WTM/RKA /ISD /161 /2014

SECURITIES AND EXCHANGE BOARD OF INDIA

ORDER

UNDER SECTION 11(1), 11(4) AND 11B OF THE SEBI ACT, 1992 AND SECTION 12A
OF THE SECURITIES CONTRACTS (REGULATION) ACT, 1956 - IN THE MATTER
OF RADFORD GLOBAL LIMITED AND OTHERS

1. Pursuant to preliminary examination by Bombay Stock Exchange Limited ("BSE") in the

dealings in the shares of Radford Global Limited {hereinafter referred to as "Radford"},
Securities and Exchange Board of India ("SEBI") undertook a preliminary inquiry in the dealings
in the shares of Radford for the period January 28, 2013 to March 24, 2014 {hereinafter referred
to as "the examination period"}.

2. On January 28, 2013, pursuant to a stock split, the face value of each share of ₹10/- was reduced
to ₹2/- per share. Post stock-split, during the period January 29, 2013 to July 23, 2013 ("Patch
I"), the price of the scrip of Radford opened at ₹49.20, rose to a high of ₹86.00 and closed at
₹74.95. During the period July 24, 2013 to March 24, 2014 ("Patch II"), the price of the scrip
continuously fell from ₹74.10 to ₹4.89. An illustration of price/volume movement in the scrip
of Radford during the examination period is given below:

No.of Shares Close Price

2000000 90
1800000 80
1600000 70
1400000 60
1200000
50
1000000
40
800000
600000 30
400000 20
200000 10
0 0

*It was noticed that during the period February 27, 2012 to January 28, 2013("Pre-Patch I") the price of the shares
of Radford was at ₹3.20, rose to a high of ₹241.35 and closed at ₹241.35.

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Order in the matter of Radford Global Ltd. Page 1 of 27
3. The preliminary examination revealed that there was a pattern in which the shares of Radford
were being traded. The modus operandi adopted by the traders in the scrip is as under :
i. Firstly, shares were allotted on preferential basis in Pre-Patch I to entities connected/related
directly or indirectly to Radford.
ii. Then, just prior to the expiry of lock-in of shares issued on preferential basis, Radford
announced a stock-split to make a passage for preferential allottees to exit on expiry of the
lock-in since the stock split would reduce the per share price and increase liquidity.
iii. After the expiry of lock-in, it was noted that after the stock split, the preferential allottees
sold the shares to entities connected/related, directly or indirectly, to Radford
Group/Suspected Entities, thereby raking in huge profits.
iv. It was also noted that the said price movement was not backed by fundamentals of the
company and its financials.

4. During the beginning of Pre-Patch I, on February 16, 2012, Radford had allotted 91,00,000
equity shares of ₹10/- each at a premium of ₹5/- on preferential basis to 48 entities aggregating
to 13.65 cr. (list provided in Annexure A). Out of these 48 entities, 4 entities viz. Brij Bhushan
Singal, Neeraj Singal, Ritu Singal and Uma Singal are connected to the Radford and 19,00,000
shares (20.87% of total number of shares allotted) were allotted to these four entities. The shares
allotted on preferential basis to aforesaid allottees were locked-in for a period of 1 year in
compliance with Securities and Exchange Board of India (Issue of Capital and Disclosure
Requirements) Regulations, 2009. Thus, these shares held by the said 48 allottees pursuant to
preferential allotment and split were not tradable in this lock in period.

5. On analysing the financial statements of Radford, the following was observed:-

Table: I - Financial year-wise particulars of Radford
FY 2011-12 FY 2012-13 FY 2013-14
Total Number of paid
1,40,62,300(₹10) 7,03,11,500(₹2) 7,03,11,500(₹2)
up Shares (Face Value)
Total Revenue 3.04 crore 22.28 crore 11.04 crore
Profit after tax 0.06 crore 0.46 crore 0.18 crore
Earning per share 0.01 0.07 0.03

6. From Table I, it is observed that the total number of paid up shares of Radford, after taking into
account the stock-split dated January 28, 2013, increased by 5 times to 70,311,500. From the
Annual Reports of Radford for FY 2011-12 and FY 2012-2013, it was observed that it is in the
business of Staffing Services, Textile and Real Estate and it had earned a profit of ₹6,17,264/-
during 2011-12 and ₹45,87,092/- during FY 2012-13. From the Annual Report of Radford for

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Order in the matter of Radford Global Ltd. Page 2 of 27
 the FY 2012-2013 it is observed that for the FY ended 2012 the EPS was ₹0.01/- and for the
FY ended March 31, 2013 EPS was ₹0.07/-. It was further noted that during the Pre-Patch I
there was no material corporate announcement made by Radford which could support such
price rise in its scrip. It is observed from the above facts that the price rise of 7442% during Pre-
Patch I was not justified and aberrant. Also the movement was extremely aberrant vis-a-vis the
movement of the stock market as the Sensex only moved from 17,645 to 20,103.

7. The sharp price rise in the scrip as discussed above was not supported by fundamentals of
Radford or any other external factor. The price in the scrip increased prior to the expiry of the
lock-in period on the shares held by the aforesaid allottees pursuant to preferential allotment and
split. After the expiry of the lock-in period, the price and volume in the scrip increased
substantially. Considering such pattern, the trading in the scrip in three patches as mentioned
above was analyzed. The analysis of the trading during the patches was carried out with a focus
on the following:-
 The trading frequency;
 The volume generated;
 Contribution to price rise;
 Buying behavior as observed from Last Traded Price ("LTP") data.

8. On analysis of trading activity in the Scrip, it was observed that certain entities was primarily
involved in pushing the price up during the lock in period, which is Pre-Patch I, by contributing
to positive LTP through first trades with negligible volumes. Another group of entities were
acting as buyers in Patch-I in order to provide exit to preferential allottees and in the process
creating artificial volume which has been dealt with in detail subsequently.

9. During Pre-Patch I, the scrip opened at ₹3.20 (pre-split price) on February 27, 2012 and rose to
a high of ₹241.35 and closed at ₹241.35 on January 28, 2013. During this period, the scrip was
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 1.6 trades 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 orders
contributed significantly to the price rise. From LTP analysis, it is observed that price of the
scrip increased from ₹3.20 to ₹241.35 mainly through first trades in 121 instances.

10. It was observed that in Pre-Patch I, out of a total of 121 instances of trades establishing new
high price in the scrip, certain entities established new high price on 91 instances (75.21% to
total instances). The contribution of these entities in establishing new high price was ₹204.3/-

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Order in the matter of Radford Global Ltd. Page 3 of 27
 out of total price rise of ₹ 246.7/-, which constitutes 82.81% of the total new high prices. The
details of contribution to price rise by these entities during Pre-Patch I are as under:

Table II : Details of entities and their contribution to price rise in Pre-Patch I

Pos
LTP
No. % to Tot Pos
Contri
Sr. Trading Member of I Total Pos Contr
Clnt Name Clnt Pan of the
No. Name nsta Insta Contri i (in
Client
nces nces In Sec %)
as a
buyer
Taran Kumar
1 ASVPR5947G Shilpa Stock Broker 14 11.57 45.21 246.7 18.33
Rungta
Pvt. Ltd.
2 Prem Lata Nahar AFAPN8764M 25 20.66 43.3 246.7 17.55
Manjulaben Sanghavi Brothers
3 ALVPP7764J 15 12.4 32 246.7 12.97
Sukhdev Pandya Brokerage Ltd.
Rajat Share Broking Shilpa Stock Broker
4 AAACR2695B 6 4.96 25.5 246.7 10.34
Pvt Ltd Pvt.Ltd.
Rajesh Pravinkumar Monarch Research &
5 ACWPJ4705B 7 5.79 24.85 246.7 10.07
Jasani Brokerage Pvt.Ltd.
Bcb Brokerage
6 Bharat Bagri Bagri AADHB8488A 16 13.22 17.86 246.7 7.24
Pvt.Ltd.
Jayesh Narendra Bharti Thakkar India
7 AAEHJ1610D 8 6.61 15.58 246.7 6.32
Kesharia Securities Pvt.Ltd.
Total 91 75.21 204.3 246.7 82.81

11. It was also observed that most of these aforementioned entities had also traded and were
instrumental in contributing to the price rise of other stocks. It was further observed that Taran
Kumar Rungta, Prem Lata Nahar and Rajat Share Broking Pvt. Ltd are related /connected to
Shilpa Stock Broker Pvt. Ltd and Bharat Bagri Bagri is related to BCB Brokerage Pvt. Ltd. through
whom they have traded. Ms. Prem Lata Nahar is the Mother of Rakesh Nahar who is the
owner/director of Shilpa Stock Broker Pvt. Ltd. and Bharat Bagri is the Promoter/ director of
BCB Brokerage Pvt. Ltd and share common address with BCB Brokerage Pvt. Ltd.

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 such dubious price-rise track record in which the said entities and their connected brokers
are involved also cast doubts on their conduct in the securities market.

13. On analysis of trading activity during Patch I, certain related/connected entities ("Radford
Group") to Radford were found to be net buyers to the preferential allottees and thereby created

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Order in the matter of Radford Global Ltd. Page 4 of 27
 artificial demand for the supply of shares from preferential allottees. Further, it was also noticed
that a group of entities connected/related ("Suspected Entities") to each other, by virtue of
common address;/e-mail id. were trading in the shares of Radford amongst themselves. During
the Patch I, significant increase in the trading volume was observed and it appears that most of
the entities were acting as counterparty to the preferential allottees. Also on further examination
direct/ indirect relationship were established among these entities through Know Your Client
(KYC) details , their bank statements, off-market transactions amongst themselves, and
information available on the Ministry of Corporate Affairs (MCA) website. List of such entities
are annexed as Annexure - B and hereinafter referred to as the "Radford Group & Suspected
Entities".

14. It is observed that during Patch I, the preferential allottees were net sellers and entities forming
part of the Radford Group & Suspected Entities were net buyers, a snapshot of which is given
below:-

Table III - Exit provided by Radford Group & Suspected Entities to allottees

Shares Total
% of
purchased % of shares
Shares Total % of Net
from preferential bought in
sold allotted Buy
preferential shares Sold the Patch I
shares
allottees by
Preferential
4,15,99,539 91.43% - - - -
Allottees
Radford Group 2,76,84,200 70.01%
& Suspected - - (refer table 67.77% 4,08,51,126 (refer table
Entities IV) IV)

15. It is observed from Table III that most of the trades were taking place between the preferential
allottees and the entities of Radford Group & Suspected Entities . During this period, the allottees
were found to be selling and in the process gaining a huge profit/gain. It was observed that
Radford Group & Suspected Entities contributed 70.01% to the net buy trade during this patch. The
details of counter parties for sale transactions by preferential allottees is given below:

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Order in the matter of Radford Global Ltd. Page 5 of 27
 Table - IV: Details of counter parties for sale transactions
Shares % of shares
purchase bought
Vol of d from from
Sr. Net Buy Net preferenti preferential
Client Name Clnt Pan
No. in Patch I Buy in al allottes allottes to
Patch I during the Net
post split Buy in
period Patch I

1 2 3 4 5 6 7=6/4*100
Radford Group
Amrusha Mercantile
1 AALCA0340D 3317965 5.69 2281121 68.75
Private Limited
Spice Merchants Private
2 AAPCS7492G 3287475 5.63 2422355 73.68
Limited
Shelter Sales Agency
Private Limited Shelter
3 Sales Agency Private AASCS1797F 3122146 5.35 2312395 74.06
Limited Shelter Sales
Agency Private Limited
Udbal Mercantile Private
4 AABCU2648C 2767601 4.74 1588720 57.40
Limited
Devakantha Trading
5 AADCD7044B 2475491 4.24 1705206 68.88
Private Limited
Winall Vinimay Private
6 AAACW8004B 2144989 3.68 1764206 82.25
Limited Ltd
7 Pine Animation Limited AAECM0267A 1858368 3.18 1081586 58.20
Limestone Properties
8 AACCL0133G 1764054 3.02 1357040 76.93
Private Limited
Runicha Merchants
9 AAECR0580M 1584913 2.72 1325164 83.61
Private Limited
Dhanleela Investments
10 & Trading Company AAACR1770P 1464988 2.51 680586 46.46
Limited
Apex Commotrade
11 AAJCA4459K 1223735 2.10 1033114 84.42
Private Limited Ltd
Shivkhori Construction
12 AAPCS7850L 926220 1.59 896440 96.78
Private Limited
Signet Vinimay Private
13 AAMCS1712Q 903711 1.55 913195 101.05
Limited
Anjali Suppliers Private
14 AAJCA1784D 893000 1.53 747275 83.68
Limited
Sanklap Vincom Private
15 AAMCS1711P 892600 1.53 613910 68.78
Limited
16 Rangan Vincom Private AAGCR1715E 725705 1.24 720970 99.35

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Order in the matter of Radford Global Ltd. Page 6 of 27
 Limited
Pyramid Trading And
17 AAACP2548R 647675 1.11 518992 80.13
Finance Ltd
Divyadrishti Merchants
18 AABCD8147K 537000 0.92 499448 93.01
Pvt Ltd
Divya Drishti Traders
19 AABCD8146J 532000 0.91 450691 84.72
Pvt Ltd
Ladios Trading Private
20 AACCL3868N 507160 0.87 473093 93.28
Limited
Skm Travels Private
21 AAICS0688K 494050 0.85 443724 89.81
Limited
Avlokan Dealcom
22 AALCA1583G 389706 0.67 368706 94.61
Private Limited
Topwell Properties
23 AADCT8403C 250000 0.43 160600 64.24
Private Limited
Esquire Enclave Private
24 AACCE7065J 225000 0.39 87233 38.77
Limited
Natural Housing Private
25 AADCN6251G 200000 0.34 183926 91.96
Limited
Radison Properties
26 AAFCR2818B 160125 0.27 114517 71.52
Private Limited
27 Ridhi Vincom Pvt Ltd AAECR9858C 115000 0.20 115000 100.00
Dhanraksha Vincom
28 AADCD6028P 113390 0.19 112390 99.12
Pvt Ltd
Kingfisher Properties
29 AAECK3394G 95000 0.16 92400 97.26
Private Limited
Vibgyor Financial
30 AAACV8378B 82000 0.14 37840 46.15
Servicepvt Ltd
Blue Circle Services
31 AAACB2131L 64073 0.11 60323 94.15
Limited
Amrit Sales Promotion
32 AACCA3220D 47000 0.08 47000 100.00
Pvt Limited
Burlington Finance
33 AABCB2575P 34500 0.06 30000 86.96
Limited
Bazigar Trading Private
34 AABCB3052B 34500 0.06 32347 93.76
Limited
Katyani Commodities
35 AAECK6244R 25000 0.04 70000 280.00
Private Limited
Manimudra Vincom
36 AADCM4316K 23500 0.04 23200 98.72
Private Limited
Devatma Distributors
37 AADCD7140G 11950 0.02 11950 100.00
Private Limited
Symphony Merchant Pvt
38 AADCS5411K 5000 0.01 5000 100.00
Ltd
39 Scope Vyapar Pvt. Ltd. AAICS6023N 0 0.01 11000 0.00
Total (I) 33946590 58.18 25392663 74.80

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Order in the matter of Radford Global Ltd. Page 7 of 27
 Suspected Entities
Jayant Security &
1 1535303 44.75
Financeltd AAACJ4848G 3430961 5.88
2 Trimurthi Finvest Ltd AAACT6383N 1051222 1.80 329978 31.39
3 Purvi Finvest Limited AABCP6564C 1077750 1.85 129253 11.99
East West Finvest India
4 224803 20.01
Limited AAACE6834D 1123353 1.92
East West Finvest India
5 72200 32.63
Limited AADCE1236G 221250 0.38
Total (II) 6904536 11.83 2291537 33.19
Grand Total (I+II) 40851126 70.01 27684200 67.77

16. It is observed that 46 allottees made a collective profit of ₹313.01 Crore on their total
investment of ₹12.99 crore, a substantial return of approximately 2309 % on their investment in
a period of 18 months (including the lock in period). It is evident from the above analysis of
trading in Patch I that the entities of Radford Group & Suspected Entities provided a hugely
profitable exit to the allottees, who also were related directly/indirectly to Radford. The
profit/gain earned by the allottees during Patch I is given below:-

Table V: Details of the trades carried out by allottees and profit calculation

Qty Post Price Qty Qty

Total Sum of Profit Earned Bala
Client Qty Stock after Bought Sold in Sell
SrNo PAN Qty in SOLD nce
Name Allotted Split (Jan Stock in Off Off
Hand QTY
Rate (₹) Qty
29, 2013) Split Market Market
Achal
ABAPB8 6094
Chand 150000 750000 3 0 500000 250000 189060 80.36 14625025
617M 0
Balar
Abhishek
AATPB8 8400
1 Achalcha 0 0 3 250000 0 250000 166000 85.22 13648846
811B 0
nd Balar
Piyush
AEMPB6 1100
Kumar 0 0 3 250000 0 250000 140000 83.39 11254028
394Q 00
Balar

AfsarZaid AADPZ8
2 100000 500000 3 0 0 500000 500000 80.04 38522857 0
i 571G

Amresh
AACPM4
Anantrai 100000 500000 3 0 450000 50000 50000 79.85 3842500 0
024E
Mody
3
Hasumati
AJSPM79
Anantrai 0 0 3 450000 0 450000 450000 83.85 36381293 0
35P
Mody
Anil Rajat
Agarwal AAFHA0
4 60000 300000 3 0 0 300000 300000 69.11 19831633 0
& Sons 709M
(Huf)

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Order in the matter of Radford Global Ltd. Page 8 of 27
 Qty Post Price Qty Qty
Total Sum of Profit Earned Bala
Client Qty Stock after Bought Sold in Sell
SrNo PAN Qty in SOLD nce
Name Allotted Split (Jan Stock in Off Off
Hand QTY
Rate (₹) Qty
29, 2013) Split Market Market
Ashok AACPJ36
5 250000 1250000 3 0 0 1250000 1250000 79.18 95222911 0
Jiwrajka 10K
Babita AAIPG4
6 150000 750000 3 0 0 750000 750000 79.34 57254421 0
Mittal 573G
Bimal AAKPD3
7 200000 1000000 3 9001 0 1009001 1009001 83.22 80945955 0
Desai 160A
Brij
AEFPS62
8 Bhushan 580000 2900000 3 0 0 2900000 2900000 82.12 229451547 0
98M
Singal
Dalsukh
ACDPT3
9 Ujamshi 100000 500000 3 0 0 500000 500000 81.3 39148937 0
428N
Trevadia
Dilip
AADPM
10 Chotalal 200000 1000000 3 0 0 1000000 1000000 55.79 52788678 0
9919M
Morzaria
Dilip AAGPJ87
11 250000 1250000 3 0 0 1250000 1250000 79.2 95246103 0
Jiwrajka 56J
GM AEYPM5
12 200000 1000000 3 0 0 1000000 1000000 71.91 68913912 0
Lingaraju 850Q
GM
AHEPG0
13 Prasanna 200000 1000000 3 0 0 1000000 1000000 76.72 73720095 0
025A
Kumar
G S Anith ADPPK9
14 200000 1000000 3 0 0 1000000 1000000 77.8 74800649 0
Kumar 874N
Harikisha
AAJPV47
15 nS 100000 500000 3 0 0 500000 500000 82.99 39994974 0
54H
Virmani
Hitesh AABPJ28
16 100000 500000 3 0 0 500000 500000 82.64 39819781 0
Jain 35R
Hukamsi
ngh
Bhawarsi AABPR9
17 100000 500000 3 0 0 500000 500000 81.16 39080552 0
nghji 949J
Rajpurohi
t
Jyoti Anil ABWPT8
18 100000 500000 3 0 0 500000 500000 81.39 39195997 0
Trevadia 000C
Jyotsna
AHPPD4
19 Jitendra 200000 1000000 3 0 9001 990999 990999 70.65 67041531 0
223L
Desai
Kalpita
AAAPL9
20 Suresh 100000 500000 3 0 0 500000 500000 58.83 27916282 0
611J
Luniya
Kamal
AFFPP52
21 Indur 100000 500000 3 0 0 500000 500000 79.31 38156782 0
07G
Punwani
Mayuri
Darshan AKJPB85
22 100000 500000 3 0 0 500000 500000 72.34 34669719 0
Bhanusha 72F
li
Mohan APFPM0
23 150000 750000 3 0 0 750000 750000 79.86 57648728 0
Mittal 496Q
Mohit ADSPA9
24 150000 750000 3 0 0 750000 750000 76.29 54964382 0
Aggarwal 301K
Mukesh AJGPM2
25 150000 750000 3 0 0 750000 750000 80.1 57826737 0
Mittal 125D

Naresh
ACRPS01
26 Nemchan 400000 2000000 3 0 0 2000000 2000000 78.78 151568641 0
82J
d Shah
Neeraj ANRPS7
27 580000 2900000 3 0 0 2900000 2900000 79.61 222156517 0
Singal 986B

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Order in the matter of Radford Global Ltd. Page 9 of 27
 Qty Post Price Qty Qty
Total Sum of Profit Earned Bala
Client Qty Stock after Bought Sold in Sell
SrNo PAN Qty in SOLD nce
Name Allotted Split (Jan Stock in Off Off
Hand QTY
Rate (₹) Qty
29, 2013) Split Market Market
Nishit
Agarwal AABTN3
28 200000 1000000 3 0 0 1000000 1000000 78.55 75549009 0
Beneficiar 350K
y Trust
Pinky ACGPA7
29 200000 1000000 3 0 0 1000000 1000000 82.47 79471984 0
Agarwal 438L
Pratik
Agarwal AABTP7
30 200000 1000000 3 0 0 1064874 1064874 79.01 76033232 0
Beneficiar 516K
y Trust
Praveen
ACSPA4 5000
31 Kumar 200000 1000000 3 0 0 1000000 500000 78.47 37735000
725A 00
Agarwal
Praveen
Kumar AAIHP6
32 200000 1000000 3 0 0 1000000 1000000 82.6 79600930 0
Agarwal 229C
Huf
Rajendra
ACPPJ98
33 Mangilal 100000 500000 3 0 0 500000 500000 82.61 39805257 0
53R
Jain
Renu AAEPA1
34 150000 750000 3 0 0 750000 750000 79.96 57719482 0
Aggarwal 694C
Renu AGMPM
35 150000 750000 3 0 0 750000 750000 81.27 58703897 0
Mittal 1488Q
Ritu ABHPS3
36 515000 2575000 3 0 0 2575000 2575000 82.77 205404070 0
Singal 711M
Santosh ABAPA4
37 150000 750000 3 0 0 750000 750000 80.11 57833909 0
Aggarwal 548E
Shailesh
AAAPJ67
38 Mangilal 100000 500000 3 0 0 500000 500000 82.4 39700599 0
65F
Jain
Shilpa AEXPA1
39 150000 750000 3 0 0 750000 750000 75.32 54238750 0
Aggarwal 230M
Surendra AACPJ43
40 250000 1250000 3 0 0 1250000 1250000 79.2 95249153 0
Jiwrajka 16L
Sushant
ACAFS8 1010
41 Investme 250000 1250000 3 0 0 1250000 239604 78.75 18149101
650G 396
nts
Tanvi
AFAPT5
42 Bhavik 100000 500000 3 0 0 500000 500000 80.07 38535769 0
888A
Trevadia
Tarun AOQPA9
43 150000 750000 3 0 0 750000 750000 79 57001648 0
Aggarwal 034E
Ujwala
AAEPM5
44 Namdev 100000 500000 3 0 0 500000 500000 46.16 21577500 0
924H
Mane
Uma ANRPS7
45 225000 1125000 3 0 0 1125000 1125000 78.6 85053164 0
Songal 987A
Yogesh
AAPPT1
46 Popatlal 200000 1000000 3 0 0 1000000 1000000 80.15 77154413 0
825P
Thakkar
1765
Total 8660000 43300000 959001 959001 43300000 41599539 ₹313,01,56,898
336

17. The transactions wherein the entities of Radford Group & Suspected Entities bought most of the
shares sold by the allottees cannot be just a coincidence particularly when sellers by virtue of
being allotees and prima facie connected / have nexus with Radford and its promoters/ directors
and buyers are the entities connected with Radford and its promoters /directors. From the

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Order in the matter of Radford Global Ltd. Page 10 of 27
 analysis presented for Pre-Patch I, it is observed that the shares of Radford 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 I. 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 Radford Group & Suspected Entities created the demand against the supply
from the preferential allotters. 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 Radford Group
& Suspected Entities provided a hugely profitable exit to the allottees. This could be only possible
if the allottees, Radford Group & Suspected Entities and Radford 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.

18. From the facts stated above, it can be safely assumed that the entire modus operandi of allotting
preference shares at a premium, announcing a stock split and then bringing in connected entities
to provide exit was a scheme devised to rake in ill-gotten gains.

19. In Patch II, the price of the shares of Radford has decreased from ₹74.10 to ₹4.89, i.e. a fall of
approximately 93.4%. Also the volumes have again decreased by 67% of the volume of Patch I.
On analysis of the top 20 sellers during the period, it was noted that 9 entities of the Radford
Group & Suspected Entities have sold approximately 37% of the net traded volume. Also on
analysis of the negative LTP contribution, it was noted that the top 20 entities had contributed
72% of the price fall of which only 13% was contributed by Radford Group & Suspected Entities . It
indicates that a sizeable quantum of gullible investors had started trading in the shares of
Radford and were disposing at any possible price.

20. From the analysis of the trading across Patches, it can be comfortably stated that the modus
operandi of allotting shares on preferential basis at a premium, pumping the share price artificially
and then dumping the price so that the same cycle could be repeated, demonstrates the mala fide
of the Radford Group & Suspected Entities . Also the mechanism is being presumably used to
deceive the authorities by laundering black money and raking in tax-free profits.

21. It was noted that the price movement of the shares are negligible Post examination period till
the date of this order.

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Order in the matter of Radford Global Ltd. Page 11 of 27
22. From the above examination and factors as described in Annexure B, I note that the allottees,
Radford and Radford Group & Suspected Entities are connected to each other. In this regard, I note
that the 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.

23. It is pertinent to mention that the key to the scheme of operations employed by Radford Group &
Suspected Entities prima facie lies in the preferential allotment of shares made by Radford. 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 ("LTCG"). From the observations of the preliminary inquiry it is inter alia
noted that :-
a) the fund brought in by way of preferential allotment was utilised for purposes other
than those disclosed;
b) even when substantial number of shares i.e. 91 lakh shares (455 lakh shares after split)
were locked-in and non transferable / tradable, price of the scrip increased substantially
to the extent of 7442% with a very small chunk of volume / purchases by certain
entities;
c) After the expiry of the lock-in period (i.e. in Patch I), the average volume increased
astronomically to the extent of 505066% (5050 times). Such increase in volume was
mainly on account of matched trading amongst Radford Group & Suspected Entities and
allottees.
d) 46 out of the 48 preferential allottees sold 91.43% shares allotted to them by Radford at
the price increased on account of the aforesaid manipulative trading in Pre-Patch I.

24. From the above facts and circumstances it can reasonably be inferred that the preferential
allottees acting in concert with Radford Group & Suspected Entities have misused the stock
exchange system to generate fictitious LTCG. It is pertinent to note that LTCG is tax exempt.

25. In the facts and circumstances of this case, I am of the view that preferential allotment was used
as a tool for implementation of the dubious plan, device and artifice of Radford Group & Suspected
Entities and preferential allottees. One could argue that in 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 Radford prior to preferential allotment was
very small, i.e., 1,40,62,300 shares (Face Value: ₹ 10) to accommodate the required fictitious

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Order in the matter of Radford Global Ltd. Page 12 of 27
 LTCG of ₹313 crore approximately. As such the capital expansion through preferential
allotment and stock split provided much bigger source to the persons involved in terms of
volume and price manipulation to facilitate the whole operation.

26. Since prior to the trading in its scrip during the Examination Period, Radford did not have any
significant 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 noted that the traded
volume and price of the scrip increased substantially only after Radford Group & Suspected Entities
and allottees started trading in the scrip. The average volume increased by 5,05,066 % (5050
times) during the Patch I, i.e., from 98 shares per day to 4,95,063 shares per day and the price
increased by 74.8% during the same period, i.e., from ₹49.2 to ₹86. Radford Group & Suspected
Entities were trading in the scrip above the LTP and their trades created artificial volumes and
manipulated the price of the scrip during the examination period. It is further noted that on the
days when Radford Group & Suspected Entities were not trading, the trading volumes in the scrip
were very low and the substantial increase in traded volumes as observed in this case was mainly
due to their trading. I further note that Radford Group & Suspected Entities and allottees traded
amongst themselves as substantiated by their matching contribution to net buy and net sell in
Patch I. 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. In view of the above, I prima facie find
that Radford Group & Suspected Entities 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.

27. I am of the considered view that the scheme, 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
inasmuch 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 Radford Group & Suspected Entities 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 SEBI Act, 1992. The said regulations are
reproduced hereunder:-

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Order in the matter of Radford Global Ltd. Page 13 of 27
 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;
(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, 2003

"Prohibition of certain dealings in securities
3. 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;

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Order in the matter of Radford Global Ltd. Page 14 of 27
 (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;
(c)………………………………………………………………
(d)…………………………………………………… ……………
(e)any act or omission amounting to manipulation of the price of a security;
(f)…………………………………………………… ……………….
(g) entering into a transaction in securities without intention of performing it or without intention of change of
ownership of such security; "

28. I note that the directors of Radford during the relevant time (i.e. Prakash Bhawarlal Biyani,
Manish Nareshchandra Shah, Rajesh Kumar Maheshwari and Nitin Shivratan Murarjka), being
in control of the day to day affairs of Radford, had the knowledge of its acts and omissions. They
were also under an obligation to ensure that acts and transactions of Radford were not in
violation of any of the applicable provisions of SEBI Regulations or other applicable laws. I,
therefore, prima facie find that these directors were responsible for Radford 's acts and omissions
in this case.

29. 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 including LTP contributors, Suspected
entities, 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.

30. SEBI strives to safeguard the interests of a genuine investor in the Indian securities market. The
acts of artificially increasing the price of scrip mislead 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 Radford Group & Suspected Entities 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.

31. 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 preventive and remedial action is
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Order in the matter of Radford Global Ltd. Page 15 of 27
 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.

32. 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 the 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:-

Sr. No. Client Name Client PAN

Company
1 Radford Global Ltd. AABCM5771E
Directors of Radford Global Ltd.
2 Prakash Bhawarlal Biyani AJNPB0702E
3 Manish Nareshchandra Shah AELPS8560A
4 Rajesh Kumar Maheshwari ACJPM4653L
5 Nitin Shivratan Murarka AMBPM9321M
Promoters of Radford Global Ltd.
6 Radford InvestmentServicesPvtLtd AACCG9982A
Director of Radford Investment Services Pvt. Ltd.
7 Roshan Dwarkani ATXPD7040B
8 Suresh Kumar Saini BCXPS0818J
Preferential Allottees
9 AachalchandBalar ABAPB8617M
10 PiyushKumarBalar AEMPB6394Q
11 AbhishekKumarBalar AATPB8811B
12 AfsarZaidi AADPZ8571G
13 AmreshA.Mody AACPM4024E
14 HasumatiA.Mody AJSPM7935P
15 AnilRajatAgarwal&Sons.Huf. AAFHA0709M
16 AshokBJiwrajka AACPJ3610K
17 BabitaMittal AAIPG4573G
18 BimalJDesasi AAKPD3160A
19 BrijBhushanSingal AEFPS6298M

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Order in the matter of Radford Global Ltd. Page 16 of 27
 20 DalsukhUjamshiTrevadia ACDPT3428N
21 DilipBJiwrajka AAGPJ8756J
22 DilipChotalalMorzaria AADPM9919M
23 GMPrasannaKumar AHEPG0025A
24 GSAnithKumar ADPPK9874N
25 HariKishanSuderlalVermani AAJPV4754H
26 HiteshMangilalJain AABPJ2835R
27 HukamsinghB.Rajpurohit AABPR9949J
28 JyotiAnilTrevadia ABWPT8000C
29 JyotsnaJitendraDesai AHPPD4223L
30 KalpitaLuniya AAAPL9611J
31 KamalPunwani AFFPP5207G
32 LingarajuGM AEYPM5850Q
33 MayuriDarshanBhanushali AKJPB8572F
34 MohanMittal APFPM0496Q
35 MohitAggarwal ADSPA9301K
36 MukeshMittal AJGPM2125D
37 NareshNemchandShah ACRPS0182J
38 NeerajSingal ANRPS7986B
39 NishitAgarwalBenTrust AABTN3350K
40 PinkyAgarwal ACGPA7438L
41 PratikAgarwalBenTrust AABTP7516K
42 PraveenKumarAgarwal ACSPA4725A
43 PraveenKumarAgarwalHuf AAIHP6229C
44 RajendraMangilalJain ACPPJ9853R
45 RenuAggarwal AAEPA1694C
46 RenuMittal AGMPM1488Q
47 RituSingal ABHPS3711M
48 SantoshAggarwal ABAPA4548E
49 ShaileshMangilalJain AAAPJ6765F
50 ShilpaAggarwal AEXPA1230M
51 SmtUjwalaNamdevMane AAEPM5924H
52 SurendraBJiwrajka AACPJ4316L
53 SushantInvestments ACAFS8650G
54 TanviBhavikTrevadia AFAPT5888A
55 TarunAggarwal AOQPA9034E
56 UmaSingal ANRPS7987A
57 YogeshPopatlalThakkar AAPPT1825P

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Order in the matter of Radford Global Ltd. Page 17 of 27
 Radford Group
58 Amrit Sales Promotion Pvt Limited AACCA3220D
59 Amrusha Mercantile Private Ltd AALCA0340D
60 Anjali Suppliers Private Limited AAJCA1784D
61 Apex Commotrade Private Limited AAJCA4459K
62 Avlokan Dealcom Private Limited AALCA1583G
63 Bazigar Trading Private Limited AABCB3052B
64 Blue Circle Services Limited AAACB2131L
65 Burlington Finance Limited AABCB2575P
66 Devakantha Trading Private Limited AADCD7044B
67 Devatma Distributors Private Limited AADCD7140G
Dhanleela Investments & Trading Company
68 AAACR1770P
Limited
69 Dhanraksha Vincom Pvt Ltd. AADCD6028P
70 Divya Drishti Traders Pvt Ltd AABCD8146J
71 Divyadrishti Merchants Pvt Ltd AABCD8147K
72 Esquire Enclave Private Limited AACCE7065J
73 Katyani Commodities Private Limited AAECK6244R
74 Kingfisher Properties Private Limited AAECK3394G
75 Ladios Trading Private Limited AACCL3868N
76 Limestone Properties Private Limited AACCL0133G
77 Manimudra Vincom Private Limited AADCM4316K
78 Natural Housing Private Limited AADCN6251G
79 Pine Animation Limited AAECM0267A
80 Pyramid Trading And Finance Ltd AAACP2548R
81 Radison Properties Private Limited AAFCR2818B
82 Rangan Vincom Private Limited AAGCR1715E
83 Ridhi Vincom Pvt Ltd AAECR9858C
84 Runicha Merchants Private Limited AAECR0580M
85 Sanklap Vincom P Ltd AAMCS1711P
86 Scope Vyapar Private Limited AAICS6023N
87 Shelter Sales Agency Pvt Ltd # AASCS1797F
88 Shivkhori Construction Private Limited AAPCS7850L
89 Signet Vinimay Private Limited AAMCS1712Q
90 SKM Travels Private Limited AAICS0688K
91 Spice Merchants Private Limited AAPCS7492G
92 Symphony Merchant Pvt Ltd AADCS5411K
93 Topwell Properties Private Limited AADCT8403C
94 Udbal Mercantile Private Limited AABCU2648C

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Order in the matter of Radford Global Ltd. Page 18 of 27
 95 Vibgyor Financial Service Pvt Ltd AAACV8378B
96 Winall Vinimay Private Limited AAACW8004B
Suspected Entities
97 Jayant Security & Financeltd AAACJ4848G
98 Trimurthi Finvest Ltd AAACT6383N
99 Purvi Finvest Limited AABCP6564C
100 East West Finvest India Limited AAACE6834D
101 East West Finvest India Limited AADCE1236G
Other
102 Taran Kumar Rungta ASVPR5947G
103 Prem Lata Nahar AFAPN8764M
104 Manjulaben Sukhdev Pandya ALVPP7764J
105 Rajat Share Broking Pvt Ltd AAACR2695B
106 Rajesh Pravinkumar Jasani ACWPJ4705B
107 Bharat Bagri Bagri AADHB8488A
108 Jayesh Narendra Kesharia AAEHJ1610D

33. 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.

34. 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.

35. 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:DECEMBER 19, 2014 RAJEEV KUMAR AGARWAL
PLACE: MUMBAI WHOLE TIME MEMBER
SECURITIES AND EXCHANGE BOARD OF INDIA

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Order in the matter of Radford Global Ltd. Page 19 of 27
 Annexure A: List of Preferential Allottees as received from BSE

Permanent No. of Qty Post Stock

Sr.
Name of the Allottee Account shares Split (Jan 29,
No.
Number (PAN) allotted 2013)
ABAPB8617M/
AachalchandBalar/PiyushKumarBal
1 AEMPB6394Q/ 150000 750000
ar/AbhishekKumarBalar
AATPB8811B
2 AfsarZaidi AADPZ8571G 100000 500000
AACPM4024E/
3 AmreshA.Mody/HasumatiA.Mody 100000 500000
AJSPM7935P
4 AnilRajatAgarwal&Sons.Huf. AAFHA0709M 60000 300000
5 AshokBJiwrajka AACPJ3610K 250000 1250000
6 BabitaMittal AAIPG4573G 150000 750000
7 BimalJDesasi AAKPD3160A 200000 1000000
8 BrijBhushanSingal AEFPS6298M 580000 2900000
9 DalsukhUjamshiTrevadia ACDPT3428N 100000 500000
10 DilipBJiwrajka AAGPJ8756J 250000 1250000
11 DilipChotalalMorzaria AADPM9919M 200000 1000000
12 GloryInvestmentServicesPvtLtd AACCG9982A 340000 1700000
13 GMPrasannaKumar AHEPG0025A 200000 1000000
14 GSAnithKumar ADPPK9874N 200000 1000000
15 HariKishanSuderlalVermani AAJPV4754H 100000 500000
16 HiteshMangilalJain AABPJ2835R 100000 500000
17 HukamsinghB.Rajpurohit AABPR9949J 100000 500000
18 JyotiAnilTrevadia ABWPT8000C 100000 500000
19 JyotsnaJitendraDesai AHPPD4223L 200000 1000000
20 KalpitaLuniya AAAPL9611J 100000 500000
21 KamalPunwani AFFPP5207G 100000 500000
22 LingarajuGM AEYPM5850Q 200000 1000000
23 MayuriDarshanBhanushali AKJPB8572F 100000 500000
24 MohanMittal APFPM0496Q 150000 750000
25 MohitAggarwal ADSPA9301K 150000 750000
26 MukeshMittal AJGPM2125D 150000 750000
27 NareshNemchandShah ACRPS0182J 400000 2000000
28 NeerajSingal ANRPS7986B 580000 2900000

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Order in the matter of Radford Global Ltd. Page 20 of 27
 29 NishitAgarwalBenTrust AABTN3350K 200000 1000000
30 PinkyAgarwal ACGPA7438L 200000 1000000
31 PratikAgarwalBenTrust AABTP7516K 200000 1000000
32 PraveenKumarAgarwal ACSPA4725A 200000 1000000
33 PraveenKumarAgarwalHuf AAIHP6229C 200000 1000000
34 RajendraMangilalJain ACPPJ9853R 100000 500000
35 RamchandraSatre ACAPS9829D 100000 500000
36 RenuAggarwal AAEPA1694C 150000 750000
37 RenuMittal AGMPM1488Q 150000 750000
38 RituSingal ABHPS3711M 515000 2575000
39 SantoshAggarwal ABAPA4548E 150000 750000
40 ShaileshMangilalJain AAAPJ6765F 100000 500000
41 ShilpaAggarwal AEXPA1230M 150000 750000
42 SmtUjwalaNamdevMane AAEPM5924H 100000 500000
43 SurendraBJiwrajka AACPJ4316L 250000 1250000
44 SushantInvestments ACAFS8650G 250000 1250000
45 TanviBhavikTrevadia AFAPT5888A 100000 500000
46 TarunAggarwal AOQPA9034E 150000 750000
47 UmaSingal ANRPS7987A 225000 1125000
48 YogeshPopatlalThakkar AAPPT1825P 200000 1000000
Total 9100000 45500000

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Order in the matter of Radford Global Ltd. Page 21 of 27
Annexure B: Radford Group & Suspected Entities and the basis of connection /relationship
amongst them.

Based on the KYC and Bank Statement analysis, off market analysis, data available with the
exchange and MCA details, Radford Group & Suspected Entities were observed to be dealing in
the scrip during the period of examination. Their basis of connection and transaction details is given
below:

Sr Client Name and Member Name

Basis of Connection
No PAN and Code
Radford Group
On analyzing the bank statement submitted by the
Dhanleela
trading member ‘Gepl Capital Pvt. Ltd ’ for its
Investments &
client ‘Dhanleela Investments & Trading Company
Trading Company
GEPL Capital Pvt. Limited’, it was observed that the client has
1 Limited
Ltd. (724) received / transferred funds from / to the
company ‘Radford Global Limited’. It was also
(AAACR1770P) observed that it has transferred funds to ‘Neeraj
Singal’, ‘Brij Bhushan Singal’ and ‘Ritu Singal’
Pyramid Trading On analyzing the bank statement submitted by the
And Finance Ltd trading member ‘C.D Equisearch Pvt Ltd’ for its
C.D.Equisearch client ‘Pyramid Trading and Finance Limited’, it
2
Pvt.Ltd. (87) was observed that the client has received /
(AAACP2548R) transferred funds from / to the company ‘Radford
Global Limited’
On analyzing the bank statement submitted by the
Pine Animation trading member ‘C.D Equisearch Pvt Ltd’ for its
Limited client ‘Pyramid Trading and Finance Limited’, it
Mehta Equities was observed that the client has transferred funds
3
Ltd. (122) to the ‘Pine Animation Limited’. From the analysis
of bank statement of Pine Animation Limited, it
(AAECM0267A) was observed that funds were transferred to one
Entity Blue Circle Services Ltd.
Amrit Sales
From the analysis of bank statement of Amrit Sales
Promotion Pvt Arch Finance Ltd.
4 Promotion Pvt. Ltd., it was observed that funds
Limited (3257)
were received from Blue Circle Services Ltd.
(AACCA3220D)
Burlington Finance
Arch Finance Ltd.
5 Limited As per bank statement of the client 'Amrit Sales
(3257)
(AABCB2575P) Promotion Pvt Limited', it has received /
Symphony transferred funds from / to 'Burlington Finance
Arch Finance Ltd.
6 Merchant Pvt Ltd Limited' and 'Symphony Merchant Pvt Ltd'.
(3257)
(AADCS5411K)

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Order in the matter of Radford Global Ltd. Page 22 of 27
 The client 'Bazigar Trading Private Limited' and the
Bazigar Trading client 'Amrit Sales Promotion Pvt Limited' have
Private Limited Arch Finance Ltd.
7 common phone number and email-id viz,
(3257)
'9831714151' and 'apareek1@hotmail.com,
(AABCB3052B) naloo.kol@gmail.com' respectively.
Manimudra As per UCC database updated by the trading
Vincom Private member ‘Arch Finance Ltd’ for its clients entity viz.
Limited Arch Finance Ltd. Bazigar Trading Private Limited (S.No 41) and
8
(3257) ‘Manimudra Vincom Private Limited have same
(AADCM4316K) address viz, ‘19 R.N. Mukherjee Lane, 2nd Floor,
Kolkata, West Bengal-700001’
Blue Circle
Mehta Equities
9 Services Limited
Ltd. (122)
(AAACB2131L)
Devatma The clients 'Blue Circle Services Limited', 'Devatma
The Calcutta
Distributors Distributors Private Limited' and 'Anjali Suppliers
10 Stock Exchange
Private Limited Private Limited' has common email id viz,
Ltd. (990)
(AADCD7140G) dhruvonarayan.jha@rediffmail.com'
Anjali Suppliers Madhya Pradesh
11 Private Limited Stock Exchange
(AAJCA1784D) Ltd. (991)
Rangan Vincom The Calcutta Rangan Vincom Private Limited' has transferred
12 Private Limited Stock Exchange shares to 'Devatma Distributors Private Limited' in
(AAGCR1715E) Ltd. (990) the off market.
Katyani As per the MCA website, ‘Rangan Vincom Private
The Calcutta
Commodities Limited’ and ‘Katyani Commodities Private
13 Stock Exchange
Private Limited Limited’ have common address viz, ‘4, N.S Road,
Ltd. (990)
(AAECK6244R) 1st Floor, Kolkata, West Bengal-700001’.
Ladios Trading The Calcutta
14 Private Limited Stock Exchange Rangan Vincom Private Limited', 'Ladios Trading
(AACCL3868N) Ltd. (990) Private Limited', 'Avlokan Dealcom Private
Avlokan Dealcom The Calcutta Limited' has common phone number viz,
15 Private Limited Stock Exchange '9831432937'.
(AALCA1583G) Ltd. (990)

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Order in the matter of Radford Global Ltd. Page 23 of 27
 On analyzing the bank statement of the client it was
observed that the client has received / transferred
funds from / to 'Esquire Enclave Private Limited’,
‘Fairlink Housing Pvt Ltd’. Further, from the bank
statement analysis, the client 'Kingfisher Properties
Pvt. Ltd.' has also transferred the funds to 'Signet
Vinimay Pvt Ltd' . On analyzing the bank statement
Kingfisher of the Fairlink Housing Pvt. Ltd., it was observed
Properties Private that the client had received / transferred funds
Limited from / to group entities viz, 'Kingfisher Properties
Private Limited', 'Divyadrishti Merchants Private
Limited', 'Divyadrishti Traders Pvt Ltd'. Further,
the client has also received / transferred funds to
Gateway Financial
its other connected / related entities viz, ‘Topwell
16 Services Ltd.
Properties Pvt Ltd’. On analyzing the bank
(3199)
statement received from the trading member ‘Korp
Securities Ltd’ for its client ‘Fairlink Housing
Private Limited’, it was observed that the said entity
has received funds from an entity viz, ‘Venkatesh
Sales Pvt Ltd’ which as per the MCA website has
the common address as that of one of the director
viz, ‘Dhruv Narayan Jha’ of the company ‘Blue
(AAECK3394G) Circle Services Limited’ viz, ‘P-27, Princep Street,
3rd Floor, Kolkata, West Bengal – 700072’.
Further, as per MCA website the email address of
‘Venkatesh Sales Pvt Ltd’ and ‘Blue Circle Services
Ltd’ is common viz,
‘dhruvonarayan.jha@rediffmail.com’.
On analyzing bank statement of the Topwell
Properties Private Limited, it was observed that
Topwell Properties
funds were received/transferred among Esquire
Private Limited
Enclave Private Limited, Radison Properties
Gateway Financial
Private Limited, Kingfisher Properties Private
21 Services Ltd.
Limited, Shivkhori Construction Pvt. Ltd. Natural
(3199)
Housing Private Limited And Limestone Properties
(AADCT8403C) Private Limited. Funds were also transferred to
Signet Vinimay Pvt. Ltd.and Sankalp Vincom Pvt.
Ltd.
Esquire Enclave Gateway Financial The clients 'Kingfisher Properties Private Limited',
17 Private Limited Services Ltd. ‘Esquire Enclave Private Limited’, 'Radison
(AACCE7065J) (3199) Properties Private Limited', 'Shivkhori Construction
Radison Properties Gateway Financial Private Limited', 'Limestone Properties Private
18 Private Limited Services Ltd. Limited', 'Topwell Properties Private Limited' and
(AAFCR2818B) (3199) 'Natural Housing Private Limited' has common
Shivkhori Gateway Financial address, email id and common directors viz, ‘95A –
19 Construction Services Ltd. C.R Avenue, 1st Floor, Kolkata, West Bengal –
Private Limited (3199) 700073’, ‘roc2011@in.com’ and ‘Vishal Sharma’

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Order in the matter of Radford Global Ltd. Page 24 of 27
 (AAPCS7850L) and ‘Chiranjit Mahanta’.
Limestone
Gateway Financial
Properties Private
20 Services Ltd.
Limited
(3199)
(AACCL0133G)
Natural Housing Gateway Financial
22 Private Limited Services Ltd.
(AADCN6251G) (3199)
Millennium Stock
Divyadrishti
Broking Private
Merchants Pvt Ltd
23 Limited (6151)
Korp Securities
(AABCD8147K)
Ltd. (6213)
As per the KYC submitted by the trading member
Millennium Stock
Divya Drishti 'Korp Securities Ltd.' for its clients 'Divyadrishti
Broking Private
Traders Pvt Ltd Merchants Pvt Ltd', 'Divya Drishti Traders Pvt
24 Limited (6151)
Ltd', 'Dhanraksha Vincom Pvt Ltd.' and 'Ridhi
Korp Securities
(AABCD8146J) Vincom Pvt Ltd', all the clients have common
Ltd. (6213)
address viz, '163 B, M.G Road, 3rd Floor, Kolkata
Dhanraksha
Korp Securities – West Bengal – 700007'.
25 Vincom Pvt Ltd.
Ltd. (6213)
(AADCD6028P)
Ridhi Vincom Pvt
Korp Securities
26 Ltd
Ltd. (6213)
(AAECR9858C)
Runicha
The Calcutta
Merchants Private
27 Stock Exchange
Limited As per the KYC submitted by the trading member
Ltd. (990)
(AAECR0580M) 'The Calcutta Stock Exchange Ltd' for its clients
Signet Vinimay The Calcutta 'Runicha Merchants Private Limited', 'Signet
28 Private Limited Stock Exchange Vinimay Private Limited', 'Winall Vinimay Private
(AAMCS1712Q) Ltd. (990) Limited' and 'Sanklap Vincom P Ltd' and as per the
Winall Vinimay The Calcutta MCA Website, all the clients have common address
29 Private Limited Stock Exchange viz, '23/1, Principal Khudiram Bose Road, Kolkata,
(AAACW8004B) Ltd. (990) West Bengal – 700006’ and common directors viz,
Sanklap Vincom P The Calcutta ‘Abhiset Basu’ and ‘Pradip Dey’.
30 Ltd Stock Exchange
(AAMCS1711P) Ltd. (990)
Spice Merchants The Calcutta As per the KYC submitted by the trading member
31 Private Limited Stock Exchange 'The Calcutta Stock Exchange Ltd' for its clients
(AAPCS7492G) Ltd. (990) 'Runicha Merchants Private Limited', 'Signet
Apex Commotrade Vinimay Private Limited', 'Winall Vinimay Private
Private Limited The Calcutta Limited', 'Spice Merchants Private Limited' and
32 Stock Exchange 'Apex Commotrade Private Limited Ltd', all clients
(AAJCA4459K) Ltd. (990) have common email id viz, ‘limited_kol@yahoo.in’
and common phone number viz, ‘9836488845’

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Order in the matter of Radford Global Ltd. Page 25 of 27
 Devakantha As per the bank statement submitted by the trading
Trading Private member 'Vishesh Capital Pvt.Ltd.' for its client
Vishesh Capital
33 Limited # 'Devakantha Trading Pvt Ltd', it was observed that
Pvt.Ltd. (3272)
the client has received / transferred fund from / to
(AADCD7044B)
'Spice Merchants Pvt Ltd'.
Anand Rathi Share
Shelter Sales As per the KYC submitted by the trading member
& Stock Brokers
Agency Pvt Ltd # 'Vishesh Capital Pvt.Ltd.' for its client 'Devakantha
Ltd. (949)
Trading Pvt Ltd' and 'Anand Rathi Share & Stock
Progressive Share
34 Brokers Ltd.' and 'Comfort Securities Ltd' for its
(AASCS1797F) Brokers Pvt.Ltd.
client 'Shelter Sales Agency Pvt Ltd', both the
(967)
clients have common phone number viz,
Comfort Securities
'8108780561'.
Ltd. (3186)
As per the KYC submitted by the trading member
Sunteck 'Vishesh Capital Pvt.Ltd.' for its client 'Devakantha
Udbal Mercantile Wealthmax Capital Trading Pvt Ltd' and 'Sunteck Wealthmax Capital
Private Limited # Private Limited Private Limited' and 'Vishesh Capital Pvt.Ltd.' for
(3070) its client 'Udbal Mercantile Private Limited', ‘Rekha
35 Arvind Gaud’ and ‘Kalavatidevi Pratap Narayan
Gaud’ who are directors of ‘Devakantha Trading
Vishesh Capital Private Limited’ and ‘Udbal Mercantile Private
(AABCU2648C) Limited’ respectively has common address viz,
Pvt.Ltd. (3272)
‘Safalya 806 A, Mahavir Nagar, Kandivali West,
Mumbai – 400067’.
Amrusha Anand Rathi Share
As per the KYC submitted by the trading member
Mercantile Private & Stock Brokers
'Vishesh Capital Pvt.Ltd.' for its client 'Udbal
Ltd # Ltd. (949)
Mercantile Private Limited' (S.No 16) and 'Anand
Progressive Share
36 Rathi Share & Stock Brokers Ltd.' and 'Comfort
(AALCA0340D) Brokers Pvt.Ltd.
Securities Ltd' for its client 'Amrusha Mercantile
(967)
Private Ltd', both the clients has common phone
Comfort Securities
number viz, ‘8108780562’.
Ltd. (3186)
SKM Travels Gateway Financial The company 'Winall Vinimay Private Limited’
37 Private Limited Services Ltd. (S.No 9) and 'SKM Travels Private Limited' have
(AAICS0688K) (3199) common director viz, 'Abhiset Basu’.
Scope Vyapar As per the bank statement submitted by the trading
Private Limited Gateway Financial member ‘The Calcutta Stock Exchange Ltd' for its
38 Services Ltd. client 'Winall Vinimay Pvt Ltd', it was observed that
(AAICS6023N) (3199) the client has received / transferred fund from / to
Scope Vyappar Pvt Ltd'
Vibgyor Financial The client ‘Vibgyor Financial Service Pvt Ltd’ has
India Infoline Ltd
39 Service Pvt Ltd received shares in off market from ‘Scope Vyapar
(AAACV8378B) Private Limited’.
Suspected Entities
Trimurthi Finvest Exclusive As per the KYC submitted by the trading member
1
Limited Securities Ltd. 'Exclusive Securities Ltd.' for its clients 'Trimurthi

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Order in the matter of Radford Global Ltd. Page 26 of 27
 (6369) Finvest Limited' and 'Purvi Finvest Limited', both
the company have common address viz, '9, Bhoj
ATS Share Nagar, Annpurna Road, Indore - 452009'
(AAACT6383N) Brokers Pvt. Ltd.
(6481)
India Infoline
Limited (179)
ATS Share
Purvi Finvest
Brokers Pvt. Ltd.
Limited
(6481)
2
Exclusive
(AABCP6564C) Securities Ltd.
(6369)
As per the MCA website and also as per the KYC
East West Finvest submitted by the trading member 'Exclusive
India Limited Exclusive
Securities Ltd.' for its clients 'Trimurthi Finvest
3 Securities Ltd.
Limited' (S.No 1) and 'East West Finvest India
(AAACE6834D/ (6369)
Limited', both the companies have common
AADCE1236G) director viz, 'Sharad Kumar Darak'.
Exclusive
Jayant Security &
Securities Ltd. As per the MCA website 'Trimurthi Finvest
Finance Ltd
(6369) Limited' (S.No 1) and 'Jayant Security & Finance
4
ATS Share Ltd', both the companies have common email id
(AAACJ4848G) Brokers Pvt. Ltd. viz, 'caashwinsethi@gmail.com'
(6481)

Sd/-
DATE:DECEMBER 19, 2014 RAJEEV KUMAR AGARWAL
PLACE: MUMBAI WHOLE TIME MEMBER
SECURITIES AND EXCHANGE BOARD OF INDIA

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Order in the matter of Radford Global Ltd. Page 27 of 27