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BEFORE THE ADJUDICATING OFFICER

SECURITIES AND EXCHANGE BOARD OF INDIA

[ADJUDICATION ORDER: EAD-2/SS/SK/2019-20/2651]

UNDER SECTION 23-I OF SECURITIES CONTRACTS (REGULATION) ACT, 1956 READ


WITH RULE 5 OF SECURITIES CONTRACTS (REGULATION) ACT (PROCEDURE FOR
HOLDING INQUIRY AND IMPOSING PENALTIES BY ADJUDICATING OFFICER)
RULES, 2005.
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In respect of:
AC Agarwal Share Brokers Private Limited
S-5, Ambabari,
Jaipur – 302023.

1. SEBI conducted an inspection of AC Agarwal Share Brokers Private Limited (hereinafter


referred to as ‘the Noticee’), a stock broker, to verify the compliance of requirements of
segregation of clients and own funds and securities. The inspection was conducted on
February 13 to 14, 2017 and the period covered under inspection was from April 01, 2015 to
February 12, 2017. The observations made during the course of inspection were
communicated to the Noticee vide letter dated August 11, 2017. The Noticee had submitted
its comments/ explanations on the observations of the inspection vide its letters dated
August 30, 2017, September 06, 2017 and September 27, 2017. SEBI did not find
comments/explanation of the Noticee satisfactory with regard to utiliz ation of clients’ funds
for other clients and own purpose on 27 sample instances leading to alleged non-compliance
with the requirements stipulated in SEBI Circulars no. SMD/SED/CIR/93/23321 dated
November 18, 1993 (hereinafter referred to as ‘1993 Circular’) and MRD/DoP/SE/Cir-
11/2008 dated April 17, 2008 (hereinafter referred to as ‘2008 Circular’).

2. Vide a communication–order dated January 25, 2019 it was informed that the competent
authority is satisfied to initiate inquiry and adjudication against the Noticee under section
23D of the Securities Contracts (Regulation) Act, 1956 (“SCRA”) for the aforesaid alleged
failures and that the undersigned has been appointed as the Adjudicating Officer under
section 23-I of the SCRA and Rule 3 of Securities Contracts (Regulation) Act (Procedure for
Holding Inquiry and Imposing Penalties by Adjudicating Officer) Rules, 2005 (hereinafter

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referred to as ‘Adjudication Rules’) to inquire into and adjudge the aforesaid alleged violation
and charges. The provisions of section 23D of the SCRA reads as under: -

Penalty for failure to segregate securities or moneys of client or clients.

23D. If any person, who is registered under section 12 of the Securities and Exchange Board of India Act, 1992 (15
of 1992) as a stock broker or sub-broker, fails to segregate securities or moneys of the client or clients or uses the securities
or moneys of a client or clients for self or for any other client, he shall be liable to a penalty which shall not be less than
one lakh rupees but which may extend to one crore rupees.

3. Accordingly, in terms of Rule 4(1) of the Adjudication Rules read with 23 -I of the SCRA a
notice to show cause no. EAD/SS-SKS/OW/3441/1/2019 dated February 04, 2019
(hereinafter referred to as ‘the SCN’) dated January 25, 2019, was issued to the Noticee,
calling upon it to show cause as to why an inquiry should not be held against it in terms of
Rule 4 of the Adjudication Rules read with section 23I of the SCRA and penalty be not
imposed upon it under section 23D of the SCRA. After seeking further time, the Noticee
filed its reply dated March 05, 2019 received on March 12, 2019 and avail ed the opportunity
of hearing on March 14, 2019 when Mr. Ravi Vijay Ramaiya, Practicing Chartered
Accountant, appeared on behalf of the Noticee and explained the contents of the said written
reply. The replies/submissions of the Noticee are summarized as f ollows:

a) The SCN is in direct violation of the principles laid down by the Hon’ble Supreme Court in the
case of Gorkha Security Services v. Govt. of NCT Of Delhi &Ors. The SCN calls upon it to answer the
SCN that is generic in nature and contains a vague allegation against for violating the above two
circulars. The Supreme Court in the case of Gorkha Security (supra.) had laid down the law in
relation to show cause notices and had held that- “the fundamental purpose behind serving of a show cause
notice is to make the noticee understand the precise case set up against him which he has to meet. This would require
statement of imputations dealing with the alleged breaches and defaults he has committed, so he gets an opportunity
to rebut the same.”

b) The SCN alleges upon it to have violated the above two circulars. It is not clarified as to how and
which part of the said circular is allegedly violated by the Noticee and therefore the SCN is not in
line with the directives of the Hon’ble Supreme Court and needs to be set aside. It has not violated
any of the requirements of the two circulars. Details of compliance with the said circulars are as
under:
Compliance with SMD/SED/CIR/93/23321 dated November 18, 1993:

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(i) There is nothing on record to substantiate that money of the clients is not kept in a separate
account and own money not kept in a separate account. Since last several years, it has been
maintaining separate accounts for clients and separate accounts for own dealings and the details
of which are also recorded in clause 3 on page 6 and 7 of the report annexed with the SCN.

(ii) Further there not a single instance of transaction in the SCN where it has made payment for
its position as a principal from client’s account.

(iii) It maintains separate ledgers of each client and also maintain a separate ledger for its own
proprietary trading. The moneys received on account of each client are always correctly
reflected in their ledgers. Likewise moneys paid to the Exchange from own account are debited
to own trading ledger.

(iv) It is maintaining the following client's accounts:


Bank Name A/c No. A/c Name
1. HDFC Bank 04290340000696
A C Agarwal Share Brokers Pvt Ltd NSE Client A/c
2. HDFC Bank 04290340000704
A C Agarwal Share Brokers Pvt Ltd NSE F&O Client A/c
3. HDFC Bank 04290340001172
A C Agarwal Share Brokers Pvt Ltd BSE Client A/c

(v) All moneys received from clients are deposited exclusively in these accounts and in no other
account. Further clause 7 on page 7 of the report annexed to the SCN clearly records that it
has received client's funds in clients account only.

(vi) The SCN or the report does not highlight a single instance where it has withdrawn funds from
clients account for purposes other than those permitted.

(vii) Rest of the circular deals lien of broker, securities of clients, payment within 2 days, margin
collection, contract notes, square off for client’s failure to make payment or deliver securities
etc. and hence, not responded to.

Compliance with MRD/DoP/SE/Cir- 11/2008 dated April 17, 2008


(i) The inspection report records having verified pay-ins and payments to the Exchanges and
clients and found it to be correct. Clause 4, 5, 6, 7 and 8 of the report clearly record compliance
with the requirements of SEBI circular.

(ii) All the records inter alia including receipt of collaterals from client, authorization to deposit
collateral with Exchange Clearing Corporation, Clearing House towards margin, record of
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deposit of collaterals with Exchange, Clearing Corporation, Clearing House, records of return
of collaterals to clients, credit of corporate action benefit to clients etc. are maintained.

(iii) Records with respect to reconciliation with the actual collateral deposited with the broker are
adequately maintained. Daily statements are being issued to the clients and there is no adverse
observation about it in the SCN or the report. There is no such complaint and none of its
clients have filed a complaint against it. There is no observation of misuse of collateral.

(iv) Rest of the part asks Exchanges to make changes to byelaws etc. and hence, irrelevant.

c) The observation letter records a table allegedly containing instances of 30 samples where a working
of alleged difference between available funds and credit balance of clients is calculated. This is
based on the working suggested by circular no. SEBI/HO/MIRSD/MIRSD2/CIR/P/2016/95
dated September 26, 2016 which was made effective from April 1, 2017 vide circular
SEBI/HO/MIRSD/MIRSD2/CIR/P/2016/138 dated December 20, 2016.

d) Prior to implementation of the said circular there was no necessity or requirement of carrying out
such a working. The period covered under the inspection conducted by SEBI was for the period
April 1, 2015 to February 12, 2017 and during this period the working annexed in the report was
never required to be carried out and maintained by the brokers. The SCN should, therefore, find
no fault with it even if the calculation of "G" column gives a negative result as the said circular was
implemented prospectively and not retrospectively.

e) As recorded in the report annexed to the SCN, it did not have any major proprietary trading. Its
net-worth is ` 2.27 Crores which is always in excess of margin requirements that can ever arise due
to its trading. A copy of the net worth certificate issued by the statutory auditor as on March 31,
2017 is provided.

f) The highest margin applicable on proprietary trading was ` 1.72 Crores and the lowest margin
applicable was ` 0.03 Crores. The Exchange allows payment of margin using 50% Cash and Cash
Equivalents and balance in securities. Therefore, the funds requirement for proprietary trading was
only ` 0.86 Crores to ` 0.015 Crores. The margin applicable on the relevant days as mentioned in
the SCN are given below:
Margin applicable on Proprietary Trades of A C Agarwal
Total Margin on Proprietary MARGIN REQUIRED IN CASH
Date Trades 50% of Total Margin
30-07-15 17199383 8599691
27-08-15 13436940 6718470
24-08-15 6844447 3422224
26-04-16 6348660 3174330
28-10-16 3927738 1963869
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Margin applicable on Proprietary Trades of A C Agarwal
Total Margin on Proprietary MARGIN REQUIRED IN CASH
Date Trades 50% of Total Margin
31-03-16 4477736 2238868
26-11-15 3782831 1891416
06-01-16 2373500 1186750
28-07-16 2310836 1155418
14-07-16 2291172 1145586
15-07-16 2285674 1142837
30-06-16 2207820 1103910
05-10-16 2161931 1080966
10-06-16 2102200 1051100
27-05-16 2084000 1042000
26-05-16 2084400 1042200
28-04-16 2088400 1044200
03-10-16 1644306 822153
07-09-16 1599408 799704
20-10-16 1427208 713604
26-10-16 795504 397752
27-07-16 756980 378490
27-10-16 528120 264060
28-09-16 337280 168640

g) Therefore the allegation that it has used the moneys lying to the credit of the clients for its own
purpose is incorrect.

h) As regards to the allegation of using one clients money for another client, it is submitted that credit
balance of the clients have never been used for other clients. None of its clients have ever
complained that they have not been allowed to transact in spite of having credit balance and this
in itself suggests that their credits were always made available to them for trading as and when
demanded. Further as a practice, the Noticee does not debit margin applicable to the clients in their
ledger. The total credit balance as arrived by SEBI in its report is the credit balance without taking
into account the margin applicable to the clients. Column ‘G’ allegedly contains a shortage of
balance, but the margin requirement of the clients against the same is ignored. The margin
requirement of clients having credit balance is in excess of the alleged shortage.

i) The credit balance of the clients also includes balances of directors and their relatives. These funds
do not belong to third party clients but to promoters, directors and relatives. After reducing the
said balance, the funds available are far in excess of the alleged shortage. A working on surplus
funds after taking into account the margin and balance of relatives is given hereunder:
Date Alleged Ledger Applicable Annexure Credit of Annexure Net
Shortage Balance Margin Directors and surplus
in SCN Relatives

30-Jul-15 5119951 21915302 4292655.66 3 6882682.1 33 16295289

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Date Alleged Ledger Applicable Annexure Credit of Annexure Net
Shortage Balance Margin Directors and surplus
in SCN Relatives

24-Aug-15 -33352832 60484522 21714270.59 4 37542973.78 34 25904412


27-Aug-15 -4602080 31773729 6317004.53 5 18597082.03 35 20312007
18-Nov-15 -4023048 31098359 18943789.15 6 15322851.45 36 30243593
26-Nov-15 -290103 27260553 34650012.51 7 17112208.94 37 51472118
27-Nov-15 1415264 24266464 23087303.42 8 15504875.67 38 40007443
06-Jan-16 -3885432 36846850 41981401.67 9 28646879.96 39 66742850
31-Mar-16 -11894257 43833104 28690877.78 10 19615604.79 40 36412226
26-Apr-16 -13612533 40504021 27299620.97 11 29968856.28 41 43655944
28-Apr-16 -57335705 88859331 14493955.08 12 61537368.55 42 18695619
26-May-16 -8280387 45529733 19669963.64 13 38289004.38 43 49678581
27-May-16 -13192852 51475516 25189821.81 14 34495545.53 44 46492515
10-Jun-16 -25629868 61346355 59424035.58 15 51090911.66 45 84885079
30-Jun-16 -21623271 59792173 45049520.12 16 48674122.79 46 72100372
14-Jul-16 -39981840 79813963 67103172.02 17 56671315.42 47 83792647
15-Jul-16 -53656176 88095848 69725301.19 18 62814914 48 78884039
27-Jul-16 -58896365 98377667 66039876.05 19 72363740.96 49 79507252
28-Jul-16 -69669498 106305504 33173681.09 20 79617434.75 50 43121618
08-Aug-16 73056 69780547 47988645.7 21 44425010.64 51 92486712
25-Aug-16 -14028113 80097638 39919589.46 22 63921757.77 52 89813234
07-Sep-16 -38240044 74487765 62462552.57 23 52073548.3 53 76296057
28-Sep-16 -26878274 62751523 82272172.64 24 44435132.68 54 99829031
29-Sep-16 -19572966 62700920 12717816.96 25 43762132.61 55 36906984
30-Sep-16 -2676367 66211192 19312479.74 26 28834319.64 56 45470432
03-Oct-16 -15398934 62722196 27359113.58 27 29623560.67 57 41583740
05-Oct-16 -23427028 60537351 50926604.74 28 38781775.7 58 66281352
20-Oct-16 -38030630 106703960 87074313.48 29 71903353.74 59 120947037
26-Oct-16 -26230932 64208556 92271840.22 30 38922896.2 60 104963804
27-Oct-16 -26377830 66770614 41596402.07 31 35010821.47 61 50229394
28-Oct-16 -15734393 52120302 41237005.44 32 29469948.23 62 54972561
Note: Copies of Annexure 3 and 33 are given in hard copies and all Annexures from 3 to 62 are given in soft copies .

j) Therefore, the allegation of having used credit balance of clients for other clients is also completely
misplaced.

k) There has not been even a single incidence of client's complaint against it. Had it resorted to use
one client's money for other, then at least on few days its clients with credit balance would have
not been allowed to take position as the same would have been already consumed by other clients
as wrongly alleged. The fact that there has never been any single instance where clients with credit
balance have been restricted in using their balance and this in itself substantiates that the allegations
in the SCN are misplaced.

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l) The process of working adopted by SEBI is only applicable from April 1, 2017 and not prior to
that. Without prejudice to the above submissions, assuming for a moment, but not accepting that
some violation has taken place, the same is purely unintentional and technical in nature. Further, it
has followed the working of enhanced supervision in letter and spirit from the date of its
applicability and therefore there has never been a single instance when the calculation of "G" has
been negative. This shows that it has robust systems in place to ensure all the compliance
requirements implemented by SEBI and Exchanges.

m) It has placed reliance on the following orders of Hon’ble Securities Appellate Tribunal (hereinafter
referred to as “the SAT”) which deals with inspection of brokers:

(i) The Hon’ble SAT in Appeal No. 109 of 2011 in UPSE Securities Ltd. V SEBI vide order dated July
25, 2011 held that “…before concluding we cannot resist observing that the object of carrying out inspection of
the books of accounts and records of any intermediary including a stock exchange or its subsidiaries is to ensure
compliance with the provisions of the Act, Rules, Regulations, By-laws and circulars issued from time to time
which are meant to regulate the securities market. Every little irregularity/ deficiency noticed during the course
of the inspection is not culpable and does not call for initiation of penalty proceedings. The purpose of inspection
in quite a few cases could be better achieved if the inspecting team at the time of the inspection were to advise the
erring entity…”

(ii) Further, Hon’ble SAT, in Appeal No. 153 of 2012 in DSE Financial Services Ltd. v SEBI in its order
dated September 11, 2012 held that “…every minor discrepancy/ irregularity found during the course of
inspection is not culpable and object of the inspection could well be achieved by pointing out the irregularities/
deficiencies to the intermediary at the time of inspection and making it complaint.”

(iii) The above judgments have been positively considered in the several SEBI orders like
Adjudication Order No. EAD/ AO-NP/ JR/ 39 /2017 dated May 22, 2017 in the matter of
IFCI Financial Services Limited and Adjudication Order No. EAD-12/ AO/SM/191 /2017-18
dated February 26, 2018 in the matter of Marfatia Stock Broking Private Limited, etc.

4. I have considered the allegations levelled in the terms of reference, the reply/submissions of
the Noticee and the relevant material available on record. Before dealing with the allegations
and charges against the Noticee on merits, I deem it appropriate to deal with technical
objections raised by the Noticee. The first such objection is with regard to the specific charge
to be leveled in the SCN. In this regard, it is relevant to mention that instant proceeding s
have been initiated based upon observations made in the inspection report of SEBI wherein
the observation with regard to alleged failure on the part of the Noticee has been made with
reference to the applicable requirements of the 1993 Circular that – “….No money shall be
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drawn from clients account other than - i. money properly required for payment to or on behalf of clients or
for or towards payment of a debt due to the Member from clients or money drawn on client’s authority, or
money in respect of which there is a liability of clients to the Member, provided that money so drawn shall
not in any case exceed the total of the money so held for the time being for such each client ”. It is to be
noted that the said 1993 Circular lays down comprehensive guidelines for stock brokers in
dealing with funds and securities of clients. It specifies several exclusive requirements. The
aforesaid observation clearly falls Clause D of the 1993 Circular. Similarly, the observation
in respect of use of clients’ collateral has been made with reference to the requirements of
the 2008 Circular that requires stock brokers to maintain proper records of client collateral
and to prevent misuse of client collateral. This observation clearly falls under Clause 2.1 of
the 2008 Circular. The observations and finding in the inspection report that are basis of
charge in this case had been provided to the Noticee alongwith the SCN. The said material
provided as Annexure-1 to the SCN show, with reasonable certainty, the charges and
allegations. In my view, therefore, the instant proceedings would not vitiate if the specific
clause number of the 1993 Circular and 2008 Circular are not mentioned in the inspection
report. Further, during hearing, the specific charge with reference to Clause D of 1993
Circular and Clause 2.1 of the 2008 Circular was again explained to the learned AR of the
Noticee when he conceded to not press the contention in this regard.

5. The other technical objection is with regard to applicability of calculation methods laid down
in SEBI Circular no. SEBI / HO / MIRSD / MIRSD2 / CIR /P / 2016 / 95 dated September
26, 2016. In this regard, the Noticee has contended that t he inspection period was prior to
coming into force of the said circular and there was no requirement of carrying out such a
working and maintaining of the same at that point of time. It is noteworthy that the
observations with respect to the allegations have been drawn by the i nspection team based
on the working suggested in the said circular dated September 26, 2016 which was made
effective from April 1, 2017 vide another SEBI Circular no.
SEBI/HO/MIRSD/MIRSD2/CIR/P/2016/138 dated December 20, 2016. Thus, the
calculation methods laid down in the said circular are not applicable with respect to accounts
maintained by the Noticee.

6. Coming to the merits of the charge, it is noted that the charge of violation of 2008 circular
has also been referred for the purpose of the instant proceedings under Section 23D of the

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SCRA. From the provisions of Section 23D it is noted that it applies in case of failure to
segregate securities or moneys of the client or clients or use of the securities or moneys of a
client or clients by the stock broker for self or for any other client whereas Clause 2.1 of the
2008 Circular stipulates the obligation of the stock brokers that – “Brokers should have adequate
systems and procedures in place to ensure that client collateral is not used for any purpose other than meeting
the respective client’s margin requirements / pay-ins. Brokers should also maintain records to ensure proper
audit trail of use of client collateral” . The failure in compliance of this stipulation is not within
the scope of section 23D of the SCRA. It is further noted that with regard to this stipulation
of Clause 2.1 of the 2008 Circular, the following observations have been made in the
inspection report:

(i) The system of the broker was checked to verify the segregation of funds and securities of their clients and
that of their own on sample basis. It was noted that securities lying in the client beneficiary accounts of
broker were segregated in the system and details of the clients to whom the securities belo ng was available.
The entries in relation to passing of the corporate benefits to clients whose securities are available in the
client beneficiary demat accounts were checked on sample basis in the system and the same was found to
be in order.
(ii) Details with regard to 5 days when consolidated securities delivery obligation was highest for proprietary
trading of the broker in each of the F.Y. 2015-16 & 2016-17 (Till 13/2/2017) were sought from
the broker. The said details as submitted by the broker were verifi ed with the trade files and own demat
account of the broker. As observed, the deliveries of the shares on account of proprietary trading were
made by the broker through its own demat account.
(iii) Details of the client who had highest securities pay -in obligation during the inspection period were
sought from broker. On analysis of sample, it was observed that the deliveries of the shares on account
of trading of top client were made by the broker through client’s demat account or from Client Beneficiary
Account where-in broker was holding client shares.
(iv) Details of top 10 clients in each of the F.Y. 2015-16 & 2016-17 (till 13/2/2017) on the basis of
consolidated turnover were sought from the broker. On sample basis, top 5 credit (fund received by the
broker) made by these clients to the broker were analyzed, to verify, if fund deposited by the said clients
were deposited in client bank account maintained by broker. It was observed that funds as received from
the clients were deposited in the said client bank account.
(v) Details of bank account mentioned in demat account maintained by the broker were checked to verify
whether broker’s client bank accounts have been mapped with the broker’s client demat accounts and

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broker’s own demat accounts has been mapped with the broker’s own bank account. It was observed
that the broker’s client bank accounts have been mapped with the broker’s client demat accounts and
broker’s own demat accounts has been mapped with the broker’s own bank account.

7. From the above observations, it is noted that there is no adverse finding with regard to
compliance of clause 2.1 of 2008 Circular and thus, no failure on the part of Noticee to this
extent is found in this case. If view of the above, the allegation levelled against the Noticee
in this regard does not sustain. Further, there is no allegation as to the failure to segregate
securities or moneys of clients so as to attract provisions of Section 23D of the SCRA.

8. The charge as regards alleged violation of Clause D of the 1993 Circular to be inquired in
this regard has been leveled on the basis of the following observation of the inspection team
– “It is observed that out of 30 sample days, on 27 days the funds of the clients available with broker
(client / settlement bank account) and clients collateral was less than the ledger credit balances of all clients
for such days. This shows possibility of the broker utilizing funds of client having credit balance, for other
purposes, such as funding the debit balance clients, own purpose, etc. ” As regards utilization of funds
for own purposes, there is not at all any basis or adverse inference in the inspection report
for this allegation. I find merit in the reply of the Noticee in this regard. Therefore, the
allegation of possibility of funds of clients having credit balance being utilized for the own
purposes of the Noticee does not sustain.

9. With respect to the calculation of shortfall as arrived at by the inspection team, the Noticee
has submitted that the credit balance of the clients also includes credit balances of directors
and their relatives and such funds do not belong to third party clients but to promoters,
directors and relatives. Hence, after reducing the said balance, the funds available in common
clients’ account are far in excess of the alleged shortages. In this regard, it is an admitted fact
that third party clients and promoters, directors and relatives who have been allocated unique
client IDs are all the clients of the Noticee. The pro moters, directors and relatives as clients
cannot be treated different from other clients for the aforesaid calculation of total credit
balance as arrived at by the inspection team. Accordingly, the contention of the Noticee to
this extent is not on sound footing.

10. However, the Noticee has further submitted that it does not debit margin applicable to the
clients in their ledger and the total credit balance as arrived by SEBI in its report is the credit

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balance without taking into account the margin obligations applicable to the clients and the
margin requirement of the clients having credit balance is in excess of the alleged shortage .
If such calculation were to be accepted then the credit balance would be in excess of the
alleged shortage in majority of instance. In the instant case, on one hand, the inspection team
has found the system and procedure of the Noticee to be in order and made the following
observation in the inspection report – “The system of the broker was checked to verify the segrega tion
of funds and securities of their clients and that of their own on sample basis. It was noted that securities
lying in the client beneficiary accounts of broker were segregated in the system and details of the clients to
whom the securities belong was available. The entries in relation to passing of the corporate benefits to clients
whose securities are available in the client beneficiary demat accounts were checked on sample basis in the
system and the same was found to be in order”, on the other hand the observation has been made
on the basis of possibilities. Admittedly, the observation in inspection report in respect of
the charge is based merely upon a possibility rather than on any specific basis or specific
instance of utilization of funds of clients having credit balance to meet the pay-in obligation
of clients having debit balance on any identified settlement date.

11. It is also relevant to mention that the penal charges should be leveled for violation of specific
legal obligations and the charges should not be based on merely, probablising or endeavoring
to prove the allegation. [Padola Veera Reddy Vs. State of Andhra Pradesh AIR 1990 SC 79; Sterlite
Industries Vs. SEBI (2001) 34 SCN 485 (SAT)]. It is also the settled position that there must
be convincing preponderance of probability to support the allegation for invoking penalty
provisions. Considering the ad hoc observations that are the basis of allegation, I am of the
view that the case deserves benefit of doubt. I, therefore, hold that the case does not warrant
imposition of any monetary penalty on the Noticee under Section 23D of the SCRA. The
SCN is disposed of accordingly.

12. In terms of Rule 6 of the Adjudication Rules, copy of this order is sent to the Noticee and
also to SEBI.

Date: April 09, 2019 Santosh Shukla


Place: Mumbai Adjudicating Officer

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