WTM/RKA/ISD/ 143 /2015

SECURITIES AND EXCHANGE BOARD OF INDIA

AD INTERIM EX PARTE ORDER

UNDER SECTION 11 AND 11B OF THE SECURITIES AND EXCHANGE BOARD
OF INDIA ACT, 1992 IN THE MATTER OF RADFORD GLOBAL LIMITED.
1. Securities and Exchange Board of India ("SEBI"), vide an ad interim ex-parte order dated
December 19, 2014 (hereinafter referred to as interim order), restrained 108 entities, including
Radford Global Ltd. (formerly known as PS Global Ltd. and prior to that as Rosette Resorts
Ltd.) (hereinafter referred to as "Radford / the company") and its promoters and directors
from accessing the securities market and further prohibited them from buying, selling or dealing
in securities in any manner whatsoever, till further directions. The said directions were issued
on the basis of prima facie findings that Radford and persons in charge of its affairs had allotted
its 91,00,000 equity shares of 10 each at a premium of 5 on preferential basis to 48 entities
aggregating to 13.65 crore in order to provide fictitious Long Term Capital Gains ("LTCG")
to the preferential allottees so as to convert their unaccounted income into accounted one with
no payment of taxes as LTCG is tax exempt. It was observed that consequent to preferential
allotment of equity shares on February 16, 2012 in Radford, price of the scrip was increased
substantially to the extent of 7442% (73 times) with a very small chunk of volume/purchases
(i.e. 98 shares per day) by certain entities and after the expiry of the compulsory lock-in period,
the average volume increased astronomically to the extent of 505066% (5050 times) and the
preferential allottees were provided exit at a high price by the entities forming part of the Radford
Group and suspected entities. It was, thus, prima facie observed that Radford and the preferential
allottees acting in concert with Radford Group and suspected entities misused the stock exchange
mechanism to generate fictitious LTCG.
2. During Pre-Patch I (i.e. February 27, 2012 to January 28, 2013), the scrip opened 3.20 (prestock split price) on February 27, 2012 and rose to a high of 241.35 and closed at 241.35 on
January 28, 2013. It was noted that during this period an artificial demand for the shares of
Radford was created by Radford and its related entities as Radford did not have the
fundamentals to command such a high demand nor were there any external factors such as
corporate announcements which could have led to such demand. When compared with the
high demand, there was hardly any supply of shares of shares of Radford during Pre-Patch I. It
was noted that during the said period, the scrip traded with an average volume of 98 shares per
day and total volume of 11,950 shares in 121 trading days with an average of 1 to 2 trades per
day.

Order in the matter of Radford Global Limited

Page 1 of 23

3. Further, during the examination, upon an analysis of the order-log and trade-log the selling
behaviour/ pattern of 15 sellers (hereinafter collectively referred to as "sellers") prima facie
appeared to be suspicious. It was observed that price of the scrip was influenced by these sellers
while trading in the scrip of Radford by selling either miniscule number of shares per day with
very less quantity vis--vis their shareholding or by controlling the trade volume of the scrip.
The selling pattern of these sellers is exemplified in the table below:
Table 1: Selling pattern of the sellers.
Sr.
No

PAN

AAKHA8826N

ATWPK6701D

Name
ANUP MANILAL
SHAH (HUF)

ARTIBEN S
KANSARA

Date

Shares
Trades
Sold

Shareholding
before placing
the sell order

10/01/2013

2800

3800

16/08/2012
17/08/2012
21/08/2012
24/08/2012
27/08/2012
30/08/2012
31/08/2012
06/09/2012
Total
09/10/2012
10/10/2012
19/11/2012
10/01/2013
Total

2
1
1
2
1
1
1
1
10
1
1
1
1
4

2
1
1
2
1
1
1
1
10
250
50
50
100
450

1500
1498
1497
1496
1494
1493
1492
1491
500
250
200
150

AGSPS5666E

BHARATKUMAR
JAYANTILAL
SHAH

AAYPM2723J

DINA
SATISHKUMAR
MEHTA

11/05/2012

100

100

ACLPK9984A

HARI MOHAN
KHANDELWAL

23/07/2012
07/09/2012
13/09/2012
21/09/2012
26/09/2012
04/10/2012
Total

1
1
1
1
1
1
6

200
200
200
100
100
200
1000

1000
800
600
400
300
200

ANIPM9254B

HASUMATI
GHANSHYAM
MANDLIA

04/10/2012

200

200

10/09/2012
13/09/2012
18/09/2012
25/09/2012
12/10/2012
Total
24/05/2012

1
1
1
1
1
5
1

100
100
100
100
100
500
1

500
400
300
200
100

ABGPG6544G

AOBPS1451C

KANAIYALAL
MANILAL
GANDHI

Order in the matter of Radford Global Limited

1000
Page 2 of 23

10

11

AALPT9962B

MANISHA
JAYESH SHAH

28/05/2012
07/06/2012
15/06/2012
18/06/2012
19/06/2012
21/06/2012
22/06/2012
26/06/2012
27/06/2012
28/06/2012
29/06/2012
01/08/2012
03/08/2012
08/08/2012
Total

1
1
1
1
1
1
2
3
4
5
6
1
1
1
30

1
1
1
1
5
1
2
3
4
5
6
1
1
1
34

999
998
997
996
995
990
989
987
984
980
975
969
968
967

MANSUKHBHAI
JAGABHAI TANTI

17/10/2015

100

100

16/01/2013
17/01/2013
18/01/2013
22/01/2013
24/01/2013
Total
21/09/2012
16/11/2012
26/11/2012
27/11/2012
29/11/2012
04/12/2012
05/12/2012
06/12/2012
07/12/2012
14/12/2012
19/12/2012
21/12/2012
26/12/2012
28/12/2012
02/01/2013
07/01/2013
10/01/2013
14/01/2013
15/01/2013
16/01/2013
17/01/2013
18/01/2013
21/01/2013
22/01/2013
23/01/2013

1
1
1
1
1
5
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
2
1
1
1
1
1
1
1
1

10
15
15
10
10
60
100
100
20
20
10
20
10
10
10
20
20
20
20
20
20
20
40
20
5
5
5
5
5
5
5

300
290
275
260
250

AGWPP5778Q PRAGNA PATEL

ACJPG8162C

RAJEEV GARG

Order in the matter of Radford Global Limited

600
500
400
400
380
350
350
330
320
300
280
260
240
220
200
180
160
120
120
100
95
90
85
80
75
Page 3 of 23

12

AELPG9023L

RAMILA GANDHI

13

AFXPS1751C

REKHABEN
LAKHABHAI
SAGPARIA

14

ANFPK3652G

SUNIL
MOHANLAL
KANSARA

15

AHGPV3775J

VEENA
MOHANDAS
VALBHANI
Total

*
**

24/01/2013
25/01/2013
28/01/2013
Total
28/08/2012
03/09/2012
05/09/2012
Total
17/09/2012
18/09/2012
Total
31/12/2012
08/01/2013
10/01/2013
Total

1
1
1
29
1
1
1
3
1
1
2
1
1
8
10

5
5
5
550
100
100
100
300
100
100
200
7
10
500
517

01/11/2012

500

111

7321

70
70
65
300
200
100
1100
0*
966
959
949
500**

Transferred 900 shares to her broker

Got 500 shares dematted in her account

4. The above mentioned selling pattern of the sellers appeared to be even more surprising in light
of the fact that almost on all dates when the above trades were executed, there was a huge
demand for the shares of Radford and buyers had continuously placed large buy orders on
upper circuit. It is noted that during Pre-patch I the percentage of sell orders in comparison to
the buy orders was miniscule as can be seen in the table below:
Table 2: Month-wise Order book snapshot during the Pre-Patch I period (Large buy
orders as compared to miniscule sell orders)

Month
February 2012
March 2012
April 2012
May 2012
June 2012
July 2012
August 2012
September 2012
October 2012
November 2012
December 2012
January 2013
Grand Total

Buy order
Order
quantity
executed
% of executed quantity out of total
(Cumulative) quantity
buy order quantity
112000
100
0.09%
880200
0
0.00%
1282900
600
0.05%
1281353
703
0.05%
1252478
430
0.03%
1111890
452
0.04%
532987
118
0.02%
654282
1504
0.23%
673260
1328
0.20%
475276
820
0.17%
353053
657
0.19%
248479
5238
2.11%
8858158
11950
0.13%

Order in the matter of Radford Global Limited

Page 4 of 23

5. It is also noted that during Pre-Patch I, on most of the days, buy orders were placed on the stock
exchange platform as soon as the trading session began, whereas the sell orders by the sellers
were placed much later on the respective days. Few instances of placement of such buy orders
at the beginning of the trading session are mentioned below:
Table 3: Instances of early placement of buy orders.

ORDERDATE
29/02/2012
07/03/2012
10/04/2012
24/05/2012
07/06/2012
25/07/2012
06/08/2012
05/09/2012
04/10/2012
19/11/2012
05/12/2012
28/01/2013

ORDERTIME
09:15:00
09:15:00
09:15:00
09:15:00
09:15:00
09:15:00
09:15:00
09:15:00
09:15:00
09:15:00
09:15:00
09:15:00

PRICE AT WHICH
THE ORDER WAS
PLACED
3.35
3.35
3.68
4.91
5.67
12.88
14.89
24.14
43
68.45
111.2
241.34

QTY
5000
1000
200
5000
5000
10000
1500
1000
150
100
500
2400

ORDER
TYPE
Buy
Buy
Buy
Buy
Buy
Buy
Buy
Buy
Buy
Buy
Buy
Buy

6. From the above description and tables, the following was observed with respect to the sellers:
a. Despite there being a huge demand for the shares of Radford and the sellers: holding large
number of shares of Radford, some of the sellers sold shares in miniscule quantities on
various occasions and thereby controlled the supply of shares.
b. During Pre-Patch I (having 121 trading days) the sellers traded on 72 trading days and
executed 84 trades. Out of these 72 days, on 64 days the sellers contributed to 100% of the
daily traded volume.
c. Some of the sellers sold shares only to maintain the average daily volume. For instance, on
17 trading days (when the average trading volume was 98 shares) the sellers sold 100 shares
only despite holding large number of shares and there being large number of buy orders.
d. The selling behaviour of the sellers also exhibited a suspicious sequential pattern i.e. in spite
of a huge demand for the shares during Pre-Patch I, most of the sellers did not sell their
shares together in one period. In fact, they sequentially sold their shares in such a manner
that one seller stopped selling when the other started selling its/his/her shares. The
suspicious trading pattern of the sellers is shown in Annexure A.
7. It prima facie appears from the above observations that the sellers were selling their shares in an
abnormal / non-genuine manner and were acting under a pre-determined plan to
fix/manipulate the price of the scrip of Radford.

Order in the matter of Radford Global Limited

Page 5 of 23

8. In addition to the above observations, during the examination, certain discrepancies were
noticed regarding the source of acquisition of the shares by the sellers. In this regard, the
following facts are noteworthy:
a) It is a matter of record that trading in the scrip of Radford was suspended on Bombay
Stock Exchange Limited (BSE), the only stock exchange where it is listed, from January
14, 2003 to December 19, 2011 for non-compliance of the equity listing agreement.
According to Radford, its current promoters had taken over it in year 2011 and it had
appointed Universal Capital Securities Limited, as Registrar and Transfer Agent (hereinafter
referred as "RTA") in January 2012. At that time, the company handed over the shareholder
list (hereinafter referred as "RTA List") to RTA.
b) It was found that 236 shareholder records were having record name as "abeyance" in RTA
List. These 236 abeyance records (amounting to total of 1,38,400 shares) had the same folio
number i.e. 13518.
c) When inquired about the justification for the abeyance records, Radford submitted that
when the current management of Radford received the data from the prior management pertaining to the
details of the shareholders, they noticed that there were no details such as name, folio nos. etc. for 1,38,400
shares. Hence, Radford had put these shares under abeyance and requested RTA not to reject any request
made by the shareholder whose names are not appearing in the share master data submitted by the company
to RTA.
d) Contrary to the aforesaid reason provided by Radford, the list submitted by the old
management to Registrar of Companies ("RoC") in year 2010 had the complete
shareholders list with details and did not contain any shareholding in abeyance category.
e) RTA, vide its letter to SEBI dated August 14, 2015, stated that the RTA List provided by
Radford to it had one record named abeyance in different distinctive number ranges and
same folio number. According to the RTA, when it sought the explanation in respect of
these shares from Radford, it replied that it did not have proper control over their
distinctive number master. Further, Radford had advised the RTA to point out any such
discrepancies before rejecting the request from investor for transfer or demat. Furthermore,
the said letter states that only after verification of folio number, number of shares and
shareholder's name, Radford or RTA issued new certificate to the shareholder requesting
the transfer or demat. It is strange to note that RTA approved the share transfers, requests
for demat and issuance of new share certificates without ascertaining the authenticity of
entities from whom the sellers apparently received the shares i.e. without sellers confirmation
notice and without checking the details like folio number, number of shares, name,
distinctive numbers, etc.
f) The latest available shareholder list as on January 1, 2012 on MCA website was that of the
Annual General Meeting held by Radford in 2010. This list was submitted by Radford to
RoC in the year 2010 (hereinafter referred to as "MCA List"). This MCA list did not contain
any abeyance records. On a comparison of the MCA list with the shareholders' master list
Order in the matter of Radford Global Limited

Page 6 of 23

g)

h)
i)
j)

provided by Radford to RTA in January 2012, most of shareholders names were not
matching.
It is surprising to note that majority of shareholders (1,976 shareholders in total) of Radford
in RTA List in year 2011 were different from those appearing in the MCA list (submitted
to RoC in 2010) especially when the scrip was suspended on BSE.
The Depositories (CDSL and NSDL) informed that first demat for the scrip of Radford
happened only in January 2012.
There was no apparent reason for the abeyance records to suddenly appear in the
shareholders list submitted by new management of Radford to RTA.
Certain complaints have also been received by SEBI from shareholders alleging that
Radford had issued duplicate shares in lieu of original certificates held by them to some
third party and is now refusing to transfer shares in their name.

9. Upon noticing the aforesaid discrepancies regarding the source of shares of the sellers, the
physical share certificates of the sellers were also examined. The examination revealed several
factors which prima facie indicate that the share certificates held by the sellers were not genuine.
The said factors (details whereof are provided in Annexure B) are summarized as under:
a. The company/RTA was not able to furnish necessary documentary evidence which was
relied upon by it/them to ascertain the genuineness of shareholding of a few sellers whose
name was not there in the MCA list namely, Rajeev Garg, Veena Mohandas Valbhani,
Bharatkumar Jayantilal Shah and Ramila Gandhi. However, as per the photocopy of share
certificate submitted by Radford, they were its shareholders since May 1995.
b. The names of three entities (Veena Mohandas Valbhani, Bharatkumar Jayantilal Shah and
Ramila Gandhi) were not part of the mailing list of shareholders for communication given
by the new management of Radford to RTA.
c. The physical share certificate of Manisha Jayesh Shah furnished by Radford had a sticker
of PS Global Ltd affixed on share certificate of Rossette Resorts Ltd. This is a deviation
from the practice followed by Radford of issuing new share certificate in lieu of old
certificate.
d. Company / RTA failed to produce any documentary evidence for establishing genuineness
of the transfer of shares from earlier shareholder to Artiben S Kansara.
e. Contradictory statements were given by RTA with respect to transfer of shares made to
Anup Manilal Shah (HUF).
f. Certain sellers namely, Hari Mohan Khandelwal, Kanaiyalal Manilal Gandhi, Rekhaben
Lakhabhai Sagparia, Rekhaben Lakhabhai Sagparia, Mansukhbhai Jagabhai Tanti and
Pragna Patel were issued shares from abeyance list. Their names did not appear either in
the MCA List or the RTA List. When inquired, Radford /RTA were not able to furnish
any documentary evidence to justify how they ascertained the genuineness of these
shareholders. This is also in contradiction with the RTA's policy of verification while

Order in the matter of Radford Global Limited

Page 7 of 23

transferring or dematerializing, wherein such policy, prima facie, does not appear to be
followed.
g. Dina Satishkumar Mehta and Priya Sanghvi held shares with the same folio number in
MCA list as well as in RTA list. These two entities did not have any transaction with each
other.
h. As per Radfords board of directors resolution dated February 15, 2012, it had authorized
its company secretary and RTA to sign the share certificate of the company. In few
instances signatures on physical share certificates of the RTA/company's authorized
personnel were missing.
10.

From the facts and circumstances discussed in the preceding paragraphs, it is prima facie inferred
that the share certificates held by the sellers were not genuine. In this regard, it is pertinent to
note that the stationary of the physical share certificate was controlled by Radford only. Also,
as seen from the physical share certificates, Radford did not number the share certificates with
consecutive serial numbers. Thus, it appears that Radford was involved in issuance of nongenuine share certificates held by the sellers. This finding is further strengthened by the fact
that Radford did not provide any information to SEBI when it was asked to furnish its IPO
allotment list and other relevant details.

11. In this case, it is a matter of record that during Pre-Patch I, the price of the shares of Radford
rose from 3.20, to 241.35. From the acts and conduct of the sellers discussed above, I prima
facie find that they played a crucial role in pushing the price of scrip of Radford to such high
levels especially by controlling the supply of shares. Their suspicious acts selling shares in
miniscule quantities despite there being a huge demand, contributing to 100% trading volume
on most of the days, placing trades in a manner so as to maintain the daily average volume and
not letting the liquidity dry out by sequentially selling shares clearly show that their selling
pattern was not normal and was prima facie directed towards pushing up the price of the scrip
of Radford. The same is further corroborated by the fact that the share certificates held by the
sellers were prima facie not genuine. The involvement of Radford in issuance of non-genuine
certificates to these sellers signifies that the sellers carried out the aforesaid acts in collusion with
Radford, its promoters and directors.
12. As noted in the interim order dated December 19, 2014, Radford and other entities named therein
misused the securities market system to artificially increase price of the scrip for providing long
term capital gain (LTCG) benefits to the preferential allottees of Radford. As discussed
above, the sellers played a crucial role in increasing the price of the scrip. I, therefore prima facie
find that the sellers were also a part of the scheme, plan, device and artifice employed in relation
to the scrip of Radford and described in the interim order dated December 19, 2014.

Order in the matter of Radford Global Limited

Page 8 of 23

13. Considering the above, I am of the prima facie view that the acts of the sellers discussed
hereinabove are fraudulent as defined under regulation 2(1)(c) of the Securities and Exchange
Board of India (Prohibition of Fraudulent and Unfair Trade Practices relating to Securities
Market) Regulations, 2003 (the PFUTP Regulations) and are in contravention of the
provisions of regulations 3(a), (b), (c) and (d) and 4(1), 4(2)(a), (b) and (e) 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 there under;
(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
there under;"
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.

Order in the matter of Radford Global Limited

Page 9 of 23

(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;
14. I am of the opinion that the ongoing investigation in the matter should also cover the entire
scheme discussed hereinabove to find out the role of any other entity therein including RTA,
connection amongst the concerned entities and other related aspects of the matter.
15. SEBI strives to safeguard the interest of genuine investors in the Indian securities market. I am
of the opinion that, while investigation in the matter is underway, allowing the sellers who are
prima facie found to be involved in such fraudulent, unfair and manipulative transactions to
continue to operate in the market is inimical to the interests of participants in the securities
market and would shake the confidence of the investors in the securities market. Considering
the facts and circumstances, I deem it a fit case where, pending investigation, effective and
expeditious preventive 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.
16. 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 sections 11(1),
11(4) and 11B read with section 19 of the SEBI Act, pending inquiry/investigation and passing
of final order in the matter, hereby restrain the following persons from accessing the securities
market and buying, selling or dealing in securities, either directly or indirectly, in any manner,
till further directions.
Sr. No
1
2
3
4
5
6
7
8
9
10
11

PAN
AAKHA8826N
ATWPK6701D
AGSPS5666E
AAYPM2723J
ACLPK9984A
ANIPM9254B
ABGPG6544G
AOBPS1451C
AALPT9962B
AGWPP5778Q
ACJPG8162C

Name
ANUP MANILAL SHAH (HUF)
ARTIBEN S KANSARA
BHARATKUMAR JAYANTILAL SHAH
DINA SATISHKUMAR MEHTA
HARI MOHAN KHANDELWAL
HASUMATI GHANSHYAM MANDLIA
KANAIYALAL MANILAL GANDHI
MANISHA JAYESH SHAH
MANSUKHBHAI JAGABHAI TANTI
PRAGNA PATEL
RAJEEV GARG

Order in the matter of Radford Global Limited

Page 10 of 23

12
13
14
15

AELPG9023L
AFXPS1751C
ANFPK3652G
AHGPV3775J

RAMILA GANDHI
REKHABEN LAKHABHAI SAGPARIA
SUNIL MOHANLAL KANSARA
VEENA MOHANDAS VALBHANI

17. 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.
18. 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.
19. 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.

Sd/DATE: November 9th, 2015

PLACE: MUMBAI

RAJEEV KUMAR AGARWAL

WHOLE TIME MEMBER
SECURITIES AND EXCHANGE BOARD OF INDIA

Order in the matter of Radford Global Limited

Page 11 of 23

Annexure A: Sequential trading pattern of the sellers

Date

PAN

11/05/2012

AAYPM2723J

24/05/2012

AOBPS1451C

28/05/2012

AOBPS1451C

07/06/2012

AOBPS1451C

15/06/2012

AOBPS1451C

18/06/2012

AOBPS1451C

19/06/2012

AOBPS1451C

21/06/2012

AOBPS1451C

22/06/2012

AOBPS1451C

26/06/2012

AOBPS1451C

27/06/2012

AOBPS1451C

28/06/2012

AOBPS1451C

29/06/2012

AOBPS1451C

23/07/2012

ACLPK9984A

01/08/2012

AOBPS1451C

03/08/2012

AOBPS1451C

08/08/2012
16/08/2012
17/08/2012
21/08/2012
24/08/2012
27/08/2012
28/08/2012
30/08/2012
31/08/2012

AOBPS1451C
ATWPK6701D
ATWPK6701D
ATWPK6701D
ATWPK6701D
ATWPK6701D
AELPG9023L
ATWPK6701D
ATWPK6701D

Name
DINA SATISHKUMAR
MEHTA
MANISHA JAYESH
SHAH
MANISHA JAYESH
SHAH
MANISHA JAYESH
SHAH
MANISHA JAYESH
SHAH
MANISHA JAYESH
SHAH
MANISHA JAYESH
SHAH
MANISHA JAYESH
SHAH
MANISHA JAYESH
SHAH
MANISHA JAYESH
SHAH
MANISHA JAYESH
SHAH
MANISHA JAYESH
SHAH
MANISHA JAYESH
SHAH
HARI MOHAN
KHANDELWAL
MANISHA JAYESH
SHAH
MANISHA JAYESH
SHAH
MANISHA JAYESH
SHAH
ARTIBEN S KANSARA
ARTIBEN S KANSARA
ARTIBEN S KANSARA
ARTIBEN S KANSARA
ARTIBEN S KANSARA
RAMILA GANDHI
ARTIBEN S KANSARA
ARTIBEN S KANSARA

Order in the matter of Radford Global Limited

Quanti
ty

Total
daily
trade
volum
e

Volu
me
contr
ibute
d

Total
sell
order
s

100

100

100%

100

100%

100%

100%

100%

100%

100%

100%

100%

100%

100%

100%

100%

200

200

100%

200

100%

100%

1
2
1
1
2
1
100
1
1

1
2
1
1
2
1
100
1
1

100%
100%
100%
100%
100%
100%
100%
100%
100%

1
2
1
1
2
1
100
1
1

Page 12 of 23

03/09/2012
05/09/2012
06/09/2012

AELPG9023L
AELPG9023L
ATWPK6701D

07/09/2012

ACLPK9984A

10/09/2012

ABGPG6544G

13/09/2012

ABGPG6544G

13/09/2012

ACLPK9984A

17/09/2012

AFXPS1751C

18/09/2012

ABGPG6544G

18/09/2012
21/09/2012

AFXPS1751C
ACJPG8162C

21/09/2012

ACLPK9984A

25/09/2012

ABGPG6544G

26/09/2012

ACLPK9984A

04/10/2012

ACLPK9984A

04/10/2012

ANIPM9254B

09/10/2012

AGSPS5666E

10/10/2012

AGSPS5666E

12/10/2012

ABGPG6544G

17/10/2012

AALPT9962B

01/11/2012
16/11/2012

AHGPV3775J
ACJPG8162C

19/11/2012
26/11/2012
27/11/2012
29/11/2012
04/12/2012
05/12/2012

AGSPS5666E
ACJPG8162C
ACJPG8162C
ACJPG8162C
ACJPG8162C
ACJPG8162C

RAMILA GANDHI
RAMILA GANDHI
ARTIBEN S KANSARA
HARI MOHAN
KHANDELWAL
KANAIYALAL
MANILAL GANDHI
KANAIYALAL
MANILAL GANDHI
HARI MOHAN
KHANDELWAL
REKHABEN
LAKHABHAI
SAGPARIA
KANAIYALAL
MANILAL GANDHI
REKHABEN
LAKHABHAI
SAGPARIA
RAJEEV GARG
HARI MOHAN
KHANDELWAL
KANAIYALAL
MANILAL GANDHI
HARI MOHAN
KHANDELWAL
HARI MOHAN
KHANDELWAL
HASUMATI
GHANSHYAM
MANDLIA
BHARATKUMAR
JAYANTILAL SHAH
BHARATKUMAR
JAYANTILAL SHAH
KANAIYALAL
MANILAL GANDHI
MANSUKHBHAI
JAGABHAI TANTI
VEENA MOHANDAS
VALBHANI
RAJEEV GARG
BHARATKUMAR
JAYANTILAL SHAH
RAJEEV GARG
RAJEEV GARG
RAJEEV GARG
RAJEEV GARG
RAJEEV GARG

Order in the matter of Radford Global Limited

100
100
1

100
100
1

100%
100%
100%

100
100
1

200

200

100%

200

100

100

100%

100

100

300

33%

300

200

300

67%

300

100

100

100%

100

100

200

50%

200

100
100

200
200

50%
50%

200
200

100

200

50%

200

100

100

100%

100

100

100

100%

100

200

400

50%

400

200

400

50%

400

250

251

100%

251

50

50

100%

150

100

100

100%

200

100

100

100%

250

500
100

500
100

100%
100%

650
250

50
20
20
10
20
10

50
20
20
10
20
10

100%
100%
100%
100%
100%
100%

150
120
120
10
20
110

Page 13 of 23

06/12/2012
07/12/2012
14/12/2012
19/12/2012
21/12/2012
26/12/2012
28/12/2012
31/12/2012
02/01/2013
07/01/2013
08/01/2013
10/01/2013
10/01/2013
10/01/2013
10/01/2013
14/01/2013
15/01/2013
16/01/2013
16/01/2013
17/01/2013
17/01/2013
18/01/2013
18/01/2013
21/01/2013
22/01/2013
22/01/2013
23/01/2013
24/01/2013
24/01/2013
25/01/2013
28/01/2013

ACJPG8162C
ACJPG8162C
ACJPG8162C
ACJPG8162C
ACJPG8162C
ACJPG8162C
ACJPG8162C

RAJEEV GARG
RAJEEV GARG
RAJEEV GARG
RAJEEV GARG
RAJEEV GARG
RAJEEV GARG
RAJEEV GARG
SUNIL MOHANLAL
ANFPK3652G KANSARA
ACJPG8162C
RAJEEV GARG
ACJPG8162C
RAJEEV GARG
SUNIL MOHANLAL
ANFPK3652G KANSARA
ANUP MANILAL
AAKHA8826N SHAH (HUF)
ACJPG8162C
RAJEEV GARG
BHARATKUMAR
AGSPS5666E
JAYANTILAL SHAH
SUNIL MOHANLAL
ANFPK3652G KANSARA
ACJPG8162C
RAJEEV GARG
ACJPG8162C
RAJEEV GARG
ACJPG8162C
RAJEEV GARG
AGWPP5778Q PRAGNA PATEL
ACJPG8162C
RAJEEV GARG
AGWPP5778Q PRAGNA PATEL
ACJPG8162C
RAJEEV GARG
AGWPP5778Q PRAGNA PATEL
ACJPG8162C
RAJEEV GARG
ACJPG8162C
RAJEEV GARG
AGWPP5778Q PRAGNA PATEL
ACJPG8162C
RAJEEV GARG
ACJPG8162C
RAJEEV GARG
AGWPP5778Q PRAGNA PATEL
ACJPG8162C
RAJEEV GARG
ACJPG8162C
RAJEEV GARG

Order in the matter of Radford Global Limited

10
10
20
20
20
20
20

10
10
82
20
20
20
20

100%
100%
24%
100%
100%
100%
100%

110
10
182
20
20
20
120

7
20
20

7
20
20

100%
100%
100%

7
120
120

10

10

100%

110

2800
40

4385
4385

64%
1%

4385
4385

100

4385

2%

4385

500
20
5
5
10
5
15
5
15
5
5
10
5
5
10
5
5

4385
20
5
15
15
20
20
40
40
5
15
15
605
40
40
5
5

11%
100%
100%
33%
67%
25%
75%
13%
38%
100%
33%
67%
1%
13%
25%
100%
100%

4385
20
5
15
15
20
20
40
40
5
15
15
605
40
40
5
5

Page 14 of 23

Annexure B: Discrepancies / observations noticed in examination of physical share

certificate of the sellers
Sr.
N
o

PAN

Name

Share
s sold

% of
total
trade
vol

Discrepancy/Observations

It is observed from the copy of share

certificate of Rosseto Resorts Limited
submitted by the company to SEBI that the
entity is a shareholder from May 15, 1995.
However, there were no subsequent
transfer(s) of these shares. On the contrary,
the name of shareholder and folio number is
present in RTA list but is not present in MCA
list (which had no Abeyance records).

ACJPG8162C

AOBPS1451C

RAJEEV
GARG

MANISHA
JAYESH
SHAH

Order in the matter of Radford Global Limited

Also 600 shares were dematerialised by the

company/RTA on 17.02.2012 out of which
550 4.60% 550 shares have been sold in 29 trades from
21.09.2012 to 28.01.2013. Further, the
company/RTA was unable to furnish
necessary documentary evidence which it had
relied upon to ascertain the genuineness of
shareholding of the seller i.e. Rajeev Garg.
The remaining 50 shares were there in his
account as on 28.01.2013.
The distinctive number range of the shares as
submitted by the RTA in its list were different
vis-a-vis the share certificate's copy furnished
by the company to SEBI.
As submitted by RTA, Sangeetha w/o Ajith
Kumar had transferred 1000 shares to
Manisha Jayesh Shah on 30.11.2011. The
name of Sangeetha w/o Ajith Kumar (whose
34 0.28%
holding was 2000 shares) figures in the MCA
list but does not figure in RTA list. These
1000 shares were dematerialised on
18.02.2012 out of which 966 shares were
Page 15 of 23

transferred to Sunil Kansara (entity

mentioned at point 6). The remaining 34
shares were sold in 30 trades from 24.5.2012
to 8.8.2012. Manisha J Shah controlled the
supply of the shares by selling 1 or 2 shares at
a time, even though large buy-side orders
were in the system.
The physical share certificate of Manisha
Jayesh Shah as furnished by the company is
that of PS Global Ltd (earlier name of
Radford Global Limited). It is also observed
that the sticker of the name i.e. P S Global Ltd
has been affixed on the share certificate of
Rossette Resorts Ltd. (P S Global was earlier
known as Rossette Resorts Ltd.). This is a
deviation from the process of issuing new
share certificate as submitted by the company
to SEBI vide letter dated Aug 21, 2015, as
there is no mention of affixing sticker of new
company name (PS Global Ltd.) on old
company name's share certificate (Rossette
Resorts Ltd.) itself. In this case the
genuineness of the shareholding has not been
established by the company / RTA.
It is also further observed that Manisha Jayesh
Shah is related with one of the then directors
of the company i.e. Manish Nareshchandra
Shah (PAN: AELPS8560A) as their address
(B-2,Vishwakarma Society, V.P. Road,
Andheri West, Mumbai, Maharashtra, India,
400058) and phone number (26280622)
registered in KYC records are same. It is also
noted that Manish Nareshchandra Shah has
already been debarred by SEBI from dealing
in securities vide the earlier interim order

Order in the matter of Radford Global Limited

Page 16 of 23

ATWPK6701
D

ARTIBEN
S
KANSARA

As per information submitted by the RTA,

Sumerji Sethia (holding 4000 shares) had
transferred 1500 shares to Artiben S Kansara.
However, neither the company nor the RTA
could produce necessary documentary
evidence for establishing the genuineness of
the transfer of shareholding from Sumerji
Sethia to Artiben S Kansara. Further, name of
Sumerji Sethia is present in MCA list. The said
1500 shares were dematerialised by Artiben S
Kansara on 18.02.2012 of which only 10
10 0.08%
shares have been sold in 10 trades from
16.08.2015 to 6.9.2012, that too when large
buy-side orders were there pending for
execution. She controlled the supply of the
shares by selling 1 or 2 shares at a time.
Remaining 1490 shares were there in her
account as on 28.01.2013.
It was also observed that she had same
address and phone number as that of Sunil
Mohanlal Kansara.

ANFPK3652
G

AAKHA8826
N

SUNIL
MOHANL
AL
KANSARA

ANUP
MANILAL
SHAH
(HUF)

Order in the matter of Radford Global Limited

517 4.33%

Received 966 shares on 31.08.2012 through

off market transaction from Manisha Jayesh
Shah (entity at point 2) who is related to the
then director of the company.
He sold 517 shares from 31.12.2012 to
10.01.2013 in 10 trades. Remaining 449 shares
were there as on 28.01.2013 in his account.

2800

Sadhana Trivedi (500 shares), Ashok Mistry

(1000 shares), Indravadan Shah (500 shares)
and Vrajmohan Parikh (1000 shares)
transferred 3000 shares to Anup Manilal Shah
23.43
(HUF) in June 2012.
%
Further, Anup Manilal Shah also received 200
shares from Sureshchandra M Raja on
31/3/2012 and 600 shares from Nirupama H.
Page 17 of 23

Badani and Harish B. Badani (joint holders)

on 31/3/2012.
Five share certificates (i.e. 500 shares out of
600 mentioned above) received by Anup
Manilal Shah from Nirupama Badani/Harish
B. Badani (joint holders) did not have
authorized signature of Company secretary or
RTA's authorized personnel on it. The
company/RTA was not able to furnish
necessary documentary evidence which it had
relied upon to
(i) ascertain the genuineness of shareholding
of the Anup Manilal Shah,
(ii) verify the transfer of shareholding from
aforesaid entities to Anup Manilal Shah
and
(iii) grant subsequent approval for the
dematerialization request of these
unsigned share certificates.
Further, as per MCA list, Indravadan Shah
and Vrajmohan Parikh were holding 10,000
shares each in single certificate and RTA did
split the share certificates of any of these
shareholders. RTA transferred 1000 shares
each from Indravadan Shah and Vrajmohan
Parikh to Anup Manilal Shah (HUF) without
splitting shareholding of 10,000 shares each
of Indravadan Shah and Vrajmohan Parikh.
Anup Manilal dematerialised Shah 3800
shares on 09.08.2012 out of which he sold
2800 shares in a single day i.e. on 10.01.2013
in 9 trades. Remaining 1000 shares were there
in his account as on 28.01.2013.

Order in the matter of Radford Global Limited

Page 18 of 23

HARI
MOHAN
ACLPK9984A
KHANDE
LWAL

KANAIYA
LAL
MANILAL
GANDHI

ABGPG6544
G

VEENA
MOHAND
AHGPV3775J AS
VALBHA
NI

Order in the matter of Radford Global Limited

The RTA, prima facie, did not seek seller

confirmation before transfer of shares to
Anup Manilal Shah (HUF).
As per the photocopy of share certificates of
Rosseto Resorts Ltd. submitted by the
company to SEBI, the entity has been a
shareholder from May 15, 1995 and there
were no subsequent transfer(s) of these
shares. However, the name of shareholder &
folio no. are not present in MCA list as well
as in RTA list. Shares were issued to him from
1000 8.37%
Abeyance List. The 1000 shares held by him
were dematerialised on 21.06.2012 The
company/RTA was not able to furnish
necessary documentary evidence which it
relied upon to ascertain the genuineness of his
shareholding. Further, these 1000 shares were
sold by him in 6 trades from 23.07.2012 to
04.10.2012.
His name and folio numbers are not present
in MCA list and RTA list. Shares were issued
to him from abeyance list. The Company has
not submitted any documentary evidence
which it relied upon to establish the
genuineness of the shares held by him before
500 4.18%
issuance from the abeyance list.
The 500 shares held by him were
dematerialised on 24.05.2012. Further, he
sold all 500 shares from 10.09.2012 to
12.10.2012 in 5 trades.
As per the photocopy of share certificates of
Rosseto Resorts Ltd. submitted by the
company to SEBI, the entity is a shareholder
from May 15, 1995 and there were no
500 4.18%
subsequent transfers of these shares.
However, her name and folio no. 11501 are
not present in MCA list and RTA list. 500
Page 19 of 23

shares were issued to her from the abeyance

list which were dematerialised on 08.10.2012.
In spite of the fact that her name does not
figure in the MCA list and the company
showed her as a shareholder since 1995 (as
per physical share certificate), the
company/RTA were not able to furnish
necessary documentary evidence which was
relied upon to ascertain the genuineness of
her shareholding.
She sold 500 shares in a single day i.e. on
1.11.2012 to Prem Lata Nahar.

AGSPS5666E

BHARAT
KUMAR
JAYANTIL
AL SHAH

As per the photocopy of share certificates of

Rosseto Resorts Ltd. submitted by the
company to SEBI, he is a shareholder from
May 15, 1995 onwards and there were no
subsequent transfers for these shares. On the
contrary, the name and folio number of the
shareholder are not present in MCA list
(which had no abeyance records in it) as well
as RTA list. He was issued shares from
abeyance list and dematerialised. 500 shares
450 3.77%
on 8.10.2012. The company/RTA was not
able to furnish necessary documentary
evidence which it relied upon to ascertain the
genuineness of his shareholding.
He had sold 450 shares from 9.10.2012 to
10.1.2013 to Taran (250 shares), Beacon (100s
hares), Bharat (50 shares) and Jagruti (50
shares). Remaining 50 shares were there in his
account as on 28.01.2013.

Order in the matter of Radford Global Limited

Page 20 of 23

10

11

12

AELPG9023L

RAMILA
GANDHI

AFXPS1751C

REKHAB
EN
LAKHAB
HAI
SAGPARI
A

HASUMA
TI
ANIPM9254B GHANSH
YAM
MANDLIA

Order in the matter of Radford Global Limited

Ramila Gandhi has sold 300 shares from

28.08.2012 to 05.09.2012 through on market
transactions. 200 shares were dematerialised
on 24.05.2012 and 100 shares were
dematerialised on 17.08.2012. 200 shares were
issued from Abeyance list by RTA.
300 2.51%
Remaining 100 shares were neither present in
RTA list nor in the shares issued from
Abeyance list by RTA. Hence, source of 100
shares is not known. Name and folio number
of the entity is not present in MCA list and
RTA list.
The entities namely Pravin Patel (500 shares),
Rekha Sojitra (400 shares), Shobhana Sohitra
(200 shares) transferred shares to Rekhaben
Lakhabhai Sagparia. As these three names
were not present in RTA list, hence they were
issued shares from the Abeyance List. The
said 1100 shares were dematerialised on
16.08.2012. Out of which, 100 shares were
sold to Manjulaben on 17.09.2012 and 100
200 1.67% shares were sold to Ankit Kachhara on
18.09.2012.
The entity was issued shares from Abeyance
List. Further the entity's name did not feature
in MCA List as well as RTA List. The
company/RTA was unable to furnish
necessary documentary evidence to ascertain
the genuineness of shareholding of Rekhaben
Lakhabhai Sagparia.
The name of the entity is not present in MCA
list and RTA list. Hasumati Ghanshya
Mandlia was issued 200 shares from the
Abeyance list. The share certificate was issued
200 1.67%
in lieu of old certificate. However, when
inquired, the company/RTA could not
furnish old certificate for verification and
ascertaining the genuineness of shareholding
Page 21 of 23

of Hasumati Ghanshya Mandlia. The said 200

shares were dematerialised by the entity on
27.09.2012. The entity has sold 150 shares to
Navin Munyal and 50 shares to Prem Lata on
market.

13

AALPT9962B

MANSUK
HBHAI
JAGABHA
I TANTI

As per the share certificate, Mr. Purshotam

Senjalia had transferred 100 shares to
Mansukhbhai Jagabhai Tanti on 01.07.1996.
However, name of Mansukhbhai Jagabhai
Tanti is not present in RTA list and MCA list.
Hence, shares were issued from the abeyance
list. The company/RTA was not able to
100 0.84% furnish necessary documentary evidence to
ascertain the genuineness of shareholding of
Mansukhbhai Jagabhai Tanti.
100 shares were dematerialised on 8.10.2012.
All the 100 shares were sold in 1 instance to
Pooja Agarwal on 17.10.2012 through onmarket transaction.

14

AAYPM2723J

DINA
SATISHK
UMAR
MEHTA

Order in the matter of Radford Global Limited

As per MCA list, Folio number 13742

corresponds to Priya Sanghvi and as per RTA
list, it corresponds to Rajendra Popatlal Patel.
As per information furnished by RTA,
Rajendra Popatlal Patel had transferred 100
shares to Dina Mehta but name of the
Rajendra Popatlal Patel is not present in the
MCA list. Further, Rajesh Popatlal Patel's
100 0.84% share certificate mentions "issued in lieu of
old certificate". However, when inquired, the
company/RTA could not furnish old
certificate for verification and to ascertain the
genuineness of shareholding of the suspected
seller, Dina Satishkumar Mehta. These 100
shares were dematerialised on 26.04.2012. She
sold entire 100 shares in 1 trade to Prem Lata
Nahar on 11.05.2012 on-market.

Page 22 of 23

15

AGWPP5778
Q

Her name is not present in the MCA list and

the RTA list. The share certificate mentioned
that it was "issued in lieu of old certificate".
However, when inquired, the company/RTA
could not furnish old share certificate for
verification and to ascertain the genuineness
60 0.50% of her shareholding. The entity was issued 300
shares by RTA from the Abeyance list and the
same were dematerialised on 10.01.2013. Out
of these 300 shares, 60 shares were sold in 5
trades during the period 16.01.2013 to
24.01.2013 and the remaining 240 shares were
there in her account on 28.01.2013.

PRAGNA
PATEL

Total

7321

61.26% of shares, whose source of acquisition

61.26
is questionable, were sold on-market during
%
the examination period.

Sd/DATE: November 9th, 2015

PLACE: MUMBAI

RAJEEV KUMAR AGARWAL

WHOLE TIME MEMBER
SECURITIES AND EXCHANGE BOARD OF INDIA

Order in the matter of Radford Global Limited

Page 23 of 23