Sr. No. Name PAN 1 Ruchi Soya Industries Limited AAACR2892L 2 National Steel and Agro Industries Limited AAACN3548H

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1 NATIONAL COMMODITY & DERIVATIVES EXCHANGE LIMITED Circular to all trading and clearing members of the Exchange Circular No : NCDEX/LEGAL-006/20/118 Date : May 25, 20 Subject : SEBI order in the matter of trading in castor seed contracts SEBI vide its Order No. WTM/RKA/ISD/CDD2/55/20 dated May 24, 20 has restrained following clients from buying, selling or dealing in the securities market, either directly or indirectly, in any manner whatsoever, till further directions: Sr. No. Name PAN 1 Industries AAACR2892L 2 National Steel and Agro Industries AAACN3548H The above directions shall take effect immediately and shall be in force until further Orders. The detailed order is available on SEBI website ( A copy of the SEBI order is enclosed for ready reference. Members and market participants are advised to take note of the above and ensure compliance. For and on behalf of National Commodity & Derivatives Exchange Suresh Nair Senior Vice President Legal For further information / clarifications, please contact 1. Customer Service Group on toll free number: Customer Service Group by to: askus@ncdex.com Registered Office: 1st Floor, Akruti Corporate Park, Near G.E. Garden, LBS Road, Kanjurmarg West, Mumbai , India. CIN No. U51909MH2003PLC1401 Phone: , Fax , Website:

2 WTM/RKA/ISD/CDD2/55/20 SECURITIES AND EXCHANGE BOARD OF INDIA EX-PARTE AD-INTERIM ORDER UNDER SECTION 11 AND 11B OF THE SECURITIES AND EXCHANGE BOARD OF INDIA ACT, 1992 IN THE MATTER OF TRADING IN CASTOR SEED CONTRACTS AT NATIONAL COMMODITY & DERIVATIVES EXCHANGE LIMITED. 1. Securities and Exchange Board of India (hereinafter referred to as SEBI ) noticed that prices in Castor Seed February 20 Contract at NCDEX fell by around 20% in month of January 20. It was observed that futures prices of Castor Seed Contracts touched lower circuit of 4% on January 25, 20 and hit lower circuit of 6% on January 27, 20. It was also noticed that there was a very high concentration of open interest in February 20 Castor Seed Contract. On January 27, 20 National Commodity & Derivatives Exchange Ltd. (hereinafter referred to as NCDEX/the exchange ) under the provisions of its Rules, Bye-laws and Regulations suspended the trading in Castor Seed Contracts at the close of business hours, vide its circular (NCDEX/TRADING-007/20/012) dated 27 January, 20. Pursuant to this, SEBI after examination, passed an ex-parte ad interim order on March 2, 20 in the matter of trading in Castor Seed Contracts at NCDEX, and restrained entities from buying, selling or dealing in the securities market, either directly or indirectly, in any manner whatsoever, till further directions. 2. As a part of preliminary examination, the bank statements of the concerned suspected entities were analysed. During preliminary examination several acts and omissions, in connection with dealing in Castor Seed Contracts trading at NCDEX having a bearing on the commodities market, including circulation/transfer of funds for creating position in Castor Seed Contracts were also observed. 3. The preliminary examination, inter alia, revealed that one client namely, Industries hereinafter referred to as '' (who was holding significant position in Castor Seed Contracts) has transferred funds of around crore during the period of Jan 01, 20 to Jan 27, 20 to 5 clients who were also holding significant position in Castor Seed Contracts. It has been also noticed that the funds transferred by to these clients were then transferred to the respective Commodity Trading Members by the clients and using which these clients created position in Castor Seed Contracts. A flowchart showing transfer of funds by to 5 clients is as follows: Interim Order in the matter of Castor Seed Contracts Page 1 of

3 4. From the bank statement analysis of above stated entities and their pattern of trading / manner of creating position in Castor Seed Contracts, it has been prima facie observed that has financed/ provided funds to aforesaid 5 clients for taking open position in Castor Seed Contracts and further to maintain positions held by them in Castor Seed Contracts. Date wise details of fund transfer to aforesaid 5 clients and subsequent details of fund transfer to Commodity Trading Members and manner in which position in Castor Seed Contracts was created by the clients is explained below : I. National Steel and Agro Industries Ltd. :- It has been prima facie observed that the client National Steel and Agro Industries Ltd. has mainly initiated long positions in Castor Seed Contracts from December 14, 20. Before that the client was holding minimal positions. Therefore, SEBI analysed bank statements from December 01, 20 till January 31, 20. Observations from bank statement analysis (HDFC Bank Ltd.- Account No ) and trading activity of client are give below : Table 1 : Bank Statement analysis HDFC Bank Ltd.- Account No Received from Transferred to Date Particulars Amt Date Particulars Amt 11-Dec- Industries Ltd Dec - Angel Commodities Pvt. Ltd Interim Order in the matter of Castor Seed Contracts Page 2 of

4 -Dec- Angel Commodities Pvt. Ltd Jan- 14-Jan- -Jan- 21-Jan- 22-Jan- Industries Ltd Industries Ltd Industries Ltd Industries Ltd Industries Ltd Jan- 13-Jan- 14-Jan- -Jan- 22-Jan- 25-Jan- Angel Commodities Pvt. Ltd Angel Commodities Pvt. Ltd Angel Commodities Pvt. Ltd Angel Commodities Pvt. Ltd Angel Commodities Pvt. Ltd Angel Commodities Pvt. Ltd i. National Steel and Agro Industries Ltd. received funds aggregating to around crore from. Out of the said funds received from, funds to the tune of crore was transferred to the member, Angel Commodities Broking Pvt. Ltd. ii. From Table 1 it has been observed that on the same day or next day the funds received from has been transferred to the member Angel Commodities Broking Ltd. by National Steel and Agro Industries Ltd. iii. The client National Steel and Agro Industries Ltd. started taking long positions in Castor Seed Contracts in a significant way from December 14, 20. Before this date the client was holding minimal positions i.e., since 1 Jan 20 till 13 Dec 20. iv. The client initiated a long position of 4750 MT as on December 14, 20. The long position has then been steadily increased by the client to 7770 MT on December, 20. Prima facie, it has been observed that the funds of 5 crore received from on December 11, 20 has then been transferred to the member Angel. Ltd. on December, 20 for payment towards margin obligations in respect of the positions taken in Castor Seed Contracts by National Steel and Agro Industries Ltd. v. On January 08, 20 National Steel and Agro Industries Ltd. was holding long position of MT which was increased to MT on January 11, 20 and further increased to MT on January 12, 20 and to MT on January 13, 20. Prima facie, it has been observed that the funds received from during January 11, 20 to January 22, 20 have been used to pay the margin requirements for the increased long positions held by National Steel and Agro Industries Ltd. vi. Thus it has been prima facie observed that the Castor Seed Contract positions of the client, National Steel and Agro Industries Ltd. were funded by Interim Order in the matter of Castor Seed Contracts Page 3 of

5 II. Mr. Anuj Jain :- It has been prima facie observed that the client Mr Anuj Jain has taken positions in Castor Seed Contracts since December 9, 20. Therefore SEBI analysed bank statements from December 01, 20 to January 31, 20. Observations from bank statement analysis (Axis Bank Ltd. - Account No and ) and trading activity of client are given below : Table 2 : Bank Statement analysis Axis Bank Ltd. - Account No and Analysis of Bank Transaction of Mr. Anuj Jain ( A/c no ) Received from Transferred to Date Particulars Amt Date Particulars Amt 3-Dec Dec- Neer Ocean Industries Multitrade Private 5-Dec Industries 9-Dec Industries Neer Ocean Dec- Industries Dec- Multitrade Private 14- Neer Ocean Dec- Multitrade Private Dec- Industries 30- Anuj Jain A/c no Dec Dec- Industries 12-Jan Jan- Anuj Jain A/c no Industries Jan Industries 13-Jan Jan- Anuj Jain A/c no Industries Jan Jan- Anuj Jain A/c no Industries Jan Jan- Anuj Jain A/c no Industries Jan Jan- Anuj Jain A/c no Industries Jan Industries 22-Jan Jan- Anuj Jain A/c no Industries Analysis of Bank Transaction of Mr. Anuj Jain ( A/c no ) Received from Transferred to Date Particulars Amt Date Particulars Amt 30- Anuj Jain A/c No Neer Ocean Interim Order in the matter of Castor Seed Contracts Page 4 of

6 Dec- 12-Jan- 13-Jan- 14-Jan- -Jan- 22-Jan- 22-Jan Dec- Multitrade Private Anuj Jain A/c No Jan- Neer Ocean Multitrade Private Anuj Jain A/c No Jan- Neer Ocean Multitrade Private Anuj Jain A/c No Jan- Neer Ocean Multitrade Private Anuj Jain A/c No Jan- Neer Ocean Multitrade Private Anuj Jain A/c No Jan- Neer Ocean Multitrade Private Anuj Jain A/c No Jan- Neer Ocean Multitrade Private i. During the period from December 01, 20 to January 30, 20, the client Mr Anuj Jain has received around crore from in his account number held with Axis Bank. ii. Out of these crore received from, 8 crore has been transferred by Mr. Anuj Jain to the member Neer Ocean Multitrade Pvt. Ltd from the said bank account on 9th,10th and 14th December 20. iii. From the remaining funds received by Mr. Anuj Jain, 4.01 crore has been transferred by Mr. Anuj Jain to his another Axis Bank account from which 3.96 crore has been then transferred to the trading member Neer Ocean Multitrade Pvt. Ltd between December 30, 20 to January 22, 20. iv. From Table 2 it has been observed that the client Mr Anuj Jain has received funds from and same has been immediately transferred to the member Neer Ocean Multitrade Pvt. Ltd. v. The client Mr Anuj Jain had no position in Castor Seed Contracts prior to December 9, 20 and has taken a long position of 5450 MT in Castor Seed Contracts as on December 9, 20 which was increased to MT on December 10, 20 and further increased to 950 MT as on December 11, 20. Prima facie, it has been observed that Mr Anuj Jain received funds to the tune of 9.5 crore from between December 3, 20 - December 10, 20 and of which 8 crore were paid to Neer Ocean Multitrade Pvt between December 9, 20 - December 14, 20 for trading and taking fresh positions in Castor Seed Contracts. Interim Order in the matter of Castor Seed Contracts Page 5 of

7 vi. Thus it has been prima facie observed that the Castor Seed Contract positions of the client, Mr. Anuj Jain were funded by. III. Sisne Polymers Pvt. Ltd. :- It has been prima facie observed that the client Sisne Polymers Pvt. Ltd. has taken substantial position in Castor Seed Contracts from December 01, 20 onwards. Therefore SEBI analysed bank statements from December 01, 20 to January 31, 20. Observations from bank statement analysis ( No and Kotak Bank Account No ) and trading activity of client are given below : Table 3 : Bank Statement analysis Kotak Bank Account No Received from Transferred to Date Particulars Amt Date Particulars Amt. 02-Dec- Ltd Dec- Industries Ltd Dec- of Sisne Polymers Dec- of Sisne Polymers Dec- Industries Ltd Dec- of Sisne Polymers Dec- Industries Ltd Dec- of Sisne Polymers Jan- Industries Ltd Jan- of Sisne Polymers Jan- Industries Ltd Jan-- of Sisne Polymers Jan- Industries Ltd Jan- of Sisne Polymers Jan- of Sisne Polymers Jan- Industries Ltd Jan- of Sisne Polymers Table 4 : Bank Statement analysis No Received from Transferred to Date Particulars Amt Date Particulars Amt Kotak Bank of 03-Dec- Sisne. Polymers Dec- Ltd Kotak Bank of 05-Dec- Sisne. Polymers Dec- Ltd Kotak Bank of 07-Dec- Sisne. Polymers Dec- Ltd Dec- Kotak Bank of Sisne Dec Interim Order in the matter of Castor Seed Contracts Page 6 of

8 13-Jan- 14-Jan- -Jan- -Jan- 22-Jan- Polymers Kotak Bank of Sisne Polymers Jan- Kotak Bank of Sisne Polymers Jan- Kotak Bank of Sisne Polymers Jan- Kotak Bank of Sisne Polymers Kotak Bank of Sisne Polymers Ltd.. Ltd Ltd Ltd Jan-. Ltd i. Sisne Polymers Pvt. Ltd. has received funds aggregating to 13 crore approximately from in its bank account no with Kotak Bank, from which Sisne Polymers Pvt. Ltd. transferred crore to his other bank account no held with Dena Bank. Sisne Polymers Pvt. Ltd. finally transferred 50 lakhs from Kotak Bank account and 12 crore from Dena Bank account to the trading member,. Ltd. through which he has traded in Castor Seed Contracts. ii. From Table 3 and Table 4 it has been observed that the amounts received from Ruchi Soya has been transferred on the same or next day to the member,. Ltd. by the client through his two bank accounts. iii. The client initiated long positions of 670 MT as on November 30, 20 which was increased to 5990 MT on December 1, 20 and further increased to MT on December 2, 20. Prima facie, it has been observed that the funds required to meet the margins in respect of the said positions has been met through the funds received from since December 02, 20. iv. Thus it has been prima facie observed that the Castor Seed positions of the client, Sisne Polymers Pvt. Ltd. were funded by. IV. Stride Multitrade Pvt. Ltd. :- It has been prima facie observed that the client Stride Multitrade Pvt. Ltd. has been consistently holding long positions in Castor Seed Contracts from January 20. Therefore SEBI analysed bank statements from January 01, 20 to January 31, 20. Observations from bank statement analysis (HDFC Bank Ltd. - Account No ) and trading activity of client are given below : Table 5 : Bank Statement analysis HDFC Bank Ltd. - Account No Received from Transferred to Date Particulars Amt Date Particulars Amt Interim Order in the matter of Castor Seed Contracts Page 7 of

9 2-Jan- 19-Jan- 5-Feb- 10-Feb- 18-Feb- 24-Feb- 8-Apr- 25-May- 30-Dec- Industries Ltd Jan- Industries Ltd Jan- Industries Ltd Feb- Industries Ltd Industries Ltd Industries Ltd Feb- 18-Feb- 25-Feb- Industries Ltd Apr- Industries Ltd Industries Ltd May- 30-Dec- Ltd Ltd Ltd Ltd Ltd Ltd Ltd Ltd Ltd i. During the period on various instances Stride Multitrade Pvt. Ltd. received funds aggregating to around crore from which has been fully transferred on the same day or next day to the member. Ltd. through which the client has traded and was holding positions in Castor Seed Contracts. ii. Stride Multitrade Pvt. Ltd. received 4.5 crore from on January 19, 20 and transferred it to its member. Ltd. on the same day. The Long positions of Stride Multitrade increased from 5050 MT as on January 19, 20 to 190 MT on January 21, 20 and further increased to MT on January 22, 20. iii. Stride Multitrade Pvt. Ltd. has received an amount of 7.5 crores from in the month of February 20 which were transferred to the member Commodities Pvt. Ltd immediately or on the next day. The long position of the client increased from 8830 MT as on February 12, 20 to MT as on February 24, 20. iv. Stride Multitrade Pvt. Ltd. has received an amount of 3.5 crores from on May 25, 20 which were transferred to the member. Ltd on the same day. The long position of the client increased from MT as on May 20, 20 to 400 MT on May 28, 20. Interim Order in the matter of Castor Seed Contracts Page 8 of

10 v. Thus it has been prima facie observed that the margin requirements in respect of the said Castor Seed positions of the client through the member. Ltd. has been funded by V. Bharat Food Co-operative Ltd:- It has been prima facie observed that the client Bharat Foods Co-operative Ltd. has been consistently holding long positions in Castor Seed Contracts. Observations from bank statement analysis (HDFC Bank- Account No ) and trading activity of client are given below : i. The client Bharat Foods Co-operative Ltd. has been consistently holding long positions in Castor Seed Contracts. ii. On October 14, 20, Bharat Food Co-operative Ltd received 13 crore from and on the same day 5.50 crore was transferred to member, Investsmart Commodities Ltd. through which client was holding position in Castor Seed Contracts. iii. The client was allocated delivery in Castor Seed for 5780 MT on October 12, 20. Thus it has been prima facie observed that the amount of 5.50 crore paid to the member, Investsmart Commodities Ltd. was towards pay-in obligation for the said deliveries in Castor Seed Contracts. 5. In view of the above, prima facie it has been observed that has provided funds to 5 clients for creating / maintaining open position on Long Side in Castor Seed Contract. Therefore, all 6 entities i.e. and 5 clients funded by (namely National Steel and Agro Industries Ltd., Mr. Anuj Jain, Sisne Polymers Pvt. Ltd., Bharat Food Cooperative Ltd. and Stride Multitrade Pvt. Ltd. ) are connected with each other and hereinafter referred to as 'Ruchi Group Entities'. Further, National Steel and Agro Industries is a Ruchi Group Company (as per website of Ruchi group). Independent Director Mr Navin Khandelwal is common to both National Steel and Agro Industries Ltd. and Industries Ltd. 6. Further, it has been prima facie observed that and 5 clients funded by were also among the top clients on Long Side in Castor Seed February 20 Contract during the month of January 20. Collectively, 'Ruchi Group Entities' were holding 1100 MT of Castor Seed position in February 20 out of total MT which was 39.39% of open position in February 20 Contract of Castor Seed (as on 27th January 20) which in value terms was approximately to the tune of 340 crore. Details of open interest position held by aforesaid 6 clients in Castor Seed February - 20 Contract is as given below : Interim Order in the matter of Castor Seed Contracts Page 9 of

11 Table 6 : Open Position held by 'Ruchi Group Entities' in Castor Seed February 20 Contract as on 27 Jan, 20 Long OI in Sr No Client Name Pan No MT 1 National Steel and Agro Industries AAACN3548H Stride Multitrade Private AAGCS5768N Industries AAACR2892L Bharat Foods Co-Operative AAAAB30D Mr. Anuj Jain ABEPJ8083F Sisne Polymers Private AAPCS4092L In view of the above, it has been prima facie observed that the manner in which Open Interest positions are held jointly by the 'Ruchi Group Entities' in Castor Seed Contracts suggests a "acting in concert" pattern and this combined with the fact that they collectively were holding a substantial open position, indicates a scenario which has a potential to disturb the market equilibrium and harm market integrity. Hence, open positions held by 'Ruchi Group Entities' are being treated as clubbed position in view of the fact that, it has been prima facie observed that though the position in Castor Seeds were taken by different clients through different Commodity Trading Members, there was a meeting of minds and intention to corner the market on Long Side in Castor Seed Contracts by 'Ruchi Group Entities'. Further, Industries has continuously provided the financial means / assistance to other clients for creating / maintaining position in Castor Seed Contracts whenever required by them. 8. Therefore above prima facie findings indicate that, 'Ruchi Group Entities' has traded in Castor Seed Contracts with a dubious plan and premeditated arrangement and artifice to corner /control the market on Long Side in Castor Seed Contracts. 9. Further, on account of clubbed position held by 'Ruchi Group Entities' in Castor Seed Contracts across different expiries it has been noticed that there were several continuous instances where position limit violations were observed. During the period of Jan 01, 20 to Jan 27, 20 (examination period indicated in aforesaid ex-parte ad interim order dated March 2, 20), Client level position limit violations as prescribed by Forward Market Commission (hereinafter referred to as FMC ) vide its circular FMC/3/2014/C/128 dated October 22, 2014 and FMC/3/2014/C/137 dated December 11, 2014 were observed on most of the trading days. Counts of position limit violations are given below and details placed as Annexure A : I. On 18 occasions 'Ruchi Group Entities' have violated commodity level client position limits as prescribed by FMC. II. On 6 occasions 'Ruchi Group Entities' have violated near month client position limit as prescribed by FMC. Interim Order in the matter of Castor Seed Contracts Page 10 of

12 10. Further, out of the aforesaid 6 clients, 4 entities namely Stride Multitrade Pvt. Ltd., Bharat Foods Co-operative, Mr Anuj Jain and Sisne Polymers Pvt. Ltd., were restrained from buying, selling or dealing in the securities market, either directly or indirectly, in any manner whatsoever, till further directions vide SEBI Ex Parte Ad Interim Order dated March 02, 20 in matter of trading in Castor seed Contracts at NCDEX. The said order clearly demonstrates that the aforesaid 4 clients have failed to discharge their MTM obligation and have disturbed the market equilibrium. 11. Based on the above stated facts and analysis, I prima facie find that: 'Ruchi Group Entities' have taken huge long positions in Castor Seed Contracts and have violated the position limits prescribed by FMC. There was a prior meeting of mind among 'Ruchi Group Entities' to form a cartel and execute their trades in Castor Seed Contracts. 'Ruchi Group Entities' have traded in Castor Seed Contracts with a dubious plan and premeditated arrangement and artifice to corner /control the market on Long Side in Castor Seed Contract. 'Ruchi Group Entities' have traded in such a manner and in high magnitude which has potential to disturb the market equilibrium and harm market integrity. 12. It is noted that the role of commodity derivative market is to provide price discovery and risk management to stakeholders in the market such as farmers, traders, exporters and consumers etc. and in this context the dominant position created by 'Ruchi Group Entities' in Castor Seed in a concealed manner, which was also in violation of prescribed limits for client level position, oblivious to other market participants has disturbed the market equilibrium and has thus harmed the market integrity. Also the dictum 'disturbing the market equilibrium' has a wide meaning and any such disturbance in commodity derivative markets may lead to disturbance in underlying physical market, as well. Therefore, in present case conduct of the aforesaid 6 entities holding 39.39% of total open interest in February-20 Castor Seed Contract has to be seen in that context. 13. Considering the above facts and circumstances, I, prima facie, find that the acts and omissions of Industries and National Steel and Agro Industries has, not only disturbed market equilibrium, but also indicate manipulative and fraudulent design to form a cartel and corner the Castor Seed market. I further, prima facie find that Industries and National Steel and Agro Industries being part of 'Ruchi Group Entities' have violated the position limits prescribed by FMC vide its circular FMC/3/2014/C/128 dated October 22, 2014 and FMC/3/2014/C/137 dated December 11, I, therefore, prima facie find that Industries and National Steel and Agro Industries have contravened the provisions of the Securities and Exchange Board of Interim Order in the matter of Castor Seed Contracts Page 11 of

13 India Act, 1992 (the SEBI Act) and have acted in fraudulent and deceitful manner which attracts prohibitions enshrined in section 12A(a), (b) and (c) of the SEBI Act and provisions of regulation 3(a) and (d) and regulation 4(1), 4(2)(a) and (g) of the Securities and Exchange Board of India (Prohibition of Fraudulent and Unfair Trade Practices relating to Securities Market) Regulations, 2003 ('PFUTP Regulations') which read as following:- Section 12A of the 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 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 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 recognized 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 recognized stock exchange, in contravention of the provisions of this Act or the rules or the regulations made thereunder;" 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) (c) (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; Interim Order in the matter of Castor Seed Contracts Page 12 of

14 (g) entering into a transaction in securities without intention of performing it or without intention of change of ownership of such security;....". I am of the opinion that detailed investigation of entire scheme, plan, device and artifice employed by concerned entities is necessary. I further note that role of other 4 entities funded by Industries i.e. Stride Multitrade Pvt. Ltd., Bharat Foods Co-operative, Mr Anuj Jain and Sisne Polymers Pvt. Ltd. against whom SEBI already has passed an Ex Parte Ad Interim Order dated March 02, 20 in matter of trading in Castor seed Contracts at NCDEX, may also be looked upon during investigation in this matter. The connected entities, acting in concert under a premeditated plan, have acquired dominant market share in Castor Seed Contracts traded at NCDEX. Their acts, conduct, behaviour and dealings connote a deceptive conduct designed to deceive or defraud market participants and by camouflaging /masking their actual position in Castor Seed, they have interfered with free market forces of supply and demand.. SEBI strives to safeguard and protect the interests of a genuine investor in the Indian securities market. It has been a point of concern when behaviour of few entities put entire market at systemic risk and disturbs the market equilibrium and integrity. 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 commodities market. Further, the fraudulent, manipulative and deceptive device, plan, device and artifice as prima facie found in this case, I am convinced that this is a fit case where, pending investigation, effective preventive and remedial action is required to be taken by way of ad interim ex-parte order to protect the interests of investors and preserve the safety and integrity of the securities market. 17. Therefore, in order to protect the interest of investors and the integrity of the securities market, I, in exercise of the powers conferred upon me by virtue of section 19 read with sections 11 and 11B of the SEBI Act, 1992, pending investigation, by way of this ad-interim exparte order restrain following clients from buying, selling or dealing in the securities market, either directly or indirectly, in any manner whatsoever, till further directions: Sr. No. NAME PAN 1 Industries AAACR2892L 2 National Steel and Agro Industries AAACN3548H 18. The commodity exchanges, stock exchanges and the depositories are directed to ensure that the above directions are strictly enforced. Interim Order in the matter of Castor Seed Contracts Page 13 of

15 19. The above order is without prejudice the right of SEBI to take any other action that may be initiated against the abovementioned entities in accordance with law. 20. The entities against whom this order is being passed may file their objections, if any, within twenty one days from the date of this Order and, if they so desire, may avail themselves of an opportunity of personal hearing before the Securities and Exchange Board of India at its Head Office at SEBI Bhavan, C4-A, G-Block, Bandra Kurla Complex, Bandra (East), Mumbai on a specific request in this regard. 21. This order shall come into force with immediate effect. DATE: May 24 th, 20 PLACE: MUMBAI Sd/- RAJEEV KUMAR AGARWAL WHOLE TIME MEMBER SECURITIES AND EXCHANGE BOARD OF INDIA Interim Order in the matter of Castor Seed Contracts Page 14 of

16 Annexure A On account of clubbed position held by 'Ruchi Group Entities' in Castor Seed Contracts across different expiries during the period of Jan 01, 20 to Jan 27, 20 (examination period indicated in aforesaid ex-parte ad interim order dated March 2, 20), Client level position limit violations as prescribed by Forward Market Commission (hereinafter referred to as FMC ) vide its circular FMC/3/2014/C/128 dated October 22, 2014 and FMC/3/2014/C/137 dated December 11, 2014 were observed on most of the trading days. Day wise details of position limit violations are as given below : On 18 occasions 'Ruchi Group Entities' have violated commodity level client position limits as prescribed by FMC. Details given below : Sr. No. Date 5% of Market OI Excess OI Qty Netted OI of 'Ruchi Group Entities' (across contracts) Market OI (across contracts) Absolute OI Limit (commodity level) 1 01/01/ /01/ /01/ /01/ /01/ /01/ /01/ /01/ /01/ /01/ /01/ /01/ /01/ /01/ /01/ /01/ /01/ /01/ On 6 occasions 'Ruchi Group Entities' have violated near month client position limit as prescribed by FMC. Details given below : Sr. No. Date 5% of Market OI Excess OI Qty Netted OI of 'Ruchi Group Entities' (near month contract) Market OI (near month contract) Absolute OI Limit (near month) 1 01/01/ /01/ /01/ /01/ /01/ /01/ Interim Order in the matter of Castor Seed Contracts Page of

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