/04

0 57090

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38000100000093195

380

1B L

490957 490957

0 15:45:12 D

19/01/04

38000100000093338

380

1B L

500000 500000 15.06 15:46:20 A

19/01/04

0 57090

17.

Thus noticee has placed two orders on behalf of the clients on January 19, 2004,
during the day, which was updated regularly and deleted, thereby creating artificial
depth in the market. The pattern of order

18.

The role of the Noticee in executing the larger game plan of creating manipulation in
the scrip of GAL cannot be overlooked. It is not possible for a single entity to
manipulate the market and the role of the entire group has to be considered in a
holistic manner to arrive at any conclusion. In the instant matter the order pattern of
the members of signifies the misleading appearance of trading.

19.

I have noted the submissions of the Noticee denying the allegations. By placing such
orders, the Noticee created artificial liquidity in the scrips and played a role in the
manipulation of the trading.

20.

Regulation 4(2)(a) of PFUTP, inter alia, prohibits a person from indulging in an act
which creates false or misleading appearance of trading in the securities market.
Regulations 4(2)(b) of PFUTP prohibits a person from dealing in security not intended
to effect transfer of beneficial ownership but intended to operate only as a device to
inflate , depress or cause fluctuation in the price of such security for wrongful gain or
avoidance of loss. Regulations 4(2)(e) of PFUTP prohibits a person from any act or
omission amounting to manipulation of the price of a security. As detailed above, the
acts of the Noticee that manner in which orders placed by noticee; it created an
illusion of large buying interest in the scrip. These orders along with the fabricated
results by the company mislead the investors. The act of the broker is in violation of
SEBI (PFUTP) Regulations, 2003 as it aided in creating misleading appearance of
trading in the market.

21.

In terms of Clauses A(1) to A(5) of the Code of Conduct prescribed under the
provision of Brokers Regulations., a stock broker shall not, inter alia, create false
market or indulge in any act detrimental to the investors interest or which leads to
the interference with the fair and smooth functioning of the securities market. The
Broker shall also maintain high standard of integrity, promptitude and fairness and
shall act with due skill, care and diligence in the conduct of his business. It also

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mandates that the Broker shall not, inter alia, indulge in a manipulative transaction
with a view to distort the market equilibrium and comply with all the statutory
requirements. The orders of the Noticee as explained hereinabove in detail
establishes that the same created a misleading appearance of tradiing, artificial
volume and price in the shares of GAL. It further shows that the Noticee had failed to
exercise due skill, care and diligence and not maintained high standard of integrity,
promptitude, fairness in the conduct of its business as a stock broker.
22.

In view of foregoing, I find that the submissions of the Noticee are not tenable and
consequently, hold that the charges leveled against the Noticee are proved and that
the allegation of violation of provision of regulations 4(1), 4(2)(a,b,e) of PFUTP, A(1),
(2), (3) (4) and (5) of Code of Conduct for Stock Brokers as specified in Schedule II
under Regulation 7 of Brokers Regulations stands established.
Issue b) Whether the Noticee is liable for monetary penalty prescribed under
Section 15 HA and 15HB of the SEBI Act for the aforesaid violation?

23.

The next issue arise for consideration is as to what would be monetary penalty that
can be imposed on the noticee for violation of aforesaid Regulations. The Honble
Supreme Court of India in the matter of SEBI Vs. Shri Ram Mutual Fund[2006] 68 SCL
216(SC) held that once the violation of statutory regulations is established,
imposition of penalty becomes since qua non of violation and the intention of parties
committing such violation becomes totally irrelevant. Once the contravention is
established, then the penalty is to follow.

24.

Thus, the aforesaid violations by the Noticee make it liable for penalty under
Sections 15HA and 15 HB of SEBI Act, 1992 which read as follows:
Penalty for fraudulent and unfair trade practices
15HA. If any person indulges in fraudulent and unfair trade practices relating
to securities, he shall be liable to a penalty of twenty-five crore rupees or

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three times the amount of profits made out of such practices, whichever is
higher.
Penalty for contravention where no separate penalty has been provided
15HB. Whoever fails to comply with any provision of this Act, the rules or the
regulations made or directions issued by the Board thereunder for which no
separate penalty has been provided, shall be liable to a penalty which may
extent to one core rupees.]
Issue c) What quantum of monetary penalty should be imposed on the Noticee
taking into consideration the factors mentioned in section 15J of SEBI Act?
25.

While determining the quantum of penalty under sections 15HA and 15HB, it is
important to consider the factors stipulated in section 15J of SEBI Act, which reads as
under:15 J Factors to be taken into account by the adjudicating officer
While adjudging quantum of penalty under section 15-I, the adjudicating
officer shall have due regard to the following factors, namely:(a)

the amount of disproportionate gain or unfair advantage, wherever

quantifiable, made as a result of the default;

(b)

the amount of loss caused to an investor or group of investors as a

result of the default;

(c)
26.

the repetitive nature of the default.

It is difficult, in cases of such nature, to quantify exactly the disproportionate gains of

unfair advantage enjoyed by an entity and the consequent losses suffered by the
investors. I have noted that the investigation report also does not dwell on the
extent of specific gains made by the clients or the brokers. Suffice to state that
keeping in mind the practices indulged in by the Noticee, gains per se were made by
the Noticee in that it traded in the scrips of GAL in a manner meant to create
artificial volumes and liquidity which is an important criterion, capable of misleading
the investors while making an investment decision. In fact, liquidity/volumes in

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particular scrip raise the issue of demand in the securities market. The greater the
liquidity, the higher is the investors attraction towards investing in that scrip. Hence,
anyone could have been carried away by the unusual fluctuations in the volumes and
been induced into investing in the said scrip. Bedsides, this kind of activity seriously
affects the normal price discovery mechanism of the securities market. People who
indulge in manipulative, fraudulent and deceptive transaction, or abet the carrying
out of such transaction which are fraudulent and deceptive should be suitably
penalized for the said acts of omissions and commissions. Considering the
continuous effort of the Noticee in this aspect where the synchronized/circular
trades were carried out over a period of time, it can safely be surmised that the
nature of default was also repetitive.
Order
27.

In view of the above, after considering all the facts and circumstances of the case
and exercising the powers conferred upon me under section 15-I (2) of the SEBI Act,
1992, I hereby impose a monetary penalty of Rs25,00,000 /- (Rupees Twenty Five
Lakh Only) under section 15HA SEBI Act and Rs.22,00,000./- (Rupees Twenty two
Lakh Only) under section 15HB SEBI Act,i.e total penalty of Rs 47,00,000/- (Rupees
Fourty Seven Lakh Only) on the Noticee which will be commensurate with the
violation/s committed by the Noticee.

28.

The penalty shall be paid by way of demand draft drawn in favour of SEBI
Penalties Remittable to Government of India payable at Mumbai within 45 days of
receipt of this order. The said demand draft shall be forwarded to Division Chief,
Enforcement Department (EFD-DRA-1), Securities and Exchange Board of India, Plot
No. C4-A, G Block, Bandra Kurla Complex, Bandra (E), Mumbai 400 051.

29.

In terms of the provisions of Rule 6 of the Adjudicating Rules the copies of this order
is sent to the Noticee and also to Securities and Exchange Board of India.

Date: March 02, 2015

Place: Mumbai

ASHA SHETTY
ADJUDICATING OFFICER

Adjudication Order in respect of Ruchiraj Share and Stock Brokers Private Ltd in the matter of M/s Gujarat Arth Ltd.
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March 02, 2015