SEBI Adjudication Cases Abate Following Discovery of Deceased Trader Ms. Anju Rani
The Securities and Exchange Board of India (SEBI) has concluded an adjudication order regarding allegations against former trader Ms. Anju Rani concerning dealings in Illiquid Stock Options at BSE. The proceedings, which targeted non-genuine trading practices spanning a period from 2014 to 2015, were formally brought to a close after SEBI determined the abatement of the case due to the Noticee's passing.Initial Allegations of Market Manipulation
SEBI investigated large-scale reversal of trades in Illiquid Stock Options (ISO) executed on BSE Ltd., which led to the creation of artificial volume. The investigation focused on trading activities between April 1, 2014, and September 30, 2015.The SEBI inquiry found that during this Investigation Period, a significant portion of trades involved reversals in buy and sell positions by clients and counterparties. A total of 2,91,744 trades showed such reversal activities, representing 81.41% of all trades in the stock options segment at BSE.
These reversal trades were alleged to be non-genuine, lacking a basic trading rationale. They were cited as potentially portraying a false or misleading appearance of trading, thereby creating artificial volume. Ms. Anju Rani was identified among 14,720 entities found executing such non-genuine trades in the stock options segment.
Timeline and Investigation Details
The adjudication proceedings against Ms. Anju Rani stemmed from alleged violations of SEBI regulations pertaining to Fraudulent and Unfair Trade Practices (PFUTP Regulations). A Show Cause Notice (SCN) was initially issued on August 31, 2021. This SCN specifically cited two non-genuine trades in one stock options contract resulting in artificial volume of 20,000 units.Subsequently, SEBI issued multiple Post SCN Intimations regarding Settlement Schemes. A notice was sent on August 04, 2022, concerning the first scheme, which later saw its deadline extended to January 21, 2023. A second PSI followed on March 05, 2024, concerning a subsequent settlement scheme.
SEBI Rules Proceedings Abate Upon Trader's Death
A critical development in the case occurred when Mr. Nitin Agarwal, Ms. Rani's son, submitted her death certificate via email dated February 20, 2025. The details of the verification confirmed that Anju Rani passed away on January 12, 2025.Before proceeding further into the merits of the case, SEBI examined whether the adjudication proceedings would continue following her demise. Citing precedents, including decisions from the Supreme Court and the Securities Appellate Tribunal (SAT), the Adjudicating Officer noted that personal actions abate upon the death of the person concerned.
In view of this legal principle, the Adjudication Officer concluded that the present adjudication proceedings against Ms. Anju Rani are liable to be abated. Accordingly, the SCN dated August 31, 2021, is disposed of in relation to the Noticee's passing.
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