Main Search Premium Members Advanced Search Disclaimer
Cites 8 docs - [View All]
The Securities and Exchange Board of India Act, 1992
The Government Securities Act, 2006
Securities And Exchange Board Of ... vs Skdc Consultants Ltd. on 12 March, 2004
Section 12A in The Securities and Exchange Board of India Act, 1992
Ex. Naik Sardar Singh vs Union Of India And Others on 3 May, 1991
Citedby 1 docs
The Bullion And Jewellers ... vs Union Of India & Ors. on 26 April, 2016
Dharti Agro Chemicals Pvt. Ltd., ... vs The Commissioner Of Central ... on 29 August, 2018

User Queries

Try out our Premium Member services: Virtual Legal Assistant, Query Alert Service and an ad-free experience. Free for one month and pay only if you like it.

Securities Appellate Tribunal
Sebi vs Karvy Stock Broking Ltd. on 22 June, 2007
Bench: G Anantharaman

ORDER G. Anantharaman, Member

1. Background:

1.1. In October 2005, the stock exchanges submitted their preliminary observations on the Initial Public Offering (IPO) of Yes Bank Ltd. (YBL) which hinted at the possibility of large scale off-market transactions immediately following the date of allotment and prior to the listing on the stock exchanges. SEBI therefore carried out a preliminary scrutiny by calling for data from the depositories and the Registrar to the Issue (RTI). SEBI found that, many demat accounts in fictitious/ benami names were opened by certain entities (hereinafter referred to as the "Key Operators") and these entities had cornered/ acquired the IPO shares, by making applications in fictitious/ benami names with each of the applications being of small value so as to make it eligible for allotment under the retail category. The aforesaid demat accounts are hereinafter referred to as "afferent accounts" for the sake of brevity. The investigation conducted by SEBI further revealed that subsequent to the allotment of IPO shares, the fictitious/benami allottees had transferred the said shares to their principals which were identified by SEBI as key operators / master account holders. The modus operandi as detailed above led to the prima facie view that the thousands of entities in whose names demat accounts and bank accounts had been opened and IPO applications made, were either benami, name lenders or non existent.

1.2. On noticing the irregularities and widespread abuse, SEBI acted against the entities who were responsible for the irregularities by passing interim order dated December 15, 2005 restraining them from participating in all future IPOs and also directing the depositories to effectively freeze their dematerialized accounts.

1.3. It was noticed during the course of preliminary scrutiny of Yes Bank IPO, that all the dematerialized accounts in fictitious / benami names had been opened with the DP Karvy Stockbroking Ltd. ("Karvy DP"). Therefore, in the said interim order dated December 15, 2005 it was mentioned that "Also, the role of Karvy-DP i.e. Karvy Stockbroking Ltd. that opened the dematerialized accounts of 6315 entities being benamis of Roopalben Panchal and 1315 entities being benamis of Sugandh probably without taking adequate steps to ascertain the genuineness of these entities while acting as a facilitator in what appears to be an act of either gross negligence or active collusion ill behoves them as a SEBI registered market participant."

1.4. In view of the prima facie finding as above, vide the interim order dated December 15, 2005 in the matter of Yes Bank IPO, the following direction was issued by SEBI against Karvy DP: NSDL is directed to undertake a comprehensive inspection of Karvy-DP particularly focusing on the sytems and procedures, if any, put in place by Karvy-DP for implementing the 'know your client' norms that DPs are required to follow. NSDL shall identify the deficiencies in Karvy-DP with regard to the above and also ascertain from Karvy-DP the particulars of other potential benami accounts more particularly those multiple accounts having the same contact address and / or having the same person / entity authorized to operate these dematerialized accounts. Karvy-DP is directed to fully co-operate with NSDL in the above inspection. NSDL shall submit a report to SEBI detailing the findings of its inspection in a time-bound programme.

1.5. Thereafter, SEBI examined the dealings in another major IPO of IDFC wherein the very same players were suspected to have played a major role in cornering the shares. SEBI issued ad interim orders in the case of IDFC also along the similar lines as done in the case of Yes Bank. In the interim order dated January 12, 2006 in the case of IDFC IPO, SEBI inter alia observed as below:

11.16. Further the reports of inspection of Karvy-DP submitted to SEBI by NSDL and CDSL shows that 'Know your client' norms have not been adhered at all while opening the dematerialized accounts.

11.17. Further, Karvy's internal e-mail correspondences given as Annexure to the NSDL inspection report show that even during November 2005 the top management of Karvy-DP were aware of the issue of multiple dematerialized accounts opened with the same address. It appears that the management of Karvy-DP, on coming to know of the same in the wake of a query from SEBI in some other case had, as early as November 2005, internally decided to process these multiple dematerialized accounts bearing the same address for closure. The above goes to confirm that Karvy-DP had knowledge about the fictitious nature of such multiple accounts.

11.18. Also, some of the documents collected by CDSL during the course of inspection show that Karvy-DP has obtained letters purported issued by the concerned banks such as Bharat Overseas Bank as proof of identity and proof of address of the person for the purpose of opening dematerialized accounts. It is seen that one branch manager has on the same date signed as authorized signatory of different branches of the bank. This raises a doubt as to the authenticity of the bank documents obtained by Karvy-DP for opening dematerialized accounts. SEBI is making reference to RBI regarding such apparent irregularities in the bank documents submitted to Karvy-DP for the purpose of opening the dematerialized accounts.

11.19. It is also noted that in view of significant irregularities noticed during the course of inspection of Karvy-DP, both NSDL and CDSL have directed Karvy-DP not to open new dematerialized accounts till the issue of verifying the genuineness of multiple dematerialized account-holders having the same address is addressed to the satisfaction of the depositories.

11.20. The above facts cast grave doubts as to the genuineness of the thousands of IPO applicants who have apparently furnished the address of Roopalben Panchal or Sugandh or Purshottam Budhwani as their address. The findings of the investigation/Inspection of the concerned banks by RBI has fortified the initial findings of SEBI that Karvy-DP has actively colluded with the above entities in opening multiple/benami bank accounts and dematerialized accounts in the names of fictitious persons.

1.6. In view of the findings as above, SEBI in the interim order dated January 12, 2006 in the matter of IDFC IPO, inter alia, issued the following directions against Karvy DP: 12.5. Thousands of dematerialized accounts being opened on the same day with the same branch and being introduced by the same bank should have alerted the DPs at the time of opening of the dematerialized accounts. However the fact that DPs failed to exercise even this basic due diligence gives rise to a suspicion that they have actively colluded with the perpetrators. It is a matter of serious concern that Karvy-DP has opened such apparently benami / fictitious accounts working out to over 95% (42,056 nos) of the multiple dematerialized accounts in relation to IDFC IPO. I note that Karvy-DP has already been directed by the depositories to verify the genuineness of the dematerialized account-holders and to close those dematerialized accounts where it is unable to verify the genuineness of identity and address of the dematerialized account-holders. The depositories have prohibited Karvy-DP from opening new dematerialized accounts till the above process has been completed. I hereby direct Karvy-DP and Pratik-DP to complete the process of verifying the identity and address of dematerialized account-holders and to close / freeze the dematerialized accounts where they are unable to do the verification not later than January 31, 2006. Further, Karvy-DP and Pratik-DP shall put in place systems and procedures to ensure that in future no non-genuine dematerialized accounts are opened by them. Karvy-DP and Pratik-DP shall submit a detailed report to SEBI narrating the actions taken by them in this regard and also give an undertaking that the SEBI's above directions have been fully complied with. I further direct that Karvy-DP and Pratik-DP shall not open new dematerialized accounts till the submission of above report and undertaking to SEBI and obtaining a no-objection from SEBI for accepting fresh business as a DP.

1.7. Further, in view of the findings of preliminary scrutiny as above, SEBI referred the matter to other government agencies including Income Tax Department, Ministry of Company Affairs and the Reserve Bank of India. Also, SEBI filed a complaint with CBI in the matter.

1.8. Pursuant to the same, RBI conducted inspections of the banks involved. The inspection by RBI brought out various irregularities at the end of the banks involved, specifically BhOB and also the role of Karvy group behind the enire gamut of operations.

1.9. Further, the parliamentary Standing Committee on Finance conducted a study on "Efficacy of Reform Process in the Capital Market - Recent IPO Scam".

1.10. For the purpose of the study / examination of the matter, the committee took oral and written testimonies / evidences of SEBI and RBI, the representatives of Investors' Grievances Forum, Indian Overseas Bank, Vijaya Bank, ICICI Bank, HDFC Bank and Bharat Overseas Bank, National Stock Exchange, Bombay Stock Exchange, National Securities Depository Ltd., and Central Depository Services Ltd. Purusuant to the study, the committee submitted its report before the parliament on November 28, 2006.

1.11. The major observations of the committee with regard to the role of Karvy group in the IPO irregularities was as follows:

...The fact that Karvy RTI had made consolidated refund favouring BhOB in respect of thousands of IPO applicants and that the Karvy Group was directing the investment of funds in respect of IPO applications are real eye openers. The Committee also note that Karvy had very conveniently issued an idea paper to BhOB certifying that the applications received for the IPO offer were valid, which shows the extent to which Karvy could prevail upon the Bank. They feel that the discreet arrangement for mutual benefit of BhOB and Karvy would have gone further ahead had there been no unearthing of the IPO scam.

61. The Committee are convinced that the role of Karvy Group of Companies in the IPO Scam was questionable right from the beginning...." In view of the above, the committee advised SEBI to conduct investigation in all areas of manipulation allegedly done by the Karvy Group. The committee further observed that

62. ... As a major part of the malfunctioning leading to the scam could be attributed to the role of the intermediary, the Karvy Group of Companies which performed multiple functions in all directions, the Committee feel that the role of such intermediaries should be examined minutely with a view to see that those operating in multiple capacity are not able to manipulate the system....

1.12. Besides the above, the committee, in various parts of the report has made many adverse observations regarding the role of Karvy group companies in the IPO irregularities.

1.13. Further, SEBI also received references from various Government Agencies including Reserve Bank of India ('RBI'), Serious Fraud Investigation Office ('SFIO') and Intelligence Bureau ('IB'). Various investor complaints were also received alleging irregularities in various IPOs.

1.14. In the course of investigations pursuant to interim orders in the cases of Yes Bank and IDFC IPOs, SEBI noticed that some of these multiple accounts were opened in June 2003. The involvement of these accounts in Initial Public Offerings prior to that of Yes Bank and IDFC were looked into. Securities and Exchange Board of India (hereinafter referred to as SEBI) conducted an investigation into the buying, selling or dealing in the shares issued through Initial Public Offerings (IPOs) of companies during the period 2003-2005. The investigation conducted by SEBI found that the modus operandi, as detailed above, had been adopted for cornering of IPO shares in 21 IPOs that came during 2003-2005.

1.15. The investigations prima facie revealed the substantial involvement of Karvy group companies in the IPO irregularities. It was found that Karvy-DP had, during 2003, tied up with BhOB for the purpose of provding IPO finance to their demat account clients. Based on introduction of saving account by Karvy, BHOB disbursed the loan amount to the clients of Karvy DP. However, with passage of time, it appears that Bharat Overseas Bank officials chose to rely more on Karvy's DP account details and drew comfort therefrom while dropping their guard in the matter of opening bank accounts and verification thereof. Exploiting the blind trust and complacency on the part of BhOB, Karvy gave short shrift to the KYC procedures. Thus in the year 2005 when market for IPOs was booming, Karvy-DP did not comply with the account opening formalities by opening multiple demat accounts in fictitious / benami names. Thereafter, in order to make its account opening procedure seemingly compliant, Karvy-DP resorted to fabrication of bank documents towards POI and POA and also arranged for photographs from other sources. The perfect matching of the fabricated bank documents with the details available in the depository system gave rise to the possibility that the bank documents might have been forged by the DP itself. Thus, it appeared that Karvy, being the progenitor of the entire scheme won over the trust of the allies in the bank and made its pitch effectively in the market, besides making common cause with the sub brokers and financiers who were part of the manipulative assemblage. Other Karvy group entities namely Karvy Consultants Ltd. and Karvy Computershare P Ltd. ("Karvy RTI") were also found to have played their part by providing / arranging IPO finance and providing consolidated refund cheques in respect of the afferent accounts and directing the bank to credit the refunds in the accounts of the key operators.

1.16. In the above facts and circumstances, SEBI vide an ad interim ex parte interim order dated April 27, 2006 inter alia directed as below:

17.7. In view of the detailed findings against Karvy DP and Pratik DP in this order, Karvy DP and Pratik DP, in my view prima facie do not appear to be fit to deal in securities market as SEBI registered intermediaries. Appropriate quasi-judicial proceedings are being initiated against the two DPs. In view of the substantial findings of a serious nature brought out in this order against Karvy DP and Pratik DP, in addition to what has been noticed in the earlier two interim orders in the cases of Yes Bank and IDFC, I direct that Karvy DP and Pratik DP shall not carry on the activities as DP till the completion of enquiry and passing of final order, excepting for effecting transfer of BO account to another SEBI registered DP on request. Notwithstanding this direction, Karvy DP and Pratik DP shall continue to be governed by the SEBI (Depositories and Participants) Regulations, 1996 and other applicable legal provisions in other respects.

17.8. Since the other business groups of Karvy have appeared to have acted in concert in the gamut of the IPO manipulations, I further direct Karvy Stock Broking Ltd., Karvy Computershare Pvt. Ltd., Karvy Investor Services Ltd. and Karvy Consultants Ltd. not to undertake fresh business as a Registrar to Issue and Share transfer agent, excepting those businesses already contracted as on date.

1.17. Subsequent to the issue of ex-parte interim directions as above, an opportunity of post decisional hearing was granted to the Karvy group. After considering the oral and written submissions of Karvy group, vide order dated May 26, 2006, the following directions were issued:

(a) KSBL is directed not to act as a depository participant, pending enquiry and passing of final orders, except for acting on the instructions of existing beneficial owners, so that the interests of existing BOs remain unaffected. It shall transfer the demat account of an existing BO to another SEBI registered DP, on request. It is clarified that KSBL shall continue to be governed by the SEBI (Depositories and Participants) Regulations, 1996 and other applicable legal provisions.

(b) KSBL, as a stock broker, is directed not to undertake any proprietary trades in securities, either off-market or on market, pending enquiry and passing of final orders.

(c) KCPL is directed not to act as a registrar to an issue and as a share transfer agent, pending enquiry and passing of final orders, except for the assignments already contracted before passing of interim order dated April 27, 2006. This direction will not apply to KCPL as Registrar and Transfer Agent to Mutual Funds. It is noted that Karvy Investor Services Ltd. and KCL are not registered as registrars to an issue or share transfer agents with SEBI.

1.18. The DP filed an appeal before the Hon'ble Securities Appellate Tribunal (SAT) against the aforesaid order of SEBI dated May 26, 2006 and the same was dismissed by SAT vide order dated January 8, 2007 with a direction to SEBI to complete the enquiry not later than March 31, 2007. Further, SAT had directed SEBI to take a final decision in accordance with law within two months thereafter. In the said order SAT had inter alia observed "what needs to be examined is whether the appellant had really failed to get alerted to the abuse of its systems by the so called sub-brokers or whether there was active collusion of the appellant with its clients for abusing the IPO process and sharing the gains arising from the same. We can not decide these issues at this stage not can it be said as to which of these two versions is correct. It is an undisputed fact that thousands of fictitious/ benami demat accounts were opened with the appellant with common addresses and more than 10000 accounts were opened on one single day. The appellant was under a duty to check and comply with the various norms. The obvious appears to have been overlooked. Is the action of the appellant innocent is the question. The appellant is clearly under a cloud and the truth can be known only after a detailed inquiry. The findings of the inquiry will either remove the appellant or the cloud.

(emphasis supplied) Thereafter, SAT, on an application filed by SEBI, extended the time limit upto the end of June 2007.

2. APPOINTMENT OF ENQUIRY OFFICER 2.1 In the facts and circumstances, SEBI appointed an Enquiry Officer vide orders dated May 25, 2006 and September 18, 2006 under regulation 5(1) of Securities and Exchange Board of India (Procedure for Holding Enquiry by Enquiry Officer and Imposing Penalty) Regulations, 2002 (hereinafter referred to as the Enquiry Regulations) to enquire into the alleged violations committed by Karvy Stock Broking Ltd. as a depository participant and stock broker and Karvy Computershare Pvt. Ltd as a Registrar to the Issue while dealing in the IPOs. The alleged violations committed by the said entities are as follows:

a. Karvy Stock Broking Ltd. as a depository participant

i) Section 12A of Securities and Exchange Board of India Act, 1992 (hereinafter referred to as the 'Act') ,

ii) Regulation 3 and 4 of Securities and Exchange Board of India (Prohibition of Fraudulent and Unfair Trade Practices Relating to Securities Market) Regulations, 2003 (hereinafter referred to as the FUTP Regulations)

iii) Regulations 19, 20A, 42, 43, 46 and 52 of Securities and Exchange Board of India (Depositories and Participants) Regulations 1996 (hereinafter referred to as DP Regulations) and

iv) Provisions of Securities and Exchange Board of India (Criteria for Fit and Proper Persons) Regulations 2004 (hereinafter referred to as Fit and Proper Regulations).

b. Karvy Stock Broking Ltd. as a Stock Broker

i) Regulation 3 and 4 of FUTP Regulations,

ii) Regulation 5, 7 and 15(1)(b) of Securities and Exchange Board of India (Stock Brokers and Sub - Brokers) Regulations, 1992 (hereinafter referred to as Broker Regulations),

iii) Provisions of the Fit and Proper Regulations and

iv) Provisions of Securities and Exchange Board of India (Disclosure and Investor Protection) Guidelines, 2000 (hereinafter referred to as DIP Guidelines).

c. Karvy Computer Share Pvt. Ltd as a Registrar to the Issue

i) Section 12A of the Act,

ii) Regulation 3 and 4 of the FUTP Regulations,

iii) Regulation 6 and 13 of Securities and Exchange Board of India (Registrars to an Issue and Share Transfer Agents) Regulations, 1993 (hereinafter referred to as RTI Regulations) and

iv) Provisions of Fit and Proper Regulations.

2.2 The Enquiry Officer submitted his reports dated March 30, 2007 (in the case of DP), March 15, 2007 (in the case of stock broker) and December 20, 2006 (in the case of RTI) and his recommendations in the respective enquiry reports are as follows:

i. to prohibit KSBL from acting as a depository participant for a period of 18 months.

ii. to suspend the certificate of registration of KSBL as a stock broker for a period of 3 months.

iii. to prohibit KCPL from acting as a registrar to an issue for a period of nine months.

The enquiry officer further clarified that the prohibition of 18 months recommended by him against the DP was in respect of taking up new assignment / fresh business as a depository participant. The Enquiry Officer also recommended to take into account the period of prohibition already undergone by the DP and the RTI, as per the interim orders of SEBI for the purpose of computing the period of prohibition recommended by him.

2.3 The Enquiry Officer in his report (in the case of DP) had inter alia considered various allegations leveled against the Karvy DP such as assisting the key operators in opening bank accounts, opening of large number of afferent accounts by the key operators, irregularities in opening the demat accounts, non verification of documents pertaining to Proof Of Identity (POI), Proof of Address (POA), fabrication of the documents, IPO funding to the key operators, financing after the closure of the issue, single consolidated refund cheques etc. In so far as the allegations pertaining to the fabrication of introduction letters, the Enquiry Officer had observed that on the basis on the circumstantial evidence alone it could not be conclusively held that the DP had fabricated the said documents. The Enquiry Officer had inter alia observed that the DP had actively facilitated, assisted and abetted many key operators in cornering the shares by facilitating opening of the accounts, facilitating the transfer of securities through pre printed DIS etc. The Enquiry Officer observed that the other entities belonging to the Karvy Group also played an important role in supplementing the action of DP and found that the DP had violated the provisions of Section 12 A of the SEBI Act, Regulation 3 and 4 of FUTP Regulation, 2003, Regulations 19, 42(2) and (3), 43, 46 and 52 of DP regulations 1996 and Clauses 3,9,12,16,19,20& 22 of the Code of Conduct specified in regulation 20A of the DP regulations.

2.4 The Enquiry Officer in his report (in the case of stock broker) had inter alia observed that the findings of the enquiry against KSBL as the depository participant might be considered as a part of the said report as the same is reflective on the various activities of KSBL as a stock broker. The Enquiry Officer further found that the Broker has violated the provisions of regulation 3 and 4(1) of the FUTP Regulations and Clauses A(1), A(3) and A(4) of Schedule II of the Broker Regulations and the provisions of DIP Guidelines.

2.5 The Enquiry Officer in his report dated December 20, 2006 (in the case of RTI) found that KCPL had violated the provisions of Section 12 A (a), (b), (c) of the Act and Regulations 3 and 4 (1) of FUTP Regulations and Clause 3 of the Code of Conduct specified under regulation 13 of the RTI Regulations.

3. SHOW CAUSE NOTICES AND REPLIES 3.1. a) In the case of KSBL DP While considering the Enquiry Report and other materials available on record (which were considered while passing interim orders dated January 12, 2006, April 27, 2006 and May 26, 2006 and also considered at the time of the hearing before the SAT), it was observed that the alleged violations committed by the DP prima facie called for a higher penalty than that recommended by the Enquiry Officer. Accordingly, a notice dated May 4, 2007 was issued to the DP to show cause as to why the period of prohibition as recommended by the Enquiry Officer should not be enhanced to 3 years.

3.2. The DP vide letter dated May 19, 2007 filed its reply to the said show cause notice. The submissions made by the DP in its aforesaid reply in brief are as follows:

i) The show cause notice was merely a formality to show the procedural fairness as it has been categorically concluded that the prohibition of 18 months should be enhanced to 3 years. The authority cannot consider any documents which were not considered by the Enquiry Officer. The authority can not travel beyond the Enquiry Report and what was considered therein.

a. On the basis of a rubber stamp on a sheet of paper containing 50 names and signatures, it cannot be said that the account holders have been introduced by it to the bank.

b. It had effected off market transfers from various accounts based on duly filled in Delivery Instructions Slips (DIS). In respect of the allegation pertaining to the opening of demat accounts using different combinations of surnames, the DP stated that the same were opened after obtaining the application forms submitted by the respective IPO sub brokers with documents relating to KYC requirements.

c. There was a clear division of operations between the DP and the other Karvy entities and that it had not acted in concert or aided and abetted the key operators in opening benami / fictitious demat accounts to corner shares in various IPOs as alleged. The DP stated that it was impracticable to expect the application which were received and bid on the last day were deposited in the bank on the same day itself by any syndicate / sub syndicate member.

d. It was not liable for any activities carried out by KCL other than the DP activities of KCL. The DP further stated that it had opened the demat accounts in the ordinary course of business after complying with the KYC requirements. In respect of opening of demat accounts earlier than the date of letter of introduction, the DP submitted that the same happened only in 27 cases as there were deficiencies in the original documents. The DP further clarified that the said deficiencies were identified at the time of the scrutiny and fresh set of documents were sought and the same were received and attached alongwith the application form.

e. KCL had financed Shri Purshottam Budhwani and his clients and the DP was aware that Shri Purshottam Budhwani and his clients were applying for the shares in IPO. However, the DP claimed that it was not aware that the said Shri Purshottam Budhwani was a key operator and that he was abusing the IPO process by making fictitious / benami applications. In respect of the issue of single consolidated refund cheques, the DP submitted that the same was a market practice.

f. The DP further stated "In retrospect it is realized that some of the IPO sub brokers who are the alleged key operators have exploited the loop holes in the system and have used Karvy DP as one of the DPs amongst others for carrying out their manipulative designs." The DP further claimed that it had not printed any other details apart from client id, serial number and name in the DIS. The DP further contended that it had not appointed any franchisee and that it had not delegated the activities of the DP to the sub brokers.

g. There was no electronic system to store and match the photographs of the demat applicants. The DP asserted that there was nothing wrong or illegal in the activation of demat accounts on the date of closure of issue. The DP also stated that it had not introduced the key operators to open the bank accounts as alleged.

h. The DP denied violating the provisions of Section 12A (a), (b) and (c) of SEBI Act and Regulations 3, 4 (1) and 4 (2) of the FUTP Regulations. It also denied of violating the provisions of DP Regulations. In respect of the quantum of penalty the DP relied upon the judgment of the Hon'ble Supreme Court in the matter of Ex-Naik Sardar Singh v. Union of India (1991) 3 SCC 212. Finally the DP has claimed that it had not committed any violations as alleged.

3.3. In the case of Stock Broker A show cause notice dated May 4, 2007 was also issued to the Broker asking it to show cause as to why action as recommended by the Enquiry Officer should not imposed against it.

The stock broker vide letter dated May 19, 2007 inter alia stated that simply because its employees had introduced the accounts and put the address or stamp of the company on the forms, it could not be concluded that the Broker was aware of the activities of the employees. The Broker also denied that it had facilitated the key operators to open many accounts as alleged. The Broker further stated that it had not violated the provisions of the Broker Regulations or the FUTP Regulations. The Broker denied that the Karvy group assisted the key operators in opening the bank account with BhOB. Further the Broker had reiterated the reply of the DP dated May 19, 2007. The Broker inter alia submitted that their employees had not introduced several bank accounts as alleged and added that the introduction of certain bank accounts by the employees were after fulfilling the KYC requirements.

In respect of 50 additional names attached to 37 bank accounts of Smt. Roopalben Panchal, the DP reiterated the stand taken by the DP. The Broker further stated that the alleged afferent accounts have been opened by IPO sub brokers. The Broker further stated that simply because the IPO sub brokers used to procure large number of applications along with others could not concluded that it was aware of the financing arrangement. The Broker added that it was not aware about the finances provided by KCL to Smt Roopalben Panchal and that she had made large number of applications. It also contended that the sale of shares by it on behalf of Shri Purshottam Budhwani and Shri Manoj Seskaria was in the ordinary course of business. The Broker asserted that it had not directly or indirectly employed any device, scheme or artifice to defraud in connection with issue or dealing in securities which were listed or proposed to be listed on a recognized stock exchange. Further it stated that it had not violated any of the provisions of law as alleged against it.

3.4. In the case of RTI A show cause notice dated December 20, 2006 was also issued to KCPL and asking it to show cause as to why the appropriate penalty including the penalty as recommended by the Enquiry Officer should not be imposed against it. An opportunity of hearing was granted to KCPL on January 4, 2007.

KCPL vide letter dated January 8, 2007 inter alia stated that there was no material to substantiate the allegation of knowledge in respect of the fictitious nature of the applications pertaining to the key operators made against it. In respect of the common management, KCPL stated that there was clear division of operations between it and the other Karvy entities. In respect of the single consolidated refund orders, KCPL stated that the same was established for the purpose of efficient investor servicing and administrative convenience. KCPL further stated that it had not issued any single consolidated refund order pertaining to the alleged benami/ fictitious applications made by Shri PUrshottam Bhuwani and Shri Manoj Seksaria. It asserted that in case of most IPO brokers such as KSBL, a co ordinator was appointed who was responsible of the effective servicing of the clients of such IPO brokers. KCPL further contended that as an RTI it had no role to play in the financing activity of KCL. In view of the above submissions KCPL requested SEBI to drop the proceedings initiated against it. KCBL further stated that single consolidated refund orders were issued by it on a uniform basis to all such institutions who sought to receive such a consolidated cheques such as ICICI Web Trade Ltd., IDBI Bank, Indian Overseas Bank etc. It is further stated that the said system was according to the specific instructions of the respective IPO applicants and the same was purely intended for facilitating the settlement process and was nearly administrative in nature. KCPL further denied of having any role in the alleged IPO irregularities and added that each of the companies forming part of Karvy Group are independent legal entities.

KCPL further added that the practice of issuance of single consolidated refund orders was undertaken by it since October 2004. It further added that the said practice was undertaken much prior to the KCL financing IPO applications, as alleged. KCPL further in respect of multiple applications stated that 487 applications (in the case of Yes Bank IPO) and 45 applications without beneficiary details were rejected. In the case of IDFC IPO, KCPL stated that 1526 application were rejected on the ground of being multiple applications and 56 applications were rejected for want of beneficiary details. KCPL further added that it was not aware of the fictitious nature of the application made by Roopalben Panchal group and in the said context KCPL stated that it had no role as an RTI to play in the financing activity of KCL.

4. HEARINGS 4.1. An opportunity of hearing was granted by SEBI to RTI on January 4, 2007 Shri R. Parthasarthy the Chairman of the Karvy Group made submissions on behalf of KCPL. As the nine months prohibition as recommended by the Enquiry Officer was already elapsed and taking into account the balance of consideration, vide order dated February 22, 2007 SEBI had lifted the prohibition imposed on KCPL vide interim order dated April 27, 2006. In the said order it was specified that the final findings as to the role of KCPL could be determined only when the final findings as to the role of KSBL was determined in the enquiry proceeding against it.

4.2. An opportunity of hearing was also granted to the DP and the Broker on May 22, 2007, May 25, 2007 and May 29, 2007. Shri Shyam Mehta, advocate represented the DP and the Broker and made submissions on behalf of them. Shri Vinay Chauhan, advocate, and Shri R Parthasarathy, were also present during the time of the hearing. Shri. Shyam Mehta made submissions on the lines of the reply of the DP and the Broker dated May 19, 2007.

4.3. Pursuant to the above hearing, the DP and the stock broker filed written submissions vide letters dated June 6, 2007 and June 8, 2007 respectively. The DP while reiterating its reply dated May 19, 2007 stated that it was not liable for the activities of the KCL as a DP which was at variance with the contentions of Karvy DP made in its reply dated May 19, 2007. The counsel further stated that the authority can not enhance the penalty what was recommended by the Enquiry Officer.

4.4. As the DP and the Broker are admittedly group companies and are functioning under the same management and control and also the fact that the issues involved in all the present proceedings (including that of RTI) are connected / similar and further since the responses of the said intermediaries are common/similar all the present proceedings (against DP, RTI and the Broker) are dealt with in a common order.

5. Issues for Consideration 5.1. Keeping in view the oral / written submissions of Karvy, various documents on record, the observations of the Hon'ble Securities Appellate Tribunal and the findings of the Enquiry Officer, the following issues remain for consideration:

• Whether it is a simple case of failure to exercise due diligence or whether Karvy DP had gone beyond in crafting a collusive game-plan with the key operators for the purpose of cornering IPO shares?

• Whether, the other entities belonging to the Karvy group, specificially Karvy Consultants Ltd. (NBFC and formerly DP), Karvy Stock Broking Ltd. (Broker) and Karvy Computershare P Ltd. (RTI) had colluded with the DP in executing the gameplan for cornering IPO shares?

• Whether, based on the material available on record, the findings of Enquiry Officer be accepted? and • Whether, based on material available on record, the penalty recommended by the Enquiry Officer is appropriate or whether it calls for a higher penalty?

5.2. Before proceeding with the issues for consideration, I note that the existence of fictitious afferent accounts as opened with Karvy DP are not in dispute as would be evident from the Hon'ble Securities Appelate Tribunal Order dated January 8, 2007. Karvy has also admitted the same in the complaint filed against 4 sub- brokers namely, Grace Consultancy, 402-403, Shashwat, Opp: Gujarat College,Ellisbridge, Ahmedabad - 380006 (Rep by its Proprietor Deepak Panchal) (Accused no.1), Arth Realty Pvt. Ltd, 803, Abhijeet-1, Mithakali Circle, Navrangpura, Ahmedabad - 380009 (Rep by its Director Parag P Jhaveri) (Accused no.2), Purshotham Budwani S/o. Late Ghanshyamdas Budwani Age: 41 years, R/o. B/2, Himalay Housing Co-op Soc, Asalfa, Ghatkopar (W) Mumbai 84 (Accused no.3) and Manoj G Sakseria S/o. Gokulchand Seksana, R/o. 33, Maheshwan Niketan, Peddar Road, Mumbai 26 (Accused no.4). In the memorandum of the complaint, Karvy DP has, inter alia, stated as below:

5.3. "The Complainant herein states and submits that the Company as a Depository Participant opens accounts through its branches and through its associates across the country. For the past 2/3 years, due to the strong market sentiments, number of Companies have offered their shares to the Public. For applying for shares offered by a company, having a depository account is a must which is opened with Depository Participants like Karvy Stock Broking Ltd. The company accepts application forms for opening depository account from business Associates also. For opening a depository account, the applicant has to submit along with application form in the prescribed format duly filled in, various supporting documents like proof of address and identity. The business associates generally collect the applications from various applicants whom they service and submit the same to our Branches for opening the depository account.

5.4. These associates are either provided special rates for opening depository accounts for their clients or are paid remuneration on each account for processing the application. These Business Associates, have collected applications for opening depository accounts from various applicants. Since they had direct contact with the applicants, they are required to verify credentials of the applicant, including verification of documents like proof of address, identity proof, Bank account details etc. of the person who intends to open the account after filling up the prescribed form as per the norms of SEBI and submit the same to our branches. With regard to the accounts under reference, these associates or their friends / relatives have also acted as introducer for each of the accounts.

5.5. The Complainant states that they believed that all the accounts forwarded by the associates are true and correct and are eligible to open the depository accounts. The accused have fraudulently opened fictitious accounts to defraud and cheat the Company. The Complainant herein states that consequent to the order issued by Securities and Exchange Board of India (sebi), National Securities Depository Limited (NSDL) had, vide their letter dated 17th December 2005, directed the Company as Depository Participant to verify the cases. On such verification, the Company came to know that the associates have committed breach of trust with the intention to cheat genuine investor. These associates on demand by the company have failed to produce their customers for identification which has lead the company to suspect that they have opened accounts of non existing persons and got lot of shares allotted to them. Thus they have cheated the genuine investors, Company and committed criminal breach of trust as the Company totally depended on the information and scrutiny of the sub-brokers.

5.6. The Complainant submits that the accused 1 to 4 herein have opened depository participant accounts with ulterior motive and malafied intention to cheat genuine investors knowing fully aware of the facts and committed criminal breach of trust as such the accused committed offence punishable under Section 406 and 420 of IPC." (emphasis supplied). Any discussion on the case would be incomplete without a proper understanding of the processes involved in IPOs. Accordingly, I proceed to deal with the same.

6. IPO Process 6.1. As per information obtained from NSE the IPO process involves the following:

1. The Book Running Lead Manager (BRLM) files the Draft Offer Document (DOD) with SEBI and the stock exchange where the Company proposes to list its securities for their comments/approval.

2. The stock exchange checks as to whether the applicant company is eligible as per the listing criteria for listing on the stock exchange pursuant to its Initial Public Offering.

3. Further, the stock exchange also checks details on the background of the promoters, disclosures made by the Company in the Draft Offer Document including the risk factors mentioned therein etc.

4. The stock exchange thereafter provides an in-principle approval for enabling the company to mention in the offer document that the shares after the issue are proposed to be listed on the stock exchange named therein.

5. After the in principle approval of the stock exchange is issued, and subject to approvals they have to obtain from SEBI and other authorities, if any, the Issuer company can make the public issue.

6.2. Book Building Book building is an electronic mechanism for collection of orders through the IPO infrastructure of the Exchanges. The members who are eligible for using the IPO system or who are entitled to enter the bids are decided by the BRLMs to the issue. (These stock brokers selected by the BRLMs for accepting bids are called syndicate members).

The bid data collected through the book building process is provided by the stock exchanges to the Book Running Lead Managers who in-turn forwards the same to the Registrars and Transfer Agent concerned. The physical applications are collected by the Registrars from the banks where the applications and cheques are deposited. The applications are processed by the Registrars and a meeting of the Book Running Lead Managers, Registrars and the Issuer company is held to decide the basis of allotment. The minutes of this meeting which inter alia contain details regarding how the basis has been drawn, total subscription received for the issue, technical rejections, total number of shares to be considered for allotment etc., is submitted to the stock exchanges. To determine the successful allotees, the draw of lots is conducted by the Designated Stock Exchange (draw of lots are done by a SEBI approved Public Representative on the Board of the Designated Stock Exchange) and the basis of allotment is finalised. As such, the stock exchanges do not process or scrutinise the physical application forms or the unique details of the applicants such as addresses, PAN number etc., during the IPO process and hence will not be in a position to ascertain multiple or fictitious applications.

On completion of the basis of allotment, the Registrars for the IPO carries out the allotment process by making allotment in accordance with the basis of allotment and then uploading the file containing the details of allotment to the depository which in turn credits the shares to the applicants' beneficiary accounts. The Issuer company will then submit a certificate from a practicing Chartered Accountant or a Company Secretary confirming that the allotment has been done by the Registrars as per the basis approved by the stock exchange. After the completion of the credit of shares, the depositories issue a certificate indicating that the shares as detailed by the Registrars have been credited to the beneficiary accounts to the Issuer which is in turn submitted to the stock exchanges by the Book Running Lead Manager / Issuer company. A confirmation of the dispatch of refund orders is submitted to the stock exchanges by the Registrars.

6.3. Stages in a Book Built Issue The various stages in the book built issue can be broadly described as under:

? In a Book Built Issue, the applicant submits his IPO application along with the cheque / DD to the syndicate member / sub syndicate member for entering bids in the Bid Book.

? It is mandatory for the applicant to indicate his demat account particulars in the application form. Thus it is mandatory for an IPO applicant to have a demat account while making application in an IPO. Further, for the purpose of refund of application money, the bank details of the applicant are downloaded by the RTI from the depository system and therefore it is mandatory for the demat account holder / IPO applicant to indicate his bank details in the depository account. Therefore, opening of bank account and Demat account can be considered as the first stage in making application in book built issue.

? Upon receipt of IPO application along with the Cheque / DD, the syndicate / sub syndicate member verifies the same and thereafter the syndicate / sub syndicate member enters the bid in the BSE / NSE system and forwards the physical applications along with the cheques / DDs to the collecting bank.

? The collecting bank separates the cheques / DDs from the application forms and sends the cheques / DDs for collection and simultaneously forwards the IPO application to the registrar to issue for preparation of application master.

? Upon realization of cheques, Banker to the issue (i.e. Collecting Bank) submits the details of the cheques realized along with bank serial number which forms the basis for the RTI to reject application where cheques have not been realized.

? The master database is prepared by Registrar to an Issue for the purpose of working out the basis of allotment after weeding out invalid and multiple applications as per applicable criteria.

? The Registrar to an Issue, the Post Issue Lead Manager, representative of stock exchange and an official of the issuer company in a meeting decide the basis of allotment and finalise the ratio of allotment.

? Based on the approved basis of allotment, registrar to an issue makes allotment to eligible investors and through a process of corporate action, electronic allotment is made to the demat account of the allottee through depository.

? Concurrently, the Confirmation of Allotment Note (CAN) is dispatched along with the refund order or refund details (in case of direct credit to the bank account).

6.4. The above process is completed within 15 days from the date of closure of the IPO. Thus, it can be seen from the above process that essential steps for applying in book built issue are broadly as under:

1. Opening BANK ACCOUNT and DEMAT ACCOUNT

2. Arranging IPO FINANCE

3. Submission of application along with payment instrument (cheque / DD) to syndicate member and BIDDING

4. Receipt of ALLOTMENT / REFUND ORDER 6.5. Karvy group's presence in the entire chain of IPO process I note that on the basis of data on record, Karvy group entities were ubiquitously present in the entire gamut of the IPO process running from introducing bank accounts, opening of dematerialized accounts, arranging IPO finance, bidding of applications, making allotment, issuing refund, making off-market transfers (DIS) and sale of IPO shares on the stock exchanges. The role of Karvy group entities at each stage of the process has been examined for uncovering Karvy's role at every stage and to ascertain overall control beginning from opening of bank and dematerialized accounts till making refund and off- market transfer of IPO shares.

The group's presence in the entire IPO process is schematically depicted as under:

7. Applicable Guidelines 7.1. While opening dematerialized accounts, the DP has to comply with the Know Your Customer (KYC) norms laid down by SEBI through circulars dated August 4, 2000 and August 24, 2004. SEBI vide circular dated SMDRP/Policy/CIR- 36/2000 dated August 4, 2000, has prescribed detailed procedure to be followed by all depository participants at the time of opening beneficiary account. The said circular prescribed the documents which can be accepted by the DPs for the purpose of proof of identity and proof of address. In respect of proof of identity the documents prescribed are PAN Id, Voter Id, Ration Card, Passport etc and for proof of address the documents prescribed are Telephone Bill, Electricity bill etc. Subsequently, vide circular ref: MRD/DoP/Dep/Cir-29/2004 dated August 24, 2004 SEBI stipulated that an identity card / document issued by Scheduled Commercial Banks containing the applicant's photo / address may be accepted as POI and POA. The circular further clarified that "the aforesaid documents are the minimum requirement for opening a BO Account. The Depository Participants (DPs) must verify the copy of the document with the original before accepting the same as valid. While opening a BO Account, the DPs are required to exercise due diligence while establishing the identity of the person to ensure the safety and integrity of the depository system."

7.2. In terms of Clause 16 of Regulation 20A of SEBI (Depositories and Participants) Regulations, 1996, "A Participant shall follow the Maker-Checker concept in all of its activities to ensure the accuracy of the data and as a mechanism to check unauthorized transaction."

7.3. While opening bank accounts, the banks have to comply with the applicable KYC norms laid down by RBI and also comply with their internal guidelines in this regard. While providing IPO finance, Banks and NBFCs have to comply with the relevant RBI guidelines including KYC norms.

7.4. The process of public issue is governed by the SEBI (Disclosure and Investor Protection) Guidelines, 2000. As regards, bidding of application forms in the retail category, in terms of Guideline 11.3.1 Clause xvii (a), "The broker may collect an amount to the extent of 100% of the application money as marging money from the clients / investors before he places an order on their behalf.... "

8. For the purpose of this order, the abbreviations occurring in various places in the order would mean: Karvy: Karvy Group including Karvy Stock Broking Limited ( KSBL), Karvy Consulatnts Limited ( KCL), Karvy Computershare Private Limited (KCPL), Karvy Securities Limited (KSL) and Karvy Investor Services Limited ( KISL).

8.1. The DP in its reply dated May 19, 2007 contended that, it was not liable for the violations committed by KCL. In support of its contention, the DP relied upon the judgment of the Hon'ble High Court of Bombay in the matter of SEBI Vs. SKDC Consultants Ltd. However, at the time of the hearing, the counsel for the DP had not pressed the said contention and further submitted that the DP would be responsible for the acts done by KCL in its capacity as the DP and not as NBFC. The said submission has been further strengthened by the following statement made by the DP in its reply dated May 19, 2007; "In this regard it is submitted that for the activities carried out by KCL, other than the DP activities, the company cannot be held liable for violations committed by KCL, if any". However, I note that in its written submission dated June 6, 2007, the DP further contended that it is not liable for the alleged violations of KCL as a DP. KSBL further stated that it only took over the business obligations of KCL and not the proceedings in connection with any alleged violation committed by KCL.

8.2. In this context, I note that SEBI had approved the transfer of depository business of KCL to KSBL, inter alia pursuant to the request made by KSBL through NSDL. I observe that NSDL vide letter dated June 16, 2005 informed SEBI about the intention of KCL to transfer its depository business to KSBL and further stated that the infrastructure of KCL would be used by KSBL, pursuant to the transfer arrangement ( between KCL and KSBL). In its letter cited above, NSDL had also enclosed the application (Form 'E') of KSBL for the grant of certificate of registration as a DP. In the said application, KSBL inter alia stated that KCL was one of its group companies and further undertaken to comply with the provisions of the Act, the DP Regulations and such other guidelines/ instructions which may be announced by SEBI from time to time. I also note that KSBL vide its letter dated April 30, 2005 had inter alia given the following undertaking to NSDL. "On completion of the transfer, all assets, liabilities, rights and obligations pertaining to DP business will transfer from KCL to KSBL."

8.3. In the aforesaid application (Form E), KSBL had inter alia given the details of the directors and the share holding pattern of KCL vis a vis KSBL. The details of such information given by KSBL are given below:

a) Details of directors Name of the intermediary Name of the Directors KCL Mr.C. Parthasarathy (Chairman) Mr. M. Yugandhar (Managing Director) Mr. M.S.Ramakrishna Mr. Prasad V. Potluri KSBL Mr.C. Parthasarathy (Chairman and Managing Director) Mr. M. Yugandhar (Managing Director) Mr. M.S.Ramakrishna

-

b) Shareholding Pattern Sr. No. Name of the shareholder Number of shares %age of total capital KCL KSBL KCL KSBL 1 C. Parthasarathy 69,539 259304 1.64 19.42 2 M. Yugandhar 4,09,998 188728 9.69 14.13 3 Compar Investments P. Ltd.

11,24,304 343310 26.58 25.71 4 Adhiraj Parthasarathy 68,000 2366 1.61 0.18 5 Rajat Parthasarathy 68,000 2366 1.61   0.18 6 M. Rajini 5,27,419 35238 12.47 2.64 7 M.S.Ramakrishna (HUF) 95,640 223966 2.26 16.77 8 C. Parthasarathy -HUF 20,000 666 0.47 0.49 9 Kokila Parthasarathy 64,000 100 1.51 0.007   Total ( sr. no. 1 to 9) *

57. 84% 79.527% 10 M. Gangadhara Rao 45,280

-

1.07

-

11

M. S. Ramakrishna 4,19,197

-

9.91

-

12

M. Spandana 97,000

-

2.30

-

13

M. Ahalya 84,120

-

1.99

-

14

M. Rushyanth 1,33,280

-

3.15

-

15

M. Meena 61,600

-

1.46

-

16

M Susheela Dei 19,540

-

0.46

-

17

Prasad V Potluri 9,23,078

-

21.82

-

18

Karvy Consultants Limited

-

230480

-

17.26 19 C.R. Rajagopalan

-

100

-

0.007 20 Adhirajat Inv. Pvt. Ltd.

-

48704

-

3.65 21 Karvy Investor Services Ltd.

-

300000

-

-

*Common shareholders 8.4. From the above table it can be seen that KCL and KSBL were having certain common directors and shareholders at the time of the transfer of business undertaking. Further, the shareholders specified at serial nos. 1 to 9 were common to both KCL and KSBL and they collectively hold 57% and 79% of the total capital of KCL and KSBL respectively. Therefore, even at the time of transfer of business undertaking of KCL to KSBL, both the entities were administered and controlled by the same management. In this context, I also note the reply of the DP to the show cause notice dated May 4, 2007, wherein it was stated that both KCL and KSBL were group companies. In view of the common control and management, KSBL is the alter ego of KCL. In any event KSBL is liable for all obligations of KCL as per the agreement with NSDL. At the time of hearing, the advocate appearing for DP did not press this point, while conceding that the liability of KSBL, in so far as it relates to the transfer of DP business from KCL would be restricted to that arising from DP business. In that view of the matter, the subsequent plea in the written submissions denying such liability besides citing the decision of the Hon'ble Bombay High Court in support smacks not only of a departure from the stand at the time of hearing but also betokens a desperate attempt to somehow wriggle out of the liability staring in the face. Such contradiction in the pleas raised by the DP seriously impairs the creditability of their defense.

8.5. Further, the DP in support of its contention relied upon the judgment of the Hon'ble Court of Bombay in the matter of SEBI vs. SKDC Consultants Ltd. I note that the facts of the said case and the present case are different and can not be compared on equal footing. In the said case, SKDC Consultants Ltd. which was incorporated in the year 1998 entered into a Memorandum of Understanding with the proprietrix of Shree Krishna Data Center and it had subsequently took over the business of Shree Krishna Data Center as a going concern with effect from April 1, 1998. Subsequently, in the wake of certain violations relating to public issue of shares which took place in the month of November / December 1995, SEBI ordered adjudication proceedings against SKDC consultants Ltd. and the adjudicating officer imposed a penalty against SKDC Consultants Ltd. The said order of the adjudicating officer was set aside by the SAT inter alia on the gound that SKDC Consultants Ltd. was a distinct legal personality from Shree Krishna Data Center. In the said case, the said Shree Krishna Data Center was owned by the sole proprietrix and she was only one of the seven subscribers to the Memorandum of Association and only one of the first directors out of the four directors of SKDC Consultants Ltd. According to SAT, the same was not sufficient to hold that Shree Krishna Data Center and SKDC Consultants Ltd. were one and the same entity for all purposes. The above proposition of SAT was upheld by the Hon'ble High Court of Bombay in the matter SEBI vs. SKDC Consultants Ltd. However, in the present case, both the entities [transferor (KCL) and the transferee (KSBL)] were under the same management and control and continued to be so at the time transfer of business undertaking. As per the shareholding pattern of both the entities (as given by KSBL), the common shareholders were holding 57% and 79% of the total capital of KCL and KSBL respectively. In such circumstances, the DP can not contend that KSBL is not liable for the violations of KCL. The presence of common directors and shareholders (with majority of the shareholding) serves to demonstrate unity of control and in that view the cited case is totally irrelevant so far as the facts of the instant case are concerned.

8.6. In view of the above coupled with the undertaking given by KSBL to NSDL to takeover inter alia the rights and obligations pertaining to Depository business of KCL, I am unable to accept the contention of the DP that SEBI cannot take action against the DP for the violations of KCL and accordingly the same is rejected.

8.7. I further note that, such a plea does not brook countenance, as any entity arraigned for market misfeasance could seek easy exculpation and avoid punishment through such subterfuges by transferring the business to another group entity.

8.8. In addition to the above, I note that the DP had not taken the aforesaid plea either before the Hon'ble High Court of Andhra Pradesh or before the SAT wherein it had challenged the interim order of SEBI. Therefore, the said contention of the DP which even otherwise is not acceptable cannot be entertained at this belated stage.

8.9. In view of the fact that both the intermediaries were under the same management and the business undertaking of KCL was transferred to KSBL as per their request, I am unable to accept the contention of DP that it is not laible for the alleged violations committed by KCL.

8.10. The DP has further taken an objection that SEBI (Chairman or the Whole Time Member) can not consider any fresh allegations (which were not considered by the Enquiry Officer) based on new materials. It has been further contended that SEBI is duty bound to pass order based on the findings in the Enquiry Report. In this context, the DP has claimed that the Authority can not travel beyond the Enquiry Report and what was considered therein. The DP has further contended that the show cause notice was merely a formality to show the procedural fairness as the Whole Time Member has categorically concluded that the prohibition of 18 months should be enhanced to 3 years. The DP clarified that the Authority had already prejudged the matter and therefore there was no scope for any effective representation. The DP further asserted that the suo moto finding of violation of law and quantification of penalty even before the hearing the defense was in violation of principles of natural justice. In addition to the above, the DP has contended that the authority can not enhance the penalty which was recommended by the Enquiry Officer.

8.11. The DP contended that SEBI could not travel beyond the Enquiry Report in the context of 37 bank account opening forms of Smt. Roopalben Panchal with Indian Overseas Bank, Thaltej Branch, Ahmedabad. I note that in the show cause notice dated May 4, 2007 it has been inter alia mentioned "Your kind attention is drawn to pages 54-55 (paras 11.3.3 and 11.3.4) of the enquiry report regarding the introduction of 37 savings bank accounts of Roopal Panchal to the Indian Overseas Bank (IOB), Thaltej Branch, Ahmedabad. IOB vide its letter dated March 4, 2006 had enclosed copies of the sample bank account opening forms of Roopal Panchal. Out of these, copies of the bank account opening forms in respect of account numbers 12004, 12140, 12149 and 12150 are enclosed as Annexure- 1. Various observations regarding the said bank accounts and the manner in which the demat accounts in names of persons figuring in the last attached with each such account were opened are enclosed as Annexure-2".

8.12. On a perusal of the said show cause notice, it can be seen that no fresh allegations are leveled against the DP and the observation mentioned therein was only an extension of the findings of the Enquiry Officer (para 11.3.3 and 11.3.4 of the Enquiry Report). Further the Enquiry Officer in his report had discussed certain instances (9 accounts) out of the said 37 bank accounts. The Enquiry Officer had also mentioned the letter dated March 4, 2006 received from the Indian Overseas Bank, Thaltej Branch, Ahmedabad. The contention that the said letter suffers from factual inconsistencies is not correct in view of the following discussion.

8.13. I note that the above letter listed out (by way of annexure) 37 savings account nos. and the names of the said savings accounts. The said letter specified that to the said 37 bank accounts which were introduced by the DP, 50 additional names were added and the said names were attached in a separate sheet with the respective account opening form. Therefore, the contention of the DP that there were inconsistencies/ contradictions in the letter of IOB dated March 04, 2006 can not be accepted. The Enquiry Officer had given his findings on the said issues in paras 11.3.3 and 11.3.4 of the Enquiry Report. The Enquiry Officer had discussed some of the accounts out of the said 37 accounts on an illustrative basis. In a case of this magnitude, it would be well neigh impossible in an order to deal with all the afferent accounts (about 50, 000 acccounts) with all their devious features. Accordingly, typical samples are taken for detailed examination. The same would not mean that the evidences available in other afferent accounts are shut out. As the modus of operandi in all the above 37 bank accounts were similar, the Enquiry Officer considered it appropriate to discuss about certain specific instances. The observations of the Enquiry Officer in respect of certain bank accounts opening forms (by way of illustration) can not by any stretch of imagination would lead to a conclusion that other bank accounts are out side the purview of the enquiry proceedings against the DP.

8.14. In addition to the above, the DP in its appeal memorandum (Appeal No. 92 of 2006) inter alia stated ".... The Respondent has not provided any proof for the introduction as stated in the impugned Order at para 6.35. The Appellant will be in a position to explain only on receipt of the documents relied upon by the Respondent to arrive at the said observation. It is stated tat the Appellant had not introduced the said 50 clients to IOB Thaltej. The Appellant had only certified, pursuant to the request of IPO sub broker, that the said 50 clients had demat account with the Appellant. It is submitted that all the said 50 clients had, as per Appellant's records, bank accounts with BhOB. Therefore the certification given by the Appellant was for existence of demat account as sought to be suggested." The aforesaid ground taken by the DP before SAT was nothing but an admission in respect of its role in certifying the additional 50 names in the said 37 accounts. Further, KSBL in its capacity as a Broker in the reply dated May 19, 2007 stated "simply because its employees had introduced the accounts and perhaps put the address or stamp of the company on the forms, it cannot be concluded that the company was aware of the activities of the employees." The said submission would fortify the fact that Karvy actively participated in the introduction of bank accounts of Smt Roopalben Panchal and the other additional 50 names who were nothing but fictitious. Such contradiction in the pleas raised by Karvy Group (before SAT and before SEBI) seriously impairs the credibility of their defence.

8.15. Further, SEBI in its orders dated April 27, 2006 and May 26, 2006, prima facie found that the DP had introduced the bank accounts of certain groups and facilitated the entire process starting from making IPO applications for them after collecting pay orders from the bank, arranging finance for them till collecting and distributing their refund orders. Therefore, the reference of 37 bank accounts with additional 50 names in the show cause notice was based on the documents which were already considered at the time of passing the orders of SEBI dated April 27, 2006 and May 26, 2006, documents which were provided to the Karvy Group at the time of the appeal before SAT and in the present enquiry proceedings. Therefore, the contention of the DP that the documents pertaining to 50 additional names attached to the Bank account introduction form of Smt Roopalben Panchal were not considered by the Enquiry Officer is not correct and the same is rejected.

8.16. Further, I note that regulation 13 (2) of the SEBI (Procedure for Holding Enquiry by Enquiry Officer and Imposing Penalty) Regulations, 2002 empowers the Chairman or the Member, as the case may be to consider the Enquiry Report and to issue a show cause notice, as to why action as it considers appropriate should not be taken. Thus, the powers of the Chairman/ Member while considering the Enquiry Report is wide and he can take any action as it considers appropriate. Further, in terms of regulation 13(4) of the Enquiry Regulations, the Chairman or Member, upon the receipt of enquiry report is empowered to "pass such order as he may deem fit" after considering the reply filed by the intermediary concerned. The expression "pass such order as he may deem fit" has to be interpreted broadly and the power of SEBI is not restricted to imposing penalty as recommended by the Enquiry Officer. If the competent authority has the jurisdiction to pass any order in reference to a specific case called for by it as it thinks fit, obviously it can come to a different conclusion/ finding from the one to which the Enquiry Officer had arrived, on the same set of facts. Obviously the competent authority can also impose a different penalty from that was recommended by the Enquiry Officer. It is settled that the question of imposing punishment can only arise after enquiry is made and the report of the Enquiry Officer is received. The competent authority may agree with the report or may differ, either wholly or partially, from the conclusions recorded in the report. i.e neither the conclusion on the evidence nor the punishment which the enquiring authority may regard as appropriate is binding upon the punishing authority.

8.17. Further, the contention of the DP that the authority has concluded to enhance the prohibition from 18 months to 3 years is also not acceptable. The proposal to enhance the prohibition from 18 months to 3 years (as mentioned in the show cause notice) was only a prima facie/tentative observation after considering the Enquiry Report and the materials available on record. Further, the penalty was not enhanced by SEBI and the object of the show cause notice dated May 04, 2007 was to give an opportunity to the DP to submit its case on the proposed enhancement in penalty. The DP was also granted an opportunity of hearing on various dates. The said opportunities were provided by SEBI to the DP towards the compliance of the principles of natural justice, so that the DP could make its submission/explanation, if any, against the proposal to enhance the penalty. The penalty has only been indicative and not finally determined and therefore, no prejudice has been caused to the DP.

8.18. Further, the contention of the DP that, if the Whole Time Member had categorically concluded that the prohibition of 18 months should be enhanced to 3 years, then the show cause notice was merely a formality to show the procedural fairness is not acceptable. I wish to add that the penalty was not increased vide the show cause notice and the proposal to enhance the penalty was only a tentative decision. Communicating the tentative decision in no way would cause prejudice to the party. On the other hand, if at all the disciplinary authority gave detailed tentative decision before seeking explanation from the appellants, it would enable the party to give an effective representation and the principles of natural justice are thus fully complied with.

8.19. As discussed above, the findings of the Enquiry Officer are only his opinion on the materials, but such findings are not binding on the decision making authority and the latter can come to its own conclusion. That apart, the issuance of show cause notice provides an opportunity to submit its reply in relation to the proposed enhanced penalty and no prejudice is caused by the same. In view of the above, I am unable to accept the above contention of the DP.

9. Consideration of Factual Issues 9.1. In order to consider the issues as above, I now propose to examine the role of Karvy group companies in the entire process of IPO beginning with the opening of afferent dematerialized accounts, introduction of bank accounts of key operators, afferent accounts and the addition of fictitious / benami names to the bank accounts for availing IPO finance, providing of IPO finance to the fictitious / benami entities through the medium of key operators, bidding of the application forms of fictitious / benami entities without the corresponding payment (100% IPO margin), issue of consolidated refund cheques, issue of directions for appropriation of refund money and execution of synchronized off-market transfers including issue and processing of DIS.

9.2. The manner of opening bank accounts and dematerialized accounts clearly demonstrates Karvy's control and their knowledge of the fictitious / benami nature of these accounts. In effect, Karvy was dealing only with the key operators and not with anyone else. The IPO process, IPO financing, RTGS transfer to the escrow account, issuance of consolidated refund order and issues relating to DIS, the discussion of which follow hereinunder, further strengthen the above finding with tell tale strands of Karvy's control with full knowledge at each and every stage of IPO process. They constitute additional material evidences to confirm the obvious as arising from the discussion relating to bank accounts and demat accounts elsewhere in the order.

9.3. Even a single instance of incontrovertible data establishing Karvy's active involvement, anywhere in the chain, in abusing the allotment process is good enough and in that view, the overwhelming body of additional material evidences only serves to exacerbate the gravity of such misconduct.

SCHEMATIC REPRESENTATION OF GAMUT OF KARVY'S OPERATIONS 9.4. Introduction of Bank Accounts by Karvy I note that during June 2003 when there were public issues of many premier companies such as Maruti Udyog Ltd, UCO Bank, Vijaya Bank etc., Karvy had presented to BhOB an idea paper and a process flow. As per the process flow, the IPO applications would be filled in by the investor and a cheque/DD in favour of the Bank towards the margin amount shall be deposited. The investor would need to open the Demat account with Karvy who would place a lien on the shares deposited into the investor's account until the investor clears the loan with the Bank. The client would deposit the payment instrument and bid form with the Bank along with the account opening document and documents for the loan. The Bank would ensure that the Savings Bank (SB) account opened by the Bank is mentioned in the relevant column in the bid form as the Bank account to which the refund is to be sent. The Bank would issue Pay order for the amount of the application by debiting loan account and margin money of the respective applicants. If the investor is not allotted shares against the IPO application, refunds are made to investor by the registrar through the Bank and the refund order credited to the account, after liquidating the loan. In case of allotment, the investor is required to bring in the required amount if there is shortfall and fulfill the obligation with the Bank along with the interest after which the lien is released by the Bank and informed to the DP for release of Bank's lien on the demat account.

9.5. A perusal of the process flow envisaged for IPO funding as spelt out by Karvy shows that there was a specific assuring clause to the effect that there were no chances for cases such as benami applications, multiple applications, fraudulent investors etc. thereby providing comfort to the bank.

9.6. Pursuant to the arrangement, it is seen that Karvy had introduced numerous bank account holders to BhOB, Ahmedabad branch. In what is seen as first of such bank accounts introduced by Karvy to BhOB Ahmedabad, there is a set of account with numbers starting with '50795'. The observations on these bank accounts with BhOB Ahmedabad branch beginning with the number '50795' is given below:

9.7. Introduction of bank account no. 50795 with BhOB Ahmedabad by Karvy It was observed that following bank accounts starting with 50795 were held in the name of Devangi Dipak Panchal as first holder and certified copies of the following bank accounts were submitted. These accounts were introduced by Karvy Securities Ltd / Karvy Investor Services Ltd. These were opened for the purpose of availing finance in the IPO of Maruti Udyog Ltd on June 17, 2003 and closed on October 27, 2003:

1. 50795/1 to 50795/2

2. 50795/5

3. 50795/14,

4. 50795/16

5. 50795/18 to 50795/24

6. 50795/26 to 50795/60

7. 50795/ 62 to 50795/ 64

8. 50795/ 67 to 50795/127

9. 50795/130 to 50795/131

10. 50795/137 to 50795/150

11. 50795/152 to 50795/153 9.8. On a random selection basis, the bank account opening form pertaining to SB account no 50795 / 081 was examined. It is seen that this account was initially opened in the name of Devangi D Panchal on the introduction of Karvy Securities Ltd. Further, it is observed that the names of Shah Manjula K and Pritesh K Shah were added to this account on the introduction of Karvy Investors Services Ltd. Similarly, a perusal of the bank account opening forms of SB account no 50795 / 082 revealed that this account was initially opened in the name of Devangi D Panchal on the introduction of Karvy Securities Ltd. Further, it is observed that the names of Pravin K Shah and Bhagwanti P Shah were added to this account on the introduction of Karvy Investors Services Ltd. Similar pattern of addition of names to the existing accounts is observed with regard to many of the above accounts. This indicates that as early as June 2003 Karvy group was indulging in the practice of introducing names at will which were added to the bank accounts of the key operators. The same script continues later, albeit on a larger canvass.

9.9. It was further observed that the above banks accounts were used for opening afferent demat accounts with Karvy DP in the month of June 2003. The details of such afferent demat accounts are mentioned in the table below.

Sr. No. Demat Client ID Name of client Address Bank acct no Bank Date of opening demat account Date of closing demat account

1. 12312738 PANCHAL DIPAK J 402-403 SHASHWAT 50795/60 BHOB, Ahmedabad 6/27/2003 11/15/2005

2. 12312746 PANCHAL DINESH J 402-403 SHASHWAT 50795/60 BHOB, Ahmedabad 6/27/2003 11/15/2005

3. 12312754 PANCHAL DILIP J 402-403 SHASHWAT 50795/60 BHOB, Ahmedabad 6/27/2003 11/15/2005

4. 12312762 PANCHAL DEVANGI D 402-403 SHASHWAT 50795/77 BHOB, Ahmedabad 6/27/2003 11/15/2005

5. 12312779 PANCHAL ROOPA D 402-403 SHASHWAT 50795/60 BHOB, Ahmedabad 6/27/2003 11/15/2005

6. 12312787 PANCHAL DHRUV D 402-403 SHASHWAT 50795/61 BHOB, Ahmedabad 6/27/2003 11/15/2005

7. 12312795 PANCHAL DEVAL D 402-403 SHASHWAT 50795/61 BHOB, Ahmedabad 6/27/2003 11/15/2005

8. 12312809 PANCHAL DEVESH D 402-403 SHASHWAT 50795/61 BHOB, Ahmedabad 6/27/2003 11/15/2005

9. 12312818 PANCHAL D 402-403 SHASHWAT 50795/62 BHOB, Ahmedabad 6/27/2003 11/15/2005

10. 12312826 PANCHAL MOXI D 402-403 SHASHWAT 50795/67 BHOB, Ahmedabad 6/27/2003 11/15/2005

11. 12312834 PANCHAL RANCHHODLAL N 402-403 SHASHWAT 50795/67 BHOB, Ahmedabad 6/27/2003 11/15/2005

12. 12312842 PAUCHAL PRAMILABEN R 402-403 SHASHWAT 50795/63 BHOB, Ahmedabad 6/27/2003 11/15/2005

13. 12312859 PANCHAL NARMADABEN M 402-403 SHASHWAT 50795/63 BHOB, Ahmedabad 6/27/2003 11/15/2005

14. 12312867 PANCHAL BHARGAV R 402-403 SHASHWAT 50795/63 BHOB, Ahmedabad 6/27/2003 11/15/2005

15. 12312875 PANCHAL HIMA B 402-403 SHASHWAT 50795/64 BHOB, Ahmedabad 6/27/2003 11/15/2005

16. 12312883 PANCHAL MALAV B 402-403 SHASHWAT 50795/64 BHOB, Ahmedabad 6/27/2003 11/15/2005

17. 12312890 PANCHAL SRINAND B 402-403 SHASHWAT 50795/64 BHOB, Ahmedabad 6/27/2003 11/15/2005

18. 12312906 PANCHAL HETA U 402-403 SHASHWAT 50795/65 BHOB, Ahmedabad 6/27/2003 11/15/2005

19. 12312914 PANCHAL KIRITBHAI R 402-403 SHASHWAT 50795/65 BHOB, Ahmedabad 6/27/2003 11/15/2005

20. 12312922 PANCHAL CHHAYABEN K 402-403 SHASHWAT 50795/65 BHOB, Ahmedabad 6/27/2003 11/15/2005

21. 12312939 PANCHAL NARESH N 402-403 SHASHWAT 50795/66 BHOB, Ahmedabad 6/27/2003 11/15/2005

22. 12312947 PANCHAL ROOPAL N 402-403 SHASHWAT 50795/66 BHOB, Ahmedabad 6/27/2003 11/15/2005

23. 12312963 PANCHAL AYUSHI N 402-403 SHASHWAT 50795/67 BHOB, Ahmedabad 6/27/2003 11/15/2005

24. 12312970 PANCHAL 402-403 50795/67 BHOB, 6/27/2003 11/15/2005     NATVARLAL SHASHWAT   Ahmedabad    

25. 12312989 PANCHAL RAMABEN N 402-403 SHASHWAT 50795/67 BHOB, Ahmedabad 6/27/2003 11/15/2005

26. 12312998 KHALAS VIJAY G 402-403 SHASHWAT 50795/68 BHOB, Ahmedabad 6/27/2003 11/15/2005

27. 12313005 KHALAS SANJAY G 402-403 SHASHWAT 50795/68 BHOB, Ahmedabad 6/27/2003 11/15/2005

28. 12313013 KHALAS SANDIP G 402-403 SHASHWAT 50795/68 BHOB, Ahmedabad 6/27/2003 11/15/2005

29. 12313039 KHALAS GOVINDBHAI N 402-403 SHASHWAT 50795/69 BHOB, Ahmedabad 6/27/2003 11/15/2005

30. 12313048 MODI NIKUNJ B 402-403 SHASHWAT 50795/69 BHOB, Ahmedabad 6/27/2003 11/15/2005

31. 12313056 MODI HETAL N 402-403 SHASHWAT 50795/70 BHOB, Ahmedabad 6/27/2003 11/15/2005

32. 12313064 MODI MADHU BALA B 402-403 SHASHWAT 50795/70 BHOB, Ahmedabad 6/30/2003 11/15/2005

33. 12313072 MODI BABULAL S 402-403 SHASHWAT 50795/70 BHOB, Ahmedabad 6/27/2003 11/15/2005

34. 12313089 PARMAR NATVARLAL N 402-403 SHASHWAT 50795/71 BHOB, Ahmedabad 6/27/2003 11/15/2005

35. 12313097 PARMAR USHABEN N 402-403 SHASHWAT 50795/71 BHOB, Ahmedabad 6/27/2003 11/15/2005

36. 12313100 PARMAR KIRITBHAI N 402-403 SHASHWAT 50795/71 BHOB, Ahmedabad 6/27/2003 11/15/2005

37. 12313119 PARMAR RAMILABEN K 402-403 SHASHWAT 50795/72 BHOB, Ahmedabad 6/27/2003 11/15/2005

38. 12313128 PARMAR AMIT K 402-403 SHASHWAT 50795/72 BHOB, Ahmedabad 6/27/2003 11/15/2005

39. 12313136 PARMAR MONIKA K 402-403 SHASHWAT 50795/72 BHOB, Ahmedabad 6/27/2003 11/15/2005

40. 12313144 PARMAR SONIKA K 402-403 SHASHWAT 50795/73 BHOB, Ahmedabad 6/27/2003 11/15/2005

41. 12313152 PARMAR YUVRAJ K 402-403 SHASHWAT 50795/73 BHOB, Ahmedabad 6/27/2003 11/15/2005

42. 12313169 PARMAR ASHVIN N 402-403 SHASHWAT 50795/73 BHOB, Ahmedabad 6/27/2003 11/15/2005

43. 12313177 PARMAR BHANUBEN A 402-403 SHASHWAT 50795/74 BHOB, Ahmedabad 6/27/2003 11/15/2005

44. 12313185 PARMAR PRIYANSHU A 402-403 SHASHWAT 50795/74 BHOB, Ahmedabad 6/27/2003 11/15/2005

45. 12313193 PARMAR MADHUSUDAN M 402-403 SHASHWAT 50795/74 BHOB, Ahmedabad 6/27/2003 11/15/2005

46. 12313208 PARMAR KARTIK N 402-403 SHASHWAT 50795/75 BHOB, Ahmedabad 6/27/2003 11/15/2005

47. 12313216 PARMAR DONIKA N 402-403 SHASHWAT 50795/75 BHOB, Ahmedabad 6/27/2003 11/15/2005

48. 12313224 PARMAR DEVENDRABHAI K 402-403 SHASHWAT 50795/75 BHOB, Ahmedabad 6/27/2003 11/15/2005

49. 12313232 RAVAL KRISHNABEN D 402-403 SHASHWAT 50795/76 BHOB, Ahmedabad 6/30/2003 11/15/2005

50. 12313249 RAVAL VISHAKHA D 402-403 SHASHWAT 50795/77 BHOB, Ahmedabad 6/30/2003 11/15/2005

51. 12313257 RAVAL KOMAL D 402-403 SHASHWAT 50795\77 BHOB, Ahmedabad 6/30/2003 11/15/2005

52. 12313265 RAVAL DIPAK N 402-403 SHASHWAT 50795\77 BHOB, Ahmedabad 6/30/2003 11/15/2005

53. 12313273 SHAH LATA D 402-403 SHASHWAT 50795\78 BHOB, Ahmedabad 6/30/2003 11/15/2005

54. 12313280 SHAH NEELAM D 402-403 SHASHWAT 50795\78 BHOB, Ahmedabad 6/30/2003 11/15/2005

55. 12313299 SHAH SONAM D 402-403 SHASHWAT 50795\78 BHOB, Ahmedabad 6/30/2003 11/15/2005

56. 12313304 SHAH ZEEL D 402-403 SHASHWAT 50795\79 BHOB, Ahmedabad 6/30/2003 11/15/2005

57. 12313312 SHAH BHARAT K 402-403 SHASHWAT 50795\79 BHOB, Ahmedabad 6/30/2003 11/15/2005

58. 12313329 SHAH BHAGVANTI B 402-403 SHASHWAT 50795\79 BHOB, Ahmedabad 6/30/2003 11/15/2005

59. 12313337 SHAH NIPA B 402-403 SHASHWAT 50795\80 BHOB, Ahmedabad 6/30/2003 11/15/2005

60. 12313345 SHAH NIHIR B 402-403 SHASHWAT 50795\80 BHOB, Ahmedabad 6/30/2003 11/15/2005

61. 12313353 SHAH MUNJAL B 402-403 SHASHWAT 50795\80 BHOB, Ahmedabad 6/30/2003 11/15/2005

62. 12313360 SHAH KANTILAL K 402-403 SHASHWAT 50795\81 BHOB, Ahmedabad 6/30/2003 11/15/2005

63. 12313379 SHAH MANJULA K 402-403 SHASHWAT 50795\81 BHOB, Ahmedabad 6/30/2003 11/15/2005

64. 12313388 SHAH PRITESH K 402-403 SHASHWAT 50795\81 BHOB, Ahmedabad 6/30/2003 11/15/2005

65. 12313396 SHAH VISHAL K 402-403 SHASHWAT 50795\82 BHOB, Ahmedabad 6/30/2003 11/15/2005

66. 12313407 SHAH PRAVIN K 402-403 SHASHWAT 50795\82 BHOB, Ahmedabad 6/30/2003 11/15/2005

67. 12313415 SHAH BHAGWANTI P 402-403 SHASHWAT 50795\82 BHOB, Ahmedabad 6/30/2003 11/15/2005

68. 12313423 SHAH SURBHI P 402-403 SHASHWAT 50795\83 BHOB, Ahmedabad 6/30/2003 11/15/2005

69. 12313430 SHAHLALU P 402-403 SHASHWAT 50795\83 BHOB, Ahmedabad 6/30/2003 11/15/2005

70. 12313449 SHAH SHAILESH N 402-403 SHASHWAT 50795\83 BHOB, Ahmedabad 6/30/2003 11/15/2005

71. 12313458 SHAH JAGRUTI S 402-403 SHASHWAT 50795\84 BHOB, Ahmedabad 6/30/2003 11/15/2005

72. 12313466 SHAH ANERI S 402-403 SHASHWAT 50795\84 BHOB, Ahmedabad 6/30/2003 11/15/2005

73. 12313474 SHAH AYUSHI S 402-403 SHASHWAT 50795\84 BHOB, Ahmedabad 6/30/2003 11/15/2005

74. 12313482 SHAH ROHIT N 402-403 SHASHWAT 50795\85 BHOB, Ahmedabad 6/30/2003 11/15/2005

75. 12313499 SHAH ANJU R 402-403 SHASHWAT 50795\85 BHOB, Ahmedabad 6/30/2003 11/15/2005

76. 12313503 SHAH ROOPA R 402-403 SHASHWAT 50795\85 BHOB, Ahmedabad 6/30/2003 11/15/2005

77. 12313510 SHAH POOJA R 402-403 SHASHWAT 50795\86 BHOB, Ahmedabad 6/30/2003 11/15/2005

78. 12313529 SHAH NANCHAND K 402-403 SHASHWAT 50795\86 BHOB, Ahmedabad 6/30/2003 11/15/2005

79. 12313538 SHAH KUSUM N 402-403 SHASHWAT 50795\86 BHOB, Ahmedabad 6/30/2003 11/15/2005

80. 12313546 SHAH BHARTI V 402-403 SHASHWAT 50795\87 BHOB, Ahmedabad 6/30/2003 11/15/2005

81. 12313554 SHAH VINOD T 402-403 SHASHWAT 50795\87 BHOB, Ahmedabad 6/30/2003 11/15/2005

82. 12313562 SHAH SANDIP V 402-403 SHASHWAT 50795\87 BHOB, Ahmedabad 6/30/2003 11/15/2005

83. 12313579 SHAH JITENDRA P 402-403 SHASHWAT 50795\88 BHOB, Ahmedabad 6/30/2003 11/15/2005

84. 12313587 SHAH SANGEETA J 402-403 SHASHWAT 50795\88 BHOB, Ahmedabad 6/30/2003 11/15/2005

85. 12313595 SHAH DHIREN J 402-403 SHASHWAT 50795\88 BHOB, Ahmedabad 6/30/2003 11/15/2005

86. 12313609 SHAH MANEK J 402-403 SHASHWAT 50795\89 BHOB, Ahmedabad 6/30/2003 11/15/2005

87. 12313618 SHAH MOHAN M 402-403 SHASHWAT 50795\89 BHOB, Ahmedabad 6/30/2003 11/15/2005

88. 12313626 SHAH SOBHNA M 402-403 SHASHWAT 50795\89 BHOB, Ahmedabad 6/30/2003 11/15/2005

89. 12313634 SHAH SUNITA M 402-403 SHASHWAT 50795\90 BHOB, Ahmedabad 6/30/2003 11/15/2005

90. 12313642 SHAH SURBHI M 402-403 SHASHWAT 50795\90 BHOB, Ahmedabad 6/30/2003 11/15/2005

91. 12313659 SHAH NIMESH M 402-403 SHASHWAT 50795\90 BHOB, Ahmedabad 6/30/2003 11/15/2005

92. 12313667 SHAH DEVICHAND M 402-403 SHASHWAT 50795\91 BHOB, Ahmedabad 6/30/2003 11/15/2005

93. 12313675 SHAH LEELA D 402-403 SHASHWAT 50795\91 BHOB, Ahmedabad 6/30/2003 11/15/2005

94. 12313683 SHAH MAHAVIR D 402-403 SHASHWAT 50795\91 BHOB, Ahmedabad 6/30/2003 11/15/2005

95. 12313690 SHAH MAMTA D 402-403 SHASHWAT 50795\92 BHOB, Ahmedabad 6/30/2003 11/15/2005

96. 12313706 SHAH AMBICA D 402-403 SHASHWAT 50795\92 BHOB, Ahmedabad 6/30/2003 11/15/2005

97. 12313714 SHAH PAWAN D 402-403 SHASHWAT 50795\92 BHOB, Ahmedabad 6/30/2003 11/15/2005

98. 12313722 SHAH NIKITA D 402-403 SHASHWAT 50795/93 BHOB, Ahmedabad 6/30/2003 11/15/2005

99. 12313747 DINESH PANCHAL 402-403 SHASHWAT 50795/26 BHOB, Ahmedabad 6/27/2003 11/15/2005

100. 12313755 DILIP PANCHAL 402-403 SHASHWAT 50795/26 BHOB, Ahmedabad 6/27/2003 11/15/2005

101. 12313763 DEVANGI PANCHAL 402-403 SHASHWAT 50795/44 BHOB, Ahmedabad 6/27/2003 11/15/2005

102. 12313770 ROOPA PANCHAL 402-403 SHASHWAT 50795/26 BHOB, Ahmedabad 6/27/2003 11/15/2005

103. 12313789 DHRUV PANCHAL 402-403 SHASHWAT 50795/27 BHOB, Ahmedabad 6/27/2003 11/15/2005

104. 12313798 DEVAL PANCHAL 402-403 SHASHWAT 50795/27 BHOB, Ahmedabad 6/27/2003 11/15/2005

105. 12313802 DEVESH PANCHAL 402-403 SHASHWAT 50795/27 BHOB, Ahmedabad 6/27/2003 11/15/2005

106. 12313819 PANCHAL 402-403 SHASHWAT 50795/28 BHOB, Ahmedabad 6/27/2003 11/15/2005

107. 12313827 MOXI PANCHAL 402-403 SHASHWAT 50795/28 BHOB, Ahmedabad 6/27/2003 11/15/2005

108. 12313835 RANCHHODLAL PANCHAL 402-403 SHASHWAT 50795/28 BHOB, Ahmedabad 6/27/2003 11/15/2005

109. 12313843 PRAMILABEN PANCHAL 402-403 SHASHWAT 50795/29 BHOB, Ahmedabad 6/27/2003 11/15/2005

110. 12313850 NARMADABEN PANCHAL 402-403 SHASHWAT 50795/29 BHOB, Ahmedabad 6/27/2003 11/15/2005

111. 12313869 BHARGAV PANCHAL 402-403 SHASHWAT 50795/29 BHOB, Ahmedabad 6/27/2003 11/15/2005

112. 12313878 HINA PANCHAL 402-403 SHASHWAT 50795/30 BHOB, Ahmedabad 6/27/2003 11/15/2005

113. 12313886 MALAV PANCHAL 402-403 SHASHWAT 50795/30 BHOB, Ahmedabad 6/27/2003 11/15/2005

114. 12313894 SRINAND PANCHAL 402-403 SHASHWAT 50795/30 BHOB, Ahmedabad 6/27/2003 11/15/2005

115. 12313909 HETA PANCHAL 402-403 SHASHWAT 50795/31 BHOB, Ahmedabad 6/27/2003 11/15/2005

116. 12313917 KIRITBHAI PANCHAL 402-403 SHASHWAT 50795/31 BHOB, Ahmedabad 6/27/2003 11/15/2005

117. 12313925 CHHAYABEN PANCHAL 402-403 SHASHWAT 50795/31 BHOB, Ahmedabad 6/27/2003 11/15/2005

118. 12313933 NARESH PANCHAL 402-403 SHASHWAT 50795/32 BHOB, Ahmedabad 6/27/2003 NA

119. 12313940 ROOPAL PANCHAL 402-403 SHASHWAT 50795/32 BHOB, Ahmedabad 6/27/2003 NA

120. 12313959 ARJAV PANCHAL 402-403 SHASHWAT 50795/32 BHOB, Ahmedabad 6/27/2003 1/5/2006

121. 12313968 AYUSHI PANCHAL 402-403 SHASHWAT 50795/33 BHOB, Ahmedabad 6/27/2003 1/4/2006

122. 12313976 NATVARLAL PANCHAL 402-403 SHASHWAT 50795/33 BHOB, Ahmedabad 6/27/2003 11/15/2005

123. 12313984 RAMABEN PANCHAL 402-403 SHASHWAT 50795/33 BHOB, Ahmedabad 6/27/2003 11/15/2005

124. 12313992 VIJAY KHALAS 402-403 SHASHWAT 50795/34 BHOB, Ahmedabad 6/27/2003 11/15/2005

125. 12314008 SANJAY KHALAS 402-403 SHASHWAT 50795/31 BHOB, Ahmedabad 6/27/2003 11/15/2005

126. 12314016 SANDIP KHALAS 402-403 SHASHWAT 50795/34 BHOB, Ahmedabad 6/27/2003 11/15/2005

127. 12314024 RAMILABEN KHALAS 402-403 SHASHWAT 50795/35 BHOB, Ahmedabad 6/27/2003 11/15/2005

128. 12314032 GOVINDBHAI KHALAS 402-403 SHASHWAT 50795/35 BHOB, Ahmedabad 6/27/2003 11/15/2005

129. 12314049 NIKUNJ MODI 402-403 SHASHWAT 50795/35 BHOB, Ahmedabad 6/27/2003 11/15/2005

130. 12314057 HETAL MODI 402-403 SHASHWAT 50795/36 BHOB, Ahmedabad 6/27/2003 11/15/2005

131. 12314065 MADHUBALA MODI 402-403 SHASHWAT 50795/36 BHOB, Ahmedabad 6/27/2003 11/15/2005

132. 12314073 BABUL AL MODI 402-403 SHASHWAT 50795/36 BHOB, Ahmedabad 6/27/2003 11/15/2005

133. 12314080 NATVARLAL PARMAR 402-403 SHASHWAT 50795/37 BHOB, Ahmedabad 6/27/2003 11/15/2005

134. 12314099 USHABEN PARMAR 402-403 SHASHWAT 50795/37 BHOB, Ahmedabad 6/27/2003 11/15/2005

135. 12314104 KIRITBHAI PARMAR 402-403 SHASHWAT 50795/37 BHOB, Ahmedabad 6/27/2003 11/15/2005

136. 12314112 RAMILABEN PARMAR 402-403 SHASHWAT 50795/38 BHOB, Ahmedabad 6/27/2003 11/15/2005

137. 12314129 AMIT PARMAR 402-403 SHASHWAT 50795/38 BHOB, Ahmedabad 6/27/2003 11/15/2005

138. 12314137 MONIKA PARMAR 402-403 SHASHWAT 50795/38 BHOB, Ahmedabad 6/27/2003 11/15/2005

139. 12314145 SONIKA PARMAR 402-403 SHASHWAT 50795/39 BHOB, Ahmedabad 6/27/2003 11/15/2005

140. 12314153 YUVRAJ PARMAR 402-403 SHASHWAT 50795/39 BHOB, Ahmedabad 6/27/2003 11/15/2005

141. 12314160 ASHVINKUMAR PARMAR 402-403 SHASHWAT 50795/39 BHOB, Ahmedabad 6/27/2003 11/15/2005

142. 12314179 BHANUBEN PARMAR 402-403 SHASHWAT 50795/40 BHOB, Ahmedabad 6/27/2003 11/15/2005

143. 12314188 PRIYANSHU PARMAR 402-403 SHASHWAT 50795/40 BHOB, Ahmedabad 6/27/2003 11/15/2005

144. 12314196 MADHUSUDAN PARMAR 402-403 SHASHWAT 50795/40 BHOB, Ahmedabad 6/27/2003 11/15/2005

145. 12314207 KARTIK PARMAR 402-403 SHASHWAT 50795/41 BHOB, Ahmedabad 6/27/2003 11/15/2005

146. 12314215 DONIKA PARMAR 402-403 SHASHWAT 50795/41 BHOB, Ahmedabad 6/27/2003 11/15/2005

147. 12314223 DEVENBHAI RAVAL 402-403 SHASHWAT 50795/41 BHOB, Ahmedabad 6/27/2003 11/15/2005

148. 12314230 KRISHNABEN RAVAL 402-403 SHASHWAT 50795142 BHOB, Ahmedabad 6/27/2003 11/15/2005

149. 12314249 VISHAKHA RAVAL 402-403 SHASHWAT 50795/43 BHOB, Ahmedabad 6/27/2003 11/15/2005

150. 12314258 KOMAL RAVAL 402-403 SHASHWAT 50795/43 BHOB, Ahmedabad 6/27/2003 11/15/2005

151. 12314266 DIPAK SHAH 402-403 SHASHWAT 50795/43 BHOB, Ahmedabad 6/27/2003 11/15/2005

152. 12314274 LATA SHAH 402-403 SHASHWAT 50795/44 BHOB, Ahmedabad 6/27/2003 11/15/2005

153. 12314282 NEELAM SHAH 402-403 SHASHWAT 50795/44 BHOB, Ahmedabad 6/27/2003 11/15/2005

154. 12314299 SONAM SHAH 402-403 SHASHWAT 50795/44 BHOB, Ahmedabad 6/27/2003 11/15/2005

155. 12314303 ZEEL SHAH 402-403 SHASHWAT 50795/45 BHOB, Ahmedabad 6/27/2003 11/15/2005

156. 12314310 BHARAT SHAH 402-403 SHASHWAT 50795/45 BHOB, Ahmedabad 6/27/2003 11/15/2005

157. 12314329 BHAGVANTI SHAH 402-403 SHASHWAT 50795/45 BHOB, Ahmedabad 6/27/2003 11/15/2005

158. 12314338 NIPA SHAH 402-403 SHASHWAT 50795/46 BHOB, Ahmedabad 6/27/2003 11/15/2005

159. 12314346 NIHIR SHAH 402-403 SHASHWAT 50795/46 BHOB, Ahmedabad 6/27/2003 11/15/2005

160. 12314354 MUNJAL SHAH 402-403 SHASHWAT 50795/46 BHOB, Ahmedabad 6/27/2003 11/15/2005

161. 12314362 KANTILAL SHAH 402-403 SHASHWAT 50795/47 BHOB, Ahmedabad 6/27/2003 11/15/2005

162. 12314379 MANJULA SHAH 402-403 SHASHWAT 50795/47 BHOB, Ahmedabad 6/27/2003 11/15/2005

163. 12314387 PRITESH SHAH 402-403 SHASHWAT 50795/47 BHOB, Ahmedabad 6/27/2003 11/15/2005

164. 12314395 VISHAL SHAH 402-403 SHASHWAT 50795/48 BHOB, Ahmedabad 6/27/2003 11/15/2005

165. 12314409 PRAVIN SHAH 402-403 SHASHWAT 50795/48 BHOB, Ahmedabad 6/27/2003 11/15/2005

166. 12314418 BHAGWANTI SHAH 402-403 SHASHWAT 50795/48 BHOB, Ahmedabad 6/27/2003 11/15/2005

167. 12314426 SURBHI SHAH 402-403 SHASHWAT 50795/49 BHOB, Ahmedabad 6/27/2003 11/15/2005

168. 12314434 LALU SHAH 402-403 SHASHWAT 50795/49 BHOB, Ahmedabad 6/27/2003 11/15/2005

169. 12314442 SHAILESH SHAH 402-403 SHASHWAT 50795/49 BHOB, Ahmedabad 6/27/2003 11/15/2005

170. 12314459 JAGRUTI SHAH 402-403 SHASHWAT 50795/50 BHOB, Ahmedabad 6/27/2003 11/15/2005

171. 12314467 ANERI SHAH 402-403 SHASHWAT 50795/50 BHOB, Ahmedabad 6/27/2003 11/15/2005

172. 12314475 AYUSHI SHAH 402-403 SHASHWAT 50795/50 BHOB, Ahmedabad 6/27/2003 11/15/2005

173. 12314483 ROHIT SHAH 402-403 SHASHWAT 50795/51 BHOB, Ahmedabad 6/27/2003 11/15/2005

174. 12314490 ANJU SHAH 402-403 SHASHWAT 50795/51 BHOB, Ahmedabad 6/27/2003 11/15/2005

175. 12314506 ROOPA T SHAH 402-403 SHASHWAT 50795/51 BHOB, Ahmedabad 6/27/2003 11/15/2005

176. 12314514 POOJA SHAH 402-403 SHASHWAT 50795/52 BHOB, Ahmedabad 6/27/2003 11/15/2005

177. 12314522 NANCHAND SHAH 402-403 SHASHWAT 50795/52 BHOB, Ahmedabad 6/27/2003 11/15/2005

178. 12314539 KUSUM SHAH 402-403 SHASHWAT 50795/52 BHOB, Ahmedabad 6/27/2003 11/15/2005

179. 12314547 BHARTI SHAH 402-403 SHASHWAT 50795/53 BHOB, Ahmedabad 6/27/2003 11/15/2005

180. 12314555 VINOD SHAH 402-403 SHASHWAT 50795/53 BHOB, Ahmedabad 6/27/2003 11/15/2005

181. 12314563 SANDIP SHAH 402-403 SHASHWAT 50795/53 BHOB, Ahmedabad 6/27/2003 11/15/2005

182. 12314570 JITENDRA SHAH 402-403 SHASHWAT 50795/54 BHOB, Ahmedabad 6/27/2003 11/15/2005

183. 12314589 SANGEETA SHAH 402-403 SHASHWAT 50795/54 BHOB, Ahmedabad 6/27/2003 11/15/2005

184. 12314598 DHIREN SHAH 402-403 SHASHWAT 50795/54 BHOB, Ahmedabad 6/27/2003 11/15/2005

185. 12314602 MANEK SHAH 402-403 SHASHWAT 50795/55 BHOB, Ahmedabad 6/27/2003 11/15/2005

186. 12314619 MOHAN SHAH 402-403 SHASHWAT 50795/55 BHOB, Ahmedabad 6/27/2003 11/15/2005

187. 12314627 SOBHNA SHAH 402-403 SHASHWAT 50795/55 BHOB, Ahmedabad 6/27/2003 11/15/2005

188. 12314635 SUNITA SHAH 402-403 SHASHWAT 50795/56 BHOB, Ahmedabad 6/27/2003 11/15/2005

189. 12314643 SURBHI SHAH 402-403 SHASHWAT 50795/56 BHOB, Ahmedabad 6/27/2003 11/15/2005

190. 12314650 NIMESH SHAH 402-403 SHASHWAT 50795/56 BHOB, Ahmedabad 6/27/2003 11/15/2005

191. 12314669 DEVICHAND SHAH 402-403 SHASHWAT 50795/57 BHOB, Ahmedabad 6/27/2003 11/15/2005

192. 12314678 LEELA SHAH 402-403 SHASHWAT 50795/57 BHOB, Ahmedabad 6/27/2003 11/15/2005

193. 12314686 MAHAVIR SHAH 402-403 SHASHWAT 50795/57 BHOB, Ahmedabad 6/27/2003 11/15/2005

194. 12314694 MAMTA SHAH 402-403 SHASHWAT 50795/58 BHOB, Ahmedabad 6/27/2003 11/15/2005

195. 12314709 AMBICA SHAH 402-403 SHASHWAT 50795/58 BHOB, Ahmedabad 6/27/2003 11/15/2005

196. 12314717 PAWAN SHAH 402-403 SHASHWAT 50795/58 BHOB, Ahmedabad 6/27/2003 11/15/2005

197. 12314725 NIKITA SHAH 402-403 SHASHWAT 50795/59 BHOB, Ahmedabad 6/27/2003 11/15/2005

198. 12314733 DIPAK JASHVANTLAL 402-403 SHASHWAT 50795/94 BHOB, Ahmedabad 6/30/2003 11/15/2005

199. 12314740 DINESH JASHVANTLAL 402-403 SHASHWAT 50795/94 BHOB, Ahmedabad 6/30/2003 11/15/2005

200. 12314759 DILIP JASHVANTLAL 402-403 SHASHWAT 50795/94 BHOB, Ahmedabad 6/30/2003 11/15/2005

201. 12314768 DEVANGI DIPAKBHAI 402-403 SHASHWAT 50795/111 BHOB, Ahmedabad 6/30/2003 11/15/2005

202. 12314776 ROOPA DIPAK 402-403 SHASHWAT 50795/94 BHOB, Ahmedabad 6/30/2003 11/15/2005

203. 12314784 DHRUV DIPAKBHAI 402-403 SHASHWAT 50795/95 BHOB, Ahmedabad 6/30/2003 11/15/2005

204. 12314792 DEVAL DIPAKBHAI 402-403 SHASHWAT 50795/95 BHOB, Ahmedabad 6/30/2003 11/15/2005

205. 12314805 DEVESH DIPAKBHAI 402-403 SHASHWAT 50795/95 BHOB, Ahmedabad 6/30/2003 11/15/2005

206. 12314813 DIPAKBHAI 402-403 SHASHWAT 50795/96 BHOB, Ahmedabad 6/30/2003 11/15/2005

207. 12314820 MOXI DIPAKBHAI 402-403 SHASHWAT 50795/96 BHOB, Ahmedabad 6/30/2003 11/15/2005

208. 12314839 RANCHHODLAL NANALAL 402-403 SHASHWAT 50795/96 BHOB, Ahmedabad 6/30/2003 11/15/2005

209. 12314848 PRAMILABEN RANCHHODLAL 402-403 SHASHWAT 50795/95 BHOB, Ahmedabad 6/30/2003 11/15/2005

210. 12314856 NARMADABEN MANEKLAL 402-403 SHASHWAT 50795/97 BHOB, Ahmedabad 6/30/2003 11/15/2005

211. 12314864 BHARGAV RANCHHODLAL 402-403 SHASHWAT 50795/97 BHOB, Ahmedabad 6/30/2003 11/15/2005

212. 12314872 HINA BHARGAVBHAI 402-403 SHASHWAT 50795/98 BHOB, Ahmedabad 6/30/2003 11/15/2005

213. 12314889 MALAV BHARGAVBHAI 402-403 SHASHWAT 50795/98 BHOB, Ahmedabad 6/30/2003 11/15/2005

214. 12314897 SRIMAND BHARGAVBHAI 402-403 SHASHWAT 50795/98 BHOB, Ahmedabad 6/30/2003 11/15/2005

215. 12314900 HETA UTTAMKUMAR 402-403 SHASHWAT 50795/99 BHOB, Ahmedabad 6/30/2003 11/15/2005

216. 12314919 KIRITBHAI RASIKLAL 402-403 SHASHWAT 50795/99 BHOB, Ahmedabad 6/30/2003 11/15/2005

217. 12314928 CHHAYABEN KIRITBHAI 402-403 SHASHWAT 50795/99 BHOB, Ahmedabad 6/30/2003 11/15/2005

218. 12314936 NARESH NATVARLAL 402-403 SHASHWAT 50795/100 BHOB, Ahmedabad 6/30/2003 11/15/2005

219. 12314944 ROOPAL NARESHBHAI 402-403 SHASHWAT 50795/100 BHOB, Ahmedabad 6/30/2003 11/15/2005

220. 12314952 ARJAV NARESHBHAI 402-403 SHASHWAT 50795/100 BHOB, Ahmedabad 6/30/2003 11/15/2005

221. 12314969 AYUSHI NARESHBHAI 402-403 SHASHWAT 50795/101 BHOB, Ahmedabad 6/30/2003 11/15/2005

222. 12314977 NATVARLAL BHALCHAND 402-403 SHASHWAT 50795/101 BHOB, Ahmedabad 6/30/2003 11/15/2005

223. 12314985 RAMABEN NATVARLAL 402-403 SHASHWAT 50795/101 BHOB, Ahmedabad 6/30/2003 11/15/2005

224. 12314993 VIJAY GOVINDBHAI 402-403 SHASHWAT 50795/102 BHOB, Ahmedabad 6/30/2003 11/15/2005

225. 12315003 SANJAY GOVINDBHAI 402-403 SHASHWAT 50795/102 BHOB, Ahmedabad 6/30/2003 11/15/2005

226. 12315010 SANDIP GOVINDBHAI 402-403 SHASHWAT 50795/102 BHOB, Ahmedabad 6/30/2003 11/15/2005

227. 12315029 RAMILABEN GOVINDBHAI 402-403 SHASHWAT 50795/103 BHOB, Ahmedabad 6/30/2003 11/15/2005

228. 12315038 GOVINDBHAI NARANDAS 402-403 SHASHWAT 50795/103 BHOB, Ahmedabad 6/30/2003 11/15/2005

229. 12315046 NIKUNJ BABULAL 402-403 SHASHWAT 50795\103 BHOB, Ahmedabad 6/30/2003 11/15/2005

230. 12315054 HETAL NIKUNJBHAI 402-403 SHASHWAT 50795\104 BHOB, Ahmedabad 6/30/2003 11/15/2005

231. 12315062 MADHUBALA BABULAL 402-403 SHASHWAT 50795/104 BHOB, Ahmedabad 6/30/2003 11/15/2005

232. 12315079 BABULAL SHANTILAL 402-403 SHASHWAT 50795\104 BHOB, Ahmedabad 6/30/2003 11/15/2005

233. 12315087 NATVARLAL NARSINHBHAI 402-403 SHASHWAT 50795\105 BHOB, Ahmedabad 6/30/2003 11/15/2005

234. 12315095 USHABEN NATVARLAL 402-403 SHASHWAT 50795\105 BHOB, Ahmedabad 6/30/2003 11/15/2005

235. 12315109 KIRITBHAI NATVARLAL 402-403 SHASHWAT 50795\105 BHOB, Ahmedabad 6/30/2003 11/15/2005

236. 12315118 RAMILABEN KIRITBHAI 402-403 SHASHWAT 50795\106 BHOB, Ahmedabad 6/30/2003 11/15/2005

237. 12315126 AMIT KIRITBHAI 402-403 SHASHWAT 50795\106 BHOB, Ahmedabad 6/30/2003 11/15/2005

238. 12315134 MONIKA KIRITBHAI 402-403 SHASHWAT 50795\106 BHOB, Ahmedabad 6/30/2003 11/15/2005

239. 12315142 SONIKA KIRITBHAI 402-403 SHASHWAT 50795\107 BHOB, Ahmedabad 6/30/2003 11/15/2005

240. 12315159 YUVRAJ KIRITBHAI 402-403 SHASHWAT 50795\107 BHOB, Ahmedabad 6/30/2003 11/15/2005

241. 12315167 ASHVINKUMAR NATVARLAL 402-403 SHASHWAT 50795\107 BHOB, Ahmedabad 6/30/2003 11/15/2005

242. 12315175 BHANUBEN ASHVINKUMAR 402-403 SHASHWAT 50795\108 BHOB, Ahmedabad 6/30/2003 11/15/2005

243. 12315183 PRIYANSHU ASHVINKUMAR 402-403 SHASHWAT 50795\108 BHOB, Ahmedabad 6/30/2003 11/15/2005

244. 12315190 MADHUSUDAN NATVARLAL 402-403 SHASHWAT 50795\108 BHOB, Ahmedabad 6/30/2003 11/15/2005

245. 12315206 KARTIK NATVARLAL 402-403 SHASHWAT 50795\109 BHOB, Ahmedabad 6/30/2003 11/15/2005

246. 12315214 DONIKA NATVARLAL 402-403 SHASHWAT 50795\109 BHOB, Ahmedabad 6/30/2003 11/15/2005

247. 12315222 DEVENBHAI KANAIYALAL 402-403 SHASHWAT 50795\109 BHOB, Ahmedabad 6/30/2003 11/15/2005

248. 12315239 KRISHNABEN DEVENBHAI 402-403 SHASHWAT 50795/110 BHOB, Ahmedabad 6/27/2003 11/15/2005

249. 12315247 VISHAKHA DEVENBHAI 402-403 SHASHWAT 50795/111 BHOB, Ahmedabad 6/27/2003 11/15/2005

250. 12315255 KOMAL DEVENBHAI 402-403 SHASHWAT 50795/111 BHOB, Ahmedabad 6/27/2003 11/15/2005

251. 12315263 DIPAK NANCHAND 402-403 SHASHWAT 50795/111 BHOB, Ahmedabad 6/27/2003 11/15/2005

252. 12315270 LATA DIPAK 402-403 SHASHWAT 50795/112 BHOB, Ahmedabad 6/27/2003 11/15/2005

253. 12315289 NEELAM DIPAK 402-403 SHASHWAT 50795/112 BHOB, Ahmedabad 6/27/2003 11/15/2005

254. 12315298 SONAM DIPAK 402-403 SHASHWAT 50795/112 BHOB, Ahmedabad 6/27/2003 11/15/2005

255. 12315302 ZEEL DIPAK 402-403 SHASHWAT 50795/113 BHOB, Ahmedabad 6/27/2003 11/15/2005

256. 12315319 BHARAT KESHRIMAL 402-403 SHASHWAT 50795/113 BHOB, Ahmedabad 6/27/2003 11/15/2005

257. 12315327 BHAGWANTI BHARAT 402-403 SHASHWAT 50795/113 BHOB, Ahmedabad 6/27/2003 11/15/2005

258. 12315335 NIPA BHARAT 402-403 SHASHWAT 50795/114 BHOB, Ahmedabad 6/27/2003 11/15/2005

259. 12315343 NIHIR BHARAT 402-403 SHASHWAT 50795/114 BHOB, Ahmedabad 6/27/2003 11/15/2005

260. 12315350 MUNJAL BHARAT 402-403 SHASHWAT 50795/114 BHOB, Ahmedabad 6/27/2003 11/15/2005

261. 12315369 KANTILAL KESHRIMAL 402-403 SHASHWAT 50795/115 BHOB, Ahmedabad 6/27/2003 11/15/2005

262. 12315378 MANJULA KANTILAL 402-403 SHASHWAT 50795/115 BHOB, Ahmedabad 6/27/2003 11/15/2005

263. 12315386 PRITESH KANTILAL 402-403 SHASHWAT 50795/115 BHOB, Ahmedabad 6/27/2003 11/15/2005

264. 12315394 VISHAL KANTILAL 402-403 SHASHWAT 50795/116 BHOB, Ahmedabad 6/27/2003 11/15/2005

265. 12315409 PRAVIN KANTILAL 402-403 SHASHWAT 50795/116 BHOB, Ahmedabad 6/27/2003 11/15/2005

266. 12315417 BHAGWANTI PRAVIN 402-403 SHASHWAT 50795/116 BHOB, Ahmedabad 6/27/2003 11/15/2005

267. 12315425 SURBHI PRAVIN 402-403 SHASHWAT 50795/117 BHOB, Ahmedabad 6/27/2003 11/15/2005

268. 12315433 LALU PRAVIN 402-403 SHASHWAT 50795/117 BHOB, Ahmedabad 6/27/2003 12/30/2005

269. 12315440 SHAILESH NANCHAND 402-403 SHASHWAT 50795/117 BHOB, Ahmedabad 6/27/2003 11/15/2005

270. 12315459 JAGRUTI SHAILESH 402-403 SHASHWAT 50795/118 BHOB, Ahmedabad 6/27/2003 11/15/2005

271. 12315468 ANERI SHAILESH 402-403 SHASHWAT 50795/118 BHOB, Ahmedabad 6/27/2003 11/15/2005

272. 12315476 AYUSHI SHAILESH 402-403 SHASHWAT 50795/118 BHOB, Ahmedabad 6/27/2003 11/15/2005

273. 12315484 ROHIT NANCHAND 402-403 SHASHWAT 50795/119 BHOB, Ahmedabad 6/27/2003 11/15/2005

274. 12315492 ANJU ROHIT 402-403 SHASHWAT 50795/119 BHOB, Ahmedabad 6/27/2003 11/15/2005

275. 12315505 ROOPA ROHIT 402-403 SHASHWAT 50795/119 BHOB, Ahmedabad 6/27/2003 11/15/2005

276. 12315513 POOJA ROHIT 402-403 SHASHWAT 50795/120 BHOB, Ahmedabad 6/27/2003 11/15/2005

277. 12315520 NANCHAND KALUJI 402-403 SHASHWAT 50795/120 BHOB, Ahmedabad 6/27/2003 11/15/2005

278. 12315539 KUSUM NANCHAND 402-403 SHASHWAT 50795/120 BHOB, Ahmedabad 6/27/2003 11/15/2005

279. 12315548 BHARTI VINOD 402-403 SHASHWAT 50795/121 BHOB, Ahmedabad 6/27/2003 11/15/2005

280. 12315556 VINOD TILAKCHAND 402-403 SHASHWAT 50795/121 BHOB, Ahmedabad 6/27/2003 11/15/2005

281. 12315564 SANDIP VINOD 402-403 SHASHWAT 50795/121 BHOB, Ahmedabad 6/27/2003 11/15/2005

282. 12315572 JITENDRA PUKHRAJ 402-403 SHASHWAT 50795/122 BHOB, Ahmedabad 6/27/2003 11/15/2005

283. 12315589 SANGEETA JITENDRA 402-403 SHASHWAT 50795/122 BHOB, Ahmedabad 6/27/2003 11/15/2005

284. 12315597 DHIREN JITENDRA 402-403 SHASHWAT 50795/122 BHOB, Ahmedabad 6/27/2003 11/15/2005

285. 12315600 MANEK JITENDRA 402-403 SHASHWAT 50795/123 BHOB, Ahmedabad 6/27/2003 11/15/2005

286. 12315619 MOHAN MANGILAL 402-403 SHASHWAT 50795/123 BHOB, Ahmedabad 6/27/2003 11/15/2005

287. 12315628 SOBHNA MOHAN 402-403 SHASHWAT 50795/123 BHOB, Ahmedabad 6/27/2003 11/15/2005

288. 12315636 SUNITA MOHAN 402-403 SHASHWAT 50795/124 BHOB, Ahmedabad 6/27/2003 11/15/2005

289. 12315644 SURBHI MOHAN 402-403 SHASHWAT 50795/124 BHOB, Ahmedabad 6/27/2003 11/15/2005

290. 12315652 NIMISH MOHAN 402-403 SHASHWAT 50795/124 BHOB, Ahmedabad 6/27/2003 11/15/2005

291. 12315669 DEVICHAND MOHAN 402-403 SHASHWAT 50795/125 BHOB, Ahmedabad 6/27/2003 11/15/2005

292. 12315677 LEELA DEVICHAND 402-403 SHASHWAT 50795/125 BHOB, Ahmedabad 6/27/2003 11/15/2005

293. 12315685 MAHAVIR DEVICHAND 402-403 SHASHWAT 50795/125 BHOB, Ahmedabad 6/27/2003 11/15/2005

294. 12315693 MAMTA DEVICHAND 402-403 SHASHWAT 50795/126 BHOB, Ahmedabad 6/27/2003 11/15/2005

295. 12315708 AMBICA DEVICHAND 402-403 SHASHWAT 50795/126 BHOB, Ahmedabad 6/27/2003 11/15/2005

296. 12315716 PAWAN DEVICHAND 402-403 SHASHWAT 50795/126 BHOB, Ahmedabad 6/27/2003 11/15/2005

297. 12315724 NIKITA DEVICHAND 402-403 SHASHWAT 50795/127 BHOB, Ahmedabad 6/27/2003 11/15/2005 9.10. The 297 demat accounts indicated in the table above were opened by Karvy DP on June 27 / 30, 2003. The bank account no. 50795 that was indicated as the bank account of the dematerialized account-holders was closed on October 27, 2003. However, these demat accounts continued to be operative till November 15, 2005 (when these were closed pursuant to verification by Karvy DP in the wake of SEBI examination of the matter of IPO irregularities). These 297 demat accounts were part of the 37,240 afferent accounts in NSDL identified by SEBI. 9.11. Thus, it may be seen that Karvy had introduced the bank account no.50795 of the key operator to BhOB, Ahmedabad. Thereafter, Karvy had introduced two additional names to the bank account. Then, Karvy DP had opened afferent dematerialized accounts indicating the bank account no.50795 and the dematerialized accounts continued to be held with Karvy DP after the closure of the bank accounts.

9.12. It appears that Karvy had introduced various such bank accounts to BhOB, Ahmedabad branch. The observations emerging from an examination of one such account no.54119 is narrated below:

9.13. Introduction of Bank account no.54119 with BhOB, Ahmedabad by Karvy It was observed that savings bank account no 54119 in the name and style of "Devangi Dipakbhai Panchal - GROUP ACCOUNT" was introduced by Karvy Securities Ltd. on December 4, 2003. From the bank account opening form, this is seen to be a GROUP ACCOUNT of Devangi Panchal. There were no specific names indicated as joint account holders. Further, this bank account was closed on April 24, 2004.

9.14. In this context it may be mentioned that Karvy DP in its reply dated May 19, 2007 to the post-enquiry show-cause notice dated May 4, 2007, had stated that "The Idea Paper and process flow submitted to BhOB clearly mentions that the proposal is for financing investors who wish to subscribing book building issue of Maruti IPO only." It may be noted the Public Issue of Maruti closed in June 2003 whereas the subject bank account number 54119 was introduced by Karvy to BhOB Ahmedabad on December 04,2003. Therefore, it is clear that the arrangement between Karvy and BhOB continued even after the Maruti IPO.

9.15. Based on examination of the details of afferent dematerialized accounts held with Karvy DP, it is observed that 3450 afferent demat accounts pertaining to the key operator, Roopal Panchal had indicated their bank account as BHOB bank account no. 54119. These demat accounts were part of the 29,309 afferent accounts held with Karvy DP on NSDL. It is seen that these dematerialized accounts had been opened on various dates during December, 2003 / January, 2004.

9.16. Though the bank account no.54119 was closed on April 24, 2004, the corresponding 3450 afferent demat accounts continued to be operative till November 15, 2005. On November 15, 2005, Karvy DP closed these dematerialized accounts pursuant to verification conducted in the wake of SEBI preliminary enquiry into the IPO irregularities. The details of 3450 afferent demat accounts held with Karvy DP with bank account no 54119 are given below:

Starting Name Last Name No.

Of Demat Accts.

Date Of Opening Bank Account No.

Daksha Luhar Induben Luhar 600 December 17, 2003 54119/1 to 54119/600 Daksha Pari Induben Pari 600 December 17, 2003 54119/451 to 54119/950 Daksha Mistri Induben Mistri 600 January 5/6, 2004 54119/1 to 54119/600 Daksha Shroff Induben Shroff 600 January 5/6, 2004 54119/601 to 54119/1200 Dasharath Seth Badri Seth 50 February 18, 2004 54119/2201 to 54119/2250 Kunal Seth** Babitha Seth 1000 January 5 /6, 2004 54119/1201 to 54119/2200 Total 3450     ** - includes the series of names from SURESH SETH to ADITI SETH which would be discussed in detaillater for the successive repeat appearances in various morphed forms.

9.17. Thus, the bank account number 54119 held with BhOB, Ahmedabad had resulted in 3450 dematerialized accounts with Karvy DP. It may be seen that the dematerialized account-holders were having the same surnames. A sample of 100 such dematerialized account-holders sharing the surname of 'Luhar' is given below:

Sr. No. CLIENT ID DP NAME NAME OF SOURCE CLIENT ADDRESS OF SOURCE CLIENT DATE OF OPENING OF DEMAT ACCOUNT DATE OF CLOSURE OF DEMAT (IF APPLICABLE) ACCOUNT STATUS

1. 13015876 KARVY STOCK BROKING LIMITED DAKSHA LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/17/2003 11/15/2005 CLOSED

2. 13015884 KARVY STOCK BROKING LIMITED DAKSHITA LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/17/2003 11/15/2005 CLOSED

3. 13015892 KARVY STOCK BROKING LIMITED DAMINI LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/17/2003 11/15/2005 CLOSED

4. 13015905 KARVY STOCK BROKING LIMITED DARPITA LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/17/2003 11/15/2005 CLOSED

5. 13015913 KARVY STOCK BROKING LIMITED DARSHA LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/17/2003 11/15/2005 CLOSED

6. 13015920 KARVY STOCK BROKING LIMITED DARSHI LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/17/2003 11/15/2005 CLOSED

7. 13015939 KARVY STOCK BROKING LIMITED DARSHIKA LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/17/2003 11/15/2005 CLOSED

8. 13015948 KARVY STOCK BROKING LIMITED DARSHINI LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/17/2003 11/15/2005 CLOSED

9. 13015956 KARVY STOCK BROKING LIMITED DEHAL LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/17/2003 11/15/2005 CLOSED

10. 13015964 KARVY STOCK BROKING LIMITED DEVAKI LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/17/2003 11/15/2005 CLOSED

11. 13015972 KARVY STOCK BROKING LIMITED DEVANA LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/17/2003 11/15/2005 CLOSED

12. 13015989 KARVY STOCK BROKING LIMITED DEVANGANA LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/17/2003 11/15/2005 CLOSED

13. 13015997 KARVY STOCK BROKING LIMITED DEVANGI LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/17/2003 11/15/2005 CLOSED

14. 13016004 KARVY STOCK BROKING LIMITED DEVANI LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/17/2003 11/15/2005 CLOSED

15. 13016012 KARVY STOCK BROKING LIMITED DEVANSHI LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/17/2003 11/15/2005 CLOSED

16. 13016029 KARVY STOCK BROKING LIMITED DEVIKA LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/17/2003 11/15/2005 CLOSED

17. 13016037 KARVY STOCK BROKING LIMITED DEVYANI LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/17/2003 11/15/2005 CLOSED

18. 13016045 KARVY STOCK BROKING LIMITED DIPALI LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/17/2003 11/15/2005 CLOSED

19. 13016053 KARVY STOCK BROKING LIMITED DIPANGI LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/17/2003 11/15/2005 CLOSED 20 13016060 KARVY STOCK BROKING LIMITED DIPTI LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/17/2003 11/15/2005 CLOSED

21. 13016079 KARVY STOCK BROKING LIMITED DITI LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/17/2003 11/15/2005 CLOSED 22 13016088 KARVY STOCK BROKING LIMITED DIVENTI LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/17/2003 11/15/2005 CLOSED

23. 13016096 KARVY STOCK BROKING LIMITED DIVITA LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/17/2003 11/15/2005 CLOSED 24 13016107 KARVY STOCK BROKING LIMITED DIVYA LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/17/2003 11/15/2005 CLOSED

25. 13016115 KARVY STOCK BROKING LIMITED DWIPA LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/17/2003 11/15/2005 CLOSED

26. 13016123 KARVY STOCK BROKING LIMITED DAKSHANT LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/17/2003 11/15/2005 CLOSED

27. 13016130 KARVY STOCK BROKING LIMITED DAKSHESH LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/17/2003 11/15/2005 CLOSED

28. 13016149 KARVY STOCK BROKING LIMITED DARPESH LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/17/2003 11/15/2005 CLOSED

29. 13016158 KARVY STOCK BROKING LIMITED DARSH LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/17/2003 11/15/2005 CLOSED 30 13016166 KARVY STOCK BROKING LIMITED DARSHIL LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/17/2003 11/15/2005 CLOSED

31. 13016174 KARVY STOCK BROKING LIMITED DARSHIT LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/17/2003 11/15/2005 CLOSED 32 13016182 KARVY STOCK BROKING LIMITED DEVPIYA LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/17/2003 11/15/2005 CLOSED

33. 13016199 KARVY STOCK BROKING LIMITED DESHAL LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/17/2003 11/15/2005 CLOSED 34 13016203 KARVY STOCK BROKING LIMITED DEV LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/17/2003 11/15/2005 CLOSED

35. 13016210 KARVY STOCK BROKING LIMITED DEVAJ LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/17/2003 11/15/2005 CLOSED

36. 13016229 KARVY STOCK BROKING LIMITED DEVAJYA LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/17/2003 11/15/2005 CLOSED

37. 13016238 KARVY STOCK BROKING LIMITED DEVAL LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/17/2003 11/15/2005 CLOSED

38. 13016246 KARVY STOCK BROKING LIMITED DEVAM LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/17/2003 11/15/2005 CLOSED

39. 13016254 KARVY STOCK BROKING LIMITED DEVANG LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/17/2003 11/15/2005 CLOSED 40 13016262 KARVY STOCK BROKING LIMITED DEVARSH LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/17/2003 11/15/2005 CLOSED

41. 13016279 KARVY STOCK BROKING LIMITED DEVAT LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/17/2003 11/15/2005 CLOSED 42 13016287 KARVY STOCK BROKING LIMITED DEVENDRA LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/17/2003 11/15/2005 CLOSED

43. 13016295 KARVY STOCK BROKING LIMITED DEVESH LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/17/2003 11/15/2005 CLOSED 44 13016309 KARVY STOCK BROKING LIMITED DEVKARAN LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/17/2003 11/15/2005 CLOSED

45. 13016318 KARVY STOCK BROKING LIMITED DHRUV LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/17/2003 11/15/2005 CLOSED

46. 13016326 KARVY STOCK BROKING LIMITED DIGESH LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/17/2003 11/15/2005 CLOSED

47. 13016334 KARVY STOCK BROKING LIMITED DIVAKAR LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/17/2003 11/15/2005 CLOSED

48. 13016342 KARVY STOCK BROKING LIMITED DRASHYA LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/17/2003 11/15/2005 CLOSED

49. 13016359 KARVY STOCK BROKING LIMITED DRUMESH LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/17/2003 11/15/2005 CLOSED 50 13016367 KARVY STOCK BROKING LIMITED DRUMIL LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/17/2003 11/15/2005 CLOSED

51. 13021373 KARVY STOCK BROKING LIMITED SAJAN LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/16/2003 11/16/2005 CLOSED 52 13021380 KARVY STOCK BROKING LIMITED SATYAM LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/16/2003 11/16/2005 CLOSED

53. 13021399 KARVY STOCK BROKING LIMITED SATEN LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/16/2003 11/16/2005 CLOSED 54 13021404 KARVY STOCK BROKING LIMITED SANNI LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/16/2003 11/16/2005 CLOSED

55. 13021412 KARVY STOCK BROKING LIMITED SATYAJIT LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/16/2003 11/16/2005 CLOSED

56. 13021429 KARVY STOCK BROKING LIMITED SARACHI LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/16/2003 11/16/2005 CLOSED

57. 13021437 KARVY STOCK BROKING LIMITED SACHIN LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/16/2003 11/16/2005 CLOSED

58. 13021445 KARVY STOCK BROKING LIMITED SAMIP LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/16/2003 11/16/2005 CLOSED

59. 13021453 KARVY STOCK BROKING LIMITED SARJIT LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/16/2003 11/16/2005 CLOSED 60 13021460 KARVY STOCK BROKING LIMITED SALENDRA LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/16/2003 11/16/2005 CLOSED

61. 13021479 KARVY STOCK BROKING LIMITED SASHIR LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/16/2003 11/16/2005 CLOSED 62 13021488 KARVY STOCK BROKING LIMITED SANGESH LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/16/2003 11/16/2005 CLOSED

63. 13021496 KARVY STOCK BROKING LIMITED SAMYA LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/16/2003 11/16/2005 CLOSED

64. 13021507 KARVY STOCK BROKING LIMITED SANDAN LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/16/2003 11/16/2005 CLOSED

65. 13021515 KARVY STOCK BROKING LIMITED SIMIT LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/16/2003 11/16/2005 CLOSED

66. 13021523 KARVY STOCK BROKING LIMITED SAVAN LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/16/2003 11/16/2005 CLOSED

67. 13021530 KARVY STOCK BROKING LIMITED SARTH LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/16/2003 11/16/2005 CLOSED

68. 13021549 KARVY STOCK BROKING LIMITED SOMIL LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/16/2003 11/16/2005 CLOSED

69. 13021558 KARVY STOCK BROKING LIMITED SEHAL LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/16/2003 11/16/2005 CLOSED

70. 13021566 KARVY STOCK BROKING LIMITED SURAJ LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/16/2003 11/16/2005 CLOSED

71. 13021574 KARVY STOCK BROKING LIMITED SPAND LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/16/2003 11/16/2005 CLOSED

72. 13021582 KARVY STOCK BROKING LIMITED SVEJ LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/16/2003 11/16/2005 CLOSED

73. 13021599 KARVY STOCK BROKING LIMITED SAUNIL LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/16/2003 11/16/2005 CLOSED

74. 13021603 KARVY STOCK BROKING LIMITED SAUMYA LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/16/2003 11/16/2005 CLOSED

75. 13021610 KARVY STOCK BROKING LIMITED SAURIN LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/16/2003 11/16/2005 CLOSED

76. 13021629 KARVY STOCK BROKING LIMITED MANJUALA LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/16/2003 11/16/2005 CLOSED

77. 13021638 KARVY STOCK BROKING LIMITED RASIKLAL LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/16/2003 11/16/2005 CLOSED

78. 13021646 KARVY STOCK BROKING LIMITED POOJA LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/16/2003 11/16/2005 CLOSED

79. 13021654 KARVY STOCK BROKING LIMITED VISHAL LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/16/2003 11/16/2005 CLOSED

80. 13021662 KARVY STOCK BROKING LIMITED DAKSHA LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/16/2003 11/16/2005 CLOSED

81. 13021679 KARVY STOCK BROKING LIMITED HANSA LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/16/2003 11/16/2005 CLOSED

82. 13021687 KARVY STOCK BROKING LIMITED NARENDRA LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/16/2003 11/16/2005 CLOSED

83. 13021695 KARVY STOCK BROKING LIMITED KUNDANBEN LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/16/2003 11/16/2005 CLOSED

84. 13021709 KARVY STOCK BROKING LIMITED GITABEN LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/16/2003 11/16/2005 CLOSED

85. 13021718 KARVY STOCK BROKING LIMITED NIRUBEN LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/16/2003 11/16/2005 CLOSED

86. 13021726 KARVY STOCK BROKING LIMITED SUNITA LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/16/2003 11/16/2005 CLOSED

87. 13021734 KARVY STOCK BROKING LIMITED ALPA LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/16/2003 11/16/2005 CLOSED

88. 13021742 KARVY STOCK BROKING LIMITED AARTI LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/16/2003 11/16/2005 CLOSED

89. 13021759 KARVY STOCK BROKING LIMITED HETAL LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/16/2003 11/16/2005 CLOSED

90. 13021767 KARVY STOCK BROKING LIMITED BINDU LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/16/2003 11/16/2005 CLOSED

91. 13021775 KARVY STOCK BROKING LIMITED DIPTI LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/16/2003 11/16/2005 CLOSED

92. 13021783 KARVY STOCK BROKING LIMITED BHAKTI LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/16/2003 11/16/2005 CLOSED

93. 13021790 KARVY STOCK BROKING LIMITED HIREN LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/16/2003 11/16/2005 CLOSED 94 13021806 KARVY STOCK BROKING LIMITED NILESH LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/16/2003 11/16/2005 CLOSED

95. 13021814 KARVY STOCK BROKING LIMITED URVASI LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/16/2003 11/16/2005 CLOSED

96. 13021822 KARVY STOCK BROKING LIMITED AMIT LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/16/2003 11/16/2005 CLOSED

97. 13021839 KARVY STOCK BROKING LIMITED DAKSHA LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/16/2003 11/16/2005 CLOSED

98. 13021847 KARVY STOCK BROKING LIMITED RADHIKA LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/16/2003 11/16/2005 CLOSED

99. 13021855 KARVY STOCK BROKING LIMITED RAVI LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/16/2003 11/16/2005 CLOSED 10 13021863 KARVY STOCK BROKING LIMITED INDUBEN LUHAR 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 12/16/2003 11/16/2005 CLOSED 9.18. From the above discussions, it may be noted that Karvy had introduced a bank account to BhOB, Ahmedabad during June 2003 and thereafter introduced another bank account to BhOB, Ahmedabad during December 2003. Additional names were added to each of these bank accounts and in certain instances, the addition of the names was certified by Karvy. Using these bank accounts and the names added thereto, thousands of dematerialized accounts were opened with Karvy DP. These dematerialized accounts were fake accounts pertaining to the key operators. While the bank accounts were closed during the year 2004, the dematerialized accounts continued to exist till November - December 2005, when they were closed pursuant to verification of genuineness by Karvy DP in the wake SEBI preliminary enquiry into the IPO irregularities.

9.19. Bank Accounts introduced by Karvy to IOB Subsequent to entering into an arrangement with BhOB and introducing the bank accounts of key operators and afferent entities for availing IPO finance, it was found that Karvy had entered into an arrangement with IOB for the same purpose. As per the arrangement of Karvy DP with IOB, IOB provided IPO finance to the persons who had their dematerialized accounts either with the DP IOB or with Karvy DP. Pursuant the arrangement with IOB, it was found that Karvy DP had introduced 40 bank accounts of the key operators Roopal Panchal and Kelan Atul Doshi. The details are narrated below:

9.20. During the verifications conducted by SEBI at the Indian Overseas Bank, Thaltej branch, vide letter dated March 4, 2006, at para 4, IOB submitted a list of 37 saving account numbers (which includes the account no 12140 taken for detailed discussions later) and names of saving account holders belonging to Roopal Panchal group. Thereafter, IOB vide letter dated October 13, 2006 submitted copies of 39 account opening forms containing list of 50 names attached with the account opening forms. Based on the details above, the tally of 40 accounts with list of 50 names added is set out in the table hereinunder.

9.21. A perusal of the 40 IOB bank account opening forms shows that 19 savings bank accounts, pertaining to the key operators Roopal Panchal and Kelan Atul Doshi, were introduced by Karvy Stock Broking Ltd and a list of 50 names attached with these forms were also certified by Karvy stock Broking Ltd. The remaining 21 saving bank accounts (40 nos. - 19 nos.) pertaining to Roopal Panchal were not introduced by Karvy stock broking Ltd. In respect of these 21 savings bank accounts it was observed that a list of 50 names were attached to each account and the list attached to as many as 19 savings bank accounts were certified by Karvy Consultants Ltd. (except in 2 cases) with the rubber stamp of Karvy Consultants and signature of Karvy's official affixed on the list of 50 names. The list of 40 bank accounts held with IOB Thaltej Branch is given below.

IOB Thaltej Branch Bank Accounts Sr No.

Name of the Bank Account Holder Bank Account No Date of Opening Bank Account Name of the Introducer Remark

1. Roopal Naresh Bhai Panchal and 50 others List of 50 applicants attached starting with DAKSHA PANCHAL To DRUMIL PANCHAL 11954 09.10.2004 Deepak J Panchal - SB 11407

-

2. Arjav N Panchal and Roopal Nareshbhai Panchal List of 50 applicants attached starting with MADHURI PANCHAL To PADMA PANCHAL 11969 11.10.2004

-

KCL had identified the list of name by affixing a signature and rubber stamp.

3. Narmadaben M Panchal and Roopal N Panchal List of 50 applicants attached starting with PADMINI PANCHAL To DILESH PANCHAL 11970 11.10.2004

-

KCL had identified the list of name by affixing a signature and rubber stamp.

4. Ranchhodlal N Panchal and Roopal Naresh Bhai Panchal List of 50 applicants attached starting with DILIP PANCHAL To HANISHA PANCHAL 11971 11.10.2004 SB 11407 (Dipak Panchal) KCL had identified the list of name by affixing a signature and rubber stamp

5. Naresh N Panchal and Roopal Naresh Bhai Panchal List of 50 applicants attached starting with PANCHAL To DRUMIL PANCHAL 11972 11.10.2004 SB 11407 (Dipak Panchal) KCL had identified the list of name by affixing a signature and rubber stamp

6. Devangi D Panchal and Roopal Naresh Bhai Panchal List of 50 applicants attached starting with SAMAR PANCHAL To UJAS PANCHAL 11973 11.10.2004 SB 11407 (Dipak Panchal) KCL had identified the list of name by affixing a signature and rubber stamp

7. Dipak J Panchal and Roopal Naresh Bhai Panchal list of 50 applicants attached starting with KANWAL PANCHAL To NAMRESH PANCHAL 11974 11.10.2004 SB 11407 (Dipak Panchal) KCL had identified the list of name by affixing a signature and rubber stamp

8. Nikunj B Modi and Roopal Naresh Bhai Panchal List of 50 applicants attached starting with UJJVAL PANCHAL To KANDAR PANCHAL 11975 11.10.2004

-

KCL had identified the list of name by affixing a signature and rubber stamp

9. Pramilaben R Panchal and Roopal Naresh Bhai Panchal List of 50 applicants attached starting with AJEY PANCHAL To NAREN MODI 11976 11.10.2004 SB 11407 (Dipak Panchal) KCL had identified the list of name by affixing a signature and rubber stamp

10. Vijay G Kalas and Roopal N Panchal List of 50 applicants attached starting with NANDAN PANCHAL To AJAY PANCHAL 11977 11.10.2004 SB 11407 (Dipak Panchal) KCL had identified the list of name by affixing a signature and rubber stamp

11. Roopal Naresh Bhai Panchal and 50 others List of 50 applicants attached starting with BANSI SETH To BEENA SETH 11982 11.10.2004 SB 11407 (Dipak Panchal) KCL had identified the list of name by affixing a signature and rubber stamp

12. Roopal Nareshb bhai Panchal List of 50 applicants attached starting with DIPAK JASVANTLAL To DEVENBHAI KANAIYALAL 11983 11.10.2004 SB 11407 (Dipak Panchal) KCL had identified the list of name by affixing a signature and rubber stamp

13. Govindbhai N Khala and Roopal N Panchal List of 50 applicants attached starting with HASIT SETH To KAMALA SETH 11984 11.10.2004 SB 11407 (Dipak Panchal) KCL had identified the list of name by affixing a signature and rubber stamp

14. Ramilaben G Kalas and Roopal N Panchal List of 50 applicants attached starting with LITESH SETH To SHAILESH SETH 11985 11.10.2004 SB 11407 (Dipak Panchal) KCL had identified the list of name by affixing a signature and rubber stamp

15. Khalas Sanjay Govindbhai and Roopal N Panchal List of 50 applicants attached starting with BIMAL SETH To DISHIT SETH 11986 11.10.2004 SB 11407 (Dipak Panchal) KCL had identified the list of name by affixing a signature and rubber stamp

16. Sandeep G Kalas and Roopal N Panchal List of 50 applicants attached starting with AMRIT SETH To BRAHMI SETH 11987 11.10.2004 SB 11407 (Dipak Panchal) KCL had identified the list of name by affixing a signature and rubber stamp

17. Modi Babulal S and Roopal N Panchal List of 50 applicants attached starting with DHAVAL SETH To TIRTHAL SETH 11988 11.10.2004 SB 11407 (Dipak Panchal) KCL had identified the list of name by affixing a signature and rubber stamp

18. Modi Madhubala B and Roopal N Panchal List of 50 applicants attached starting with LAPESH SETH To LAVANYA SETH 11989 11.10.2004 SB 11407 (Dipak Panchal) KCL had identified the list of name by affixing a signature and rubber stamp

19. Hetal N Modi and Roopal N Panchal List of 50 applicants attached starting with NAINESH SETH To ALKA SETH 11990 11.10.2004 SB 11407 (Dipak Panchal) KCL had identified the list of name by affixing a signature and rubber stamp

20. Hinaben B Panchal and Roopal N Panchal List of 50 applicants attached starting with ANJAL KADIA To VEDANT KADIA 12000 13.10.2004 SB 11407 (Dipak Panchal) KCL had identified the list of name by affixing a signature and rubber stamp

21. Kantilal J Shah and Roopal N Panchal List of 50 applicants attached starting with RELIKA KADIA To ANITA KADIA 12001 13.10.2004 SB 11407 (Dipak Panchal)

-

22. Kelan Atul Doshi and 50 others List of 50 applicants attached starting with DARPAN RAJESH SHAH To NEHA MANILAL THAKKAR 12004 N.A.

KSBL KSBL had identified the list of name by affixing a signature and rubber stamp

23. Roopal N Panchal & DEVANGI DIPAKBHAI PANCHAL list of 50 applicants attached starting with BADRI SHROFF to MAHENDRA SHROFF 12131 9.03.2005 KSBL KSBL had identified the list of name by affixing a signature and rubber stamp

24. ROOPAL N PANCHAL& DEVANGI DIPAKBHAI PANCHAL list of 50 applicants attached starting with MAHIPAL SHROFF to HEJHAL SHROFF 12132 9.03.2005 KSBL KSBL had identified the list of name by affixing a signature and rubber stamp

25. ROOPAL N PANCHAL& DEVANGI DIPAKBHAI PANCHAL list of 50 applicants attached starting with HELENA SHROFF to KANAK SHROFF 12133 9.03.2005 KSBL KSBL had identified the list of name by affixing a signature and rubber stamp

26. ROOPAL N PANCHAL7 DEVANGI DIPAKBHAI PANCHAL list of 50 applicants attached starting with KAPIL SHROFF to CHANDAN SHROFF 12134 9.03.2005 KSBL KSBL had identified the list of name by affixing a signature and rubber stamp

27. ROOPAL N PANCHAL& DEVANGI DIPAKBHAI PANCHAL list of 50 applicants attached starting with CHANDRA SHROFF to RAMANI SHROFF 12135 9.03.2005 KSBL KSBL had identified the list of name by affixing a signature and rubber stamp

28. ROOPAL N PANCHAL& DEVANGI DIPAKBHAI PANCHAL list of 50 applicants attached starting with RASHMI SHROFF to AGRIKA SHROFF 12136 9.03.2005 KSBL KSBL had identified the list of name by affixing a signature and rubber stamp

29. ROOPAL N PANCHAL& DEVANGI DIPAKBHAI PANCHAL list of 50 applicants attached starting with AISHVARYA SHROFF to VIDUR SHROFF 12137 9.03.2005 KSBL KSBL had identified the list of name by affixing a signature and rubber stamp

30. ROOPAL N PANCHAL& DEVANGI DIPAKBHAI PANCHAL list of 50 applicants attached starting with VINAT SHROFF to AMIT SHROFF 12138 9.03.2005 KSBL KSBL had identified the list of name by affixing a signature and rubber stamp

31. ROOPAL N PANCHAL& DEVANGI DIPAKBHAI PANCHAL list of 50 applicants attached starting with RADHIKA SHROFF to NIRMAN SETH 12139 9.03.2005 KSBL KSBL had identified the list of name by affixing a signature and rubber stamp

32. ROOPAL N PANCHAL DEVANGI DIPAKBHAI PANCHAL list of 50 applicants attached starting with SURESH SETH to ADITI SETH 12140 9.03.2005 KSBL KSBL had identified the list of name by affixing a signature and rubber stamp

33. ROOPAL N PANCHAL& DEVANGI DIPAKBHAI PANCHAL list of 50 applicants attached starting with RAGHU SHROFF to NALANDA SHROFF 12145 10.03.2005 KSBL KSBL had identified the list of name by affixing a signature and rubber stamp

34. ROOPAL N PANCHAL & DEVANGI DIPAKBHAI PANCHAL list of 50 applicants attached starting with DAKSHANT SHROFF to MUSKAN SHROFF 12146 10.03.2005 KSBL KSBL had identified the list of name by affixing a signature and rubber stamp

35. ROOPAL N PANCHAL& DEVANGI DIPAKBHAI PANCHAL list of 50 applicants attached starting with NAMRATA SHROFF to BADRESH SHROFF 12147 10.03.2005 KSBL KSBL had identified the list of name by affixing a signature and rubber stamp

36. ROOPAL N PANCHAL& DEVANGI DIPAKBHAI PANCHAL list of 50 applicants attached starting with NITIN DABHI to ROMI DABHI 12148 10.03.2005 KSBL KSBL had identified the list of name by affixing a signature and rubber stamp

37. ROOPAL N PANCHAL& DEVANGI DIPAKBHAI PANCHAL list of 50 applicants attached starting with TVATA DABHI to BHAGYESH DABHI 12149 10.03.2005 KSBL KSBL had identified the list of name by affixing a signature and rubber stamp

38. ROOPAL N PANCHAL& DEVANGI DIPAKBHAI PANCHAL list of 50 applicants attached starting with DHIREN DABHI to TISHA DABHI 12150 10.03.2005 KSBL KSBL had identified the list of name by affixing a signature and rubber stamp

39. ROOPAL N PANCHAL& DEVANGI DIPAKBHAI PANCHAL list of 50 applicants attached starting with KAHAN DABHI to MANTHAN DABHI 12151 10.03.2005 KSBL KSBL had identified the list of name by affixing a signature and rubber stamp

40. ROOPAL N PANCHAL& DEVANGI DIPAKBHAI PANCHAL list of 22 applicants attached starting with NRUPAL DABHI to ALKA DABHI list of 20 applicants attached starting with DARSHI SHROFF to DWIPA SHROFF 12152 10.03.2005 KSBL KSBL had identified the list of name by affixing a signature and rubber stamp 9.22. When KSBL introduced the said accounts in March 2005, it was not a DP.

9.23. From the above table, it may be seen that in most of the instances, the 50 account- holders added to each bank account number were sharing the same surnames. The names added to the bank accounts were in the same order as that in which the dematerialized accounts were held with Karvy DP. For instance, the list of 50 names added to the bank account no. 11954, began with Daksha Panchal and ended with Drumil Panchal. It may be recalled that, as narrated in an earlier part of this order, in the set of 100 dematerialized account-holders of Karvy DP having the surname of 'Luhar', the names of 'Daksha' to 'Drumil' appeared as the first 50 names. Further, in many instances, the bank accounts to which the 50 names were added were bearing continuous numbers. It is observed that such an arrangement was made for availing IPO finance from IOB.

9.24. On perusal of the documents pertaining to the bank accounts, it is seen that all the signatures have been made with the same pen and by the same person in one go. It may be noted that all the names contained in the list attached to the application forms had dematerialized accounts with Karvy DP and had been identified as afferent accounts.

9.25. In this regard, I note that at para 14.10 of its reply dated May 19, 2007, Karvy DP stated "It is not understood as to on what basis it has been held that KCL had certified that all the respective applicants are maintaining their demat accounts with them and that KCL had also certified their signatures. For any such certification, any person of normal intelligence would have sought the demat account number along with the name and signature, which is not the case in the list that has been brought out."

9.26. In this context, I note that the DP in its appeal memorandum (Appeal NO. 92 of 2006) inter alia stated that "... the Appellant had not introduced the said 50 clients to IOB Thaltej. The appellant has only certified pursuant to IPO sub- broker, that the said 50 demat accounts with the Appellant. It is submitted that all the said 50 clients had, as per appellant's record, bank accounts with BHOB. Therefore, the certification given by the Appellant was for existence of demat account as sought to be suggested".

9.27. The submissions of Karvy DP in its reply dated May 19, 2007 contradicts the earlier submissions made by it before the Hon'ble SAT. In any case, I note that the bank account opening forms did contain enclosures listing out the dematerialized account particulars of the 50 names added to the IOB bank account.Also, the names added to the bank accounts were in the same order as that in which the dematerialized accounts were held with Karvy DP. Therefore, the denial of Karvy that it did not certify to IOB that the 50 names added to the bank accounts had dematerialized accounts with Kavy DP is merely a denial of convenience.

9.28. Observations on Savings Bank Account No. 12140 with IOB, Ahmedabad Introduced By Karvy Out of the 19 bank accounts of Roopal Panchal group that were introduced by KSBL and where there were additions of 50 names certified by KSBL, one bank account having no.12140 was randomly selected for examination. The observations emerging from the same is narrated below:

9.29. A perusal of account opening form of savings bank account number 12140 with IOB, Thaltej Branch, Ahmedabad in the name of Roopal Nareshbhai Panchal and Devangi Dipakbhai Panchal bearing the address 402, Shashwat Opp Gujarat College, Ellisbrdige, Ahmedabad 3800006 reveals as under:

? The said account (opened on March 9, 2005) was introduced by M/s. Karvy Stock Broking Ltd.

? A list of 50 names and specimen signatures is attached to the account opening form and the list is certified by Karvy Stock Broking Ltd. with their rubber stamp affixed.

? The rubber stamp of Karvy on the main bank account introduction column and that in the attached list is similar.

? The signature of the representative of Karvy as appearing on the main bank account introduction column and that in the attached list appears to have been made with the same pen.

? The list of 50 names and signatures bears the account number 12140 on the top right hand side of the list.

? The 50 applicants bear common surname "SETH" starting from SURESH SETH and ending with ADITI SETH.

? The signatures of the 50 applicants are in English, Hindi and Gujarathi and appear to have been made by the same person.

9.30. Further, it is seen that Karvy DP held the dematerialized accounts of the 50 names that were added to the bank account no.12140 and the dematerialized accounts had been opened prior to the opening of the bank account. The details are as below:

Sr. No. DP ID CLIENT ID IOB Thaltej Bank Account No. Name Of The Demat / Bank Account Holder Date Of Opening Of Demat Account Date Of Opening Of Bank Account

1. IN300394 13130266 12140 SURESH SETH 05.01.2004 9.03.2005

2. IN300394 13130274 12140 ABHAY SETH 05.01.2004 9.03.2005

3. IN300394 13130299 12140 DEVANSHI SETH 05.01.2004 9.03.2005

4. IN300394 13130303 12140 GULJAR SETH 05.01.2004 9.03.2005

5. IN300394 13130310 12140 JENNY SETH 05.01.2004 9.03.2005

6. IN300394 13130329 12140 LABDHA SETH 05.01.2004 9.03.2005

7. IN300394 13130338 12140 YASHI SETH 05.01.2004 9.03.2005

8. IN300394 13130346 12140 NIRU SETH 05.01.2004 9.03.2005

9. IN300394 13130354 12140 NITA SETH 05.01.2004 9.03.2005 10 IN300394 13130362 12140 UTPALL SETH 05.01.2004 9.03.2005 11 IN300394 13130379 12140 ABHIGNA SETH 05.01.2004 9.03.2005 12 IN300394 13130387 12140 BALWANT SETH 05.01.2004 9.03.2005 13 IN300394 13130395 12140 DEVARSHI SETH 05.01.2004 9.03.2005 14 IN300394 13130409 12140 GUMAN SETH 05.01.2004 9.03.2005 15 IN300394 13130418 12140 JHANKI SETH 05.01.2004 9.03.2005 16 IN300394 13130426 12140 LAGNI SETH 05.01.2004 9.03.2005 17 IN300394 13130434 12140 YASHU SETH 05.01.2004 9.03.2005 18 IN300394 13130442 12140 NIRUPAMA SETH 05.01.2004 9.03.2005 19 IN300394 13130459 12140 NITANSH SETH 05.01.2004 9.03.2005 20 IN300394 13130467 12140 SWATI SETH 05.01.2004 9.03.2005 21 IN300394 13130475 12140 ABHILASH SETH 05.01.2004 9.03.2005 22 IN300394 13130483 12140 BALWIR SETH 05.01.2004 9.03.2005 23 IN300394 13130490 12140 DEVASYA SETH 05.01.2004 9.03.2005 24 IN300394 13130506 12140 GUNISH SETH 05.01.2004 9.03.2005 25 IN300394 13130514 12140 JIGAR SETH 05.01.2004 9.03.2005 26 IN300394 13130522 12140 LAHAR SETH 05.01.2004 9.03.2005 27 IN300394 13130539 12140 YATNA SETH 05.01.2004 9.03.2005 28 IN300394 13130547 12140 NIRVI SETH 05.01.2004 9.03.2005 29 IN300394 13130555 12140 NITIN SETH 05.01.2004 9.03.2005 30 IN300394 13130563 12140 TRUSHIT SETH 05.01.2004 9.03.2005 31 IN300394 13130570 12140 ABHISHEK SETH 05.01.2004 9.03.2005 32 IN300394 13130589 12140 BANJUL 05.01.2004 9.03.2005 33 IN300394 13130598 12140 DEVENDRA SETH 05.01.2004 9.03.2005 34 IN300394 13130602 12140 GUNJAK SETH 05.01.2004 9.03.2005 35 IN300394 13130619 12140 JIGISH SETH 05.01.2004 9.03.2005 36 IN300394 13130627 12140 LAJJA SETH 05.01.2004 9.03.2005 37 IN300394 13130635 12140 YATRI SETH 05.01.2004 9.03.2005 38 IN300394 13130643 12140 NISAR SETH 05.01.2004 9.03.2005 39 IN300394 13130650 12140 DEPARV SETH 05.01.2004 9.03.2005 40 IN300394 13130669 12140 TUKHAR SETH 05.01.2004 9.03.2005 41 IN300394 13130678 12140 ADIP SETH 05.01.2004 9.03.2005 42 IN300394 13130686 12140 BANKIM SETH 05.01.2004 9.03.2005 43 IN300394 13130694 12140 DEVI SETH 05.01.2004 9.03.2005 44 IN300394 13130717 12140 JIMISH SETH 05.01.2004 9.03.2005 45 IN300394 13130725 12140 LAKENDRA SETH 05.01.2004 9.03.2005 46 IN300394 13130733 12140 YAVAN SETH 05.01.2004 9.03.2005 47 IN300394 13130740 12140 MIYA SETH 05.01.2004 9.03.2005 48 IN300394 13130759 12140 ROHINI SETH 05.01.2004 9.03.2005 49 IN300394 13130768 12140 TURANG SETH 05.01.2004 9.03.2005 50 IN300394 13130776 12140 ADITI SETH 05.01.2004 9.03.2005 9.31. A cursory look at the names appearing in the list suggests that they could be names of fictitious persons in view of the pattern of the names mentioned in the list i.e. 50 different names with same surname of SETH. The signatures of the 50 persons also appear similar and appear to have been made by one person only. Anyway all afferent accounts have been found to be fictitious. Accordingly it would follow that only one central / control person could have signed. Therefore, from the above observations on the bank account opening form (account no. 12140) wherein Karvy Stock Broking Ltd had certified the account holders, it stands to reason that Karvy were aware that the names and signatures are of fictitious persons.

9.32. In this regard, KSBL in its reply dated May 19, 2007 has contended that the list of 50 names is a separate document and is not connected to the savings connected. I do not find merit in the argument of Karvy since the relevant documents were submitted by the concerned bank i.e. IOB. If the documents were not relating to savings account, the bank would not have come to possess the document.

9.33. Karvy had further contended that the documents attached to the bank account no. 12140 pertain to another bank account bearing no.11983. In this regard I note that the documents are in one set kept together with the savings account opening form of account no.12140. Also the list of 50 names attached to the account no. 12140 mentions in the account no.12140 in the top right hand corner. In any case, I note that the savings account 11983 also had a list of 50 names added and the name addition in that case was certified by KCL. Therefore, I do not find merit in this argument of Karvy.

9.34. Further Karvy had contended that "it can't be held that the employee of the company had introduced 50 additional names." In this context it is relevant to note that Karvy DP in its appeal memorandum (Appeal NO. 92 of 2006) inter alia stated that "... the Appellant had not introduced the said 50 clients to IOB Thaltej. The appellant has only certified pursuant to IOB sub- broker, that the said 50 demat accounts with the Appellant. It is submitted that all the said 50 clients had, as per appellant's record, bank accounts with BHOB. Therefore, the certification given by the Appellant was for existence of demat account as sought to be suggested".

9.35. Therefore, I find that indeed 50 names were added to the SB account no.12140 of Roopal Panchal group held with IOB, Thaltej branch and Karvy had indeed introduced the bank account and certified the names added to the bank account. In this regard, I note that Karvy DP had an arrangement with IOB along the same lines as that with BhOB, whereby, IOB provided IPO finance to the dematerialized account-holders of Karvy DP.

9.36. In the demat system, the bank accounts of all the above afferent dematerialized account-holders have indicated as being held with BhOB and the account number indicated is 54119. It may be recalled that the BhOB account no.54119 is Devangi Dipakbhai Panchal group account that had been introduced by Karvy Securities Ltd. on December 4, 2003. Threfore, it follows that after the opening of bank group account of Devangi Dipakbhai Panchal on December 4, 2003, Karvy DP opened their dematerialized accounts on January 5, 2004 and thereafter, the DP introduced these names to IOB Thaltej during March 2005 for the purpose of opening bank accounts and availing IPO finance. In this context, it may recalled that Karvy DP had an arrangement with IOB also on the same lines as with BhOB.

9.37. The various unique characteristics relating to the add-on list of the IOB bank account demonstrates a common modus operandi with a common control. All the above 50 are existing dematerialized account holders with Karvy and their demat accounts were opened in January 2004 on the basis of single BHOB account with sub-numbers opened in December 2003 with the introduction of Karvy Securities Ltd. Thus there is a clear nexus between the genesis of these accounts and their subsequent reappearance with IOB in March 2005 for availing IPO finance. These are all incontrovertible factual data.

9.38. Further, there is a continuity in the said pattern from December 2003 to March 2005 and thereafter as well which can hardly escape anybody's attention. Also the key operators account had been introduced by KSBL, while the add-on list had been certified by KSBL by affixing rubber stamp and signature as admitted in the grounds of appeal before SAT. KSBL has taken the stand in its reply dated May 19, 2007 in the present proceedings that "simply because employees of Karvy had introduced the accounts and perhaps put the address or stamp of the company on the forms it cannot be concluded that the company was aware of the activities of the employees." Such a shifting stance hardly canvasses any strength for Karvy's defence.

9.39. Further as per the arrangement with IOB, IOB was to provide IPO finance only to those borrowers having demat accounts with Karvy DP or IOB DP. Therefore Karvy cannot distance itself from the arrangement by putting the blame on employees. In any event Karvy is responsible.

9.40. In such a context, Karvy was not only aware of fictitious accounts but also was actively involved in scouting financial package for such non-existing persons, on the basis of fictitious demat accounts (afferent accounts). It is a matter of record that Karvy was only dealing with the key operators and as such was a privy to the arrangement Karvy had with the key operators in opening bank accounts and afferent demat accounts and arranging IPO finance.

9.41. Combinations of 50 Names with different surnames in Karvy DP on CDSL Sr.

No.

Surname No.

of CDSL Demat Accounts

1. Zala 50

2. Rathod 50

3. Vania 50

4. Patil 50

5. Ranka 50

6. Pandya 50

7. Desai 50

8. Rathi 50

9. Verma 50

10. Trivedi 50

11. Gandhi 50

12. Barot 50

13. Vala 50

14. Pathak 50

15. Bhatt 50 Sr. No. Surname No. of CDSL Demat Accounts   Total 750 9.42. The details of dematerialized accounts in respect of two such surnames viz. Zala and Pandya are as below:

BOID Acc Op Date BOName BOAdd BOCity Bank Acc No BenBank Name 1301440000056768 15072005 SURESH ZALA.

Office No.403, Shashwat Bldg.

AHMEDABAD 9550-10048 BHOB 1301440000056772 15072005 ABHAY ZALA.

Office No.403, Shashwat Bldg.

AHMEDABAD 9550-10049 BHOB 1301440000056787 15072005 DEVANSHI ZALA.

Office No.403, Shashwat Bldg.

AHMEDABAD 9550-10050 BHOB 1301440000056791 15072005 GULJAR ZALA.

Office No.403, Shashwat Bldg.

AHMEDABAD 9550-10051 BHOB 1301440000056808 15072005 JENNY ZALA.

Office No.403, Shashwat Bldg.

AHMEDABAD 9550-10052 BHOB 1301440000056812 15072005 LABDHA ZALA.

Office No.403, Shashwat Bldg.

AHMEDABAD 9550-10053 BHOB 1301440000056827 15072005 YASHI ZALA.

Office No.403, Shashwat Bldg.

AHMEDABAD 9550-10054 BHOB 1301440000056831 15072005 NIRU ZALA Office No.403, Shashwat Bldg.

AHMEDABAD 9550-10055 BHOB 1301440000056846 15072005 NITA ZALA Office No.403, Shashwat Bldg.

AHMEDABAD 9550-10056 BHOB 1301440000056850 15072005 UTPALL ZALA.

Office No.403, Shashwat Bldg.

AHMEDABAD 9550-10057 BHOB 1301440000056865 15072005 ABHIGNA ZALA.

Office No.403, Shashwat Bldg.

AHMEDABAD 9550-10058 BHOB 1301440000056871 15072005 BALWANT ZALA.

Office No.403, Shashwat Bldg.

AHMEDABAD 9550-10059 BHOB 1301440000056884 15072005 DEVARSHI ZALA.

Office No.403, Shashwat Bldg.

AHMEDABAD 9550-10060 BHOB 1301440000056899 15072005 GUMAN ZALA.

Office No.403, Shashwat Bldg.

AHMEDABAD 9550-10061 BHOB 1301440000056905 15072005 JHANKI ZALA.

Office No.403, Shashwat Bldg.

AHMEDABAD 9550-10062 BHOB 1301440000056911 15072005 LAGNI ZALA.

Office No.403, Shashwat Bldg.

AHMEDABAD 9550-10063 BHOB 1301440000056924 15072005 YASHU ZALA.

Office No.403, Shashwat Bldg.

AHMEDABAD 9550-10064 BHOB 1301440000056939 15072005 NIRUPAMA ZALA.

Office No.403, Shashwat Bldg.

AHMEDABAD 9550-10065 BHOB 1301440000056943 15072005 NITANSH ZALA.

Office No.403, Shashwat Bldg.

AHMEDABAD 9550-10066 BHOB 1301440000056958 15072005 SWATI ZALA.

Office No.403, Shashwat Bldg.

AHMEDABAD 9550-10067 BHOB 1301440000056962 15072005 ABHILASH ZALA.

Office No.403, Shashwat Bldg.

AHMEDABAD 9550-10068 BHOB 1301440000056977 15072005 BALWIR ZALA.

Office No.403, Shashwat Bldg.

AHMEDABAD 9550-10069 BHOB 1301440000056981 15072005 DEVASYA ZALA.

Office No.403, Shashwat Bldg.

AHMEDABAD 9550-10070 BHOB 1301440000056996 15072005 GUNISH ZALA.

Office No.403, Shashwat Bldg.

AHMEDABAD 9550-10071 BHOB 1301440000057003 15072005 JIGAR ZALA.

Office No.403, Shashwat Bldg.

AHMEDABAD 9550-10072 BHOB 1301440000057018 15072005 LAHAR ZALA.

Office No.403, Shashwat Bldg.

AHMEDABAD 9550-10073 BHOB 1301440000057022 15072005 YATNA ZALA.

Office No.403, Shashwat Bldg.

AHMEDABAD 9550-10074 BHOB 1301440000057037 15072005 NIRVI ZALA.

Office No.403, Shashwat Bldg.

AHMEDABAD 9550-10075 BHOB 1301440000057041 15072005 NITIN ZALA.

Office No.403, Shashwat Bldg.

AHMEDABAD 9550-10076 BHOB 1301440000057056 15072005 TRUSHIT ZALA.

Office No.403, Shashwat Bldg.

AHMEDABAD 9550-10077 BHOB 1301440000057060 15072005 ABHISHEK ZALA.

Office No.403, Shashwat Bldg.

AHMEDABAD 9550-10078 BHOB 1301440000057075 15072005 BANJUL .

Office No.403, Shashwat Bldg.

AHMEDABAD 9550-10079 BHOB 1301440000057081 15072005 DEVENDRA ZALA.

Office No.403, Shashwat Bldg.

AHMEDABAD 9550-10080 BHOB 1301440000057094 15072005 GUNJAK ZALA.

Office No.403, Shashwat Bldg.

AHMEDABAD 9550-10081 BHOB 1301440000057100 15072005 JIGISH ZALA.

Office No.403, Shashwat Bldg.

AHMEDABAD 9550-10082 BHOB 1301440000057115 15072005 LAJJA ZALA.

Office No.403, Shashwat Bldg.

AHMEDABAD 9550-10083 BHOB 1301440000057121 15072005 YATRI ZALA.

Office No.403, Shashwat Bldg.

AHMEDABAD 9550-10084 BHOB 1301440000057134 15072005 NISAR ZALA.

Office No.403, Shashwat Bldg.

AHMEDABAD 9550-10085 BHOB 1301440000057149 15072005 DEPARV ZALA.

Office No.403, Shashwat Bldg.

AHMEDABAD 9550-10086 BHOB 1301440000057153 15072005 TUKHAR ZALA.

Office No.403, Shashwat Bldg.

AHMEDABAD 9550-10087 BHOB 1301440000057168 15072005 ADIP ZALA Office No.403, Shashwat Bldg.

AHMEDABAD 9550-10088 BHOB 1301440000057172 15072005 BANKIM ZALA.

Office No.403, Shashwat Bldg.

AHMEDABAD 9550-10089 BHOB 1301440000057187 15072005 DEVI ZALA Office No.403, Shashwat Bldg.

AHMEDABAD 9550-10090 BHOB 1301440000057191 15072005 JIMISH ZALA.

Office No.403, Shashwat Bldg.

AHMEDABAD 9550-10091 BHOB 1301440000057208 15072005 LAKENDRA ZALA.

Office No.403, Shashwat Bldg.

AHMEDABAD 9550-10092 BHOB 1301440000057212 15072005 YAVAN ZALA.

Office No.403, Shashwat Bldg.

AHMEDABAD 9550-10093 BHOB 1301440000057227 15072005 MIYA ZALA.

Office No.403, Shashwat Bldg.

AHMEDABAD 9550-10094 BHOB 1301440000057231 15072005 ROHINI ZALA.

Office No.403, Shashwat Bldg.

AHMEDABAD 9550-10095 BHOB 1301440000057246 15072005 TURANG ZALA.

Office No.403, Shashwat Bldg.

AHMEDABAD 9550-10096 BHOB 1301440000057250 15072005 ADITI ZALA.

Office No.403, Shashwat Bldg.

AHMEDABAD 9550-10097 BHOB   BOID AccOp Date BOName BOAdd BOCity Ben Bank AccNo Bank Status 1301440000106761 16072005 SURESH PANDYA.

406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-48 BHOB Closed 1301440000106774 16072005 ABHAY PANDYA.

406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-49 BHOB Closed 1301440000106789 16072005 DEVANSHI PANDYA.

406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-50 BHOB Closed 1301440000106793 16072005 GULJAR PANDYA.

406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-51 BHOB Closed 1301440000106801 16072005 JENNY PANDYA.

406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-52 BHOB Closed 1301440000106814 16072005 LABDHA PANDYA.

406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-53 BHOB Closed 1301440000106829 16072005 YASHI PANDYA.

406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-54 BHOB Closed 1301440000106833 16072005 NIRU PANDYA.

406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-55 BHOB Closed 1301440000106848 16072005 NITA PANDYA.

406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-56 BHOB Closed 1301440000106852 16072005 UTPALL PANDYA.

406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-57 BHOB Closed 1301440000106867 16072005 ABHIGNA PANDYA.

406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-58 BHOB Closed 1301440000106871 16072005 BALWANT PANDYA.

406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-59 BHOB Closed 1301440000106886 16072005 DEVARSHI PANDYA.

406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-60 BHOB Closed 1301440000106890 16072005 GUMAN PANDYA.

406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-61 BHOB Closed 1301440000106907 16072005 JHANKI PANDYA.

406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-62 BHOB Closed 1301440000106911 16072005 LAGNI PANDYA.

406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-63 BHOB Closed 1301440000106926 16072005 YASHU PANDYA.

406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-64 BHOB Closed 1301440000106930 16072005 NIRUPAMA PANDYA.

406, SHASHWAT OPP. GUJARAT COLLEGE AHMED AB AD 9550-65 BHOB Closed 1301440000106945 16072005 NITANSH PANDYA.

406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-66 BHOB Closed 1301440000106951 16072005 SWATI PANDYA.

406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-67 BHOB Closed 1301440000106964 16072005 ABHILASH PANDYA.

406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-68 BHOB Closed 1301440000106979 16072005 BALWIR PANDYA.

406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-69 BHOB Closed 1301440000106983 16072005 DEVASYA PANDYA.

406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-70 BHOB Closed 1301440000106998 16072005 GUNISH PANDYA.

406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-71 BHOB Closed 1301440000107005 16072005 JIGAR PANDYA.

406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-72 BHOB Closed 1301440000107011 16072005 LAHAR PANDYA.

406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-73 BHOB Closed 1301440000107024 16072005 YATNA PANDYA.

406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-74 BHOB Closed 1301440000107039 16072005 NIRVI PANDYA.

406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-75 BHOB Closed 1301440000107043 16072005 NITIN PANDYA.

406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-76 BHOB Closed 1301440000107058 16072005 TRUSHIT PANDYA.

406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-77 BHOB Closed 1301440000107062 16072005 ABHISHEK PANDYA.

406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-78 BHOB Closed 1301440000107077 16072005 BANJUL PANDYA.

406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-79 BHOB Closed 1301440000107081 16072005 DEVENDRA PANDYA.

406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-80 BHOB Closed 1301440000107096 16072005 GUNJAK PANDYA.

406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-81 BHOB Closed 1301440000107102 16072005 JIGISH PANDYA.

406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-82 BHOB Closed 1301440000107117 16072005 LAJJA PANDYA.

406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-83 BHOB Closed 1301440000107121 16072005 YATRI PANDYA.

406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-84 BHOB Closed 1301440000107136 16072005 NISAR PANDYA.

406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-85 BHOB Closed 1301440000107140 16072005 DEPARV PANDYA.

406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-86 BHOB Closed 1301440000107155 16072005 TUKHAR PANDYA.

406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-87 BHOB Closed 1301440000107161 16072005 ADIP PANDYA.

406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-88 BHOB Closed 1301440000107174 16072005 BANKIM PANDYA.

406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-89 BHOB Closed 1301440000107189 16072005 DEVI PANDYA.

406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-90 BHOB Closed 1301440000107193 16072005 JIMISH PANDYA.

406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-91 BHOB Closed 1301440000107201 16072005 LAKENDRA PANDYA.

406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-92 BHOB Closed 1301440000107214 16072005 YAVAN PANDYA.

406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-93 BHOB Closed 1301440000107229 16072005 MIYA PANDYA.

406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-94 BHOB Closed 1301440000107233 16072005 ROHINI PANDYA.

406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-95 BHOB Closed 1301440000107248 16072005 TURANG PANDYA.

406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-96 BHOB Closed 1301440000107252 16072005 ADITI PANDYA.

406, SHASHWAT OPP. GUJARAT COLLEGE AHMEDABAD 9550-97 BHOB Closed Note: It may be seen from discussions in later paragraphs that KCL had provided IPO finance in respect of the above dematerialized account-holders i.e. SURESH PANDYA to ADITI PANDYA 9.43. The BHOB bank account number 9550 is indicated as the bank account of the above demat account holders. Upon perusal of the account opening form of the BHOB bank account number 9550 it is seen that the said account is held in the name of 'Arjav Naresh Panchal' and the account had been introduced by Devangi Dipak Panchal having the address 402-403, Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad 380 006. The account had been opened in December 2004.

9.44. It is observed that the 750 demat accounts were opened on CDSL during July 15 - 16, 2005 and were activated on July 15-16, 2005 i.e. during the period of IDFC IPO. Thereafter, during the course of verification of genuineness of demat clients in the wake of SEBI's preliminary enquiry in the matter of Yes Bank IPO, the dematerialized accounts were closed. These afferent accounts closely match the ones noticed in the context of IOB accounts opened earlier in March 2005. The CDSL demat accounts were opened for making applications in IDFC IPO and it is seen that KCL had provided IPO finance to the fictitious applicants having their demat accounts with CDSL. The details of the same have been discussed elsewhere in this order.

9.45. Karvy DP CDSL Accounts pending Activation with names of Suresh to Aditi It was found that the same pattern of opening of demat accounts with the same 50 first names from 'SURESH' to 'ADITI' and various surnames had been adopted in respect of 500 dematerialized accounts opened with Karvy DP on September 22, 2005 that were pending for activation. The table below indicates the details of the demat accounts which are pending for activation:

Sr.

No.

Surname No.

of CDSL Demat Accounts Date of Opening demat accounts Remarks

1. Kapur 50 September 22, 2005 Demat accounts opened and pending activation

2. Tated 50 As above As above

3. Kela 50 As above As above

4. Sen 50 As above As above

5. Roy 50 As above As above

6. Irani 50 As above As above

7. Jha 50 As above As above

8. Mehta 50 As above As above

9. Das 50 As above As above

10. Prasad 50 As above As above   Total 500     9.46. The details of the above 500 CDSL dematerialized accounts held with Karvy DP opened on September 22, 2005 and pending activation is given below:

BOID AccOpDate BOName BO Address BOCity BenBankAccNo BANK NAME 1301440000410188 22092005 SURESH TATED.

Office No.402, Shashwat Bldg.

AHD 2611-16048 IOB 1301440000410192 22092005 ABHAY TATED.

Office No.402, Shashwat Bldg.

AHD 2611-16049 IOB 1301440000410209 22092005 DEVANSHI TATED.

Office No.402, Shashwat Bldg.

AHD 2611-16050 IOB 1301440000410213 22092005 GULJAR TATED.

Office No.402, Shashwat Bldg.

AHD 2611-16051 IOB 1301440000410228 22092005 JENNY TATED.

Office No.402, Shashwat Bldg.

AHD 2611-16052 IOB 1301440000410232 22092005 LABDHA TATED.

Office No.402, Shashwat Bldg.

AHD 2611-16053 IOB 1301440000410247 22092005 YASHI TATED.

Office No.402, Shashwat Bldg.

AHD 2611-16054 IOB 1301440000410251 22092005 NIRU TATED.

Office No.402, Shashwat Bldg.

AHD 2611-16055 IOB 1301440000410266 22092005 NITA TATED.

Office No.402, Shashwat Bldg.

AHD 2611-16056 IOB 1301440000410270 22092005 UTPALL TATED.

Office No.402, Shashwat Bldg.

AHD 2611-16057 IOB 1301440000410285 22092005 ABHIGNA TATED Office No.402, Shashwat Bldg.

AHD 2611-16058 IOB 1301440000410291 22092005 BALWANT TATED.

Office No.402, Shashwat Bldg.

AHD 2611-16059 IOB 1301440000410306 22092005 DEVARSHI TATED.

Office No.402, Shashwat Bldg.

AHD 2611-16060 IOB 1301440000410310 22092005 GUMAN TATED.

Office No.402, Shashwat Bldg.

AHD 2611-16061 IOB 1301440000410325 22092005 JHANKI TATED.

Office No.402, Shashwat Bldg.

AHD 2611-16062 IOB 1301440000410331 22092005 LAGNI TATED.

Office No.402, Shashwat Bldg.

AHD 2611-16063 IOB 1301440000410344 22092005 YASHU TATED.

Office No.402, Shashwat Bldg.

AHD 2611-16064 IOB 1301440000410359 22092005 NIRUPAMA TATED.

Office No.402, Shashwat Bldg.

AHD 2611-16065 IOB 1301440000410363 22092005 NITANSH TATED Office No.402, Shashwat Bldg.

AHD 2611-16066 IOB 1301440000410378 22092005 SWATI TATED.

Office No.402, Shashwat Bldg.

AHD 2611-16067 IOB 1301440000410382 22092005 ABHILASH TATED.

Office No.402, Shashwat Bldg.

AHD 2611-16068 IOB 1301440000410397 22092005 BALWIR TATED.

Office No.402, Shashwat Bldg.

AHD 2611-16069 IOB 1301440000410403 22092005 DEVASYA TATED.

Office No.402, Shashwat Bldg.

AHD 2611-16070 IOB 1301440000410418 22092005 GUNISH TATED.

Office No.402, Shashwat Bldg.

AHD 2611-16071 IOB 1301440000410422 22092005 JIGAR TATED.

Office No.402, Shashwat Bldg.

AHD 2611-16072 IOB 1301440000410437 22092005 LAHAR TATED.

Office No.402, Shashwat Bldg.

AHD 2611-16073 IOB 1301440000410441 22092005 YATNA TATED.

Office No.402, Shashwat Bldg.

AHD 2611-16074 IOB 1301440000410456 22092005 NIRVI TATED.

Office No.402, Shashwat Bldg.

AHD 2611-16075 IOB 1301440000410460 22092005 NITIN TATED.

Office No.402, Shashwat Bldg.

AHD 2611-16076 IOB 1301440000410475 22092005 TRUSHIT TATED.

Office No.402, Shashwat Bldg.

AHD 2611-16077 IOB 1301440000410481 22092005 ABHISHEK TATED.

Office No.402, Shashwat Bldg.

AHD 2611-16078 IOB 1301440000410494 22092005 BANJUL.

Office No.402, Shashwat Bldg.

AHD 2611-16079 IOB 1301440000410500 22092005 DEVENDRA TATED.

Office No.402, Shashwat Bldg.

AHD 2611-16080 IOB 1301440000410515 22092005 GUNJAK TATED.

Office No.402, Shashwat Bldg.

AHD 2611-16081 IOB 1301440000410521 22092005 JIGISH TATED.

Office No.402, Shashwat Bldg.

AHD 2611-16082 IOB 1301440000410534 22092005 LAJJA TATED.

Office No.402, Shashwat Bldg.

AHD 2611-16083 IOB 1301440000410549 22092005 YATRI TATED.

Office No.402, Shashwat Bldg.

AHD 2611-16084 IOB 1301440000410553 22092005 NISAR TATED.

Office No.402, Shashwat Bldg.

AHD 2611-16085 IOB 1301440000410568 22092005 DEPARV TATED.

Office No.402, Shashwat Bldg.

AHD 2611-16086 IOB 1301440000410572 22092005 TUKHAR TATED.

Office No.402, Shashwat Bldg.

AHD 2611-16087 IOB 1301440000410587 22092005 ADIP TATED.

Office No.402, Shashwat Bldg.

AHD 2611-16088 IOB 1301440000410591 22092005 BANKIM TATED.

Office No.402, Shashwat Bldg.

AHD 2611-16089 IOB 1301440000410608 22092005 DEVI TATED.

Office No.402, Shashwat Bldg.

AHD 2611-16090 IOB 1301440000410612 22092005 JIMISH TATED.

Office No.402, Shashwat Bldg.

AHD 2611-16091 IOB 1301440000410627 22092005 LAKENDRA TATED.

Office No.402, Shashwat Bldg.

AHD 2611-16092 IOB 1301440000410631 22092005 YAVAN TATED.

Office No.402, Shashwat Bldg.

AHD 2611-16093 IOB 1301440000410646 22092005 MIYA TATED.

Office No.402, Shashwat Bldg.

AHD 2611-16094 IOB 1301440000410650 22092005 ROHINI TATED.

Office No.402, Shashwat Bldg.

AHD 2611-16095 IOB 1301440000410665 22092005 TURANG TATED.

Office No.402, Shashwat Bldg.

AHD 2611-16096 IOB 1301440000410671 22092005 ADITI TATED.

Office No.402, Shashwat Bldg.

AHD 2611-16097 IOB 9.47. Examination Demat Account opening forms in respect of names added to IOB Thaltej branch Account 12140 During the course of the instant proceedings, as required by SEBI, Karvy had submitted a few NSDL demat account opening forms in respect of the demat accounts list of names attached to the IOB Thaltej branch account no. 12140. The observations on the documents submitted by Karvy DP are tabulated below:

Demat Account No Name of The Applicant Address Bank Account POI / POA (Observations Of SEBI in bracket) Remarks Of SEBI 13130303 GULJAR SETH 402, Shashwat Opp Guj College, Ellisbridge, Ahmedabad 54119 / 1253 Letter from BHOB (No photograph affixed) Bank account 54119 (group account) introduced by Karvy Securities 13130475 ABHILASH SETH 402, Shashwat Opp Guj College, Ellisbridge, Ahmedabad 54119 / 1270 Letter from BHOB (No photograph affixed) Bank account 54119 (group account) introduced by Karvy Securities 13130506 GUNISH SETH 402, Shashwat Opp Guj College, Ellisbridge, Ahmedabad 54119 / 1273 Letter from BHOB (No photograph affixed) Bank account 54119 (group account) introduced by Karvy Securities 13130539 YATNA SETH 402, Shashwat Opp Guj College, Ellisbridge, Ahmedabad 54119 / 1276 Letter from BHOB (No photograph affixed) Bank account 54119 (group account) introduced by Karvy Securities 13130547 NIRVI SETH 402, Shashwat Opp Guj College, Ellisbridge, Ahmedabad 54119 / 1277 Letter from BHOB (No photograph affixed) Bank account 54119 (group account) introduced by Karvy Securities 13130570 ABHISHOK SETH 402, Shashwat Opp Guj College, Ellisbridge, Ahmedabad 54119 / 1280 Letter from BHOB (No photograph affixed) Bank account 54119 (group account) introduced by Karvy Securities 13130598 DEVANDR ASETH 402, Shashwat Opp Guj College, Ellisbridge, Ahmedabad 54119 / 1282 Letter from BHOB (No photograph affixed) Bank account 54119 (group account) introduced by Karvy Securities 13130650 DEPARV SETH 402, Shashwat Opp Guj College, Ellisbridge, Ahmedabad 54119 / 1288 Letter from BHOB (No photograph affixed) Bank account 54119 (group account) introduced by Karvy Securities 9.48. From the above table it may be seen that the IOB bank account holders introduced by Karvy to IOB Thaltej branch had indicated in the depository system, the BHOB bank account number 54119 as their bank account. It may be recalled that the said BHOB bank account number 54119 had been introduced by Karvy Securities Ltd. during December 2003.

9.49. Financing by KCL in respect of Names added to IOB Thaltej Bank account no.12140 It has been observed that out of the above set of demat accounts opened on CDSL on July 15-16, 2005 with various combination of names starting with SURESH TO ADITI, in respect of following set of names, KCL had also financed in the IPO of IDFC and KCPL had issued consolidated refund order no. 69001 in respect of these applicants. Further, it was also observed that Karvy DP had issued loose DIS slips bearing continuous serial numbers which were used for making off-market transfers from these dematerialized accounts to the dematerialized account of Roopalben Panchal.

9.50. In its reply dated May 19, 2007, Karvy DP had at para 15.2 (ii) stated "KCL had not extended finance to any of the applicants, for any of the IPOs, whose names are appearing in the sheet attached to the savings bank account opening application forms as contained in Annexure 1 to the Notice in any of the Issues. Admittedly, IOB Thaltej branch Ahmedabad, had provided IPO funding in respect of the said applicants in IDFC." The details as culled out from the allotment master and from the DIS data furnished by CDSL in respect of those dematerialized accounts / IPO applicants where KCL had provided finance in the IPO of IDFC shows that KCL had indeed provided IPO finance through various combinations of surnames of the fictitious / benami names that were added to the IOB bank account. In fact, the application money in respect of these applicants was directly remitted by KCL to the IDFC public issue escrow account through RTGS transfer and it never went through the bank accounts of the afferent entities. The details of the applications made, refund and allotment details are given below:

Mode of Financing Place of Bidding Appl_No Name of Applicant Bid Amt (Rs.) Amt of Refund (Rs.) Refund Order No. No.

of Shares Allotted DIS No RTGS HYDERABAD 32985831 SURESH PANDYA 47600 38556 690001 266 74919 RTGS HYDERABAD 32985830 ABHAY PANDYA 47600 38556 690001 266 74920 RTGS HYDERABAD 32985829 DEVANSHI PANDYA 47600 38556 690001 266 74921 RTGS HYDERABAD 32985828 GULJAR PANDYA 47600 38556 690001 266 74922 RTGS HYDERABAD 32985827 JENNY PANDYA 47600 38556 690001 266 74923 RTGS HYDERABAD 32985826 LABOHA PANDYA 47600 38556 690001 266 74924 RTGS HYDERABAD 32985825 YASHI PANDYA 47600 38556 690001 266 74925 RTGS HYDERABAD 32985824 NIRU PANDYA 47600 38556 690001 266 74926 RTGS HYDERABAD 32985823 NITA PANDYA 47600 38556 690001 266 74927 RTGS HYDERABAD 32985822 UTAPLL PANDYA 47600 38556 690001 266 74928 RTGS HYDERABAD 32985821 ABHIGNA PANDYA 47600 38556 690001 266 74929 RTGS HYDERABAD 32985820 BALWANT PANDYA 47600 38556 690001 266 74930 RTGS HYDERABAD 32985819 DEVARSHI PANDYA 47600 38556 690001 266 74931 RTGS HYDERABAD 32985818 GUMAN PANDYA 47600 38556 690001 266 74932 RTGS HYDERABAD 32985817 JHANKI PANDYA 47600 38556 690001 266 74933 RTGS HYDERABAD 32985816 LAGNI PANDYA 47600 38556 690001 266 74934 RTGS HYDERABAD 32985815 KASHU PANDYA 47600 38556 690001 266 74935 RTGS HYDERABAD 32985554 NIRUPAMA PANDYA 47600 38556 690001 266 74936 RTGS HYDERABAD 32985553 NITANSH PANDYA 47600 38556 690001 266 74937 RTGS HYDERABAD 32985552 SWATI PANDYA 47600 38556 690001 266 74938 RTGS HYDERABAD 32985776 ABHILASH PANDY 47600 38556 690001 266 74939 RTGS HYDERABAD 32985771 BALWIR PANDYA 47600 38556 690001 266 74940 RTGS HYDERABAD 32985770 DEVASPA PANDYA 47600 38556 690001 266 74941 RTGS HYDERABAD 32985769 GUNISH PANDYA 47600 38556 690001 266 74942 RTGS HYDERABAD 32985768 JIGAR PANDYA 47600 38556 690001 266 74943 RTGS HYDERABAD 33016532 LAHAR PANDYA 47600 38556 690001 266 74944 RTGS HYDERABAD 32985766 YATNA PANDYA 47600 38556 690001 266 74945 RTGS HYDERABAD 32985765 NIRVI PANDYA 47600 38556 690001 266 74946 RTGS HYDERABAD 32985764 NITIN PANDYA 47600 38556 690001 266 74947 RTGS HYDERABAD 32985763 TRUSHIT PANDYA 47600 38556 690001 266 74948 RTGS HYDERABAD 32985813 ABHISHEK PANDYA 47600 38556 690001 266 74949 RTGS HYDERABAD 32985812 BANJUL PANDYA 47600 38556 690001 266 74950 RTGS HYDERABAD 32985811 DEVENDRA PANDYA 47600 38556 690001 266 74951 RTGS HYDERABAD 32985810 GUNJAK PANDYA 47600 38556 690001 266 74952 RTGS HYDERABAD 32985809 JIGISH PANDYA 47600 38556 690001 266 74953 RTGS HYDERABAD 32985808 LAJJA PANDYA 47600 38556 690001 266 74954 RTGS HYDERABAD 32985789 YATRI PANDYA 47600 38556 690001 266 74955 RTGS HYDERABAD 32985788 NISAR PANDYA 47600 38556 690001 266 74956 RTGS HYDERABAD 32985787 DEPARV PANDYA 47600 38556 690001 266 74957 RTGS HYDERABAD 32985807 TUKHAR PANDYA 47600 38556 690001 266 74958 RTGS HYDERABAD 32985805 ADIP PANDYA 47600 38556 690001 266 74959 RTGS HYDERABAD 32985804 BANKIM PANDYA 47600 38556 690001 266 74960 RTGS HYDERABAD 32985803 DEVI PANDYA 47600 38556 690001 266 74961 RTGS HYDERABAD 32985802 JIMISH PANDYA 47600 38556 690001 266 74962 RTGS HYDERABAD 32985801 LAKENDRA PANDYA 47600 38556 690001 266 74963 RTGS HYDERABAD 32985800 YAVAN PANDYA 47600 38556 690001 266 74964 RTGS HYDERABAD 32985799 MIYA PANDYA 47600 38556 690001 266 74965 RTGS HYDERABAD 32985798 ROHINI PANDYA 47600 38556 690001 266 74966 RTGS HYDERABAD 32985797 TURANG PANDYA 47600 38556 690001 266 74967 RTGS HYDERABAD 32985796 ADITI PANDYA 47600 38556 690001 266 74968 9.51. From the above table it may be seen that KCL had done RTGS transfer of application money to the IDFC escrow account. KSBL bid the applications without obtaining application money and KCPL (RTI) issued consolidated refund order no. 690001 in respect of these fictitious applicants. Thereafter, KSBL (DP) transferred the IPO shares from the demat accounts of the fictitious/benami entities to the demat accounts of the key operators using the DIS numbers indicated in the last column of the table. It is noted that the DIS pertaining to different applicants were in continous serial numbers indicating the control of one or few persons in the maintenance and operation of the numerous demat accounts held in fictitious/benami names. That Karvy DP accepted consolidated payments from the key operators towards maintenance of these demat accounts also supports this finding.

9.52. It is also observed that while the details pertaining to the series of applications from 'SURESH PANDYA' to 'ADITI PANDYA' has been indicated in the table, there were also other sets of applications wherein the same features were observed. While the first names in respect of these applications were in the same series beginning from 'SURESH' and ending with 'ADITI', the surnames that were used instead of 'Pandya' were Verma, Gandhi, Trivedi and Desai.

9.53. Issuance of Consolidated Refund by KCPL in respect of Names added to IOB Thaltej Bank account no. 12140 Based on the allotment master in the IPO of IDFC, as submitted by KCPL, it is seen that the list of names of the IPO applicants starting from SURESH SETH to ADITI SETH are in the same order as the list of names attached to the IOB Thaltej branch account no 12140. Further, it is also seen that KCPL (which is RTI in the IPO of IDFC) had issued a consolidated refund order no. 660004 in favour of IOB for Rs 61.24 crores in respect of 15,751 applications including those made by the set of 50 applicants starting from Suresh Seth to Aditi Seth.

9.54. Thus, from the above, it is clear that Karvy had initially introduced BhOB Ahmedabad bank account no. 54119 in the month of December 2003. Subsequently demat accounts were opened with Karvy DP on NSDL in the month of December 2003 / January 2004 indicating the bank details of BHOB. The said NSDL dematerialized accounts include the 50 names beginning from SURESH SETH to ADITI SETH. The said bank account no.54119 was thereafter closed on April 24, 2004. The dematerialized accounts continued to exist with Karvy DP even after the closure of the bank account.

9.55. Thereafter, in March 2005, Karvy introduced bank account of Devangi Dipakbhai Panchal (account no: 12140), a key operator belonging to the Panchal group, to IOB Thaltej Branch and also certified the list of names attached with the said bank account (SURESH SETH to ADITI SETH) for the purpose of arranging IPO finance. It is observed that in the IPO of IDFC (July 2005), IOB had financed 15,751 applications which include the 50 names beginning with SURESH SETH till ADITI SETH.

Further, Karvy Computer share Pvt. Ltd, RTI in the IPO of IDFC had issued consolidated refund order no. 660004 to IOB.

9.56. Synchronised Off-market transfers from Afferent Accounts to Key Operators After the allotment of shares on August 6, 2005 the shares were transferred through off-market transactions from the dematerialized accounts of the allottees (including SURESH SETH till ADITI SETH) to the demat account of Roopal Panchal (client ID: 11920868) on August 8, 2005. With regard to these off-market transfers, it was observed that Karvy DP had issued loose DIS slips which had continuous serial numbers. The details of the off market transfers in the IPO of IDFC in respect of these transactions are given in the table below:

Sr.

No.

CLIENT ID NAME OF THE DEMAT ACCOUNT HOLDER TARGET CLIENT NAME Date of execution NO OF SHARES SLIPNO

1. 13130266 SURESH SETH Roopal Panchal August 8, 2005 266 200167245

2. 13130274 ABHAY SETH Roopal Panchal August 8, 2005 266 200167246

3. 13130299 DEVANSHI SETH Roopal Panchal August 8, 2005 266 200167248

4. 13130329 LABDHA SETH Roopal Panchal August 8, 2005 266 200167249

5. 13130338 YASHI SETH Roopal Panchal August 8, 2005 266 200167250

6. 13130346 NIRU SETH Roopal Panchal August 8, 2005 266 200167251

7. 13130354 NITA SETH Roopal Panchal August 8, 2005 266 200167252

8. 13130362 UTPALL SETH Roopal Panchal August 8, 2005 266 200167253

9. 13130379 ABHIGNA SETH Roopal Panchal August 8, 2005 266 200167254

10. 13130387 BALWANT SETH Roopal Panchal August 8, 2005 266 200167255

11. 13130395 DEVARSHI SETH Roopal Panchal August 8, 2005 266 200167256

12. 13130409 GUMAN SETH Roopal Panchal August 8, 2005 266 200167257

13. 13130418 JHANKI SETH Roopal Panchal August 8, 2005 266 200167258

14. 13130426 LAGNI SETH Roopal Panchal August 8, 2005 266 200167259

15. 13130434 YASHU SETH Roopal Panchal August 8, 2005 266 200167260

16. 13130442 NIRUPAMA SETH Roopal Panchal August 8, 2005 266 200167261

17. 13130459 NITANSH SETH Roopal Panchal August 8, 2005 266 200167262

18. 13130467 SWATI SETH Roopal Panchal August 8, 2005 266 200167263

19. 13130475 ABHILASH SETH Roopal Panchal August 8, 2005 266 200167264

20. 13130483 BALWIR SETH Roopal Panchal August 8, 2005 266 200167265

21. 13130490 DEVASYA SETH Roopal Panchal August 8, 2005 266 200167266

22. 13130506 GUNISH SETH Roopal Panchal August 8, 2005 266 200167267

23. 13130514 JIGAR SETH Roopal Panchal August 8, 2005 266 200167268

24. 13130522 LAHAR SETH Roopal Panchal August 8, 2005 266 200167269

25. 13130539 YATNA SETH Roopal Panchal August 8, 2005 266 200167270

26. 13130547 NIRVI SETH Roopal Panchal August 8, 2005 266 200167271

27. 13130555 NITIN SETH Roopal Panchal August 8, 2005 266 200167272

28. 13130563 TRUSHIT SETH Roopal Panchal August 8, 2005 266 200167273

29. 13130570 ABHISHEK SETH Roopal Panchal August 8, 2005 266 200167274

30. 13130589 BANJUL Roopal Panchal August 8, 2005 266 200167275

31. 13130598 DEVENDRA SETH Roopal Panchal August 8, 2005 266 200167276

32. 13130602 GUNJAK SETH Roopal Panchal August 8, 2005 266 200167277

33. 13130619 JIGISH SETH Roopal Panchal August 8, 2005 266 120204845

34. 13130627 LAJJA SETH Roopal Panchal August 8, 2005 266 200167278

35. 13130635 YATRI SETH Roopal Panchal August 8, 2005 266 200167279

36. 13130643 NISAR SETH Roopal Panchal August 8, 2005 266 200167280

37. 13130650 DEPARV SETH Roopal Panchal August 8, 2005 266 200167281

38. 13130669 TUKHAR SETH Roopal Panchal August 8, 2005 266 200167282

39. 13130678 ADIP SETH Roopal Panchal August 8, 2005 266 200167283

40. 13130686 BANKIM SETH Roopal Panchal August 8, 2005 266 200167284

41. 13130694 DEVI SETH Roopal Panchal August 8, 2005 266 200167285

42. 13130717 JIMISH SETH Roopal Panchal August 8, 2005 266 200167287

43. 13130725 LAKENDRA SETH Roopal Panchal August 8, 2005 266 200167288

44. 13130733 YAVAN SETH Roopal Panchal August 8, 2005 266 200167289

45. 13130740 MIYA SETH Roopal Panchal August 8, 2005 266 200167290

46. 13130759 ROHINI SETH Roopal Panchal August 8, 2005 266 200167291

47. 13130768 TURANG SETH Roopal Panchal August 8, 2005 266 200167292

48. 13130776 ADITI SETH Roopal Panchal August 8, 2005 266 200167293 9.57. The allotted shares were immediately transferred from the afferent demat accounts to the demat account of Roopal Panchal (client ID 11920868) using DIS bearing continuous serial numbers as seen from the table above, all the events happening within Karvy DP's system.

9.58. Thus Karvy group entities were involved in all the activities of cornering of IPO shares by the key operators beginning from the introduction of bank account (no.54119 with BhOB Ahmedabad), the opening of demat account in NSDL, arrangement of finance from IOB, issue of consolidated Refund Order to IOB and making off-market transfers from the dematerialized accounts of fictitious/benami entities to the dematerialized accounts of the key operators.

9.59. Afferent Accounts Introduced by Karvy Group with BhOB Goregaon Branch It was observed that Karvy had not only introduced bank accounts at BhOB, Ahmedabad and IOB, Thaltej branch but had also introduced bank accounts to BhOB Goregaon branch. Pradeep Bhogale, employee of Karvy Consultants Ltd. had introduced the following bank accounts with BhOB, Goregaon. 121 afferent dematerialized account-holders with Karvy DP had indicated these bank accounts introduced by KCL as their bank accounts. The details are given below:

Sr. No. SOURCE CLIENT ID SOURCE CLIENT NAME ADDRESS1 BANK ACCOUNT

1. 40082103 JAGDISH MITHILAKSHA A Mahalaxmi CHS R No 22, Chatrapati Shivaji Nagar, Asalpha Village Ghatkopar W, Mumbai 1971320

2. 40081887 ACHARYA JAGDISH M Mahalaxmi CHS R No 22, Chatrapati Shivaji Nagar, Asalpha Village Ghatkopar W, Mumbai 1971320

3. 40082089 BINDI BISHIR M B 5 Nilkanth Dhara, 90 Feet Road, Ghatkopar East, Mumbai 1971320

4. 40082646 MEHTA G DHARMESH Kailash Niwas 2 Block No 39 6th Flr, Mehta Road, Ghatkopar East, Mumbai 1971318

5. 40082863 G DHARMESH MEHTA Kailash Niwas 2 Block No 39 6th Flr, Mehta Road, Ghatkopar East, Mumbai 1971318

6. 40081758 MEHTA CHETNA D Kailash Niwas 2 Block No 39 6th Flr, Mehta Road, Ghatkopar East, Mumbai 1971318

7. 40081766 MEHTA GRISHMA D Kailash Niwas 2 Block No 39 6th Flr, Mehta Road, Ghatkopar East, Mumbai 1971318

8. 40081782 MEHTA BHUPENDRA K Flat No 19/20 5th Floor Parijat, R B Mehta Marg, Ghatkopar E, Mumbai 1971318

9. 40082216 GRISHMABEN DHARMESHBHAI M Kailash Niwas 2 Block No 39 6th Flr, Mehta Road, Ghatkopar East, Mumbai 1971318

10. 40082662 MEHTA B KUVARJI Flat No 19/20 5th Floor Parijat, R B Mehta Marg, Ghatkopar E, Mumbai 1971318

11. 40082888 B KUVARJI MEHTA 6/1 Damodar Park R No 904, LBS Marg, Ghatkopar W, Mumbai 1971318

12. 40082208 CHETNABEN DHARMESHBHAI Kailash Niwas 2 Block No 39 6th Flr, Mehta Road, Ghatkopar East, Mumbai 1971318

13. 40081976 CHETNA DHARMESH M Kailash Niwas 2 Block No 39 6th Flr, Mehta Road, Ghatkopar East, Mumbai 1971318

14. 40082638 MEHTA C DHARMESH Kailash Niwas 2 Block No 39 6th Flr, Mehta Road, Ghatkopar East, Mumbai 1971318

15. 40082855 C DHARMESH MEHTA Kailash Niwas 2 Block No 39 6th Flr, Mehta Road, Ghatkopar East, Mumbai 1971318

16. 40082232 BHUPENDRA BHAI KUVARJIBHAI M Flat No 19/20 5th Floor Parijat, R B Mehta Marg, Ghatkopar E, Mumbai 1971318

17. 40082402 DHARMESHLAL B M 501 Parijat Plot No 60, 60 Feet Road, Ghatkopar East, Mumbai 1971318

18. 40082419 CHETNADEVI D M Kailash Niwas 2 Block No 39 6th Flr, Mehta Road, Ghatkopar East, Mumbai 1971318

19. 40082427 GRISHMADEVI D M R No 4 Mahadik Niwas, Jamili Nagar, Sahyadri Nagar Bhandup W, Mumbai 1971318

20. 40082445 BHUPENDRALAL K M 6/1 Damodar Park R No 904, LBS Marg, Ghatkopar W, Mumbai 1971318

21. 40082620 MEHTA D BHUPENDRA Kailash Niwas 2 Block No 39 6th Flr, Mehta Road, Ghatkopar East, Mumbai 1971318

22. 40081993 GRISHMA DHARMESH M Kailash Niwas 2 Block No 39 6th Flr, Mehta Road, Ghatkopar East, Mumbai 1971318

23. 40082654 MEHTA V DHARMESH Kailash Niwas 2 Block No 39 6th Flr, Mehta Road, Ghatkopar East, Mumbai 1971306

24. 40082436 VIRAJLAL D M Kailash Niwas 2 Block No 39 6th Flr, Mehta Road, Ghatkopar East, Mumbai 1971306

25. 40082926 U KETAN MEHTA B 5 Nilkanth Dhara, 90 Feet Road, Ghatkopar East, Mumbai 1971306

26. 40081774 MEHTA VIRAJ D Kailash Niwas 2 Block No 39 6th Flr, Mehta Road, Ghatkopar East, Mumbai 1971306

27. 40082870 V DHARMESH MEHTA Kailash Niwas 2 Block No 39 6th Flr, Mehta Road, Ghatkopar East, Mumbai 1971306

28. 40082224 VIRAJBHAI DHARMESHBHAI Kailash Niwas 2 Block No 39 6th Flr, Mehta Road, Ghatkopar East, Mumbai 1971306

29. 40082048 UDVIT KETAN M 171/6 Vinay Bhuvan, Garodia Nagar Ghatkopar East, Mumbai 1971306

30. 40081820 MEHTA UDVIT K 171/6 Vinay Bhuvan, Garodia Nagar Ghatkopar East, Mumbai 1971306

31. 40082486 UDVITLAL K M B 5 Nilkanth Dhara, 90 Feet Road, Ghatkopar East, Mumbai 1971306

32. 40081985 VIRAJ DHARMESH M Kailash Niwas 2 Block No 39 6th Flr, Mehta Road, Ghatkopar East, Mumbai 1971306

33. 40082696 MEHTA UDVIT KETAN 171/6 Vinay Bhuvan, Garodia Nagar Ghatkopar East, Mumbai 1971306

34. 40082275 UDVITBHAI KETANBHAI M 171/6 Vinay Bhuvan, Garodia Nagar Ghatkopar East, Mumbai 1971306

35. 40082152 KAMAL CHANDRAKANT W R No 4 Mahadik Niwas, Jamil Nagar, Sahyadri Nagar Bhandup W, Mumbai 1971290

36. 40082812 WAUGH C LAXMAN R No 4 Mahadik Niwas, Jamil Nagar, Sahyadri Nagar Bhandup W, Mumbai 1971290

37. 40082829 WAUGH K CHANDRAKANT R No 4 Mahadik Niwas, Jamil Nagar, Sahyadri Nagar Bhandup W, Mumbai 1971290

38. 40082613 KAMLADEVI C W R No 4 Mahadik Niwas, Jamil Nagar, Sahyadri Nagar Bhandup W, Mumbai 1971290

39. 40082605 CHANDRA KANTLAL L W R No 4 Mahadik Niwas, Jamil Nagar, Sahyadri Nagar Bhandup W, Mumbai 1971290

40. 40081942 WAUGH KAMAL C Mahadik Niwas, R No. 4, Jamil Nagar, Sahyadri Nagar Bhandup W, Mumbai 1971290

41. 40083057 K CHANDRAKANT WAUGH R No 4 Mahadik Niwas, Jamil Nagar, Sahyadri Nagar Bhandup W, Mumbai 1971290

42. 40083049 C LAXMAN WAUGH R No 4 Mahadik Niwas, Jamil Nagar, Sahyadri Nagar Bhandup W, Mumbai 1971290

43. 40082177 CHANDRAKANT LAXMAN W R No 4 Mahadik Niwas, Jamil Nagar, Sahyadri Nagar Bhandup W, Mumbai 1971290

44. 40081926 WAUGH CHANDRAKANT L R No 4 Mahadik Niwas, Jamil Nagar, Sahyadri Nagar Bhandup W, Mumbai 1971290

45. 40082398 KAMALBEN CHANDRA KANTBHAI W R No 4 Mahadik Niwas, Jamil Nagar, Sahyadri Nagar Bhandup W, Mumbai 1971290

46. 40082380 CHANDRA KANTBHAI LAXMANBHAI W R No 4 Mahadik Niwas, Jamil Nagar, Sahyadri Nagar Bhandup W, Mumbai 1971290

47. 40081799 MEHTA KETAN B 171/6 Vinay Bhuvan, Garodia Nagar Ghatkopar East, Mumbai 1971288

48. 40082687 MEHTA D KETAN 171/6 Vinay Bhuvan, Garodia Nagar Ghatkopar East, Mumbai 1971288

49. 40082460 DARSHNADEVI K M 171/6 Vinay Bhuvan, Garodia Nagar Ghatkopar East, Mumbai 1971288

50. 40082453 KETANLAL B M 171/6 Vinay Bhuvan, Garodia Nagar Ghatkopar East, Mumbai 1971288

51. 40082679 MEHTA K BHUPENDRA 171/6 Vinay Bhuvan, Garodia Nagar Ghatkopar East, Mumbai 1971288

52. 40082558 SATISHLAL M A Mahalaxmi Chsl 1 R No 22, Chatrapati Shivaji Nagar, Asalpha Village Ghatkopar W, Mumbai 1971288

53. 40081805 MEHTA DARSHNA K 171/6 Vinay Bhuvan, Garodia Nagar Ghatkopar East, Mumbai 1971288

54. 40082023 DARSHNA KETAN M 171/6 Vinay Bhuvan, Garodia Nagar Ghatkopar East, Mumbai 1971288

55. 40082896 K BHUPENDRA MEHTA 171/6 Vinay Bhuvan, Garodia Nagar Ghatkopar East, Mumbai 1971288

56. 40082015 KETAN BHUPENDRA M 171/6 Vinay Bhuvan, Garodia Nagar Ghatkopar East, Mumbai 1971288

57. 40082478 UMANGLAL K M 171/6 Vinay Bhuvan, Garodia Nagar Ghatkopar East, Mumbai 1971276

58. 40082917 UMANGK MEHTA 171/6 Vinay Bhuvan, Garodia Nagar Ghatkopar East, Mumbai 1971276

59. 40081959 WAUGH SASHIKALA Mahadik Niwas, R No 4 Jamil Nagar, Sahyadri Nagar Bhandup W, Mumbai 1971276

60. 40082169 SASHIKALA LAXMAN W R No 4 Mahadik Niwas, Jamil Nagar, Sahyadri Nagar Bhandup W, Mumbai 1971276

61. 40082266 UMANGBHAI KETANBHAI M 501 Parijat Plot No 60, 60 Feet Road, Ghatkopar East, Mumbai 1971276

62. 40082599 SASHIDEVI L W R No 4 Mahadik Niwas, Jamil Nagar, Sahyadri Nagar Bhandup W, Mumbai 1971276

63. 40082837 WAUGH SASHI LAXMAN 501 Parijat Plot No 60, 60 Feet Road, Ghatkopar East, Mumbai 1971276

64. 40081813 MEHTA UMANG K 171/6 Vinay Bhuvan, Garodia Nagar Ghatkopar East, Mumbai 1971276

65. 40082700 MEHTA U KETAN 501 Parijat Plot No 60, 60 Feet Road, Ghatkopar East, Mumbai 1971276

66. 40082030 UMANG KETAN M 171/6 Vinay Bhuvan, Garodia Nagar Ghatkopar East, Mumbai 1971276

67. 40081896 ACHARYA SATISH M Mahalaxmi Chsl 1 R No 22, Chatrapati Shivaji Nagar, Asalpha Village Ghatkopar W, Mumbai 1971264

68. 40082136 MITHILAKSHA RUDRAYYA A Mahalaxmi Chsl R No 22, Chatrapati Shivaji Nagar, Asalpha Village Ghatkopar W, Mumbai 1971264

69. 40082776 ACHARYA S MITHILAKSHA Mahalaxmi Chsl 1 R No 22, Chatrapati Shivaji Nagar, Asalpha Village Ghatkopar W, Mumbai 1971264

70. 40082992 S MITHILAKSHA ACHARYA Mahalaxmi Chsl 1 R No 22, Chatrapati Shivaji Nagar, Asalpha Village Ghatkopar W, Mumbai 1971264

71. 40083016 M RUDRAYYA ACHARYA Mahalaxmi Chsl 1 R No 22, Chatrapati Shivaji Nagar, Asalpha Village Ghatkopar W, Mumbai 1971264

72. 40082574 MITHILAKSHALAL R A 171/6 Vinay Bhuvan, Garodia Nagar Ghatkopar East, Mumbai 1971264

73. 40082793 ACHARYA MITHILAKSHA R 501 Parijat Plot No 60, 60 Feet Road, Ghatkopar East, Mumbai 1971264

74. 40082110 SATISH MITHILAKSHA A Mahalaxmi CHS R No 22, Chatrapati Shivaji Nagar, Asalpha Village Ghatkopar W, Mumbai 1971264

75. 40081918 ACHARYA MITHILAKSHA R Mahalaxmi CHS R No 22, Chatrapati Shivaji Nagar, Asalpha Village Ghatkopar W, Mumbai 1971264

76. 40082950 H BISHIR MEHTA B 5 Nilkanth Dhara, 90 Feet Road, Ghatkopar East, Mumbai 1971252

77. 40082290 HELLYBEN BISHIRBHAI M A 17/18 Nilkanth Dhara, 90 Feet Road, Ghatkopar East, Mumbai 1971252

78. 40082306 RADHIBEN BISHIRBHAI M B 5 Nilkanth Dhara, 90 Feet Road, Ghatkopar East, Mumbai 1971252

79. 40082525 RADHIDEVI B M B 5 Nilkanth Dhara, 2nd flr, 90 Feet Road, Ghatkopar East, Mumbai 1971252

80. 40082734 MEHTA H BISHIR 501 Parijat Plot No 60, 60 Feet Road, Ghatkopar East, Mumbai 1971252

81. 40081854 MEHTA HELLY B B 5 Nilkanth Dhara, 2nd flr, 90 Feet Road, Ghatkopar East, Mumbai 1971252

82. 40082846 D BHUPENDRA MEHTA 501 Parijat Plot No 60, 60 Feet Road, Ghatkopar East, Mumbai 1971252

83. 40081862 MEHTA RADHI B B 5 Nilkanth Dhara, 2nd flr, 90 Feet Road, Ghatkopar East, Mumbai 1971252

84. 40082064 HELLY BISHIR M B 5 Nilkanth Dhara, 90 Feet Road, Ghatkopar East, Mumbai 1971252

85. 40082742 MEHTA R BISHIR B 5 Nilkanth Dhara, 90 Feet Road, Ghatkopar East, Mumbai 1971252

86. 40082072 RADHI BISHIR M B 5 Nilkanth Dhara, 90 Feet Road, Ghatkopar East, Mumbai 1971252

87. 40082516 HELLYDEVI B M B 5 Nilkanth Dhara, 2nd flr, 90 Feet Road, Ghatkopar East, Mumbai 1971252

88. 40082186 BISHIRBHAI BHUPENDRABHAI B 5 Nilkanth Dhara, 90 Feet Road, Ghatkopar East, Mumbai 19712400

89. 40082097 GEETA BISHIR M B 5 Nilkanth Dhara, 90 Feet Road, Ghatkopar East, Mumbai 19712400

90. 40082314 BINDIBEN BISHIRBHAI M B 5 Nilkanth Dhara, 90 Feet Road, Ghatkopar East, Mumbai 19712400

91. 40082056 BISHIR BHUPENDRA M B 5 Nilkanth Dhara, 2nd flr, 90 Feet Road, Ghatkopar East, Mumbai 19712400

92. 40082283 GEETABEN BISHIRBHAI B 5 Nilkanth Dhara, 90 Feet Road, Ghatkopar East, Mumbai 19712400

93. 40081846 MEHTA GEETA B B 5 Nilkanth Dhara, 2nd flr, 90 Feet Road, Ghatkopar East, Mumbai 19712400

94. 40082533 BINDIDEVI B M 501 Parijat Plot No 60, 60 Feet Road, Ghatkopar East, Mumbai 19712400

95. 40082507 GEETADEVI B M B 5 Nilkanth Dhara, 2nd flr, 90 Feet Road, Ghatkopar East, Mumbai 19712400

96. 40082718 MEHTA B BHUPENDRA 501 Parijat Plot No 60, 60 Feet Road, Ghatkopar East, Mumbai 19712400

97. 40082726 MEHTA G BISHIR B 5 Nilkanth Dhara, 2nd flr, 90 Feet Road, Ghatkopar East, Mumbai 19712400

98. 40082494 BISHIRLAL B M B 5 Nilkanth Dhara, 2nd flr, 90 Feet Road, Ghatkopar East, Mumbai 19712400

99. 40082759 MEHTA BINDI BISHIR 501 Parijat Plot No 60, 60 Feet Road, Ghatkopar East, Mumbai 19712400

100. 40082935 B BHUPENDRA MEHTA 501 Parijat Plot No 60, 60 Feet Road, Ghatkopar East, Mumbai 19712400

101. 40082943 G BISHIR MEHTA B 5 Nilkanth Dhara, 2nd flr, 90 Feet Road, Ghatkopar East, Mumbai 19712400

102. 40082976 BINDIKUMARI B MEHTA Kailash Niwas 2 Block No 39 6th Flr, Mehta Road, Ghatkopar East, Mumbai 19712400

103. 40081838 MEHTA BISHIR B B 5 Nilkanth Dhara, 90 Feet Road, Ghatkopar East, Mumbai 19712400

104. 40082785 ACHARYA L MITHILAKSHA 501 Parijat Plot No 60, 60 Feet Road, Ghatkopar East, Mumbai 1971239

105. 40082144 SASHIKANT LAXMAN W R No 4 Mahadik Niwas, Jamili Nagar, Sahyadri Nagar Bhandup W, Mumbai 1971239

106. 40082804 WAUGH S LAXMAN 501 Parijat Plot No 60, 60 Feet Road, Ghatkopar East, Mumbai 1971239

107. 40083008 L MITHILAKSHA ACHARYA Mahalaxmi CHS 1 R No 22, Chatrapati Shivaji Nagar, Asalpha Village Ghatkopar W, Mumbai 1971239

108. 40083024 S LAXMAN WAUGH R No 4 Mahadik Niwas, Jamili Nagar, Sahyadri Nagar Bhandup W, Mumbai 1971239

109. 40082195 DHARMESHBHAI BHUPENDRABHAI Kailash Niwas 2 Block No 39 6th Flr, Mehta Road, Ghatkopar East, Mumbai 1971239

110. 40083032 SASHINATH L WAUGH R No 4 Mahadik Niwas, Jamili Nagar, Sahyadri Nagar Bhandup W, Mumbai 1971239

111. 40081900 ACHARYA LALITHA M Mahalaxmi CHS 1 R No 2, Chatrapati Shivaji Nagar, Asalpha Village Ghatkopar W, Mumbai 1971239

112. 40082339 SATISHBHAI MITHILAKSHABHAI A Mahalaxmi CHS 1 R No 22, Chatrapati Shivaji Nagar, Asalpha Village Ghatkopar W, Mumbai 1971239

113. 40082566 LALITHADEVI M A R No 4 Mahadik Niwas, Jamil Nagar, Sahyadri Nagar Bhandup W, Mumbai 1971239

114. 40082347 LALITHABEN MITHILAKSHA BHAI A Mahalaxmi CHS R No 22, Chatrapati Shivaji Nagar, Asalpha Village Ghatkopar W, Mumbai 1971239

115. 40082365 SASHIBHAI LAXMANBHAI W 501 Parijat Plot No 60, 60 Feet Road, Ghatkopar East, Mumbai 1971239

116. 40081967 DHARMESH BHUPENDRA M Kailash Niwas 2 Block No 39 6th Flr, Mehta Road, Ghatkopar East, Mumbai 1971239

117. 40081934 WAUGH SHASHIKANT Mahadik Niwas, R No. 4 Jamil Nagar, Sahyadri Nagar Bhandup W, Mumbai 1971239

118. 40081740 MEHTA DHARMESH B Kailash Niwas 2 Block No 39 6th Flr, Mehta Road, Ghatkopar East, Mumbai 1971239

119. 40082582 SASHILAL L W 501 Parijat Plot No 60, 60 Feet Road, Ghatkopar East, Mumbai 1971239

120. 40082373 SASHIBEN LAXMANBHAI W R No 4 Mahadik Niwas, Jamil Nagar, Sahyadri Nagar Bhandup W, Mumbai 1971239

121. 40082128 LALITHA MITHILAKSHA A Mahalaxmi CHS R No 22, Chatrapati Shivaji Nagar, Asalpha Village Ghatkopar W, Mumbai 1971239 9.60. From the above table, it may be seen that a few bank accounts held with BhOB, Goregaon branch resulted in numerous dematerialized accounts with Karvy DP. It is pertinent to note that Karvy DP had introduced these bank accounts.

9.61. Analysis of Afferent dematerialized accounts held with Karvy DP and their Characteristics During the course of SEBI investigations into the IPO related irregularities during 2003-2005 it was found that as many as 58,938 afferent dematerialized accounts had been opened with various DPs by the Key Operators for cornering the IPO shares. It was found that a substantial proportion of the afferent accounts identified by SEBI were held with Karvy DP and the details are given below:

Name of Depository Total No. of Afferent Demat accounts No.

of Afferent Demat accounts with Karvy DP % of Afferent Demat Accounts with Karvy NSDL 37,240 29,309 79% CDSL 21,698 20,399 94% Total 58,938 49,708 84% 9.62. Further, it was noticed that many of these afferent demat accounts had been opened on the same day with the address of the key operators shown as the address of fictitious / benami BOs. The details are as below:

Sr.

No Date of opening account Address CDSL NSDL 1 June 27 /30, 2003 402 403, Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad - 380006 (Roopal Panchal)

-

321 2

September 27-29, 2003 68, Samashta B Society Opp Pinakin Soc Paldi, Ahmedabad (Kelan Atul Doshi)   500 3 November 6, 2003 402 403, Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad - 380006 (Roopal Panchal)   570 4 December 16 / 17, 2003 402 403, Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad - 380006 ( Roopal Panchal)   1220 5 January 2004 C/o P P Jhaveri, 804, Abhijeet I Mithakhali Circle, Ellisbridge, Ahmedabad (Parag Jhaveri)   565 6 January 5 / 6, 2004 402 403, Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad - 380006 (Roopal Panchal)

-

3,200 7 February 16, 2004 402 403, Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad - 380006 ( Roopal Panchal)

-

1529 8

April 20, 2004 C/o. SEIPL, G-1, Devpath Complex B/h. Lal Bunglow, Ahmedabad. (Sugandh Estates)

-

1096 8

August 16-17, 2004 402 403, Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad - 380006 (Roopal Panchal   2,742 68, Samashta B Society Opp Pinakin Soc Paldi, Ahmedabad (Kelan Atul Doshi)   564 C/o. SEIPL, G-1, Devpath Complex B/h. Lal Bunglow, Ahmedabad. (Sugandh Estates)   4239 9 October, 15 - 26, 2004 C/o. SEIPL, G-1, Devpath Complex B/h. Lal Bunglow, Ahmedabad. (Sugandh Estates)

-

4,512 10 October 23, 2004 68, Samashta B Society Opp Pinakin Soc Paldi, Ahmedabad Kelan Atul Doshi   202 C/o.

SEIPL, G-1, Devpath Complex B/h. Lal Bunglow, Ahmedabad. (Sugandh Estates)   1559 11 Various dates in the year 2004 OTHERS LIKE D B MEHTA, D KATAKIA   820 12 July 08, 2005 Niketan Maheshwar, 33, Peddar Road, 5B (Manoj Sekseria 489

-

13

July 15, 2005 Office No 403, Shashwat Bldg nr. Hotel Kanak Ellisbridge Ahmedabad (Roopal Panchal) 4886   14 July 16, 2005 406, Shashwat Opp Gujarat College, Ellisbridge, Ahmedabad (Roopal Panchal) 9943   15 July 19, 2005 402 403, Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad - 380006 (Roopal Panchal)

-

1,004 16 July 20, 2005 402 403, Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad - 380006 (Roopal Panchal)

-

1,532 17 July 21, 2005 402 403, Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad - 380006 (Roopal Panchal)

-

755 18

July 22, 2005 B/2 Himalaya Asalaya Ghatkopar, W, Mumbai.

(Purshottam Bhudhwani) 2823

-

Niketan Maheshwar, 33, Peddar Road, 5B (Manoj Sekseria) 1135

-

19

July 25, 2005 Niketan Maheshwar, 33, Peddar Road, 5B (Manoj Sekseria) 572   20 August 17, 2005 Niketan Maheshwar, 33, Peddar Road, 5B(Manoj Sekseria) 415

-

B/2 Himalaya Asalaya Ghatkopar, W, Mumbai. (Purshottam Bhudwani) 136   21 August 2-5, 2005 68, Samashta B Society Opp Pinakin Soc Paldi, Ahmedabad (Ketan Atul bhai Doshi)   718 23, Payal Complex, Sayajigunj, Paldi, Baroda, 3900053 (biren kantilal shah)   780 22 August 16 /17 2005 C/o P P Jhaveri, 804, Abhijeet I Mithakhali Circle, Ellisbridge, Ahmedabad (Parag Jhaveri)   881     Total 20,399 29,309 9.63. From the above table, it may be seen that thousands of fictitious / benami dematerialized accouts were opened with Karvy DP with common addresses and thousands of such dematerialized accounts were opened on one single day. Karvy DP as per the SEBI guidelines relating to opening of dematerialized accounts was under a duty to exercise due diligence while opening the dematerialized accounts. That it did not do so shows that the obvious was apparently overlooked. It is clearly indicative that Karvy was aware of the existence of fictitious afferent accounts.

9.64. Charecteristics of the afferent dematerialized accounts In respect of the afferent dematerialized accounts opened with Karvy DP, various features that should have alerted the DP while opening the dematerialized accounts were noticed.

9.65. Afferent Accounts opened on the Same Date A sample of 50 afferent dematerialized accounts opened with Karvy DP on the same date i.e. July 19, 2005 is given below:

Sr No Source Client ID Source DP ID Source DP Name Name Of Source Client Address Of Source Client Date Of Opening Of Demat Account Date Of Closure Of Demat (If Applicable) Account Status

1. 15442390 IN300394 Karvy Stock Broking Ltd SURESH JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 7/19/2005 11/24/2005 CLOSED

2. 15442406 IN300394 Karvy Stock Broking Ltd ABHAY JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 7/19/2005 11/24/2005 CLOSED

3. 15442414 IN300394 Karvy Stock Broking Ltd DEVANSHI JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 7/19/2005 11/24/2005 CLOSED

4. 15442422 IN300394 Karvy Stock Broking Ltd GULJAR JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 7/19/2005 11/24/2005 CLOSED

5. 15442439 IN300394 Karvy Stock Broking Ltd JENNY JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 7/19/2005 11/24/2005 CLOSED

6. 15442447 IN300394 Karvy Stock Broking Ltd LABDHA JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 7/19/2005 11/24/2005 CLOSED

7. 15442455 IN300394 Karvy Stock Broking Ltd YASHI JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 7/19/2005 11/24/2005 CLOSED

8. 15442463 IN300394 Karvy Stock Broking Ltd NIRU JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 7/19/2005 11/24/2005 CLOSED

9. 15442470 IN300394 Karvy Stock Broking Ltd NITA JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 7/19/2005 11/24/2005 CLOSED

10. 15442489 IN300394 Karvy Stock Broking Ltd UTPALL JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 7/19/2005 11/24/2005 CLOSED

11. 15442498 IN300394 Karvy Stock Broking Ltd ABHIGNA JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 7/19/2005 11/24/2005 CLOSED

12. 15442502 IN300394 Karvy Stock Broking Ltd BALWANT JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 7/19/2005 11/24/2005 CLOSED

13. 15442519 IN300394 Karvy Stock Broking Ltd DEVARSHI JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 7/19/2005 11/24/2005 CLOSED

14. 15442527 IN300394 Karvy Stock Broking Ltd GUMAN JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 7/19/2005 11/24/2005 CLOSED

15. 15442535 IN300394 Karvy Stock Broking Ltd JHANKI JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 7/19/2005 11/24/2005 CLOSED

16. 15442543 IN300394 Karvy Stock Broking Ltd LAGNI JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 7/19/2005 11/24/2005 CLOSED

17. 15442550 IN300394 Karvy Stock Broking Ltd YASHU JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 7/19/2005 11/24/2005 CLOSED

18. 15442569 IN300394 Karvy Stock Broking Ltd NIRUPAMA JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 7/19/2005 11/24/2005 CLOSED

19. 15442578 IN300394 Karvy Stock Broking Ltd NITANSH JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 7/19/2005 11/24/2005 CLOSED

20. 15442586 IN300394 Karvy Stock Broking Ltd SWATI JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 7/19/2005 11/24/2005 CLOSED

21. 15442594 IN300394 Karvy Stock Broking Ltd ABHILAS JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 7/19/2005 11/24/2005 CLOSED

22. 15442609 IN300394 Karvy Stock Broking Ltd BALVIR JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 7/19/2005 11/24/2005 CLOSED

23. 15442617 IN300394 Karvy Stock Broking Ltd DEVASYA JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 7/19/2005 11/24/2005 CLOSED

24. 15442625 IN300394 Karvy Stock Broking Ltd GUNISH JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 7/19/2005 11/24/2005 CLOSED

25. 15442633 IN300394 Karvy Stock Broking Ltd JIGAR JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 7/19/2005 11/24/2005 CLOSED

26. 15442640 IN300394 Karvy Stock Broking Ltd LAHAR JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 7/19/2005 11/24/2005 CLOSED

27. 15442659 IN300394 Karvy Stock Broking Ltd YATNA JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 7/19/2005 11/24/2005 CLOSED

28. 15442668 IN300394 Karvy Stock Broking Ltd NIRVI JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 7/19/2005 11/24/2005 CLOSED

29. 15442676 IN300394 Karvy Stock Broking Ltd NITIN JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 7/19/2005 11/24/2005 CLOSED

30. 15442684 IN300394 Karvy Stock Broking Ltd TRUSHIT JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 7/19/2005 11/24/2005 CLOSED

31. 15442692 IN300394 Karvy Stock Broking Ltd ABHISHEK JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 7/19/2005 11/24/2005 CLOSED

32. 15442705 IN300394 Karvy Stock Broking Ltd BANJUL JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 7/19/2005 11/24/2005 CLOSED

33. 15442713 IN300394 Karvy Stock Broking Ltd DEVENDRA JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 7/19/2005 11/24/2005 CLOSED

34. 15442720 IN300394 Karvy Stock Broking Ltd GUNJAK JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 7/19/2005 11/24/2005 CLOSED

35. 15442739 IN300394 Karvy Stock Broking Ltd JIGISH JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 7/19/2005 11/24/2005 CLOSED

36. 15442748 IN300394 Karvy Stock Broking Ltd LAJJA JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 7/19/2005 11/24/2005 CLOSED

37. 15442756 IN300394 Karvy Stock Broking Ltd YATRI JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 7/19/2005 11/24/2005 CLOSED

38. 15442764 IN300394 Karvy Stock Broking Ltd NISAR JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 7/19/2005 11/24/2005 CLOSED

39. 15442772 IN300394 Karvy Stock Broking Ltd DEPARV JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 7/19/2005 11/24/2005 CLOSED

40. 15442789 IN300394 Karvy Stock Broking Ltd TUKHAR JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 7/19/2005 11/24/2005 CLOSED

41. 15442797 IN300394 Karvy Stock Broking Ltd ADIP JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 7/19/2005 11/24/2005 CLOSED

42. 15442800 IN300394 Karvy Stock Broking Ltd BANKIM JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 7/19/2005 11/24/2005 CLOSED

43. 15442819 IN300394 Karvy Stock Broking Ltd DEVI JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 7/19/2005 11/24/2005 CLOSED

44. 15442828 IN300394 Karvy Stock Broking Ltd JIMESH JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 7/19/2005 11/24/2005 CLOSED

45. 15442836 IN300394 Karvy Stock Broking Ltd LAKENDRA JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 7/19/2005 11/24/2005 CLOSED

46. 15442844 IN300394 Karvy Stock Broking Ltd YAVAN JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 7/19/2005 11/24/2005 CLOSED

47. 15442852 IN300394 Karvy Stock Broking Ltd MIYA JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 7/19/2005 11/24/2005 CLOSED

48. 15442869 IN300394 Karvy Stock Broking Ltd ROHINI JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 7/19/2005 11/24/2005 CLOSED

49. 15442877 IN300394 Karvy Stock Broking Ltd TURANG JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 7/19/2005 11/24/2005 CLOSED

50. 15442885 IN300394 Karvy Stock Broking Ltd ADITI JANI 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 7/19/2005 1/3/2006 CLOSED 9.66. It is seen that all the above afferent dematerialized accounts were opened on July 19, 2005. All the account holders had the same surname viz. "Jani". All the account holders had the same address i.e. 402 403 SHASWAT, OPP GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD, 380006, which is the address of key operator viz. the Panchal family. The names of the account holders run in the same series from "Suresh" to "Aditi", as contained in the 50 names added to the IOB bank account no.12140, which has been discussed in detail in earlier paragraphs.

9.67. Pursuant to verification of the genuineness conducted by Karvy DP during November 2005 i.e. subsequent to the commencement of SEBI's preliminary enquiry into the matter, the DP had closed these dematerialized accounts.

9.68. Another sample of 50 such afferent accounts opened by Karvy DP for another key operator viz. the Jhaveri group on January 7, 2004 is given below:

Sr.

No Source Client ID Source DP ID Source DP Name Name of Source Client Address of Source Client Date of Opening of Demat Account Date of Closure of Demat (If Applicable) Account Status

1. 13120297 IN300394 Karvy Stock Broking Ltd.

AJAY B PARIKH C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006 1/7/2004 12/16/2005 CLOSED

2. 13119893 IN300394 Karvy Stock Broking Ltd.

AJIT B PARIKH C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006 1/7/2004 12/16/2005 CLOSED

3. 13119869 IN300394 Karvy Stock Broking Ltd.

AMI I PARIKH C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006 1/7/2004 12/16/2005 CLOSED

4. 13120239 IN300394 Karvy Stock Broking Ltd.

ASHWIN J MEHTA C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006 1/7/2004 12/16/2005 CLOSED

5. 13120272 IN300394 Karvy Stock Broking Ltd.

BHADRESH S PARIKH C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006 1/7/2004 12/16/2005 CLOSED

6. 13120560 IN300394 Karvy Stock Broking Ltd.

BHANUPRASAD M SONI C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006 1/7/2004 12/16/2005 CLOSED

7. 13119819 IN300394 Karvy Stock Broking Ltd.

BHARAT K PARIKH C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006 1/7/2004 12/16/2005 CLOSED

8. 13119756 IN300394 Karvy Stock Broking Ltd.

BHARTI C DESAI C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006 1/7/2004 12/16/2005 CLOSED

9. 13120256 IN300394 Karvy Stock Broking Ltd.

BHUPENDRA B MEHTA C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006 1/7/2004 12/16/2005 CLOSED

10. 13120289 IN300394 Karvy Stock Broking Ltd.

BIJAL R PARIKH C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006 1/7/2004 12/16/2005 CLOSED

11. 13120094 IN300394 Karvy Stock Broking Ltd.

BIJAL S DESAI C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006 1/7/2004 12/16/2005 CLOSED

12. 13119965 IN300394 Karvy Stock Broking Ltd.

BIRVA J PARIKH C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006 1/7/2004 12/16/2005 CLOSED

13. 13120205 IN300394 Karvy Stock Broking Ltd.

CHANDRA KANT R DESAI C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006 1/7/2004 12/30/2005 CLOSED

14. 13119828 IN300394 Karvy Stock Broking Ltd.

CHETAN D PARIKH C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006 1/7/2004 12/16/2005 CLOSED

15. 13120109 IN300394 Karvy Stock Broking Ltd.

DAKSHA M MEHTA C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006 1/7/2004 12/16/2005 CLOSED

16. 13120213 IN300394 Karvy Stock Broking Ltd.

DAKSHA S MEHTA C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006 1/7/2004 12/16/2005 CLOSED

17. 13119844 IN300394 Karvy Stock Broking Ltd.

DEPTI A DESAI C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006 1/7/2004 12/16/2005 CLOSED

18. 13120133 IN300394 Karvy Stock Broking Ltd.

HARSHIDABEN B SONI C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006 1/7/2004 12/16/2005 CLOSED

19. 13119932 IN300394 Karvy Stock Broking Ltd.

ILA M DESAI C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006 1/7/2004 12/16/2005 CLOSED

20. 13119877 IN300394 Karvy Stock Broking Ltd.

ILESH A PARIKH C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006 1/7/2004 12/16/2005 CLOSED

21. 13119772 IN300394 Karvy Stock Broking Ltd.

JANAK S DESAI C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006 1/7/2004 12/16/2005 CLOSED

22. 13119924 IN300394 Karvy Stock Broking Ltd.

JASUMATI N DESAI C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006 1/7/2004 12/16/2005 CLOSED

23. 13120588 IN300394 Karvy Stock Broking Ltd.

JIGNESH P DESAI C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006 1/7/2004 12/16/2005 CLOSED

24. 13120336 IN300394 Karvy Stock Broking Ltd.

JITENDRA K PARIKH C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006 1/7/2004 12/16/2005 CLOSED

25. 13120159 IN300394 Karvy Stock Broking Ltd.

KETKI A DESAI C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006 1/7/2004 12/16/2005 CLOSED

26. 13120168 IN300394 Karvy Stock Broking Ltd.

KEYURI A DESAI C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006 1/7/2004 12/16/2005 CLOSED

27. 13120125 IN300394 Karvy Stock Broking Ltd.

MADHUSUDAN M SONI C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006 1/7/2004 12/16/2005 CLOSED

28. 13120117 IN300394 Karvy Stock Broking Ltd.

MAHENDRA H MEHTA C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006 1/7/2004 12/16/2005 CLOSED

29. 13120264 IN300394 Karvy Stock Broking Ltd.

MANAN B PARIKH C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006 1/7/2004 12/16/2005 CLOSED

30. 13120069 IN300394 Karvy Stock Broking Ltd.

MANAN M MEHTA C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006 1/7/2004 12/16/2005 CLOSED

31. 13119908 IN300394 Karvy Stock Broking Ltd.

MAULIN T MEHTA C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006 1/7/2004 12/16/2005 CLOSED

32. 13119885 IN300394 Karvy Stock Broking Ltd.

MRUDULA A PARIKH C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006 1/7/2004 12/16/2005 CLOSED

33. 13120086 IN300394 Karvy Stock Broking Ltd.

MRUDULA BEN J PARIKH C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006 1/7/2004 12/16/2005 CLOSED

34. 13120140 IN300394 Karvy Stock Broking Ltd.

MRUGAVATI A DESAI C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006 1/7/2004 12/16/2005 CLOSED

35. 13119764 IN300394 Karvy Stock Broking Ltd.

NIKITA C DESAI C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006 1/7/2004 12/16/2005 CLOSED

36. 13120176 IN300394 Karvy Stock Broking Ltd.

NILIMA A DESAI C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006 1/7/2004 12/16/2005 CLOSED

37. 13120328 IN300394 Karvy Stock Broking Ltd.

NRUPAL M PARIKH C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006 1/7/2004 12/16/2005 CLOSED

38. 13120035 IN300394 Karvy Stock Broking Ltd.

PARESH D DESAI C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006 1/7/2004 12/16/2005 CLOSED

39. 13120019 IN300394 Karvy Stock Broking Ltd.

PIYUSH M SONI C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006 1/7/2004 12/16/2005 CLOSED

40. 13119957 IN300394 Karvy Stock Broking Ltd.

PRASHANT M DESAI C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006 1/7/2004 12/16/2005 CLOSED

41. 13119973 IN300394 Karvy Stock Broking Ltd.

PUNITA T MEHTA C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006 1/7/2004 12/16/2005 CLOSED

42. 13120300 IN300394 Karvy Stock Broking Ltd.

PURVI A PARIKH C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006 1/7/2004 12/16/2005 CLOSED

43. 13120248 IN300394 Karvy Stock Broking Ltd.

RASHMI B MEHTA C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006 1/7/2004 12/16/2005 CLOSED

44. 13120050 IN300394 Karvy Stock Broking Ltd.

ROOPA D DESAI C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006 1/7/2004 12/16/2005 CLOSED

45. 13120192 IN300394 Karvy Stock Broking Ltd.

RUPA M PARIKH C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006 1/7/2004 12/16/2005 CLOSED

46. 13119852 IN300394 Karvy Stock Broking Ltd.

RUPAL A PARIKH C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006 1/7/2004 12/16/2005 CLOSED

47. 13119797 IN300394 Karvy Stock Broking Ltd.

SHOBHANA S DESAI C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006 1/7/2004 12/16/2005 CLOSED

48. 13119980 IN300394 Karvy Stock Broking Ltd.

SUBHADRA H MEHTA C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006 1/7/2004 12/16/2005 CLOSED

49. 13120319 IN300394 Karvy Stock Broking Ltd.

SUBHASH H MEHTA C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006 1/7/2004 12/16/2005 CLOSED

50. 13120184 IN300394 Karvy Stock Broking Ltd.

SUMIR DESAI C O K P Jhaver, 803 Abhijit, Mithakali Circle Ellisbridg, Ahmedabad, 380006 1/7/2004 12/16/2005 CLOSED 9.69. It may be seen that all the account holders had the address of C O K P JHAVER, 803 ABHIJIT, MITHAKALI CIRCLE ELLISBRIDG, AHMEDABAD, 380006, which is the address of a key operator viz. the Jhaveri group. Pursuant to verification of the genuineness conducted by Karvy DP during November 2005 i.e. subsequent to the commencement of SEBI's preliminary enquiry into the matter, the DP had closed these dematerialized accounts.

9.70. Afferent Accounts with the same Surname It was found that many of the afferent dematerialized account-holders had common surnames. A summary of some such common surnames are given below:

Sr.

No.

Surname No.

of afferent demat accounts Address Date of Opening Date of Closure

1. Daksha Luhar (13015876) to Induben Luhar (13021863) 600 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 16

- 18 December 2003 November

-December 2005

2. Daksha Pari (13040728) to Induben Pari (13046715) 600 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 16 19 December 2003 November

-December 2005

3. Daksha Mistri (13139789) to Induben Mistri (13145777) 600 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 5-6 January 2004 November 16 -17, 2005 (one account closed in January 2006)

4. Daksha Shroff (13145785) to Induben shroff (13151778) 600 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 5-6 January 2004 November

-December 2005 (one account closed in January 2006)

5. Daksha Soni (14243715) to Induben Soni (14249666) 589 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 16/18 August 2004 November 2005 (two accounts closed in January 2006)

6. Daksha Suthar (14249674) to Induben Suthar (14255448) 578 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 16/18 August 2004 November 2005 (four accounts closed in January 2006)

7. Daksha Patel (14255456) to Induben Patel (14261229) 578 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 16/18 August 2004 November

-December 2005 (four account s closed in January 2006)

8. Daksha Joshi (14349790) to Induben Joshi (14355564) 578 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 16/18 August 2004 November

-December 2005

9. Daksha Dapki (15457926) to Induben Dapki (15463820) 591 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 20-21 July 2005 November 28, 2005

10. Daksha Panchal (12912969) to Ayushi Panchal (12915969) 301 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 6/24 November 2003 November

-December 2005

11. Daksha Kadia (14261238) to Samik Kadia (14263753) 253 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 16 August 2004 November 23 -24, 2005

12. Daksha Rami (15463839) to Naymesh Rami (15467905) 407 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 20-21 July 2005 November

-December 2005

13. Dasharath Seth (13162815) to Badri Seth (13163300) 50 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 20-21 July 2005 November

-December 2005

14. Kunal Seth (13129788) to Babita Seth (13139770) * 1000 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad, 380006 5-6 January 2004 (two accounts opened on 12.04.04) November

-December 2005   Total 7325       * - includes the set of 50 names from Suresh Seth to Aditi Seth as referred to earlier in various contexts.

9.71. From the above table, it may be seen that thousands of afferent dematerialized accounts were opened on a few dates. The thousands of the afferent account holders had a few common surnames. The address of the afferent dematerialized account- holders was indicated as the address of the key operator viz. Roopalben Panchal.

9.72. During November - December 2005, pursuant to verification of genuineness of the account holders in the wake of SEBI preliminary enquiry in the matter, Karvy DP had closed these dematerialized accounts.

9.73. The contention of Karvy DP that the applications were not received on the same date and because it follows a batch processing system, the dematerialized accounts were opened on the same day does not absolve it of its apparent failure to exercise due diligence while opening the dematerialized accounts. Further, even if the applications had not been received on a single day, it is clear that they would have been received around the same period and were processed by the DP on one or a few days. Further, admittedly, Karvy DP follows a batch processing system whereby many applications are verified, uploaded and activated en masse. Thus, when the DP had processed these applications together, it should have got alerted regarding the features of the applications as seen from the table above. In any case, as brought out by the discussions in this order, it was not mere failure to exercise due diligence that made Karvy to overlook these tell-tale signs. It is something more than that.

9.74. Examination of dematerialized accounts pending activation With regard to the dematerialized accounts that had been opened by Karvy DP and were pending for activation, during the course of the instant proceeding, Karvy DP was advised to submit the dematerialized account opening forms and the KYC documents. In this regard, Karvy DP vide letter dated June 8, 2007 stated that "The demat account opening forms pertaining to the clients of the sub broker Grace Consultancy, which are pending for activation, are not available with us as the same were returned back to the sub broker for complying with the required documentation at that point of time". From the submission of Karvy DP it can be deduced that when the DP entered the details in the CDSL system and generated BO IDs, the documentation in respect of the dematerialized accounts was either incomplete or absent. Though the DP may argue that the dematerialized accounts were not activated, it is clear that the DP opened dematerialized accounts on the basis of incomplete / non-existent documents. In the face of such fait accompli, the plea that the documents were incomplete and hence returned to the 'sub-broker' does not cut much ice.

9.75. Further, an examination of the details of these 10,000 dematerialized accounts shows that the account holders had 10 common surnames in sets of 1000 each. Further all these account holders had their bank accounts with Indian Overseas Bank. The details are as below:

Sr.

No.

Starting Name Last Name No of accounts Date of opening IOB Bank account No Remarks

1. KUNAL KAPUR RITU KAPUR 1000 22-Sep-05 2611-15001 to 2611-16000 Account opening forms returned

2. KUNAL TATED RITU TATED 1000 22-Sep-05 2611-16001 to 2611 - 17000 Account opening forms returned

3. KUNAL KELA RITU KELA 1000 22-Sep-05 2611-17001 to 2611-18000 Account opening forms returned

4. KUNAL SEN RITU SEN 1000 22-Sep-05 2611-18001 to 2611-19000 Account opening forms returned

5. KUNAL ROY RITU ROY 1000 22-Sep-05 2611-19001 to 2611-20000 Account opening forms returned

6. KUNAL IRANI RITU IRANI 1000 22-Sep-05 2611-20001 to 2611-21000 Account opening forms returned

7. KUNAL JHA RITU JHA 1000 22-sep-05 2611-21001 to 2611-22000 Account opening forms returned

8. KUNAL MEHTA RITU MEHTA 1000 22-sep-05 2611-22001 to 2611-23000 Account opening forms returned

9. KUNAL DAS RITU DAS 1000 22-sep-05 2611-23001 to 2611-24000 Account opening forms returned

10. KUNAL PRASAD RITU PRASAD 1000 22-sep-05 2611-24001 to 2611-25000 Account opening forms returned     Total 10000       9.76. The details of 50 such accounts on a sample basis is given below. It may be mentioned that as per the demat records all the account holders mentioned in the table below had their Savings Bank account with IOB, Stadium Road Branch.

BOID AccOp Date BOName BO Add BOCity BOPin DPName Ben BankMICR Ben Bank AccNo 1301440000399716 22092005 KUNAL KAPUR.

Office No.402, Shashwat Bldg. Nr. Hotel Kanak Ellisbridge AHMEDABAD 380006 KARVY STOCK BROKING LIMITED 380020011 2611-15001 1301440000399720 22092005 BAKULA KAPUR.

Same as above AHMEDABAD 380006 KARVY STOCK BROKING LIMITED 380020011 2611-15002 1301440000399735 22092005 GRAHI KAPUR.

Same as above AHMEDABAD 380006 KARVY STOCK BROKING LIMITED 380020011 2611-15003 1301440000399741 22092005 JAYSHREE KAPUR.

Same as above AHMEDABAD 380006 KARVY STOCK BROKING LIMITED 380020011 2611-15004 1301440000399754 22092005 KUNJ KAPUR.

Same as above AHMEDABAD 380006 KARVY STOCK BROKING LIMITED 380020011 2611-15005 1301440000399769 22092005 YAGNA KAPUR.

Same as above AHMEDABAD 380006 KARVY STOCK BROKING LIMITED 380020011 2611-15006 1301440000399773 22092005 NIRAV KAPUR.

Same as above AHMEDABAD 380006 KARVY STOCK BROKING LIMITED 380020011 2611-15007 1301440000399788 22092005 NISHA KAPUR.

Same as above AHMEDABAD 380006 KARVY STOCK BROKING LIMITED 380020011 2611-15008 1301440000399792 22092005 RAMESH KAPUR.

Same as above AHMEDABAD 380006 KARVY STOCK BROKING LIMITED 380020011 2611-15009 1301440000399809 22092005 AAKASH KAPUR.

Same as above AHMEDABAD 380006 KARVY STOCK BROKING LIMITED 380020011 2611-15010 1301440000399813 22092005 BALA KAPUR.

Same as above AHMEDABAD 380006 KARVY STOCK BROKING LIMITED 380020011 2611-15011 1301440000399828 22092005 DEV KAPUR.

Same as above AHMEDABAD 380006 KARVY STOCK BROKING LIMITED 380020011 2611-15012 1301440000399832 22092005 GRASHIT KAPUR.

Same as above AHMEDABAD 380006 KARVY STOCK BROKING LIMITED 380020011 2611-15013 1301440000399847 22092005 JEET KAPUR.

Same as above AHMEDABAD 380006 KARVY STOCK BROKING LIMITED 380020011 2611-15014 1301440000399851 22092005 KUNJAL KAPUR.

Same as above AHMEDABAD 380006 KARVY STOCK BROKING LIMITED 380020011 2611-15015 1301440000399866 22092005 YAJAN KAPUR.

Same as above AHMEDABAD 380006 KARVY STOCK BROKING LIMITED 380020011 2611-15016 1301440000399870 22092005 NIRBHAY KAPUR.

Same as above AHMEDABAD 380006 KARVY STOCK BROKING LIMITED 380020011 2611-15017 1301440000399885 22092005 NISHANT KAPUR.

Same as above AHMEDABAD 380006 KARVY STOCK BROKING LIMITED 380020011 2611-15018 1301440000399891 22092005 RANI KAPUR.

Same as above AHMEDABAD 380006 KARVY STOCK BROKING LIMITED 380020011 2611-15019 1301440000399906 22092005 AANSHI KAPUR.

Same as above AHMEDABAD 380006 KARVY STOCK BROKING LIMITED 380020011 2611-15020 1301440000399910 22092005 BALCHAND KAPUR.

Same as above AHMEDABAD 380006 KARVY STOCK BROKING LIMITED 380020011 2611-15021 1301440000399925 22092005 DEVAN KAPUR.

Same as above AHMEDABAD 380006 KARVY STOCK BROKING LIMITED 380020011 2611-15022 1301440000399931 22092005 GRISHA KAPUR.

Same as above AHMEDABAD 380006 KARVY STOCK BROKING LIMITED 380020011 2611-15023 1301440000399944 22092005 JEEVAN KAPUR.

Same as above AHMEDABAD 380006 KARVY STOCK BROKING LIMITED 380020011 2611-15024 1301440000399959 22092005 KUNTI KAPUR.

Same as above AHMEDABAD 380006 KARVY STOCK BROKING LIMITED 380020011 2611-15025 1301440000409461 22092005 VIRAJ KAPUR.

Same as above AHMEDABAD 380006 KARVY STOCK BROKING LIMITED 380020011 2611-15976 1301440000409476 22092005 BADAL KAPUR.

Same as above AHMEDABAD 380006 KARVY STOCK BROKING LIMITED 380020011 2611-15977 1301440000409480 22092005 DAXESH KAPUR.

Same as above AHMEDABAD 380006 KARVY STOCK BROKING LIMITED 380020011 2611-15978 1301440000409495 22092005 GIRISH KAPUR.

Same as above AHMEDABAD 380006 KARVY STOCK BROKING LIMITED 380020011 2611-15979 1301440000409501 22092005 JAVAL KAPUR.

Same as above AHMEDABAD 380006 KARVY STOCK BROKING LIMITED 380020011 2611-15980 1301440000409516 22092005 KOMAL KAPUR.

Same as above AHMEDABAD 380006 KARVY STOCK BROKING LIMITED 380020011 2611-15981 1301440000409520 22092005 UDAYA KAPUR.

Same as above AHMEDABAD 380006 KARVY STOCK BROKING LIMITED 380020011 2611-15982 1301440000409535 22092005 MINA KAPUR.

Same as above AHMEDABAD 380006 KARVY STOCK BROKING LIMITED 380020011 2611-15983 1301440000409541 22092005 SUMIT KAPUR.

Same as above AHMEDABAD 380006 KARVY STOCK BROKING LIMITED 380020011 2611-15984 1301440000409554 22092005 RAKESH KAPUR.

Same as above AHMEDABAD 380006 KARVY STOCK BROKING LIMITED 380020011 2611-15985 1301440000409569 22092005 BADREN KAPUR.

Same as above AHMEDABAD 380006 KARVY STOCK BROKING LIMITED 380020011 2611-15986 1301440000409573 22092005 DAYA KAPUR.

Same as above AHMEDABAD 380006 KARVY STOCK BROKING LIMITED 380020011 2611-15987 1301440000409588 22092005 GIRISHA KAPUR.

Same as above AHMEDABAD 380006 KARVY STOCK BROKING LIMITED 380020011 2611-15988 1301440000409592 22092005 JAY KAPUR Same as above AHMEDABAD 380006 KARVY STOCK BROKING LIMITED 380020011 2611-15989 1301440000409609 22092005 KONY KAPUR.

Same as above AHMEDABAD 380006 KARVY STOCK BROKING LIMITED 380020011 2611-15990 1301440000409613 22092005 UDHBHAV KAPUR.

Same as above AHMEDABAD 380006 KARVY STOCK BROKING LIMITED 380020011 2611-15991 1301440000409628 22092005 MINAKSHI KAPUR.

Same as above AHMEDABAD 380006 KARVY STOCK BROKING LIMITED 380020011 2611-15992 1301440000409632 22092005 SUNIL KAPUR.

Same as above AHMEDABAD 380006 KARVY STOCK BROKING LIMITED 380020011 2611-15993 1301440000409647 22092005 RAKHI KAPUR.

Same as above AHMEDABAD 380006 KARVY STOCK BROKING LIMITED 380020011 2611-15994 1301440000409651 22092005 VIRAL KAPUR.

Same as above AHMEDABAD 380006 KARVY STOCK BROKING LIMITED 380020011 2611-15995 1301440000409666 22092005 BADRI KAPUR.

Same as above AHMEDABAD 380006 KARVY STOCK BROKING LIMITED 380020011 2611-15996 1301440000409670 22092005 DIPTI KAPUR.

Same as above AHMEDABAD 380006 KARVY STOCK BROKING LIMITED 380020011 2611-15997 1301440000409685 22092005 SAUNIL KAPUR.

Same as above AHMEDABAD 380006 KARVY STOCK BROKING LIMITED 380020011 2611-15998 1301440000409691 22092005 DIYA KAPUR.

Same as above AHMEDABAD 380006 KARVY STOCK BROKING LIMITED 380020011 2611-15999 1301440000409706 22092005 RITU KAPUR.

Same as above AHMEDABAD 380006 KARVY STOCK BROKING LIMITED 380020011 2611-16000 9.77. From the above table, it may be seen that the above dematerialized accounts were opened in bulk on the same date and have the same address. The account holders had common surnames. Further, it is seen that the dematerialized account holders have bank accounts with consecutive numbers.

9.78. Further, as narrated in a later paragraph, the characteristics of the above account holders matches that of the clients financed by KCL through IPO finance provided to key operators who were sub-brokers of KSBL for IPO distribution. In this regard, I note that SEBI in the interim order dated April 27, 2006 had indicated "accounts opened but not activated. Probably were meant to be used later". Karvy DP in its reply dated May 09, 2006 to the observations of the interim order had stated "This observation itself is indicative of the bias against us by you. The observations is in the realm of conjectures, surmises and hypothesis and is totally unjustified and uncalled for."

Thus, the earlier inference of SEBI that the 10,000 dematerialized accounts indicated in the table above were meant to be used in subsequent IPOs appears to be correct.

9.79. Examination of Demat Accounts closed by Karvy DP Karvy-DP vide e-mail dated January 30, 2006 furnished the details of accounts closed by Karvy-DP where 20 or more dematerialized account-holders share common addresses. Upon perusal of the information it is seen that Karvy-DP has closed 38,409 accounts held with CDSL and 30,221 accounts held with NSDL. Prior to these closures Karvy-DP had 43,327 BO accounts with CDSL and 7,56,886 BO accounts with NSDL. Thus, it is seen that about 90% of the CDSL accounts held with Karvy-DP have been closed in the course of verification of genuineness of account-holders. Upon examining the details of the dematerialized accounts closed by Karvy-DP (taking address 1 as the basis for analysis), the following observations emerge:

Sr.

No.

Address No.

of dematerialized account-holders sharing the address Name of the Depository Comments 1 C O SEIPL, 804 Abhijeet I, Mithakhali Circle, Ahmedabad 380009 5793 NSDL This address is same as that of SEIPL 2 402 403 Shaswat, Opp Gujarat College, Ellisbridge, Ahmedabad - 380006 5492 NSDL This address is same as that of the Panchals 3 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad - 380006 3180 NSDL This address is same as that of the Panchals 4 402-403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad - 380006 1710 NSDL This address is same as that of the Panchals 5 C/0 SEIPL, 804 Abhijeet I, Mithakhali Circle Ellisbridge, Ahmedabad-380006 1472 NSDL This address is same as that of SEIPL 6 402 403 Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad - 380006 1415 NSDL This address is same as that of the Panchals 7 68 Samshta B Society, Opp Pinakin Society, Paldi, Ahmedabad-380007 1293 NSDL This address is same as that of Kelan Atulbhai Doshi 8 C/O SEIPL, 804 Abhijeet I, Mithakhali Circle, Ellisbridge Ahmedabad- 380006 1214 NSDL This address is same as that of SEIPL 9 803 Abhijit, Mithakhali Circle, Ellisbridge, Ahmedabad-380006 1099 NSDL This address is same as that of SEIPL 10 406, Shashwat, Opp. Gujarat College, Ellisbridge, Ahmedabad, 380006 4998 CDSL This address is same as that of the Panchals 11 307, Shashwat, Opp. Gujarat College, Ellisbridge, Ahmedabad, 380006 4975 CDSL This address is same as that of the Panchals 12 Office No.403, Shashwat Bldg., Nr. Hotel Kanak, Ellisbridge, Ahmedabad, 380006 4961 CDSL This address is same as that of the Panchals 13 Himalaya B-2, Asalfa, Ghatkopar W, Mumbai 400084 3814 CDSL This address is same as that of Budhwani 14 C/o.

SEIPL, G-1, Devpath Complex, B/h. Lal Bunglow, Navrangpura, Ahmedabad, 380009 2500 CDSL This address is same as that of SEIPL 15 Niketan Maheshwar 33, Peddar Road 5B, Mumbai - 400026 1120 CDSL This address is same as that of Seksaria 16 Maheshwar Niketan 33,Pedd, Mumbai, 400026 822 CDSL This address is same as that of Seksaria 9.80. From the above table relating to demat accounts closed by Karvy DP, it is seen that Karvy DP had opened numerous (running into many hundreds) demat accounts with common addresses, the common addresses being that of Karvy DP's sub-brokers namely Grace Consultancy, C/o Dipak Panchal, who is the husband of Devangi Panchal and the brother-in-law of Roopalben Panchal, Arth Realty Pvt. Ltd. (related to SEIPL), Purshottam Budhwani and Manojdev Seksaria.

9.81. Other observations regarding dematerialized accounts opened with Karvy DP In view of the cornering of retail portion of IPO shares observed in the case of Yes Bank IPO and the fact that almost all the afferent dematerialized accounts that were used for the cornering were held with Karvy DP, SEBI advised the depositories to conduct inspection of the DP and submit report to SEBI. Based on the inspection report of CDSL, it was noticed that BhOB has issued letters, which showed that multiple bank accounts have been opened by same person (same photograph) with different names and possessing the same or similar address. Some of such cases are listed below:

Multiple bank accounts opened with same photograph Sr.

No.

Name A/c no. with BhOB Name A/c no. with BhOB Name A/c no. with BhOB 1 Bhagyesh Vania 9550-12175 Abhilash Rathi 9550-2068 Abhilash Desai 9550-1068 2 Darni Verma 9550-3909 Karina Desai 9550-1576 Aarti Zala 9550-10040 3 Agat Pathak 9550-8117 Bhadresh Vala 9550-7165

-

-

4

Aanshi Pandya 9550-20 Aanshi Rathi 9550-2020

-

-

5

Bablu Pathak 9550-8958 Aakash Verma 9550-3010

-

-

6

Abhishek Rathi 9550-2078 Abhishek Desai 9550-1078

-

-

7

Agni Pathak 9550-8137 Badren Barot 9550-6986

-

-

8

Akshar Bhatt 9550-9222 Bablu Patil 9550-13958

-

-

9

Bhadresh Desai 9550-1165 Bhadresh Rathi 9550-2165

-

  10

Aditya Pandya 9550-107 Aakash Patil 9550-13010

-

-

11

Abhilash Verma 9550-3068 Agat Pandya 9550-117

-

-

12

Agat Rathi 9550-2117 Agat Desai 9550-1117  

-

Demat accounts opened with Karvy DP for the aforesaid account holders Sr.No Name BOlD Name BOlD Name BOlD 1 Bhagyesh Vania 78034 Abhilash Rathi 126968 Abhilash Desai 116966 2 Dami Verma 145379 Karina Desai 122049 Aarti Zala 56681 3 Agat Pathak 187451 Bhadresh Vala 177937 4 Aanshi Pandya 106487 Aanshi Rathi 126480 5 Bablu Pathak 195861 Aakash Verma 136385 6 Abhishek Rathi 127066 Abhishek Desai 117064 7 Agni Pathak 187656 Badren Barot 176141 8 Akshar Bhatt 198501 Bablu Patil 95869 9 Bhadresh Desai 117936 Bhadresh Rathi 127938 10 Aditya Pandya 107351 Aakash Patil 86383 11 Abhilash Venna 136961 Agat Pandya 107457 12 Agat Rathi 127450 Agat Desai 117459

-

9.82. In cases of letters of Vijaya Bank (VB) accepted by Karvy DP towards POI and POA for opening demat accounts, it was observed that the signature column of the branch manager consisted of just 'two ticks' and apparently such impression does not appear to constitute a bonafide signature.

9.83. Demat Accounts opened with POI and POA In case of accounts opened by Karvy DP on the basis of the letters issued by VB, it was observed that in many instances the date of opening of the BO account was much earlier than the date of issue of such letter issued by VB. Some of such instances are mentioned as under:

BOlD Date of account opening Date of POI & POA from Vijaya Bank 390669 27/8/05 08/09/05 389826 14/7/05 08/09/05 390181 17/8/05 08/09/05 390329 17/8/05 08/09/05 390293 17/8/05 08/09/05 390071 17/8/05 08/09/05 390196 17/8/05 08/09/05 390202 17/8/05 08/09/05 390221 17/8/05 08/09/05 389923 17/8/05 08/09/05 390240 17/8/05 08/09/05 391170 27/8/05 08/09/05 9.84. Different BOs with same signatures It was observed that the signature of the different BOs substantially match with each other. Some of the instances are as under:

Sr.

No BOID Name BOID Name BOID Name 1 108159 Hari Pandya 188153 Hari Pathuk 158158 Hari Trivedi 2 168151 Hari Barot 178151 Hari Vala 118150 Hari Desai 3 392856 Munny B Gupta 390859 Munni B Maniar 382854 Munni B Chokshi 4 143825 Jacky Verma 73821 Jacky Rathod 93823 Jacky Patil 5 227392 Dani D Pritam 227559 Dani D P (different person)

----

----

6

171842 Fida Barot 111841 Fida Pandya

----

----

7

111744 Fenil Pandya 121746 Fenil Desai.

-----

----

8

61645 Fena Zala 81649 Fena Vania 181641 Fena Vala 9 202046 Karina Bhatt 152044 Karina Gandhi 172048 Karina Barot 9.85. Consolidated Payment of account charges for various demat accounts:

The inspection of Karvy DP by SEBI revealed that the DP had accepted third party cheques for dues payable by various BOs. In case of 225 accounts, Karvy DP had accepted a single cheque (Cheque Number 273329 issued by HDFC Bank Navranpura, Ahmedabad) towards their dues. Similarly in case of 1276 accounts a single cheque (Cheque Number 699328 issued by HDFC Bank, Navrangpura, Ahmedabad) was accepted by Karvy DP. It was further observed that the DP had issued a single receipt in case of the amount paid on behalf of various accounts. Similarly in various accounts of Panchal Family/group a single consolidated cheque had been deposited by a third party on behalf of these account holders to settle the outstanding dues. Such practices are at variance with the market practices and clearly demonstrate tha Karvy DP knew for certain that it was only dealing with Roopalben Panchal or other key operators while purporting to deal with others on paper.

9.86. Based on information furnished to SEBI by Karvy DP vide letter dated June 8, 2007, it is seen that Karvy DP had accepted consolidated payments from key operators towards AMC charges and transaction charges of numerous dematerialized accounts held with the DP. The details are given below:

     

CHEQUE COLLECTION AMOUNT (PANCHAL)           Total AMC Charges Transactions Charges Sl No.

Chq_No.

Date Bank Name No of Accounts Amount No of Accounts Amount No of Accounts Amount 1 627986 12-May-03 HDFC 4 2743.00     4 2743.00 2 907406 12-May-03 HDFC 3 2449.00     3 2449.00 3 907407 12-May-03 HDFC 1 780.00     1 780.00 4 984761 12-May-03 HDFC 1 1589.00     1 1589.00 5 6278986 12-May-03 HDFC 1 192.00     1 192.00 6 774641 12-May-03 ICICI 1 324.00     1 324.00 7 780184 12-May-03 ICICIC 1 371.00     1 371.00 8 749833 12-May-03 VIJAYA 1 316.00     1 316.00 9 417618 22-Aug-03 HDFC BANK 1 146.00     1 146.00 10 766900 09-Sep-03 VIJAYA 1 150.00     1 150.00 11 273329 24-Oct-03 HDFC BANK 225 11250.00 225 11250.00     12 699328 24-Dec-03 HDFC BANK 1277 63850.00 1277 63850.00     13 699329 24-Dec-03 HDFC BANK 600 30000.00 600 30000.00     14 815625 24-Mar-04 BANK OF BARODA 1 119.32     1 119.32 15 144388 31-Mar-04 BOBL 1334 200000.00 1334 200000.00     16 394242 10-Jun-04 HDFC BANK 1 2600.00     1 2600.00 17 774588 24-Jul-04 ICICI 1 319.62     1 319.62 18 907683 24-Jul-04 ICICI 1 439.03     1 439.03 19 941364 24-Jul-04 ICICI 1 883.58     1 883.58 20 955211 24-Jul-04 ICICI 926 100000.00 926 100000.00     21 853131 24-Jul-04 SCB 1 966.12     1 966.12 22 853128 24-Jul-04 SCB 1 191.64     1 191.64 23 853129 24-Jul-04 SCB 1 110.43     1 110.43 24 853130 24-Jul-04 SCB 1 256.83     1 256.83 25 865238 24-Jul-04 SCB 1 198.06     1 198.06 26 984167 24-Jul-04 SCB 1 124.20     1 124.20 27 984168 24-Jul-04 SCB 1 135.34     1 135.34 28 984171 24-Jul-04 SCB 1 1162.14     1 1162.14 29 984172 24-Jul-04 SCB 1 477.36     1 477.36 30 985719 24-Jul-04 SCB 1 254.89     1 254.89 31 986122 24-Jul-04 SCB 1 526.72     1 526.72 32 984169 24-Jul-04 SCCB 1 126.24     1 126.24 33 984170 24-Jul-04 STANDARD CHARTERED 1 316.45     1 316.45 34 749844 24-Jul-04 VIJAYA 1 180.49     1 180.49 35 955249 19-Aug-04 ICICI BANK 2507 300000.00 2507 300000.00     36 152462 25-Aug-04 BOBL 566 56600.00 566 56600.00     37 151219 19-Nov-04 STANDARD CHARTERED 428 295500.00     428 295500.00 38 623168 21-Jan-05 hdfc bank 171 45000.00     171 45000.00 39 774593 25-J an-05 ICICI 1 211.58     1 211.58 40 907688 25-Jan-05 ICICI 1 380.19     1 380.19 41 936348 25-J an-05 ICICI 1 928.99     1 928.99 42 940881 25-Jan-05 ICICI 1 232.52     1 232.52 43 941368 25-J an-05 ICICI 1 631.45     1 631.45 44 943874 25-J an-05 ICICI 4 1078.78     4 1078.78 45 962365 25-J an-05 ICICI 1 1147.18     1 1147.18 46 940692 25-J an-05 ICII 4 3389.79     4 3389.79 47 984188 25-Jan-05 SCB 1 284.32     1 284.32 48 749850 25-J an-05 VIJAYA 1 160.89     1 160.89 49 64640 28-Mar-05 SBI 1 327.00     1 327.00 50 815633 29-Mar-05 BOB 1 495.40     1 495.40 51 35625 09-Jun-05 VIJAYA BANK 1 414.00     1 414.00 52 983781 12-Jul-05 ICICI 2778 300000.00 2778 300000.00     53 426709 10-Nov-05 SBI 1 586.70     1 586.70 54 40553 29-Nov-05 CIT! BANK 1 520.00     1 520.00 55 80498 29-Nov-05 CIT! BANK 1 500.00     1 500.00 56 41747 22-Dec-05 VIJAYA BANK 1 496.00     1 496.00       Total 10869 1432433.25 10213 1061700.00 656 370733.25         CHEQUE COLLECTION AMOUNT (JHAVERI)           Total AMC Charges Transactions Charges Sr.

No ChCl-No.

Date Bank Name No of Accounts Amount No of Accounts Amount No of Accounts Amount 1 36442 11-Dec-03 SIDDHI COOP BANK 3 300.00 3 300.00     2 497953 11-Dec-03 VIJAYA BANK 49 4900.00 49 4900.00     3 500376 08-J an-04 VIJAYA BANK 150 15000.00 150 15000.00     4 604590 08-J an-04 VIJAYA BANK 149 14900.00 149 14900.00     5 604855 08-J an-04 VIJAYA BANK 149 14900.00 149 14900.00     6 605500 08-J an-04 VIJAYA BANK 150 15000.00 150 15000.00     7 272992 10-J an-04 HDFC BANK 75 7500.00 75 7500.00     8 976373 24-Jul-04 VIJAYA 1 20244.60     1 20244.60 9 906815 25-Aug-04 VIJAYA BANK 1000 100000.00 1000 100000.00     10 185223 08-Nov-04 BHARAT OVERSEAS 225 22500.00 225 22500.00     11 909880 08-Nov-04 VIJAYA BANK 2500 250000.00 2500 250000.00     12 909888 18-Nov-04 VIJAYA BANK 800 80000.00 800 80000.00     13 269230 25-Jan-05 HDFC 179 16800.00     179 16800.00 14 269231 25-Jan-05 HDFC 466 41751.64     466 41751.64 15 287528 25-Jan-05 HDFC 564 33600.00     564 33600.00 16 287529 25-Jan-05 HDFC 714 33660.00     714 33660.00 17 287530 25-J an-05 HDFC 2570 128996.25     2570 128996.25 18 255190 31-Mar-05 HDFC 174 11124.69     174 11124.69 19 255393 31-Mar-05 HDFC 204 12777.69     204 12777.69 20 255789 31-Mar-05 HDFC 148 14182.74     148 14182.74 21 390999 31-Mar-05 HDFC 506 11157.75     506 11157.75 22 891948 31-Mar-05 VIJAYA 4150 122322.00     4150 122322.00 23 906878 31-Mar-05 VIJAYA 2436 78517.50     2436 78517.50 24 266069 25-May-05 VIJAYA BANK 1 1114.76     1 1114.76 25 906895 25-May-05 VIJAYA BANK 1 28381.69     1 28381.69 26 417645 17

-Nov-05 HDFC 3787 275500.00     3787 275500.00 27 417646 17

-Nov-05 HDFC 6771 206625.00     6771 206625.00 28 127526 02-Dec-05 BOB 1 86.16     1 86.16       Total 27923 1561842.47 5250 525000.00 22673 1036842.47 9.87. Summary of observations on the demat account holders of Karvy DP Keeping in view of the discussions regarding the dematerialized accounts opened by Karvy DP, the following conclusions emerge:

9.88. Thousands of dematerialized accounts were opened with Karvy DP on the same date. Many of these afferent accounts had common surnames. The addresses of the thousands of dematerialized account-holders were indicated as the addresses of the key operators. In many instances, bank letters were accepted towards POI and POA. Karvy itself had introduced the bank accounts of the dematerialized account- holders. In certain instances, dematerialized accounts had been opened without obtaining POI and POA. In certain instances, same photographs were used by various BOs. In other instances, many BOs had the same signatures. Karvy DP had accepted consolidated payments from the key operators towards numerous dematerialized accounts maintained with the DP. As discussed elsewhere in this order, Karvy DP had executed synchronized off-market transfers from the afferent dematerialized accounts to the dematerialized accounts of the key operators using pre-printed DIS and in certain cases even without the DIS. Pursuant to the verification conducted in the wake of SEBI preliminary enquiry in the matter of IPO irregularities, Karvy had closed these dematerialized accounts. Thus, it emerges that these dematerialized account-holders whose accounts were held with Karvy DP were fictitious / benami in nature and that Karvy was aware of it.

9.89. From the above, it is seen that Karvy DP has admitted that it did not do any KYC related verification while opening demat accounts and relied on the sub-brokers for the same. In the criminal complaint, Karvy has admitted that these sub-brokers / key operators had opened demat accounts in fictitious names.

9.90. The IPO financing provided by the Karvy to the afferent dematerialized account- holders was released to the key operators and no money was released to the ficititious / benami entities. The funds for IPO applicantions in the names of the afferent demat account holders came from the bank accounts of the key operators / sub-brokers of Karvy and not from the afferent dematerialized account-holders / IPO applicants. Similarly the refund money also went to the bank accounts of the key operators only.

9.91. From the above, it is logical to conclude that the thousands of dematerialized account-holders whose demat accounts had been opened with Karvy DP were fictitious / benami in nature and that Karvy was aware of the same.

9.92. Reliance on 'sub-brokers' for KYC verification In terms of SEBI circulars dated August 4, 2000 and August 24, 2004, the KYC verifications for the purpose of opening dematerialized accounts are required to the carried out by the DP. The SEBI circular ref: MRD/DoP/Dep/Cir-29/2004 dated August 24, 2004 specifically states that "While opening a BO Account, the DPs are required to exercise due diligence while establishing the identity of the person to ensure the safety and integrity of the depository system."

9.93. With regard to the KYC verification done by it while verifying the identity of the person, Karvy DP has claimed that it relied on sub-brokers appointed by it for carrying out the verification process. This is in contravention of the SEBI circular which places the onus on the DP to exercise due diligence while establishing identity of the person opening the demant account. Also, I do not find merit in the contention of Karvy DP for the following reasons:

9.94. In terms of Regulation 52 of SEBI (Depositories and Participants) Regulations, 1996, "No Participant shall assign or delegate its functions as participant to any other person, without the prior approval of the depository." In the instant case, there is nothing on record to suggest that Karvy DP had obtained the permission of depositories to assign or delegate its function of carrying out KYC verifications while opening demat accounts to its purported sub-brokers. Further, it may be noted that in terms of SEBI (DP) Regulations, there is no concept of sub-broker.

9.95. Process flow adopted by Karvy DP for opening Demat Accounts The process flow adopted while opening dematerialized accounts by Karvy DP for KYC compliance in respect of applications procured through sub-brokers, as per submissions of Karvy vide letter dated January 19, 2007 before the Enquiry Officer is given below:

9.96. From the above, it may be seen that as per the process flow detailed by Karvy -DP, it needs to verify the KYC documents procured through the sub-brokers, while opening dematerialized accounts.

9.97. In another proceeding in the matter of IPO irregularities, Karvy has produced a letter dated June 8, 1999 issued to a key operator namely Shri Purshottam Budhwani to substantiate their claim that the key operator was a sub-broker who procured demat clients for Karvy DP. Upon perusal of the letter, it is observed that the letter has been issued by Karvy Securities Ltd. intimating the allotment of sub- broker code no.42338 to Shri Purshottam G Budhwani. The letter mentions that "We will inform you the rate of sub broker payable to you for each issue separately." (emphasis supplied). Thus, a prima facie reading of the letter issued by Karvy Securities Ltd. suggests that Shri Budhwani was expected to operate as a sub-broker of Karvy Securities Ltd. for the purpose of procuring applicants in public issues. Though Karvy might argue now that the word 'issue' should be construed in its broader sense, I am of the view that the word 'issue' needs to be given an interpretation in the context in which it appears i.e. in the context of Karvy Securities Ltd. being an IPO broker. Therefore, it follows that Karvy Securities Ltd., as an IPO broker, had appointed Shri Budhwani as a sub-broker and assigned him a sub-broker code. It does not lie in the mouth of Karvy to claim now that it had appointed Shri Budhwani as a sub-broker for its DP operations. In any case, as noted earlier, there is no concept of sub-broker with regard to the activities of DP.

9.98. Further, in terms of the process flow for opening dematerialized accounts as per Karvy DP's own submissions also shows that the DP was required to conduct KYC verification in respect of the demat clients procured through the sub-brokers.

9.99. Considering the above, Karvy DP's claim of having relied on purported sub- brokers that are neither registered with SEBI nor recognized in law for carrying out the obligations relating to KYC verifications imposed upon Karvy DP as a SEBI registered Depository Participant, rings hollow and the same deserves to be dismissed in toto. In any event the DP cannot palm off its duties under the regulations to anyone else.

9.100. Role of KCL - IPO Financier The next step in the IPO process after the opening of bank accounts and dematerialized accounts is arrangement of IPO finance. It was found that for the purpose of arranging IPO finance for its demat clients, Karvy DP had tied up with BhOB during June 2003. The details of IPO financing done by BhOB in various IPOs pursuant to the tie-up with Karvy is given below:

IPOs financed by BHOB Name of IPO No.

of applications relating to suspect entities Amount Financed (Rs. In Lakhs) Maruti Udyog 725 552.91 UCO Bank 1020 321.34 Vijaya Bank 878 318.19 Indraprastha Gas Ltd.

4631

1707.69 TV Today 8503 2446.92 Patni Computers 10386 2415.23 Bank of Maharashtra 347 83.17 Biocon 1487 236.49 TCS 7605 2040.16 NTPC 10473 3120.31 Jet Airways 3084 718.01 Jay Prakash Hydro 1950 468 Yes Bank 12778 3038.19 SPL 2594 635.53 ILFS 11030 2412.81 Sasken 16123 3977.12 Prthvi Comm.

12

5.67 Pyramid 16 6.37 IDFC 6898 1693.46 Suzlon 12 2.94 9.101. From the above table, it is seen that pursuant to the arrangement with Karvy, BHoB provided IPo finance to 725 IPO applicants in the Maruti IPO that came during June 2003. Thereafter, the number of applications and the amount financed by BHoB increased as seen in the IPOs of Indraprastha Gas Ltd. (December 2003) wherein 4631 IPO applicants were financed by BHoB and Patni Computer Systems Ltd. (February 2004) wherein 10386 applicants were financed by BHoB. In this context, it may be recalled that pursuant to the arrangement with BHoB, Karvy had introduced the account holders to BHoB, based on which, they were able to obtain IPO finance from the Bank.

9.102. Thereafter, during October 2004 and March 2005, Karvy had introduced the key operators to Indian Overseas Bank, Ahmedabad and had also introduced fictitious joint account holders whose names were added to the IOB Bank accounts of the key operators. Based on the same, the key operators were able to obtain IPO finance from IOB also as in the case of BHoB.

9.103. Apparently, after having introduced the key operators and the afferent account holders to the banks during 2003, 2004 and the first quarter of 2005 as mentioned above, during July 2005, a Karvy group entity (Karvy Consultants Ltd., an NBFC) had provided IPO finance to the afferent account holders by extending IPO finance to the Key Operators.

9.104. Based on Annexure A of Karvy Consultants Ltd's reply dated May 9, 2006 to the SEBI interim order dated April 27, 2006, it is seen that KCL, an NBFC, had provided IPO finance to the following key operators in the IPOs listed below:

ROOPAL PANCHAL KCL FUNDING DETAILS IN VARIOUS ISSUES Issue Chq No. Margin Chq No. disbursement Loan Chq No. Repayment Chq No. Interest IDFC 484887 61880000 RTGS 247520000 185640000 777196 185640000 484887 3640000                     SASKEN   0 891062 20000000 260000000 269105 112500000 623077 2030140       891063 20000000   269106 57500000           891064 20000000   TFR TO AMAR 90000000           891065 20000000                 891066 20000000                 891067 20000000                 891068 20000000                 891069 20000000                 891070 20000000                 891071 20000000                 891072 20000000                 891073 20000000                 891074 20000000                               AMAR     RTGS 208900000 298900000 RTGS 298900000 623077 2333877       TFR FM SASKEN 90000000           MANOJ SEKSARIA KCL FUNDING DETAILS IN VARIOUS ISSUES Issue Chq No. Margin Chq No. disbursement Loan Chq No. Repayment Chq No. Interest Int. TDS ILFS 723248 2161250 530271 20000000 19451250 763602 19451250 723249 117798 34082       530272 1612500                                   IDFC 763603 9800000 891127 20000000 80920000 624990 19040000 763608 490056 141785   763604 4400000 891128 20000000   628989 19040000 763617 10955 3169   763605 80000 891129 17120000   763606 38318000             891130 19040000   763607 4522000             891131 19040000                                   SASKEN 763616 9100000 891143 20000000 172900000 800783 9000000             891144 20000000   800780 20000000             891145 20000000   800776 20000000             891146 20000000   763624 20000000             891147 20000000   763623 20000000             891148 20000000   800778 20000000             891149 20000000   800779 20000000             891150 20000000   763625 20000000             891172 20000000   800777 20000000             891173 2000000   763642 3900000                             SUZLON 800799 4993920 891214 20000000 44945280 800752 37500000 723195 272154 78752       891215 20000000   723194 5439200             891216 9939200   800762 2000000                   Recon 6080       PURUSHOTTAM BUDHWANI KCL FUNDING DETAILS IN VARIOUS ISSUES Issue Chq No. Margin Chq No. disbursement Loan Chq No. Repayment Chq No. Interest Int. TDS IDFC 276018 11280000 891152 20000000 80920000 276024 39032000 276027 490056 141785   276019 3000000 891153 20000000   768077 19040000 276032 9224 2669       891154 17120000   738076 19040000             891155 19040000   276025 3808000             891156 19040000                                   SASKEN 276031 9100000 891175 20000000 172900000 242163 4300000 242174 104709 2 302949       891176 20000000   242153 20000000             891177 20000000   242154 20000000             891178 20000000   242155 20000000             891179 20000000   242156 20000000             891180 20000000   242173 80000000             891181 20000000   242166 8600000             891182 20000000                   891183 20000000                   891174 2000000                                   SUZ 800799 4993920 891214 20000000 44945280 800752 37500000 723195 272154 78752 LON                           891215 20000000   723194 5439200             891216 9939200   800762 2000000                     6080                                                   PARAG JHAVERI KCL FUNDING DETAILS IN VARIOUS ISSUES Issue Chq No. Margin Chq No. disbursement Loan Chq No. Repayment Chq No. Interest IDFC 287559 11900000 RTGS 101150000 75862500 982650 75862500 287561 1487500   287560 700000                 287562 87500                 287566 12600000                                   SASKEN   6500000 891076 45500000 39000000 266141 39000000   600000                     9.105. Observations on IPO Financing by Karvy: From the above table, it may be seen that as per Karvy's submissions, it had provided IPO finance to Roopalben Panchal in the IPOs of IDFC, Sasken and Amar Remedies. For instance, in the case of IDFC, Karvy had provided IPO finance of Rs. 18,56,40,000 i.e.Rs. 18.56 crores to Roopalben Panchal. Based on the IPO loan agreement dated July 21, 2005 entered into between Karvy Consultants Ltd. and Roopalben Panchal, it is seen that Karvy had provided IPO finance to Roopalben Panchal to apply for 7280000 shares in IDFC IPO. Shri Mayur Modi and Shri Aditya Gupta, employees of Karvy had acted as references for Roopal Panchal.

9.106. It is seen that the disbursement of the loan was made by Karvy through RTGS transfer to the IDFC escrow account. Vide its letter dated May 19, 2007, KSBL had submitted that an amount of Rs. 51,90,78,000 i.e. Rs. 51.90 crores was transferred to the escrow account of ICICI who were bankers to the issue of IDFC. The amount was in respect of 10,900 applications which were being financed by KCL as an NBFC. The amount of Rs. 51,90,78,000 was inclusive of Rs. 12,97,69,500 i.e. 12.97 crores, being the amount collected from various loan applicants as margin money.

9.107. It is seen that in the case of Sasken IPO, Karvy did not take any margin from Roopalben Panchal. Karvy had provided 100% IPO finance of Rs. 26 crores to Roopalben Panchal. Further, Karvy had transferred Rs. 9 crores out of the refund money of Sasken IPO for making application in the IPO of Amar Remedies on behalf of Roopalben Panchal. In addition, Karvy had made RTGS transfer of Rs. 20.89 crores in the IPO of Amar Remedies towards IPO loan given to Roopalben Panchal. In this regard Karvy DP in its reply dated May 19, 2007 has stated that "it may however, be noted that the margin amount was not transferred to KCL, but only the loan amount was disbursed to the loanee, who inturn has deposited the total amount inclusive of the margin amount to the escrow account of the issuer." In the normal course of IPO finance the financier collects the margin amount from the borrower and issues cheque / DD favourig the escrow account for the application money. This practice is adopted to ensure that the loan money is utilized only for the purpose of making IPO application. That KCL, instead of adopting the normal practice as above, released the loan amount directly to the key operator (Roopal Panchal) shows that Karvy had full control over the manner of application of funds. In this regard, I note that RBI has issued guidelines to NBFCs regarding Customer identification procedures and KYC norms to be followed by them.

9.108. Similarly, it is seen that Karvy had provided IPO finance to various other Key Operators, namely, Manoj Seksaria, Purushottam Budhwani a nd Parag Jhaveri in respect of various IPOs namely, ILFS, IDFC, Sasken and Suzlon. As regards the financing by KCL to Purshottam Budhwani, it was found that KCL had disbursed the loan amount many days after the closure of the IDFC IPO. In this regard KSBL in its reply dated May 19, 2006 has stated that "we had received the margin subsequently. It is submitted that the margin was received by KCL on the date of closure of the issue. It is reiterated that KCL had not disbursed the loan amount to Purshottam Budhwani, since KCL had not received the margin." In this regard it is noted that KSBL, the stock broker, had bid the IDFC IPO application forms pertaining to Purshottam Budhwani on the last day of the issue i.e. July 22, 2005. Apparently the cheques attached to the application forms were encashed a week later i.e. after the disbursal of the loan money by KCL.

9.109. Based on the data furnished by Karvy Consultants Ltd. (KCL) in its letter dated May 9, 2006, it was seen that KCL had granted IPO financing to 5200 individual applicants on the strength of loan applications purportedly received from them in regard to the IPO of IDFC. When KSBL was asked to furnish copies of all 5200 loan applications in the course of personal hearing, it pointed out that all the original loan applications were seized by CBI in the course of search and seizure operation and were lying in the custody of CBI. SEBI has obtained sample copies of some of the request letters for sanction of IPO funding from CBI. A perusal of these request letters reveals that each such document consists of two pages and comprises Request Letter for Sanction of Loan, Receipt of Loan, and Letter to the Bank to debit the account of the account holder / loan applicant and Promissory Note in favour of KCL. As per these documents, the salient features of IPO funding to these 5200 loan applicants are as under:

The cheque for the loan amount was issued in favour of each individual applicant.

KCL was authorized to credit the bank account of each applicant towards refund for the said IPO directly and debit each bank account subsequent to receipt of refunds towards principal amount as well as interest etc. The loan amount was advanced for a period of 15 days from July 22, 2005 which was the last day of currency of IDFC IPO.

9.110. However, it is a matter of record that no separate cheques were issued by KCL towards the loan amount in favour of individual applicants presumably because KCL was very well aware that the SB Account Nos. mentioned in the said 5200 loan applications did not exist at all. It was for this reason again that individual refund orders for crediting the respective bank accounts of the said 5200 loan applicants were not issued by Karvy RTI pursuant to allotment in the IPO of IDFC and in lieu thereof, consolidated refund orders were issued.

A scrutiny of the said Request Letters and other loan documents brings out that:

The SB Account Nos. of the applicants were shown as 9550-1, 9550-2, 9550-3, 9550-4 and so on with the BhOB, Ellisbridge, Ahmedabad.

The cheque number for the loan amount granted by KCL was not mentioned on any of the Receipts.

There was no individual loan sanction letter issued by KCL to each applicant.

There was no mention of rate of interest on any of the Promissory Notes executed by each applicant. No interest has actually been paid to KCL by any of 5200 individual loan applicants.

There was no mention of receipt of any margin from any of the individual applicants. The application amount for each application was Rs.47,600/- whereas the loan amount was Rs.35,700/- per application. In other words, the differential amount of Rs.11,900/- represented the margin amount (25%) to be contributed by each applicant. There is no evidence to suggest that KCL received margin moneys from any of the 5200 individual loan applicants.

9.111. KCL is also stated to have entered into another loan agreement with Roopal N Panchal on July 21, 2005 in the IPO of IDFC. The following points need to be considered in this regard:

i) The loan applicant, Roopal N Panchal based at Ahmedabad made an application for loan to KCL, Hyderabad on July 21, 2005. KCL, Hyderabad sanctioned the said loan to her on the same day subject to her executing Agreement of Pledge, POA, Demand Promissory Note, Post Dated Cheques etc. which was also done on the same day.

ii) There is nothing in the loan agreement with Roopal N Panchal to show that she had underwritten the loan for 5200 applicants.

iii) The application was made by Roopal N Panchal for loan of Rs.18,56,40,000/- for applying in the IPO of IDFC wherein KCL "may be the second applicant". The amount of loan was required by Roopal N Panchal for the purpose of applying for 7280000 shares in the IPO of IDFC.

iv) A perusal of the loan sanction letter shows that the column of rate of interest is left blank.

v) No disbursement of funds was made by KCL to any of 5200 individual loan applicants.

vi) Subsequent to allotment, the refund money was given to Roopalben Panchal through a few consolidated refund orders.

vii) Roopal N Panchal paid interest of Rs.36,40,000/- on loan of Rs. 18,56,40,000/- for a period of 15 days from the date of closure of issue i.e. 22.07.2005 although money was disbursed by KCL on 30.07.2005 till the date of allotment/ refund, i.e. 06.08.2005. This gives an interest rate of over 47% p.a. for a period of 15 days. No reasonable or prudent person would pay such exorbitant rate of interest, especially when he can avail of IPO finance from Bank/ NBFCs @ 14-15% p.a. Karvy has not been able to offer any explanation in this regard. KCL has admittedly charged 18% -19% p.a. from the Key Operators namely Purushottam Budhvani and Manoj Dev Seksaria.

viii) Apparently, there were no efforts on the part of Karvy for ascertaining the identity of borrowers by way of photographs, identification documents etc.

ix) Apparently, KCL did not take any steps to ascertain the credit worthiness of the borrowers.

x) Also, Karvy made no attempt to obtain the correct address - permanent address of the loan applicants.

9.112. In effect, what emerges is that KCL funded Roopalben Panchal for making 5200 IPO applications in the IPO of IDFC. The so-called loan applications with 5200 individual loan applicants were nothing but just a make-believe.

9.113. Even if it is assumed for the sake of argument that the 5200 borrowers were real persons, it is hard to believe that the said 5200 loan applicants having the same address as Roopalben Panchal at Ahmedabad would approach KCL, Hyderabad for obtaining IPO finance @ 47%p.a. whereas they could have availed such finance locally on more reasonable terms.

9.114. A perusal of the Income-Tax returns of Roopalben Panchal shows that she had shown total income of Rs.76,760 and Rs.1,08,420 in her I.T. return for A.Y.s 200304 and 2004-05 respectively. With such meager income/ resources, it is hard to believe that any financier would have provided IPO finance to the tune of Rs.18,56,40,000/-to her. All these circumstances put a big question mark on the genuineness of the loan documentation as well as the loan transaction. A perusal of loan applications indicates that this was meant to be a single application for allotment of 26,78,500 shares to Roopal N Panchal presumably under the HNI category.

9.115. Based on documents submitted by Karvy, it is seen that Karvy Consultants Ltd. had provided loan of Rs. 4,85,52,000/- at 19% p.a. for a period of 15 days to a key operator namely Shri Purshottam Budhwani for making application in the IPO of IDFC Ltd. Karvy had specified a margin of Rs.85,68,000/- for the loan.

9.116. In the normal course of a financier providing IPO loan, the financier enters into an agreement with the borrower, collects the margin money from the borrower and issues a cheque / DD favouring the IPO escrow account for the full application money. The release of loan by way of cheque / DD favouring the escrow account ensures that the loan money is used only for the intended purpose of applying in the IPO and is not diverted / misused by the borrower for any other purpose. Further, a lien is noted on the demat account of the borrower to ensure IPO shares that get allotted are available as security for the loan and a lien is noted on the bank account to ensure refund money is available for adjustment against the loan.

9.117. In the case of purported IPO finance provided by Karvy Consultants Ltd. to the key operator, the loan money was apparently released directly to the key operator, who in turn divided the same for making numerous small value applications so as to be eligible for allotment in the retail category. The above leads to the possible inference that Karvy Consultants released the IPO finance to the key operator rather than issue a cheque favouring the escrow account, as is the normal practice, to enable the key operator to execute their gameplan of dividing the IPO finance into numerous IPO applications in the retail category. If Karvy Consultants was providing IPO finance in the normal course, it would necessarily issue a cheque favouring the escrow account to ensure that the borrower uses the money only for the purpose of IPO finance. In the instant case, Karvy Consultants, in order to enable the key operator to make multiple applications in fictitious / benami names, provided IPO finance directly to the key operator rather than to the escrow account. From this, it may be inferred that Karvy Consultants was aware of the intentions of the key operator and did its part to ensure that the key operator's gameplan got executed without a hitch.

9.118. DETAILS OF THE AFFERENT ACCOUNTS/ BANK ACCOUNTS OF KEY OPERATORS USED IN THE IPO OF IDFC FOR AVAILING FINANCE FROM BHOB / IOB / KCL Name of the Key Operator (Bank Account No.) No of afferent entities that were financed Address of the afferent account holder as per demat account Name of the Bank as per the demat records of the afferent accounts (significant for purpose of Refund) Finance availed from with BhOB/ IOB / KCL Roopal Panchal (55045) - BHOB (50795) - BHOB (54119)-BHOB IOB (15,107) KCL (5,200) 402-403, Shashwat, Opp Gujarat College, Ellisbridge, Ahmedabad - 380006 BHOB IOB / KCL Parag Jhaveri / SEIPL BHOB (3125) KCL (2125) C/o.

SEIPL, G-1, Devpath Complex B/h. Lal Bunglow, Ahmedabad.

Vijaya Bank BHOB /KCL Kelan Atul Doshi (2527) - IOB (8993) - BHOB IOB( 1994) BHOB (495) 68, Samashta B Society Opp Pinakin Soc Paldi, Ahmedabad BHOB /IOB BHOB / IOB Biren Kantilal Shah KCL (1210) 23, Payal Complex, Sayajigunj, Paldi, Baroda, 3900053 Tamilnadu Mercantile Bank (TMB) KCL Purshottam Bhudwani KCL (2000) B/2 Himalaya Asalaya Ghatkopar, W, Mumbai.

HDFC BANK KCL Manoj Sekseria KCL (2000) Niketan Maheshwar, 33, Peddar Road, 5B HDFC BANK KCL D B Mehta KCL ( 498) BHOB (1032) 6 Vinay Bhuvan, 90 Foot Road, Ghatkopar (E) Mumbai BHOB BHOB / KCL Dhaval Katakia KCL (519) BHOB (722) Kailash Plaza, Bldg no 126, Near Kar Ke RAs Hotel, Above ICICI Bank, Ghatkopar (e), Mumbai.

BHOB BHOB / KCL Total 36,027       9.119. It is seen from the above table that 36,051 afferent demat accounts (out of 49, 708 afferent accounts held with Karvy DP) were used in the IPO of IDFC where finance was availed from BhOB / IOB / KCL. It is relevant to note that majority of the afferent account holders had their bank accounts with BhOB which were introduced by Karvy (viz. SB Account Nos. 50795 and 54119). Karvy admittedly certified the signatures of the afferent account holders to IOB and also introduced the bank accounts of the Key Operator like Roopal Panchal who availed financed from IOB and thereafter KCL itself started financing these key operators. Thus, Karvy had initially introduced afferent account holders with BhOB (as per the Idea Paper in the IPO of Maruti Udyog Ltd.) in the month of June, 2003 and then in the month of December, 2003 and thereafter encouraged Key Operators to open bank accounts with same modus operandi and opened demat accounts with one bank accounts with series of names attached with each account. Thereafter, Karvy had introduced saving bank accounts of Key Operators like Roopal Panchal, Kelan Atul Doshi with IOB in the month of March, 2005 and thereafter also certified list of names attached with each account and enabled them to get finance from IOB. Further, Karvy itself in the month of July, 2005 extended finance to the key operators whom it had introduced with BhOB and IOB and in the month of September, 2005 Karvy made an attempt to open 10,000 demat accounts of Roopal Panchal with the bank accounts of IOB. Karvy submitted that it had returned the demat account opening forms to the applicants for want of adequate compliance of KYC norms. However, it is relevant to note that Karvy had already extended finance to demat accounts with the same modus operandi and with the same name with different surnames as explained elsewhere in the report.

9.120. The analysis of the afferent demat accounts of Roopalben Panchal used in the IPO of IDFC is mentioned in the table below:

No of afferent demat accounts Name of the Bank as per demat records Name of the account holder Date of opening of bank account Date of opening of demat account on NSDL / CDSL 297 BHOB 50795

- Devangi Dipak Panchal (introduced by Karvy Securities and Karvy investors Services Ltd) 17.06 03 (Closed on 27.10.03) 27.06.03 3200 BHOB 54119 (-Devangi Dipak Panchal -Group a/c) (introduced by Karvy Securities Ltd) 4.12.03 (Closed on 24.04.04) 12.12.03 6810 BHOB 55045 Arajav N Panchal (Introduced by Dipak Jasvantlal Panchal) 5.02.04 6.02.04 (1045) 16.08.04 (2996) 20.10.04 (200) 17-19.07.05 (2569) 10,000 BHOB 9550 Arjav Naresh Panchal (introduced by Devangi Dipak Panchal) December

-2004 16.07.05 (10,000) - CDSL accounts 20307     Total   9.121. It is noted that the afferent demat account holders financed by IOB had indicated BhOB as their banker in their respective demat records. It is seen that Karvy Stock broking Pvt. Ltd had introduced the 19 bank accounts of Roopal Panchal with IOB Thaltej Branch with list of 50 names and signatures certified by Karvy Stock Broking. Based on such certification, the afferent accounts of Roopal Panchal were able to avail IPO finance in the IPO of IDFC for 15,131 afferent applicants. The analysis of the said demat accounts suggests that first bank accounts were introduced by Karvy and thereafter Key Operators have adopted same modus operandi as could be observed from the fact that all the key operators had same modus operandi of having one main account with series of sub-numbers. The following Key Operators who hold bank account with BhOB had used the same modus operandi. The details of such bank accounts and the number of dematerialized accounts that indicated these bank accounts in their demat records is given below:

Name of the Key Operator BhOB Bank account no Number of demat accounts Remarks Roopal Panchal 9550 15000 The bank accounts number had bank account number starting from 9550 / 1 to 9550 / 15000 Kelan Atul Doshi 151008993 700 The bank accounts number had bank account number starting from 151008993/ 1 to 151008993 / 700 Biren Kantilal Shah 2527 700 The bank accounts number had bank account number starting from 2527 / 1300 to 2527 / 2000 9.122. It is observed that Karvy stock broking had introduced the bank account no. 12004 of Kelan Atul Doshi with IOB, Stadium Branch, Ahmedabad.

9.123. Role of KSBL as Broker (Observations on bidding of IPO forms):

The process flow relating to bidding of application forms as indicated by Karvy during the enquiry proceedings is given below:

9.124. KSBL in its reply dated May 09, 2006 to the SEBI interim dated April 27, 2006 had stated as below at para 4.25.11: It is submitted that the changes in the process followed by BHOB as part of the internal procedure and process towards IPO funding had never been suggested in the Idea Paper. Maintaining of "manual control sub ledger account" confirms that the bank was aware of individual customers and had accounts for them, though not in the system. Further the applications have been handed over to us for the purpose of bidding along with individual pay orders, signifying loans being provided to that many applicants. It is necessary for each such application to be bidded in the NSE / BSE system before depositing the applications along with the payment instrument, with the bank, designated as the collecting Bank for the IPO. Biding can be done only by syndicate / sub-syndicate members to the issue and we being a syndicate / sub syndicate have provided the service of upload to NSE / BSE for these loan cases.

9.125. Further, KSBL, in its reply dated May 19, 2007 to the post enquiry show cause notice dated May 04, 2007 of SEBI stated at para 17.6 as below: On the last day of the issue, there are huge volumes of applications submitted by various investors. These applications along with the payment instruments are submitted to the escrow bankers to the issue on the following da subsequent to the closure of the issue.

9.126. From the reply, it is clear that at the time of bidding of the IPO application form, it is necessary for the syndicate member to obtain the duly filled in application form along with the payment instrument (cheque/DD). Further, in terms of Guideline 11.3.1 Clause xvii (a) of SEBI (DIP) Guidelines, 2000, "The broker may collect an amount to the extent of 100% of the application money as marging money from the clients / investors before he places an order on their behalf... ". Thus in terms of the guidelines prescribed by SEBI before placing the order of the IPO applicant on the Exchange System ( i.e. bidding), the broker is required to collect 100% of the application money as margin from the clients/investors.

9.127. Also, based on information collected by SEBI from Market Participants which act as brokers/syndicate members, it is gathered that while bidding the IPO application, the broker/syndicate member verifies the application form and ascertains that the application money is duly filled in with the cheque/DD attached to the application form.

9.128. Therefore, in terms of regulatory guidelines, market practices and Karvy's own submissions, it is essentital for the IPO application forms to be accompainied by payment instruments. After bidding, the syndicate member forwards the application form along with the payment instrument to the banker to the issue (also known as Escrow Collection Bank). The banker to the issue detaches the instrument and sends the same for collection while simultaneously forwarding the application form to the Registrar to the issue.

9.129. As mentioned earlier, in the case of IDFC IPO, wherein Karvy Consultant Ltd. had acted as IPO financier, it had done RTGS transfer of Rs.51,90,78,000 to the IDFC escrow account on July 30, 2005. The IDFC IPO opened on July 15, 2005 and closed on July 22, 2005. Therefore it is seen that the RTGS transfer made by Karvy Consultants Ltd. to IDFC Escrow account was after the date of closure of the IPO. In view of the fact that RTGS took place in respect of 10900 applicants after the closure of the IPO, it appeared that these IPO applications were not accompanied by payment instruments at the time of bidding of the applications.

9.130. Further, in the case of Suzlon IPO, the public issue closed on September 29, 2005 and it was found that KCL had made RTGS transfer of Rs.20.51 crores to the escrow account of Suzlon IPO on October 5, 2005 i.e. many days after the date of close of the IPO. In this regard, KSBL has submitted that the amount to be transferred towards margin and the loan funded by KCL for various afferent applicants in the Suzlon IPO was ascertained only by the evening of September 29, 2005. Since September 30, 2005, October 1 and October 2, 2005 were Bank holidays KCL made RTGS transfer to the Suzlon IPO Escrow account on October 5, 2005 in respect of the applicants financed by it. Thus it may be seen that at the time when KSBL, a stock broker and also a sub-syndicate member had bid the application forms on September 29, 2005, the application forms were not accompanied by cheques / DDs for the application money.

9.131. Bidding of IDFC IPO Applications by KSBL (Stock Broker) In view of the above, the bidding of the IPO applications was examined:

Based on the examination of the bid book data obtained from Karvy as well as the Stock Exchange, it is seen that the application was bid by the broker having the code "07701". Based on information obtained from NSE, it is seen that the broker code "07701" belongs to Karvy Stock Broking Ltd. Thus it is seen that KSBL in its capacity as a broker of NSE and also a sub-syndicate member has bid the application forms in respect of the applicants financed by KCL through IPO finance to the Key Operators. It is clear that the individual application forms of these applicants did not contain the payment for the IPO application. This is evidenced by the fact that if there had been a cheque/DD attached to the application form, the same would have been collected by the banker to the issue and there would have been no occasion for KCL to make RTGS transfer directly to the escrow account may days after the closure of the public issue.

9.132. It was seen that the 5200 IDFC IPO applicants financed by Karvy through Roopal Panchal had only eight surnames i.e. Pandya, Rathi, Desai, Verma, Gandhi, Trivedi, Vala and Pathak. The details are as below:

Last Name No.

of Applicants PANDYA 1000 RATHI 500 DESAI 680 VERMA 1000 GANDHI 1000 TRIVEDI 200 VALA 100 PATHAK 720 Total 5,200 9.133. An extract of the salient fields of the bid book is given below in respect of 100 bids made in the name of applicants having the last name as "Pandya":

BROKER LOCATION USER ID NAME OF USER DATE OF ENTRY IHNO APPL_NO NAME ADD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:23:07 PM 2975001 32990828 KUNAL PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:23:10 PM 2975002 32990829 BAKULA PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:23:13 PM 2975003 32990830 GRAMI PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:23:16 PM 2975004 32990831 JAKSHREE PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:23:18 PM 2975005 32068477 KUNJ PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:23:22 PM 2975006 32068478 VAGNA PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:23:25 PM 2975007 32068479 NIRAN PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:23:27 PM 2975008 32068480 NISHA PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:23:30 PM 2975009 32068481 RAMESH PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:23:33 PM 2975010 32068482 AAKASH PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:23:35 PM 2975011 32068483 BALA PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:23:39 PM 2975012 32068484 DEV PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:23:41 PM 2975013 32068485 GRASHIT PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:23:44 PM 2975014 32068486 JEET PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:23:46 PM 2975015 32068487 KUNALPANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:23:49 PM 2975016 32068488 PAJAN PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:23:52 PM 2975017 32068489 NIRBHAY PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:23:55 PM 2975018 32068490 NISHANT PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:23:58 PM 2975019 32068491 RANI PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:24:00 PM 2975020 32068492 AANSHI PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:24:02 PM 2975021 32068493 BALCHAND PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:24:05 PM 2975022 32068494 DEVAN PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:24:07 PM 2975023 32068495 GRISHA PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:24:10 PM 2975024 32068496 JEEVAN PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:24:13 PM 2975025 32068497 KUNIT PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:24:15 PM 2975026 32068498 VAMYA PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:24:18 PM 2975027 32068499 NIRDESH PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:24:21 PM 2975028 32068500 NISHIT PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:24:23 PM 2975029 32068501 RANJIT PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:24:26 PM 2975030 32068502 USHMA PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE                 ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:24:28 PM 2975031 32068503 BALI PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:24:30 PM 2975032 32068504 DEVANG PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:24:32 PM 2975033 32068505 GUDDY PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:24:34 PM 2975034 32068506 JENITH PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:24:37 PM 2975035 32068507 KUSH PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:24:40 PM 2975036 32068508 YASH PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:24:43 PM 2975037 32985551 NIRJA PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:24:46 PM 2975038 32985550 NISHU PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:24:48 PM 2975039 32985549 SUNITA PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:24:51 PM 2975040 32985957 AARTI PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:24:53 PM 2975041 32985775 BALRAM PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:24:56 PM 2975042 32985774 DEVANSH PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:24:59 PM 2975043 32985836 GULAB PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:25:01 PM 2975044 32985835 TRIKAL PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:25:03 PM 2975045 32985834 KUSUM PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:25:06 PM 2975046 32985833 YASHANG PANDYA AHMEDABAD 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:25:09 PM 2975047 32985832 NIRMAM PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:25:12 PM 2975048 32985831 SURESH PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:25:15 PM 2975049 32985830 ABHAY PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:25:18 PM 2975050 32985829 DEVANSH I PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:25:20 PM 2975051 32985828 GULJAR PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:25:23 PM 2975052 32985827 JENNY PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:25:26 PM 2975053 32985826 LABOHA PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:25:28 PM 2975054 32985825 YASHI PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:25:31 PM 2975055 32985824 NIRU PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:25:33 PM 2975056 32985823 NITA PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:25:36 PM 2975057 32985822 UTAPLL PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:25:39 PM 2975058 32985821 ABHIGNA PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:25:41 PM 2975059 32985820 BALWANT PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:25:44 PM 2975060 32985819 DEVARSH I PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:25:46 PM 2975061 32985818 GUMAN PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:25:48 PM 2975062 32985817 JHANKI PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:25:50 PM 2975063 32985816 LAGNI PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:25:53 PM 2975064 32985815 KASHU PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:25:56 PM 2975065 32985554 NIRUPAMA PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:25:58 PM 2975066 32985553 NITANSH PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:26:01 PM 2975067 32985552 SWATI PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:26:03 PM 2975068 32985776 ABHILAS H PANDY 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:26:06 PM 2975069 32985771 BALWIR PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:26:08 PM 2975070 32985770 DEVASPA PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:26:11 PM 2975071 32985769 GUNISH PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:26:14 PM 2975072 32985768 JIGAR PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:26:17 PM 2975073 33016532 LAHAR PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:26:19 PM 2975074 32985766 YATNA PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:26:22 PM 2975075 32985765 NIRVI PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:26:25 PM 2975076 32985764 NITIN PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:26:28 PM 2975077 32985763 TRUSHIT PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:26:31 PM 2975078 32985813 ABHISHEK PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:26:34 PM 2975079 32985812 BANJUL PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:26:36 PM 2975080 32985811 DEVENDRA PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:26:39 PM 2975081 32985810 GUNJAK PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:26:43 PM 2975082 32985809 JIGISH PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:26:45 PM 2975083 32985808 LAJJA PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:26:48 PM 2975084 32985789 YATRI PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:26:50 PM 2975085 32985788 NISAR PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:26:53 PM 2975086 32985787 DEPARV PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:26:55 PM 2975087 32985807 TUKHAR PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:26:57 PM 2975088 32985805 ADIP PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:27:00 PM 2975089 32985804 BANKIM PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:27:03 PM 2975090 32985803 DEVI PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:27:05 PM 2975091 32985802 JIMISH PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:27:10 PM 2975092 32985801 LAKENDRA PANDYA AHMEDABAD 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:27:13 PM 2975093 32985800 YAVAN PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:27:17 PM 2975094 32985799 MIYA PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:27:21 PM 2975095 32985798 ROHINI PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:27:23 PM 2975096 32985797 TURANG PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:27:25 PM 2975097 32985796 ADITI PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:27:29 PM 2975098 32985795 BANSI PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:27:34 PM 2975099 32985794 DHAIVAT PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:27:37 PM 2975100 32985793 GUNJAL PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 9.134. From the above table, it may be seen that the bids were entered by one Shri Shrishailam L, an employee of KSBL. The above 100 applications have been entered in a time span of 1 minute and 16 seconds ranging from 3:23:07 pm to 3:27:37 pm. It is seen that the bids have been entered within a time difference of 2-3 seconds. The address of all the applicants is the same. In many of the instances, the application numbers are continuous e.g. 32068477, 32068478, 32068479, 32068480, 32068481, 32068482, 32068483, 32068484, 32068485, 32068486, 32068487, 32068488, 32068489, 32068490, 32068491, 32068492, 32068493, 32068494, 32068495, 32068496, 32068497, 32068498, 32068499 and 32068500.

9.135. Further, the examination of the bid data revealed that KSBL had similarly bid the application forms in respect of thousands of applicants belonging to various Key Opertor Groups. The details are given below:

Name of Key Operator No.

of Application forms Application Amount (Rs.) Allotment Amount (Rs.) Refund Amount (Rs.) Refund Order Number Biren Kantilal Shah 1210 57596000 10943240 46652760 690001, 690003, 690005, 690008 and 770001 Purushottam Budhwani 2000 95200000 18088000 77112000 183144 to 184143 (1000 numbers) D.B.

Mehta 498 23704800 4503912 19200888 690001 Roopalben Panchal 5200 247520000 47028800 200491200 173217 to 174033 (817 numbers), 173193 to 173197 (5 numbers) and 690001 Dhaval Katakia 519 24704400 4693836 20010564 690001 Parag Jhaveri/SEIPL 2125 101150000 19218500 81931500 690009 Manoj Dev Seksaria 1998 95104800 18069912 770034888 181146 to 182145 (1000 numbers) 9.136. It may be noted that in respect of the above applicants, Karvy provided consolidated refund order and also requested BhOB to adjust the refund against the loan provided by them.

9.137. Bidding in Suzlon IPO Further, it is noted that in Suzlon IPO, KSBL had bid the applications of the afferent entities pertaining to the key operators at Hyderabad. Since KCL had provided finance to the applicants and since the application was provided by KCL through direct RTGS transfer to the escrow account of Suzlon IPO, it follows that at the time of bidding these applications no payment instrument i.e. cheque / DD was available with the applications. Therefore, it follows that KSBL, acting as a broker and sub-syndicate member had bid the applications without receiving the 100% margin.

9.138. Issuance of Consolidated Refund:

It is seen that Karvy-RTI has issued consolidated refund orders in the IDFC IPO favouring banks / financial institutions in respect of the applications that were financed by the banks / financial institutions. Based on data furnished by Karvy, the details of consolidated refunds given by Karvy-RTI in respect of large number of applicants is given below:

Consolidated Refunds issued by KCPL in IDFC IPO Refund Order No. No.

of applicants Amount of Refund (Rs.) 690001 6488 25,01,51,328 690003 19 7,32,564 690005 93 35,85,708 690008 989 3,81,31,884 690009 2125 8,19,31,500 770001 364 1,42,27,334 9.139. The details of the consolidated refund orders issued by KCPL in the IPOs of ILFS and Sasken Communication are given below. It may be seen that the consolidated refunds were given in respect of the key operators Roopalben Panchal, Parag Jhaveri and Dharmesh Mehta. In these instances where consolidated refunds were issued by KCPL it is observed that the IPO applications were financed by KCL or BHOB and KCPL was also the RTI in these IPOs.

Name of the IPO Name of Key Operators Consolidated Refund Order no No of applicants Amount Financed by ILFS Roopal Panchal 600002 10,497 43,13,75,000 BHOB Sasken Communication Roopal Panchal 500002 9,041 40,37,34,500 BHOB   Dharmesh B Mehta 500002 1,079 5,40,73,500 BHOB   Dharmesh B Mehta 534002 1,447 1,99,94,000 KCL   Parag Jhaveri 534005 999 4,46,03,000 KCL   Parag Jhaveri 500002 8,067 13,95,68,000 BHOB 9.140. The details of the Refund Orders pertaining to the IPO applications wherein KCL had made direct RTGS transfer of Rs.2089 crores to the Suzlon Energy escrow account are not available and hence no comments can be made on the Refund Orders in the IPO of Suzlon Energy. It is also seen that in respect of the applicants, IPO applications have been bidded by Karvy Stock Broking in its terminal.

9.141. It is understood that issue of a consolidated refund cheque in respect of numerous IPO applicants is not a market practice, as claimed by Karvy. It is understood that RTIs have a practice of issuing consolidated refund cheques only for applications made through internet i.e. web trades. In case of physical applications, the RTIs do not give a consolidated refund for multiple applicants. Thus, the issue of consolidated refund cheque was a practice peculiar to Karvy, which facilitated quick and easy encashment of refund money by the key operators. The refund money was used immediately thereafter by the key operators for making applications in the subsequent IPOs.

Name of the KO IPOs financed Date of Closure of IPO Date of disbursement Amount disbursed Date of RO Date of repayment Repayment amount Roopal Panchal IDFC 22-07-05 30-07-05 (RTGS) 24,75,20,000 (5,200 appl) 05-08-05 (consol RO) 08-08-05 18,56,40,000   SASKEN 17-08-05 17-08-05 26,00,00,000 (no margin received) 31-08-05 31-08-05 17,09,00,000   AMAR REMED 31-08-05 05-09-05 (RTGS) 29,89,00,000 NA.

NA.

29,89,00,000 Parag Jhaveri IDFC 22-07-05 30-07-05 (RTGS 10,11,50,000 (appl money for 2,125 appl) 05-08-05 (consol RO) 10-08-05 7,58,62,500   SASKEN 17-08-05 17-08-05 4,55,00,000 (1000 appl) 31-08-05 02-09-05 3,90,00,000 Bhudwani IDFC 22-07-05 28-07-05 9,52,00,000 (2000 appl) 05-08-05 11-08-05 8,09,20,000   SASKEN 17-08-05 22-08-05 18,20,00,000 (4000 appl) 31-08-05 02-09-05 17,29,00,000   Suzlon 29-09-05 03-10-05 4,99,39,200 (1020 appl) 14-10-05 17-10-05 4,49,39,200 Manoj Sekseria IDFC 22-07-05 28-07-05 9,52,00,000 (2000 appl) 05-08-05 11-08-05 8,09,20,000   SASKEN 17-08-05 22-08-05 18,20,00,000 (4000 appl) 31-08-05 02-09-05 17,29,00,000   Suzlon 29-09-05 03-10-05 4,99,39,200 (1020 appl) 14-10-05 17-10-05 4,49,39,200   ILFS 08-07-05 NA 2,16,12,500 (494 appl) 21-07-05 30-07-05 1,94,51.250 OTHER ILFS 08-07-05 NA 1,77,00,000 NA NA NA   IDFC 22-07-05 NA 17,58,00,000 NA NA NA   SASKEN 17-08-05 NA 14.85,00,000 na NA NA   Suzlon 29-09-05 NA 31,35,00,000 NA NA NA 9.142. From the above table, it may be seen that in the IDFC IPO, KCL had made direct RTGS transfer to the escrow account on July 30, 2005 whereas the IPO had closed on July 22, 2005. The RTGS transfer of Rs. 51.91 crores was made by KCL in respect of the 10,900 applicants financed by it. Further, KCPL, the RTI, had issued consolidated refund orders in respect of these applications vide refund order dated August 5, 2005, which is a Friday. It is seen that the refund orders pertaining to the key operators were dispatched in the first lot of refund orders issued by the RTI In this context it may be recalled that KCL vide letter dated August 8, 2005 had requested BHOB to adjust the IPO finance provided by it against the refund amount. Thus, it may be seen that KCL had provided IPO finance to the key operators for a period of 15 days and had charged interest at 19% p.a. reckoning the 15 day finance period. However, by adopting the above modus operandi which was facilitated by the presence of the Karvy group entities at various stages of the IPO process, Karvy ensured that its money was actually used only for a period of 8-10 days thereby improving the returns on the money loaned by it.

9.143. Issuance of Refund in cases where no bank accounts were mentioned in demat records In terms of SEBI guidelines, in public issues, at the time of making allotment and issuing refunds the RTIs should use the demographic and bank details of the IPO applicants as contained in the depository system. It was found that in respect of 4000 dematerialized accounts held with Karvy DP pertaining to the key operators Purshottam Budhwani and Manojdev Seksaria, the data in the depository system did not indicate the bank account details of the dematerialized account-holders. Therefore, in the case of IDFC IPO, Karvy RTI could not have issued refund orders in respect of these 4000 dematerialized accounts pertaining to the key operators. However, it was found that Karvy RTI had indeed issued refund orders in respect of these 4000 dematerialized account-holders. When queried by the Enquiry Officer in this regard, KSBL in its reply dated January 19, 2007 stated that the bank details of the demat account holders was mentioned in the respective application forms and the same had been captured in the back office of the DP and upload to the DPM (Depository Participant Module of the CDSL depository system). KSBL further stated that b. ...On verification of the back office records, we find that the bank account details are available....

c. The absence of these details with CDSL may be due to system related issues in the software of CDSL, at the time of bulk upload.

9.144. Thus, it is clear that the depository system did not contain the bank account details of the 4000 afferent dematerialized account holders pertaining to the key operators Purshottam Budhwani and Manojdev Seksaria.

9.145. It follows that the refund was issued by Karvy RTI in respect of these 4000 applicants by accessing the back office records of Karvy DP, which shows that various entities belonging to the Karvy group were acting in a collusive manner with the key operators.

9.146. Directions of Karvy regarding Appropriation of Refunds BhoB Ahmedabad branch confirmed that they had not funded the IDFC IPO. However, it was seen that Roopal Panchal (through her bank account no. 15.100.9000 maintained with the branch) transferred an amount of around Rs. 14.28 crores on July 26, 2005 for the said issue. The refund for the same was received from Karvy Consultants Ltd.(KCL) through BhoB, Hyderabad branch. KCL., vide letter dated August 8, 2005 addressed to the Bhob, Hyderabad branch, enclosed a Bankers Cheque no 103594 dated 5/8/2005 drawn on ICICI Bank Ltd. for Rs.28.17 crores towards the refund of excess application money of IDFC issue and provided the list of account holders to whom credit of this amount was to be done. As per the said letter, KCL had funded these applications and had received a mandate letter from the customers for collecting the refunds as well as adjusting the same against the loan. KCL requested BhOB, Hyderabad Branch to debit Rs.26.08 crores to the customers' account and pay the same in favor of Karvy Consultants Ltd. As per the list attached by KCL, refund amount for account no. 9550 in the name of Devangi Panchal was Rs.20.04 crores out of which Rs.18.56 crores was to be paid to KCL.

9.147. Upon perusal of a letter bearing the subject "IPO of IDFCL issue" dated August 8. 2005 from BhOB Hyderabad branch addressed to BhOB Ahmedabad it is observed that it is mentioned in the letter that "We have been advised by M/s Karvy Consultants Ltd. that they have funded the IPO application of the enclosed list of parties who are your branch customers.

9.148. A consolidated refund order has been received at our end for the crediting the refund amount to the parties account. We understand (that) the customers have given an authority to debit their account with your branch and credit KCL for the loan granted for the purpose of the subject IPO funding. To avoid delay we have refunded the amount payable to KCL from our end out of the consolidated refund received.

 

Refund money Payment to KCL Payment to investor No of applications Panchal 200491200 185640000 14851200 5200 D B Mehta 19200888 17778600 1422288 498 Dhaval Katakia 10024560 9282000 742560 260 Dharmesh Katakia 9986004 8925000 714000 259 Alpesh Lakhani 9639000 8925000 714000 250 Mukesh G Popat 9639000 8925000 714000 250 Hemal Lakhani 9639000 8925000 714000 250 Hemal Lakhani 9639000 8925000 714000 250 Purshottam Bhudwani       2000 manoj Sekseria       2000 Parag Jhaveri       2125 Biren Kantilal Shah       1210 others       348 Total KO applications financed by KCL 14900 9.149. The above goes to show that Karvy was controlling the banking leg of the IPO activities through BhOB. While the securities market related transactions in the IPOs were handled by Karvy group entities, the funds part was managed by Karvy group through BhOB. This gave complete control to Karvy group over the entire process of IPO while using fictitious / benami names to corner IPO shares through the key operators.

9.150. Execution of off-market transfers During the course of enquiry proceedings, Karvy had submitted the process of DIS execution adopted by it. The same is reproduced below:

9.151. It was found during the SEBI inspection of Karvy DP that the issuance of welcome Kit which contains the DIS was decentralized and the Regional Managers were the authorized signatories for issuing the Welcome Kit to the investors. It was noticed that the welcome kit for IPO clients who were referred through the IPO sub- brokers of Karvy contained only single leaf DIS booklets along with the DIS booklet requisition slip. The correspondence addresses in respect of the accounts referred through IPO sub-brokers were those of the IPO sub-brokers. The Welcome Kit was sent to the correspondence address of demat clients and hence went to the IPO sub-brokers.

9.152. It was found during the course of inspection that the DIS issued to various BOs, who had opened the accounts introduced by the sub-brokers under the IPO scheme, were in continuous serial numbers.

9.153. It was seen that these DIS were pre-printed and contained all the material details such as ISIN number, company name, name of the BO, quantity, execution date etc. The verification of DIS revealed that the one person had signed on behalf of the BOs.

9.154. Based on a sample of physical DIS, prima-facie, it is observed that these DIS are computer generated with columns like Bo account number, First holder, ISIN, security name, Qty, Target client number being pre-printed. The details are as below:

Sr.

No.

DIS Sr. No. Instruction No.

Source Client ID Source Client name Source DP Target Client ID Target DP Name of Security Quantity Date of Execution

1. 200190918 1956033 14544833 Gandhi Roshan M KCL 14405199 KCL IDFC 266 08.08.05

2. 200190917 1956032 14544825 Gandhi Trishul M KCL 14405199 KCL IDFC 266 08.08.05

3. 200190916 1956031 14544817 Gandhi Payal M KCL 14405199 KCL IDFC 266 08.08.05

4. 200190915 1956030 14544809 Sheth Hitendra H KCL 14405199 KCL IDFC 266 08.08.05

5. 200190914 1956029 14544794 Sheth Mauli H KCL 14405199 KCL IDFC 266 08.08.05

6. 200190913 1956028 14544786 Sheth Vasu H KCL 14405199 KCL IDFC 266 08.08.05

7. 200190912 1956027 14544778 Sheth Vasu H KCL 14405199 KCL IDFC 266 08.08.05

8. 200190911 1956026 14544769 Doshi Vatsal G KCL 14405199 KCL IDFC 266 08.08.05

9. 200190910 1956025 14544750 Doshi Kajri G KCL 14405199 KCL IDFC 266 08.08.05

10. 200190909 1956024 14544743 Mistry Bokshi P KCL 14405199 KCL IDFC 266 08.08.05

11. 200190908 1956023 14544735 Mistry Kalpen P KCL 14405199 KCL IDFC 266 08.08.05

12. 200190907 1956022 14544727 Mistry Vibhut P KCL 14405199 KCL IDFC 266 08.08.05

13. 200190919 1956034 14544840 Mistry Mohan R KCL 14405199 KCL IDFC 266 08.08.05

14. 200190901 1956016 14544663 Sheth Chirag S KCL 14405199 KCL IDFC 266 08.08.05

15. 200190902 1956017 14544670 Sheth Samrat S KCL 14405199 KCL IDFC 266 08.08.05

16. 200190903 1956018 14544689 Sheth Kanjari S KCL 14405199 KCL IDFC 266 08.08.05

17. 200190904 1956019 14544698 Gandhi Chetak R KCL 14405199 KCL IDFC 266 08.08.05

18. 200190905 1956020 14544702 Gandhi Akshar R KCL 14405199 KCL IDFC 266 08.08.05

19. 200190906 1956021 14544719 Gandhi Anali R KCL 14405199 KCL IDFC 266 08.08.05 Note: The target BO ID of 14405199 belongs to SEIPL.

9.155. The above table shows that details contained in the DIS used for making off- market transfers from the afferent dematerialized accounts to the dematerialized account of key operator viz. SEIPL. It may be noted that the DIS are in continuous serial number.

9.156. Further, in the above DIS all the material particulars including Bo account number, First holder, ISIN, security name, Qty, Target client number and Transaction Number being printed. It may be mentioned that the transaction number is generated after execution of DIS and the number is hand written by the DP staff after execution. In the normal course, the DP executes the transaction by punching in the depository system the details contained in the DIS. Upon execution, the depository system generates a transaction number which is hand written by the DP for the purpose of reference and the DIS is kept in the records of the DP. The printing of Transction number in the DIS as detailed in the table above, is possible only when the DIS has been printed after the execution of the transction i.e. no DIS existed at the time of execution of off-market transactions and the DIS was printed after execution. In terms of Regulation 42(2) and 42(3) of SEBI DP Regulations 1996 (2) A participant shall register the transfer of securities to or from a beneficial owner's account only on receipt of instructions from the beneficial owner and thereafter confirm the same to the beneficial owner in a manner as specified by the depository in its bye-laws.

(3) Every entry in the beneficial owner's account shall be supported by electronic instructions or any other mode of instruction received from the beneficial owner in accordance with the agreement with the beneficial owner.

9.157. It may be seen from the above that the DIS serial numbers issued to clients of various groups are in continuous serial numbers. This is possible only if loose DIS of one booklet is issued to various clients. Even in such a scenario it is highly unlikely that the DIS executed by various persons making off-market transfers to one entity will have continuous serial number. This is possible only if DIS slips had been issued by the DP to one or few persons controlling the alleged group.

9.158. The details contained in the sample CDSL DIS executed by Karvy DP is summarized below:

Sr.

No.

DIS Sr. No. Instruction No.

Source Client Id Source Client name Source DP Target Client ID Target DP Name of Security Quantity Date of Execution

1. 78965 18420 130144000 0147251 Aditi Gandhi KCL 130144000 0307503 KCL IDFC 266 11.08.05

2. 78964 18419 130144000 0147245 Turang Gandhi KCL 130144000 0307503 KCL IDFC 266 11.08.05

3. 78963 18418 130144000 0147230 Rohini Gandhi KCL 130144000 0307503 KCL IDFC 266 11.08.05

4. 78962 18417 130144000 0147226 Miya Gandhi KCL 130144000 0307503 KCL IDFC 266 11.08.05

5. 78961 18416 130144000 0147211 Yavan Gandhi KCL 130144000 0307503 KCL IDFC 266 11.08.05

6. 78960 18415 130144000 0147207 Lakendra Gandhi KCL 130144000 0307503 KCL IDFC 266 11.08.05

7. 78959 18414 130144000 0147190 Jimish Gandhi KCL 130144000 0307503 KCL IDFC 266 11.08.05

8. 78958 18413 130144000 0147186 Devi Gandhi KCL 130144000 0307503 KCL IDFC 266 11.08.05

9. 78957 18412 130144000 0147171 Bankim Gandhi KCL 130144000 0307503 KCL IDFC 266 11.08.05

10. 78956 18411 130144000 0147167 Adip Gandhi KCL 130144000 0307503 KCL IDFC 266 11.08.05

11. 78955 18410 130144000 0147152 Tukhar Gandhi KCL 130144000 0307503 KCL IDFC 266 11.08.05

12. 78954 18409 130144000 0147148 Deparv Gandhi KCL 130144000 0307503 KCL IDFC 266 11.08.05

13. 78953 18408 130144000 0147133 Nisar Gandhi KCL 130144000 0307503 KCL IDFC 266 11.08.05

14. 78952 18407 130144000 0147129 Yatri Gandhi KCL 130144000 0307503 KCL IDFC 266 11.08.05

15. 78951 18406 130144000 0147114 Lajja Gandhi KCL 130144000 0307503 KCL IDFC 266 11.08.05

16. 78990 18405 130144000 0147509 Lakshana Gandhi KCL 130144000 0307503 KCL IDFC 266 11.08.05

17. 78989 18404 130144000 0147492 Jinal Gandhi KCL 130144000 0307503 KCL IDFC 266 11.08.05

18. 78988 18403 130144000 0147488 Hanil Gandhi KCL 130144000 0307503 KCL IDFC 266 11.08.05

19. 78987 18402 130144000 0147473 Dhara Gandhi KCL 130144000 0307503 KCL IDFC 266 11.08.05

20. 78986 18401 130144000 0147469 Barun Gandhi KCL 130144000 0307503 KCL IDFC 266 11.08.05 Note: The target BO ID of 1301440000307503 belongs to Roopalben Panchal 9.159. In respect of the above CDSL DIS, it was observed that all the relevant columns including the target DP and target BO ID were pre-printed. The transaction number was not mentioned in the DIS as is the normal practice. The pre-printing of all the relevant columns including target DP and target BO ID shows that the DP was assisting the key operators in executing their game plan. 9.160. Based on information obtained from CDSL, it is seen that hundreds of the DIS submitted by each of the following groups are in continuous serial numbers thereby showing that Karvy DP had issued the DIS slips pertaining to hundreds of benami / fictitious dematerialized account-holders to a few purporting to represent the group and the details are as below:

9.161. CDSL DIS bearing continuous serial numbers used by various key operators in IDFC IPO Sr.

No Name of the Group DIS Serial no. From and To.

No of DIS.

1

Manoj Sakseria 40,001-42,000 1,999 2 Pushottam Bhudwani 32,001-32,130 32,141-32,300 32,311-32,845 61,001-61,100 61,201-62,600 65,401-66,200 129 159 534 100 1,399 799 3 Roopal Panchal 70,001-84,807 14,806 4 Dhaval A Mehta 19,679-20,018 339 5 Dharmesh B Mehta 20,405-21,106 701 6 Dhaval A Katakia 21,107-21,027 21,172-22,283 80 1,111 7 Dharmesh K Katakia 21,586-21,711 125 8 Dhaval A Mehta 19679-20,018 22541-22,612 339 71     Total 22,691 9.162. CDSL DIS bearing continuous serial numbers in respect of various IPOs Based on the information submitted by KSBL vide letter dated June 18, 2007, it is observed that the DP had issued loose DIS slips bearing continuous serial numbers to key operators in respect of various afferent accounts pertaining to these key operators. The details of DIS used by the key operators for making off- market transfers of IPO shares in respect of ILFS, Sasken and Suzlon IPOs are given below:

9.163. Issue of loose slips to Key Operators in the IPO of ILFS as submitted by Karvy Name of the Key operators DIS Serial No from DIS serial No To No of DIS Manoj Sekseria 42853 43064 211 Roopal Panchal 200142961 200148122 5161     Total 5372 9.164. In the IPO of Sasken Communications.

Name of the Key operators DIS Serial No from DIS serial No To No of DIS Jhaveri group 200211506 200212027 521 Roopal Panchal 84146 200209281 86237 200210877 2091 1596 Dharmesh B Mehta 69652 69993 341     Total 4549 9.165. IPO OF SUZLON ENERGY Name of the Key operators.

Name of the Key operators DIS Serial No from DIS serial No To No of DIS Manoj Sekseria 214330 215347 1017 Bhudwani 213312 214329 1017     Total 2034 9.166. KSBL has contended that requests for issuance of DIS slips were received from sub-brokers and hence their numbers are continuous. They further contended that signature on DIS tallied with specimen signature available with them and there was no irregularity. In view of the numerous facts which corroborate one another and the fact that issuance of loose DIS slips is a violation of SEBI Circulars, I find this explanation to be prima facie unacceptable.

9.167. In respect of the off-market transfers from the afferent accounts to the demat accounts of the key operators, it was observed that the delivery instructions slips (DIS), which were necessary to be filled in and signed by the beneficial owner to transfer the shares in his demat account, were pre-printed by KSBL including the details of the scrip name, ISIN, quantity of shares and the target ID. This was done to facilitate the transfer of shares from thousands of afferent accounts to the demat accounts of the key operators, as otherwise, it would have been impossible to manually fill in the particulars in thousands of DIS slips in respect of each of those accounts.

9.168. KSBL submitted that they had pre-printed only the serial number, name of the client and client ID and that the other pre-printed details in DIS like the ISIN, number of shares, target DP ID etc. were filled in probably by sub-broker. In my view, this contention too is prima facie unacceptable as pre-printing of all details including serial numbers and the above details appears to have been done at one go, as seen from the copies of relevant DIS.

9.169. It is seen that transaction number mentioned on the DIS is the credit transaction number and is not the debit transaction number, as is the normal case. It is significant to note that credit transaction number is not available with the DP at the time of entering the DIS in the system as the details are only available in the target client account. Incidentally in this case target client account was also with the same DP ie. KSBL and therefore it was possible for the DP to have the details of the credit transaction number.

9.170. It was further noted that in respect of the subject off-market transactions many demat accounts were debited and a single demat account was credited. Since it is easier to obtain credit transaction number from the demat account statement of Roopalben Panchal, it appears that the DP has conveniently used the credit transaction number on the DIS used for debiting various demat accounts and this indicates that the DP had no debit instruction from the afferent account holders and DIS had been generated post-facto to make up the records by conveniently using the CIN available from one account thereby dispensing with the rigmarole of wading through thousands of afferent account statements which is cumbersome and laborious.

9.171. With respect to the credit instruction number (CIN) mentioned in the DIS instead of debit transaction number, Karvy DP has claimed that the CINs were filled in at the instance of CDSL during the inspection of the DP by the depository. In this regard, I note that in an earlier proceeding before me i.e. the post-decisional hearing granted to the DP pursuant to the interim order dated April 27, 2006, KSBL contended that the mentioning of CIN in the DIS was a clerical error. The excuse of clerical error then proferred by Karvy DP did not pass muster in the earlier proceeding and therefore, it appears that Karvy DP has thought up a new excuse stating that the CIN was entered at the instance of the depository. Therefore, I find this explanation to be prima facie untenable.

9.172. Observations on Fabrication of records The account opening forms of many of the afferent dematerialized accounts opened in bulk, as above, were found to contain letters from scheduled commercial banks certifying the identity and address of the account holders. Karvy DP accepted these bank letters towards POI and POA for opening demat accounts. On further verification, it was found that these bank letters relied upon by Karvy DP for opening dematerialized accounts were forged. An inference of fabrication of KYC documents (bank introduction letters) by KSBL for showing compliance with KYC norms was drawn. The reasons broadly for such inference were the following:

(a) The respective banks had denied issuing the same and stated that the stationery was materially different from their bank stationery (in case of BHOB), that there was no official by name of purported signatory (in case of two branches of BHOB). Further, the photographs appearing in the introduction letter and in the corresponding bank records did not match.

(b) The clients representing various groups have denied having submitted such bank introduction letters with their demat account opening forms.

(c) The client details in the relevant bank introduction letters have exact correspondence with that in the depository system including minutiae like capital letter, space, comma, full stop etc. The inference was that the client details were downloaded from the depository system, after the demat account was opened.

(d) There was perfect matching of bank details, including minutiae between that in the depository system (which are associated with a bank branch's MICR number) and that contained in the forged bank letter. In this context, it was observed that practically the MICR details such as bank name, branch name, address and PIN code were already available in the depository system and could not have been uploaded by anybody else. The inference therefore was that these details might have been downloaded from the depository system together with other details as in (c) above for use in forging bank introduction letters by someone who had access to the depository system, i.e. most likely the DP, KSBL.

9.173. Karvy DP contended that the fabrication might have been done by other parties involved i.e. key operators and banks. The perfect matching of the details contained in the fabricated bank letters including minutiae with the data available in the depository system shows that the fabrication could have been done by an entity having access to the depository system. In this regard, I note that the key operators were not DPs and do not have access to the depository software. As for banks, I find no reason for them fabricate their own letterheads when they might as well have used the original letterheads available with them.

9.174. As regards the finding that the bank introduction letters contained the client details corresponding exactly even to the last spelling and punctuation mark to that in the depository system, KSBL contended that such data in soft form was taken from sub-brokers and used for upload in the system and therefore was also available with the sub-brokers. While it is possible that such data was also available with sub- brokers, the further matching of the details in the bank introduction letters also with the MICR details like bank address, city and PIN code as decoded in the depository system could reasonably lead to the inference that KSBL might have used the data in fabricating the letters.

9.175. The uploading of data in soft copy cannot explain the perfect matching of the bank details in the fabricated bank letter with the MICR details contained in the depository system. The perfect matching of the bank details in the fabricated bank letters accepted by Karvy DP towards KYC verification for opening demat accounts with the MICR details in the depository system can only lead to the inference that the MICR data in the depository system has been downloaded to fabricate the bank letters. Since only the DP has the facility to download the data from the depository system, the attempt of Karvy DP to deflect the needle of suspicion does not pass muster.

9.176. Karvy DP claimed that taking information from agents is a market practice adopted by DPs. In this regard, I understand that DPs do not accept information in soft copy from agents. In cases where large number of DP application details need to be entered into the depository system, the DPs engage data entry operators who come to the premise of the DP and make the entries in the depository software available at the DP's premise. An independent verification of the data is done by a staff of DP before uploading the same in the depository system. Thus, Karvy's claim of having accepted the details of demat clients in soft copies from the sub- brokers is at variance to the market practice and the claim is an after-thought to shift the blame to the key operators for the acts of commissions and omissions of Karvy DP.

9.177. Further, in order to accept the soft copy in the format that can be directly uploaded in the depository system, the DP would have to provide its agent the software relating to the depository system. If Karvy DP had indeed adopted such practice, the same is at variance to the market practice, as DPs do not provide access to the depository software to third parties outside the premise of the DP. 9.178. As noted earlier, it is not a practice of the DPs to provide the depository software outside their premise. If Karvy DP had provided the depository software to its sub- brokers for use outside the premises the same is at variance to the market practice. Alternatively, if it did not provide the depository software outside its premises, then the fabrication of the bank letters could have happened only in the premises of Karvy DP. Either way Karvy DP is guilty of allowing the depository software that is available to it as a registered DP, for being used to fabricate bank letters which in turn were used for opening dematerialized accounts in fictitious / benami names with the DP. That apart, the very creation of about 50,000 fictitious afferent accounts is nothing but fabrication.

10. CONSIDERATION OF KCPL RTI MATTER I have considered the Enquiry Report, the Show Cause Notice, the Reply submitted by KCPL and the oral submissions made on behalf of KCPL. Admittedly, KCPL, KCL, KSBL etc. are the group companies of Karvy and the connection between the various Karvy Group entities including that of KCPL is established in the discussion mentioned earlier in this order. The contention of KCPL that there was a clear division of operations between it and other Karvy entities is not acceptable in the facts and circumstances of the case which amply demonstrate how such a division gave way to a common cause by abusing their respective positions in the business chain which was evident in some of the IPO's.

10.1. I note that KCPL in its reply dated January 8, 2007 stated that it is a joint venture with equal shareholding between KCL (admittedly a Karvy group entity) and Computershare Ltd., Australia. In the reply of KSBL (in its capacity as a DP and a stock broker) it has been specifically mentioned that the Karvy group companies inter alia comprised of KCPL. Further, the communication of Shri Vincent Paul (an employee of KSBL) on behalf of KCPL would establish that there were certain managerial links between KCPL and KSBL and which also indicate that KCPL failed to maintain arms length distance with its associates as mentioned above. Further, Shri V. Mahesh (employee of KSBL was also the signatory of KCPL in the inspection conducted by SEBI.

10.2. As discussed earlier in this order the key operators opened multiple and fictitious applications in various IPOs and the act on the part of KCPL sending common refund order in respect of the applications made by the key operators would establish that the KCPL was supplementing the activities of its associates in various irregularities in the process of IPOs.

10.3. In the facts and circumstances, in view of the established direct connection between KCPL and other Karvy group entities the role of KCPL cannot be viewed in isolation but has to be seen in the overall context of the activities of other Karvy group intermediaries as discussed earlier.

10.4. I also note that KCPL had issued single consolidated refund orders in respect of the benami/ fictitious applications of Key Operators like Roopalben Panchal, Purushottam Budhwani, Manoj Seksaria and Sugandh Estates. In the Yes Bank IPO, KCPL issued a single refund order no: 400002 favouring Bharat Overseas Bank( BhOB) for 53.89 crores in respect of 12676 applicants. In the IPO of IDFC, single refund order no:610003 for Rs.27.35 crores was issued favouring BhOB in respect of 6878 IPO applicants.

10.5. It is pertinent to note that issuing of single consolidated cheque/refund orders have not been disputed by KCPL and it is evident that the consolidated cheques were forwarded to the financier. The fact that there were common directors at the helm of KCL and KCPL necessarily indicates that the said entities were aware of each others actions more so when one entity (KCL) was financing the IPO applicants and the other (KCPL) was issuing common refund orders in such cases. In this context, I note that KCL who acted as a financier in many such issues, obtained its dues in respect of repayments from IPO applicants whom it financed, directly from the bank out of the consolidated refunds credited to the bank by KCPL. Hence the act of issuing singe refund orders facilitated the entities who extended finance and the key operators who had applied in the IPO's to continue with the scheme/ arrangement till the same was detected by SEBI. Therefore, the action of KCPL cannot be viewed as facilitating the 'settlement process' and administrative in nature as contended by them. Though KCPL submitted that it had received requests from the financier institutions for issuing a consolidated refund order, the act of KCL adjusting the amount due to it as a financier out of the consolidated refund order issued by KCPL clearly indicates that KCPL was privy to the activities KCL.

10.6. Therefore, the alleged violations made by KCPL have to be viewed in the overall factual context. I note that KCL had arranged large amount of finance for many key operators mainly to Shri Purshottam Bhudiani, Shri Manoj Seskaria and Smt Roopalben Panchal. I also note that large number of afferent accounts were opened by the said key operators with the Karvy DP. Admittedly the issue of single consolidated cheques/ refund orders have not been disputed by KCPL and that the consolidated cheques were forwarded to the financier. The submission of KCPL was that if KCL was aware of the fictitious nature to the application the same could not be attributed to KCL. In the present case, I note that there were common directors in KCL and KCPL and that indicates that the entities were aware of the actions of each other, more so when one entity (KCL) was financing the IPO applicants and the other (KCPL) was issuing common refund orders in such cases. I also note that KCL who was the financier in many IPOs, obtained its dues in respect of repayments from IPO applicants whom it financed, directly from the bank out of the consolidated refunds credited to the bank by KCPL. Therefore, the action of KCPL could not be viewed as facilitating the settlement process and administrative in nature as contended by them. Further I also note that KCPL was aware of the actions of its related entities which was discussed in detail in the enquiry report.

10.7. Issuance of Refund in cases where no bank accounts were mentioned in demat records 10.8. In terms of SEBI guidelines, in public issues, at the time of making allotment and issuing refunds the RTIs should use the demographic and bank details of the IPO applicants as contained in the depository system. It was found that in respect of 4000 dematerialized accounts held with Karvy DP pertaining to the key operators Purshottam Budhwani and Manojdev Seksaria, the data in the depository system did not indicate the bank account details of the dematerialized account-holders. Therefore, in the case of IDFC IPO, Karvy RTI could not have issued refund orders in respect of these 4000 dematerialized accounts pertaining to the key operators. However, it was found that Karvy RTI had indeed issued refund orders in respect of these 4000 dematerialized account-holders. When queried by the Enquiry Officer in this regard, KSBL in its reply dated January 19, 2007 stated that the bank details of the demat account holders was mentioned in the respective application forms and the same had been captured in the back office of the DP and upload to the DPM (Depository Participant Module of the CDSL depository system). KSBL further stated that b. ...On verification of the back office records, we find that the bank account details are available....

c. The absence of these details with CDSL may be due to system related issues in the software of CDSL, at the time of bulk upload.

10.9. Thus, it is clear that the depository system did not contain the bank account details of the 4000 afferent dematerialized account holders pertaining to the key operators Purshottam Budhwani and Manojdev Seksaria.

10.10. It follows that the refund was issued by Karvy RTI in respect of these 4000 applicants by accessing the back office records of Karvy DP, which shows that various entities belonging to the Karvy group were acting in a collusive manner with the key operators.

10.11. All the activities of RTI need to be appraised in the context of the big picture. The same reveals that the afferent accounts were fictitious, crafted by playing on names in several permutations and combinations in a repetitive sequence. It was just a play on the names without the players. In effect the Karvy group was dealing only with key operators. In that view of the matter consolidated refund, albeit administratively convienent, assumes ominous significance. It turned out to be a collusive activity under the guise of administrative expediency. In appraising the role of Karvy Group, the basic feature of the case should not be lost sight of i.e one has to look beyond the elaborate edifice of make believe. Further, the closure of such afferent accounts by Karvy later in December 2005 confirms the nature of accounts the group was dealing, during their existence.

10.12. I note that the inspection conducted by SEBI found that KCPL had not exercised due diligence in weeding out multiple, invalid applications thereby allowing such applications to be allotted shares in the public issue of Yes Bank and IDFC Ltd. The details of such discrepancies as revealed during the said inspection were explained in detail in the enquiry report. Further, the discussion relating to DP contains copious references to interconnected activities among the group members besides highlighting their complementary role in abusing the IPO process. In view of the above, I do not find any reason to disagree with the findings of the Enquiry Officer.

11. CONSIDERATION OF KSBL BROKER MATTER I note that the Enquiry Officer in his report dated March 15, 2007 observed that the findings of the enquiry against KSBL as the depository participant might by considered as the same and was reflecting on the various activities of KSBL as the stock broker. He also observed that the various irregularities in the opening of accounts, irregularities in off market transactions by way of pre printed DIS etc. have to be taken into account as the same would also highlight the activities of KSBL as a stock broker in facilitating the key operators in furtherance of their objectives.

11.1. I note that KSBL had assisted and introduced the key operators in opening of bank accounts with BhOB, Worli, Goregaon and Ahmedabad branch. The said accounts have been introduced by the employees of KSBL. The submission of KSBL is that simply because its employees had introduced the accounts and put the address or stamp of the company on the forms, it could not be concluded that the Broker was aware of the activities of the employees. It further added that its employees introduced certain bank accounts after fulfilling the KYC requirements. In this context I note that in respect of the bank account number 12149 of Roopal maintained with BhOB 50 additional names were attached. As discussed above, KSBL in his appeal memo (SAT) admitted that it had given such certificate. Similarly 37 accounts were opened in the said branch with additional 50 names attached with the bank account opening forms certified by KSBL.

11.2. In view of the fact that the employees of KSBL were actively introducing the accounts to the bank indicate that it was facilitating opening of many bank accounts which in turn facilitated the opening of large number of demat accounts which were used for applying the IPO shares. In this context, I also note that the Karvy DP had opened as many as 37105 and 17795 demat accounts in CDSL and NSDL in a short time. The contention that the alleged afferent accounts have been opened by IPO sub brokers cannot be accepted in the facts and circumstances wherein the participation of the Karvy Group in its various roles as a broker and DP was manifest from their active involvement in the entire gamut of events. Further, I note that KCPL (another Karvy group entity) was the registrar to the issue in the public issue of Sasken Technologies and Suzlon Energy and the same facilitated the activities of the key operators and their subsequent sale of shares through KSBL. In the facts and circumstances, it is established that KSBL was involved in the entire manipulation by its active presence in various roles such as DP, broker, RTI (group company).

11.3. Based on the examination of the bid book data obtained from Karvy as well as the Stock Exchange, it is seen that the application was bid by the broker having the code "07701". Based on information obtained from NSE, it is seen that the broker code "07701" belongs to Karvy Stock Broking Ltd. Thus it is seen that KSBL in its capacity as a broker of NSE and also a sub-syndicate member has bid the application forms in respect of the applicants financed by KCL through IPO finance to the Key Operators. It is clear that the individual application forms of these applicants did not contain the payment for the IPO application. This is evidenced by the fact that if there had been a cheque/DD attached to the application form, the same would have been collected by the banker to the issue and there would have been no occasion for KCL to make RTGS transfer directly to the escrow account may days after the closure of the public issue.

11.4. It was seen that the 5200 IDFC IPO applicants financed by Karvy through Roopal Panchal had only eight surnames i.e. Pandya, Rathi, Desai, Verma, Gandhi, Trivedi, Vala and Pathak. The details are as below:

Last Name No.

of Applicants PANDYA 1000 RATHI 500 DESAI 680 VERMA 1000 GANDHI 1000 TRIVEDI 200 VALA 100 PATHAK 720 Total 5,200 11.5. An extract of the salient fields of the bid book is given below in respect of 100 bids made in the name of applicants having the last name as "Pandya":

BROKER LOCATION USER ID NAME OF USER DATE OF ENTRY IHNO APPL_NO NAME ADD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:23:07 PM 2975001 32990828 KUNAL PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:23:10 PM 2975002 32990829 BAKULA PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:23:13 PM 2975003 32990830 GRAMI PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:23:16 PM 2975004 32990831 JAKSHREE PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:23:18 PM 2975005 32068477 KUNJ PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:23:22 PM 2975006 32068478 VAGNA PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:23:25 PM 2975007 32068479 NIRAN PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:23:27 PM 2975008 32068480 NISHA PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:23:30 PM 2975009 32068481 RAMESH PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:23:33 PM 2975010 32068482 AAKASH PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:23:35 PM 2975011 32068483 BALA PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:23:39 PM 2975012 32068484 DEV PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:23:41 PM 2975013 32068485 GRASHIT PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:23:44 PM 2975014 32068486 JEET PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:23:46 PM 2975015 32068487 KUNALPANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:23:49 PM 2975016 32068488 PAJAN PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:23:52 PM 2975017 32068489 NIRBHAY PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:23:55 PM 2975018 32068490 NISHANT PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:23:58 PM 2975019 32068491 RANI PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:24:00 PM 2975020 32068492 AANSHI PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:24:02 PM 2975021 32068493 BALCHAND PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:24:05 PM 2975022 32068494 DEV AN PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:24:07 PM 2975023 32068495 GRISHA PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:24:10 PM 2975024 32068496 JEEVAN PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:24:13 PM 2975025 32068497 KUNIT PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:24:15 PM 2975026 32068498 VAMYA PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:24:18 PM 2975027 32068499 NIRDESH PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:24:21 PM 2975028 32068500 NISHIT PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:24:23 PM 2975029 32068501 RANJIT PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:24:26 PM 2975030 32068502 USHMA PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:24:28 PM 2975031 32068503 BALI PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:24:30 PM 2975032 32068504 DEVANG PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:24:32 PM 2975033 32068505 GUDDY PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:24:34 PM 2975034 32068506 JENITH PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:24:37 PM 2975035 32068507 KUSH PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:24:40 PM 2975036 32068508 YASH PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:24:43 PM 2975037 32985551 NIRJA PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:24:46 PM 2975038 32985550 NISHU PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:24:48 PM 2975039 32985549 SUNITA PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:24:51 PM 2975040 32985957 AARTI PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:24:53 PM 2975041 32985775 BALRAM PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:24:56 PM 2975042 32985774 DEVANSH PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:24:59 PM 2975043 32985836 GULAB PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:25:01 PM 2975044 32985835 TRIKAL PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:25:03 PM 2975045 32985834 KUSUM PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:25:06 PM 2975046 32985833 YASHANG PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:25:09 PM 2975047 32985832 NIRMAM PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:25:12 PM 2975048 32985831 SURESH PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:25:15 PM 2975049 32985830 ABHAY PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:25:18 PM 2975050 32985829 DEVANSH I PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:25:20 PM 2975051 32985828 GULJAR PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:25:23 PM 2975052 32985827 JENNY PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:25:26 PM 2975053 32985826 LAB OH A PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:25:28 PM 2975054 32985825 YASHI PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:25:31 PM 2975055 32985824 NIRU PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:25:33 PM 2975056 32985823 NITA PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:25:36 PM 2975057 32985822 UTAPLL PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:25:39 PM 2975058 32985821 ABHIGNA PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:25:41 PM 2975059 32985820 BALWANT PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:25:44 PM 2975060 32985819 DEVARSH I PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:25:46 PM 2975061 32985818 GUMAN PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:25:48 PM 2975062 32985817 JHANKI PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:25:50 PM 2975063 32985816 LAGNI PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:25:53 PM 2975064 32985815 KASHU PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:25:56 PM 2975065 32985554 NIRUPAMA PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:25:58 PM 2975066 32985553 NITANSH PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:26:01 PM 2975067 32985552 SWATI PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:26:03 PM 2975068 32985776 ABHILAS H PANDY 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:26:06 PM 2975069 32985771 BALWIR PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:26:08 PM 2975070 32985770 DEVASPA PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:26:11 PM 2975071 32985769 GUNISH PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:26:14 PM 2975072 32985768 JIGAR PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:26:17 PM 2975073 33016532 LAHAR PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:26:19 PM 2975074 32985766 YATNA PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:26:22 PM 2975075 32985765 NIRVI PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:26:25 PM 2975076 32985764 NITIN PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:26:28 PM 2975077 32985763 TRUSHIT PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:26:31 PM 2975078 32985813 ABHISHEK PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:26:34 PM 2975079 32985812 BANJUL PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:26:36 PM 2975080 32985811 DEVENDRA PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:26:39 PM 2975081 32985810 GUNJAK PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:26:43 PM 2975082 32985809 JIGISH PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:26:45 PM 2975083 32985808 LAJJA PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:26:48 PM 2975084 32985789 YATRI PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:26:50 PM 2975085 32985788 NISAR PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:26:53 PM 2975086 32985787 DEPARV PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:26:55 PM 2975087 32985807 TUKHAR PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:26:57 PM 2975088 32985805 ADIP PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:27:00 PM 2975089 32985804 BANKIM PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:27:03 PM 2975090 32985803 DEVI PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:27:05 PM 2975091 32985802 JIMISH PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:27:10 PM 2975092 32985801 LAKENDRA PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:27:13 PM 2975093 32985800 YAVAN PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:27:17 PM 2975094 32985799 MIYA PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:27:21 PM 2975095 32985798 ROHINI PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:27:23 PM 2975096 32985797 TURANG PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:27:25 PM 2975097 32985796 ADITI PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:27:29 PM 2975098 32985795 BANSI PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:27:34 PM 2975099 32985794 DHAIVAT PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 07701 HYDERABAD 10753 SHRISHAILAM L 7/22/2005 3:27:37 PM 2975100 32985793 GUNJAL PANDYA 406, SHASHWAT OPP. GUJARAT COLLEGE ELLISBRIDGE OPP. GUJARAT COLLEGE, ELLISBRIDGE, AHMEDABAD 11.6. From the above table, it may be seen that the bids were entered by one Shri Shrishailam L, an employee of KSBL. The above 100 applications have been entered in a time span of 1 minute and 16 seconds ranging from 3:23:07 pm to 3:27:37 pm. It is seen that the bids have been entered within a time difference of 2-3 seconds. The address of all the applicants is the same. In many of the instances, the application numbers are continuous e.g. 32068477, 32068478, 32068479, 32068480, 32068481, 32068482, 32068483, 32068484, 32068485, 32068486, 32068487, 32068488, 32068489, 32068490, 32068491, 32068492, 32068493, 32068494, 32068495, 32068496, 32068497, 32068498, 32068499 and 32068500.

11.7. Further, the examination of the bid data revealed that KSBL had similarly bid the application forms in respect of thousands of applicants belonging to various Key Opertor Groups. The details are given below:

Name of Key Operator No.

of Application forms Application Amount (Rs.) Allotment Amount (Rs.) Refund Amount (Rs.) Refund Order Number Biren Kantilal Shah 1210 57596000 10943240 46652760 690001, 690003, 690005, 690008 and 770001 Purushottam Budhwani 2000 95200000 18088000 77112000 183144 to 184143 (1000 numbers) D.B.

Mehta 498 23704800 4503912 19200888 690001 Roopalben Panchal 5200 247520000 47028800 200491200 173217 to 174033 (817 numbers), 173193 to 173197 (5 numbers) and 690001 Dhaval Katakia 519 24704400 4693836 20010564 690001 Parag Jhaveri/SEIPL 2125 101150000 19218500 81931500 690009 Manoj Dev Seksaria 1998 95104800 18069912 770034888 181146 to 182145 (1000 numbers) 11.8. It may be noted that in respect of the above applicants, Karvy provided consolidated refund order and also requested BhOB to adjust the refund against the loan provided by them.

11.9. Bidding in Suzlon IPO Further, it is noted that KSBL had bid the applications of the afferent entities pertaining to the key operators. Since KCL had provided finance to the applicants and since the application was provided by KCL through direct RTGS transfer to the escrow account of Suzlon IPO, it follows that at the time of bidding these applications no payment instrument i.e. cheque / DD was available with the applications. Therefore, it follows that KSBL, acting as a broker and sub-syndicate member had bid the applications without receiving the 100% margin.

11.10. In addition, it needs to be recognized that the fictitious nature of affrenet accounts is not disputed. In that view of the matter, the introduction of bank accounts relating to such afferent accounts by KSBL is a just a make -believe. Also the group was only dealing with the key operators. That being so, the entire exercise of introduction of accounts, the bidding process and the sale of shares peters out to be a screaming farce, which they now well. The bed-rock of material evidences as discussed in relation to DP while covering the IPO process bears eloquent testimony to the same.

11.11. The role of the DP and the Broker has been discussed in the preceeding paragraphs of this order. The said discussion is to be taken into account while deciding the role of the broker in the present proceedings. In view of the above, it is fairly established that the various irregularities in opening of accounts, assisting and facilitating the key operators in cornering of shares, irregularities in off market transaction by way of pre printed DIS etc. have to be taken into account as the same would also highlight the activities of KSBL as a stock broker in facilitating the key operators in their manipulative designs.

11.12. In the facts and circumstances it is fairly established that the Broker violated the provisions of Section 12 A (a), (b) and (c) of the SEBI Act and also regulation 3 & 4 (1) of the FUTP Regulations, 2003. Further by actively facilitating many key operators. It is established that the broker had failed to maintain high standards of integrity and further indulged in manipulation and malpractices and thereby violated the code of conduct specified in Clause A (1), A (3)and A (4) of Shedule II of the code of conduct specified in the Broker Regulations.

11.13. A mere denial on self serving assertion cannot displace the presumption of fact arising from inferences drawn from a mass of factual details which are incontrovertible. The circumstances are telltale and the presumption based upon them should prevail, more so where intentions are shrouded in secrecy or within the special or peculiar knowledge of persons concerned. Several circumstances of a determinative character coupled with the inference arising from the conduct of the parties in a major market manipulation could not simply be the handiwork of the key operators alone (as alleged by the DP) and could reasonably lead to a conclusion that the others were also responsible as brought out by wealth of material evidences. The cumulative evaluation of what has transpired at every stage of the transaction in a large number of IPOs clearly shows that the actions and inactions, and omissions and commissions on the part of the DP cannot be neglected as "at the highest a failure of KYC". On the other hand the activities of the Karvy group ex-facie exhibits a scheme to deny the genuine retail investors their quota of allotment.

11.14. Further the entire transactions starting from the introduction of bank accounts of key operators, opening of demat accounts of key operators, IPO funding to key operators and the sale of shares of key operators, through the Karvy group consisting KSBL (as a DP and a stock broker) and KCPL (RTI) would prove the active participation of the above intermediaries in the entire manipulation. The contention of the Karvy that it was not aware about the manipulation cannot be accepted. The contention of the Karvy that afferent accounts were opened by the key operators, some of them admittedly their IPO sub brokers, would show that Karvy had directly dealt with the said key operators and the entire transactions (from cornering the shares and subsequent sale of the said shares) were held between the karvy and the key operators under the guise of various demat accounts which were nothing but fictioius accounts created by the key operators with the assistance of Karvy. In this context, the observation of the SAT ".... It is an undisputed fact that thousands of fictitious/ benami demat accounts were opened with the appellant with common addresses and more than 10000 accounts were opened on one single day. The appellant was under a duty to check and comply with the various norms. The obvious appears to have been overlooked. Is the action of the appellant innocent is the question. The appellant is clearly under a cloud and the truth can be known only after a detailed inquiry. The findings of the inquiry will either remove the appellant or the cloud."

11.15. Admittedly, the fictitious demat accounts were opened by Karvy DP on the basis of bank accounts some of which were admittedly introduced by the employees of the Karvy Group and the same can be inferred from the reply of KSBL ( Broker) dated May 19, 2007 " simply because its employees had introduced the accounts and perhaps put the address or stamp of the company on the forms, it cannot be concluded that the company was aware of the activities of the employees." Coupled with the statement of Karvy in the appeal memo that the Respondent has not provided any proof for the introduction as stated in the impugned Order at para 6.35. The Appellant will be in a position to explain only on receipt of the documents relied upon by the Respondent to arrive at the said observation. It is stated tat the Appellant had not introduced the said 50 clients to IOB Thaltej. The Appellant had only certified, pursuant to the request of IPO sub broker, that the said 50 clients had demat account with the Appellant. It is submitted that all the said 50 clients had, as per Appellant's records, bank accounts with BhOB. Therefore the certification given by the Appellant was for existence of demat account as sought to be suggested" it is fairly established that Karvy was very much involved in the game plan. In the facts and circumstances, it is inconceivable that such large number of activities such as opening of demats accounts, bank accounts, IPO finance etc. could have been possible without active collusion of the Karvy group. Karvy can not escape by pleading ignorance and the only inference that can be drawn is that there was active participation on the part of Karvy group in the entire gamut of events which took place from the introduction of the bank accounts, opening of fictitious demat accounts, IPO finance to key operators etc. The DP is only feigning innocence which in the facts and circumstances can not be accepted.

11.16. Even otherwise, the evidence, direct or circumstantial, should be sufficient to raise a presumption in its favour with regard to the existence of a fact sought to be proved. As pointed out by Best in "Law of Evidence", the presumption of innocence is no doubt presumptio juris; but everyday practice shows that it may be successfully encountered by the presumption of guilt arising from circumstances, though it may be a presumption of fact. Since it is exceedingly difficult to prove facts which are especially within the knowledge of parties concerned, the legal proof in such circumstances partakes the character of a prudent man's estimate as to the probabilities of the case. However, in the present case, it is fairly established that the Karvy Group was actively involved in each and every part of the manipulation committed by the key operators by introducing the bank accounts of the key operators, opening the afferent accounts for the key operators, financing to key operators and further culminating in the sale of the IPO cornered shares on behalf of the key operators.

11.17. The series of transactions in the form of opening of bank accounts and demat accounts by the key operators with the assistance of Karvy and the subsequent funding to key operators and the sale of shares cornered by the key operators through the Karvy group would only lead to the finding that the said transactions were done with a manipulative intent. The said concerted level of activity and that too on a large scale in opening about 50,000 fictitious afferent accounts with the participation of all the necessary functionaries in the securities market viz. registrar to the issue, depository participant, financier and the stock broker is only compatible with the scheme of manipulating the IPO process with the other members of the group. The same entails violation of the provisions of Section 12A of Securities and Exchange Board of India Act, 1992, Regulation 3 and 4 of Securities and Exchange Board of India (Prohibition of Fraudulent and Unfair Trade Practices Relating to Securities Market) Regulations, 2003, Regulations 19, 20A, 42, 43, 46 and 52 of Securities and Exchange Board of India (Depositories and Participants) Regulations 1996, Securities and Exchange Board of India (Disclosure and Investor Protection) Guidelines, 2000, 6 and 13 of Securities and Exchange Board of India (Registrars to an Issue and Share Transfer Agents) Regulations, 1993, Regulation 5, 7 and 15(1)(b) of Securities and Exchange Board of India (Stock Brokers and Sub - Brokers) Regulations, 1992.

11.18. Though the Enquiry Officer had observed that it can not be conclusively established that Karvy fabricated the bank introduction letters, I note that by introducing fictitious bank accounts, by opening fictitious demat accounts Karvy in a mannert of speaking, had fabricated such accounts which are otherwise non existent.

11.19. The elaborate discussion in this order on the various activities clearly demonstrate that Karvy group (RTI, Broker and the DP) were involved in the manipulation of IPO process. In the course of their reply, it has been canvassed that as group companies they were coordinating with each other in the group activities by rendering the necessary assistance respective to their business operations. In my view, it would take extreme naivet to believe in such a version, because the putative co-ordination under the guise of group activity in the vicissitudes of the instant case virtually amounted to making a common cause in the abuse of the IPO process. A group activity normally implies sharing of synergies for a combined business operation, where the group members have to contribute in their respective spheres. In the instant case, the summum bonum of the group activity was one of abusing the IPO process to facilitate cornering of the shares by key operators through fictitious afferent accounts. The same cannot partake the character of a group activity as understood in normal commercial parlance. Further , the case history as brought out is replete with profusion of instances where KSBL, KCPL( RTI) and KCL joined hands making use of their commercial engagements in the IPO process chain and such a concerted activity in unison with unity of control and purpose made it easy for the Group to steer the intended course of action without any hiccups.

11.20. It is not a case of any defect in the system, but a classic example of hoodwinking the system in seeming compliance with all the beguilements.

12. Conclusion The findings of the investigations on the role of Karvy group entities in the IPO irregularities, the findings of the enquiry proceedings and the findings emerging from the consideration of submissions of Karvy and the various related documents forming part of record from interim orders through the course of appeal till the present proceedings are briefly as under:

12.1. At the outset, the present order seeks to capture the developments in the present case from 2003 - 2005 in terms of the escalating scale of operations of Karvy group in diversified roles.

12.2. It is found that Karvy group entities were ubiquitously present in the entire gamut of the IPO process running from introducing bank accounts, opening of dematerialized accounts, arranging IPO finance, bidding of applications, making allotment, issuing refund, making off-market transfers (DIS) and sale of IPO shares on the stock exchanges. The role of Karvy group entities at each stage of the process has been examined for uncovering Karvy's role at every stage and to ascertain overall control beginning from opening of bank and dematerialized accounts till making refund and off-market transfer of IPO shares.

12.3. The examination covered the following activities of Karvy:

Introducing the BhOB and IOB bank accounts of key operators and certifying addition of fictitious / benami names to the bank accounts of the key operators. This was done for the key operators to avail retail IPO finance from the banks in the names of the fictitious / benami entities.

Using the bank accounts introduced by them for opening dematerialized accounts in the names of key operators and afferent entities. The afferent dematerialized accounts were opened in bulk on few dates around the dates of major IPOs. For the purpose of opening dematerialized accounts, the names / surnames of the afferent entities were used in various permutations and combinations and the address of the key operators were indicated as the address of afferent dematerialized account-holders.

Providing of IPO finance to the fictitious / benami entities through the medium of key operators. KCL released the IPO finance (in non-RTGS cases) directly to the key operators. In effect, no funds were received from the bank accounts of the afferent entities and no refund was given to the bank accounts of the afferent entities. Karvy knew that the entities to which they purportedly provided IPO finance were fictitious / benami and in effect, Karvy was dealing only with the key operators. KCL an NBFC provided IPO finance to the key operator at an interest rate of 19% p.a. The interest was computed on the basis of IPO finance for a period 15 days. However, due direct RTGS transfer to the escrow account many days after the close of issue and due to prompt encashment of the consolidated refund, the period of financing was compressed to about one week, thereby significantly improving the returns on the loan provided by KCL.

Bidding of the application forms of fictitious / benami entities without the corresponding payment (100% IPO margin). KSBL acting as a stock broker and sub-syndicate member bid the application forms of the fictitious / benami applicants pertaining to various key operators even though application money was not received from the applicants at the time of bidding.

Issuing of consolidated refund orders. KCPL, acting as RTI issued consolidated refund orders in respect of thousands of fictitious / benami applicants. This enabled quick and easy encashment of the refund money by the key operators and the refund money was recycled for the subsequent IPOs. This also facilitated quick return of the IPO finance where KCL had funded the key operators for making applications in fictitious / benami names. Further, since in many cases the bank accounts of the fictitious / benami applicants did not exist, if the RTI had issued individual refund orders mentioning the bank account numbers as available in the depository system, the encashment of the refund orders would have been impossible.

Issuing directions for appropriation of refund money. KCL, acting as an NBFC had requested BhOB to adjust the refund pertaining to thousands of fictitious / benami applicants towards the IPO finance provided by it to the key operators.

Executing off-market transfers including irregularities relating to issuing and processing of DIS. KSBL (erstwhile KCL), acting as DP, had executed thousands of off-market transfers from the afferent dematerialized accounts to the dematerialized accounts of the key operators within a span of one day. In ordinary course, the key operators could not have got the same done without the involvement of the DP. It was found that the off-market transfers had been executed by the DP in some instances without there being any Delivery Instruction Slips and in certain other instances, featuring pre-printed columns in respect of all relevant fields including target client details which can never be in the knowledge of the DP before execution, enabling the key operators to execute thousands of off-market transfers in a single day.

12.4. The manner of opening bank accounts and dematerialized accounts clearly demonstrates Karvy's control and their knowledge of the fictitious / benami nature of these accounts. In effect, Karvy was dealing only with the key operators and not with anyone else. The IPO process, IPO financing, RTGS transfer to the escrow account, issuance of consolidated refund order and issues relating to DIS, further strengthen the above finding with tell tale strands of Karvy's control at each and every stage of IPO process. The examination of Karvy's role, as above, inter alia, revealed the following salient findings:

12.5. The evolution of Karvy's role in the IPO irregularities began during the year 2003 when Karvy had presented to BhOB an idea paper and a process flow. As per the process flow, the IPO applications would be filled in by the investor and a cheque/DD in favour of the Bank towards the margin amount shall be deposited. The investor would need to open the Demat account with Karvy who would place a lien on the shares deposited into the investor's account until the investor clears the loan with the Bank. A perusal of the process flow envisaged for IPO funding as spelt out by Karvy shows that there was a specific assuring clause to the effect that there were no chances for cases such as benami applications, multiple applications, fraudulent investors etc. thereby providing comfort to the bank.

12.6. Pursuant to the arrangement, Karvy had introduced numerous bank account holders to BhOB, Ahmedabad branch. The first such bank account introduced by Karvy to BhOB Ahmedabad appears to be a set of account numbers starting with '50795'. The system of internal numbers (e.g. 50795/1, 50795/5, 50795/14 etc.) was used for opening many bank accounts starting with the same account number. The said account no. 50795 was held in the name of Devangi Dipak Panchal as first holder. It was found that in some of these bank accounts names had been added on introduction of Karvy Investor Services Ltd.

12.7. Thereafter during June 27 - 30, 2003 Karvy had opened 297 demat accounts on NSDL indicating the bank account details of the BOs as BHOB, Ahmedabad branch, Bank account number 50795. While the said bank account no. 50795 was closed on October 27, 2003 the corresponding demat account continued till November 2005 when the demat accounts were closed pursuant to verification by Karvy DP in the wake of SEBI examination of the matter of IPO irregularities.

12.8. Subsequently during December 2003 Karvy Securities Ltd. had introduced a savings bank account number 54119 in the name and style of "Devangi Dipakbhai Panchal - GROUP ACCOUNT". Therefore it is clear that the arrangement between Karvy and BHOB continued even after the Maruti IPO which closed on June 19, 2003. Further based on analysis of afferent demat accounts held with Karvy DP it was found that 3450 afferent demat account holders pertaining to the key operator Roopalben Panchal had indicated their bank account as BHOB bank account number 54119. These 3450 afferent demat account holders had five common surnames viz. Luhar (600 nos.), Pari (600), Mistry (600), Shroff (600) and Seth (1050). Though the bank account number 54119 was closed on April 24, 2004 the corresponding 3450 afferent demat accounts continued to be held with Karvy DP and were closed during November 2005 only.

12.9. Thereafter, during October 2004 - March 2005, KCL / KSBL had introduced 38 bank accounts of the key operators (Roopal Panchal and Kelan Atul Doshi) to IOB, Thaltej branch. Furhter, KCL / KSBL had certified the list of 50 names that were attached to each of the above bank accounts. Out of the above 38 bank accounts one bank account having number 12140 pertaining to Roopalben Panchal was examined in detail. It ws observed that the said bank account number 12140 was introduced to IOB Thaltej branch by KSBL. A list of 50 names and specimen signatures is found attached to the bank account opening form and the list is certified by KSBL and their rubber stamp is affixed. In this context it may be mentioned that Karvy in its appeal memorandum (Appeal No. 92 of 2006) inter alia stated that "...the Appellant had not introduced the said 50 clients to IOB Thaltej. The appellant has only certified pursuant to IPO sub-broker, that the said 50 demat accounts with the Appellant. It is submitted that all the said 50 clients had, as per appellant's record, bank accounts with BHOB. Therefore, the certification given by the Appellant was for existence of demat account as sought to be suggested".

12.10. The list of 50 names attached to the bank account number 12140 held with IOB,Thaltej branch begins with the name of SURESH SETH and ends with ADITI SETH. It is found that Karvy DP had opened the demat accounts in these 50 names on January 5, 2004 and had thereafter introduced the names to IOB on March 9, 2005. The signatures of the 50 persons certified by Karvy appear similar and appear to have been made by one person only. Therefore it follows that Karvy were aware that the names and signatures certified by them were fictitious in nature.

12.11. It was found that on CDSL Karvy DP had opened as many as 1250 demat accounts using the series of 50 proper names beginning with SURESH and ending with ADITI. This had been done by adding different surnames to the series of first names beginning with SURESH and ending with ADITI. The surnames that were added included Zala, Rathod, Vania, Patil, Ranka, Pandya, Desai, Rathi, Verma, Trivedi, Gandhi, Barot, Vala, Pathak, Bhatt, Kapoor, Tated, Kela, Sen, Roy, Irani, Jha, Mehta, Das and Prasad. Out of these 1250 CDSL demat accounts, 750 demat accounts have been opened on July 15 - 16 2005 and 500 accounts were opened on September 22, 2005. On September 22, 2005, Karvy DP had opened 10,000 demat accounts but had not activated them due to certain alleged deficiencies in the account opening documents. The 10,000 demat accounts include the 500 dematerialized accounts mentioned above.

12.12. Upon comparing the demat account opening documents of eight entities namely Guljar Seth, Abhilash Seth, Gunish Seth, Yatna Seth, Nirvi Seth, Ahishok Seth, Devandra Seth, and Deparv Seth, with the bank loan documents of IOB, it was observed that IOB had extended IPO finance to these eight names. However, the photographs affixed on the demat account opening forms and that on the loan document of IOB were completely different. Instances like this can be multiplied.

12.13. It was found that KCL had provided IPO finance to the various combinations of 50 names starting from SURESH and ending with ADITI. Furhter it was found that in the IPO of IDFC, KCL had made RTGS transfers to the Escrow account in respect of the IPO finance provided to these fictitious / benami applicants. Also KCPL, the RTI, had issued consolidated refund orders in respect of these fictitious / benami applicants.

12.14. It was found that KCL had provided IPO finance in IDFC IPO to seven key operators namely Biren Kantilal Shah, Purshottam Budhwani, Dharmesh Mehta, Roopal Panchal, Dhaval Katakia, Parag Jhaveri and Manoj Seksaria. Based on information submitted by Karvy it is seen that KCL had executed a loan agreement with Roopalben Panchal pursuant to which KCL had provided IPO finance of Rs. 18.56 crores to Roopalben Panchal. It was found that Shri Mayur Modi and Shri Aditya Gupta, employees of Karvy had acted as references for Roopalben Panchal. The application money in respect of 10,900 applications pertaining to Roopal Panchal and other key operators amounting to Rs.51.90 crores was transferred directly by KCL to the IDFC escrow account on July 30, 2005. It may be noted that the IDFC IPO closed on July 22, 2005. The amount transferred through RTGS for Roopalben Panchal was purportedly towards the application money for 5200 applicants. Thus it was found that the 5200 application forms pertaining to Roopalben Panchal were not accompanied by cheque / DD when the applications were bid on the exchange system on July 22, 2005. Karvy RTI, pursuant to allotment of IPO shares, issued consolidated refund orders in respect of these applicants pertaining to the key operator namely Roopalben Panchal. KCL requested BHOB to adjust the refund money against the loan provided by it and the same was complied by BHOB. The same is true in the case of the IPO financing provided by KCL to the other key operators also. Thus it was found that the margin money towards loan did not come from the bank accounts of the respective applicants and the refund money also did not go to the respective applicants. In essence Karvy was dealing only with the key operators while purporting to deal with thousands of persons who were nothing but a figment of imagination.

12.15. Further, with regard to the IPO finance provided to the key operators, it was found that KCL had provided IPO finance to the key operators for a period of 15 days and had charged interest at 19% p.a. reckoning the 15 day finance period. However, it was found that in respect of the IPO finance provided by KCL to the key operators, it had made RTGS transfers to the IPO escrow account many days after the closure of the issue. KSBL the stock broker and sub-syndicte member had bid these applications without receiving the application money. KCPL the RTI had issued consolidated refund orders in respect of the applicants financed by KCL and KCL requested the bank (BHOB) to adjust the refund against the loan provided by it. This ensured that the money towards IPO finance was given by KCL many days after the closure of issue and the refund was received immediately upon completion of allotment. Thus the money of KCL was used for IPO finance only for a period of 8-10 days while it charged interest for 15 days to the key operators. By adopting the above modus operandi which was facilitated by the presence of the Karvy group entities at various stages of the IPO process, Karvy ensured that its money was actually used only for a period of 8-10 days while charging interest for 15 days thereby improving the returns on the money loaned by it. It is seen that interest rate charged by KCL works out to about 47% p.a. 12.16. In terms of provisions of SEBI (DIP) guidelines, market practices and Karvy's own submissions it is essential for the IPO application forms in the retail category to be accompanied by payments towards the application money. As mentioned earlier KCL had made direct RTGS transfer of Rs.51.90 crores to the IDFC Escrow account on July 30, 2005 in respect of the 10,900 applications pertaining to various key operators. The last day for bidding in IDFC IPO was July 22, 2005. Therefore, it follows that at the time of bidding these 10,900 applications were not accompanied by the application money in the form of cheque / DD. In this regard, I note that KSBL has claimed that in respect of the 10,900 IDFC IPO applicants financed by it a cheque issued by KCL bearing number 336429 dated July 21, 2005 drawn on HDFC Bank was sent by it to the collecting bank at Hyderabad. However, alledgedly the cheque was misplaced and therefore KCL made the RTGS transfer of Rs51.91 crores to the IDFC Escrow account on July 30, 2005. The alleged consolidated cheque number 336429 issued by KCL and the RTGS transfer made by KCL needs to be viewed in the context of the 10,900 applicants pertaining to various key operators financed by KCL were fictitious / benami in nature.

12.17. It is seen that in the case of Sasken IPO, Karvy did not take any margin from Roopalben Panchal. Karvy had provided 100% IPO finance of Rs. 26 crores to Roopalben Panchal. Further, Karvy had transferred Rs. 9 crores out of the refund money of Sasken IPO for making application in the IPO of Amar Remedies on behalf of Roopalben Panchal. In addition, Karvy had made RTGS transfer of Rs. 20.89 crores in the IPO of Amar Remedies towards IPO loan given to Roopalben Panchal. In this regard Karvy DP in its reply dated May 19, 2007 has stated that "it may however, be noted that the margin amount was not transferred to KCL, but only the loan amount was disbursed to the loanee, who inturn has deposited the total amount inclusive of the margin amount to the escrow account of the issuer." In the normal course of IPO finance the financier collects the margin amount from the borrower and issues cheque / DD favourig the escrow account for the application money. This practice is adopted to ensure that the loan money is utilized only for the purpose of making IPO application. That KCL, instead of adopting the normal practice as above, released the loan amount directly to the key operator (Roopal Panchal) shows that Karvy had full control over the manner of application of funds.

12.18. Similarly, it is seen that Karvy had provided IPO finance to various other Key Operators, namely, Manoj Seksaria, Purushottam Budhwani a nd Parag Jhaveri in respect of various IPOs namely, ILFS, IDFC, Sasken and Suzlon. As regards the financing by KCL to Purshottam Budhwani, it was found that KCL had disbursed the loan amount many days after the closure of the IDFC IPO. In this regard KSBL in its reply dated May 19, 2006 has stated that "we had received the margin subsequently. It is submitted that the margin was received by KCL on the date of closure of the issue. It is reiterated that KCL had not disbursed the loan amount to Purshottam Budhwani, since KCL had not received the margin." In this regard it is noted that KSBL, the stock broker, had bid the IDFC IPO application forms pertaining to Purshottam Budhwani on the last day of the issue i.e. July 22, 2005. Apparently the cheques attached to the application forms were encashed a week later i.e. after the disbursal of the loan money by KCL.

12.19. Further, in the case of Suzlon IPO, the public issue closed on September 29, 2005 and it was found that KCL had made RTGS transfer of Rs.20.51 crores to the escrow account of Suzlon IPO on October 5, 2005 i.e. many days after the date of close of the IPO. In this regard, KSBL has submitted that the amount to be transferred towards margin and the loan funded by KCL for various afferent applicants in the Suzlon IPO was ascertained only by the evening of September 29, 2005. Since September 30, 2005, October 1 and October 2, 2005 were Bank holidays KCL made RTGS transfer to the Suzlon IPO Escrow account on October 5, 2005 in respect of the applicants financed by it.

12.20. In view of the above SEBI examined the bid book of IDFC IPO in respect of the applications financed by KCL. Examination of the bid book revealed that KSBL in its capacity as a broker of NSE and also as a sub-syndicate member had bid the 10,900 application forms pertaining to the key operators financed by KCL. Further, a sampling of the data revealed that many of the applications had been entered by one or few employees of Karvy. The time gap between entry of successive applications was only 2-3 seconds. Many of the applicants shared a few common surnames. The applicants pertaining to a key operator had the same address i.e. the address of the key operator. Thus KSBL, the stock broker, knew at the time of bidding the applications that these 10,900 applicants were fictitious / benami in nature.

12.21. It was found that subsequent to the allotment, KCPL the RTI had issued consolidated refund orders in respect of these applicants. The refund amount was adjusted against the loan provided by KCL.

12.22. After the allotment of IDFC IPO shares on August 6, 2005 Karvy DP transferred these shares from the afferent demat accounts to the demat account of Roopalben Panchal (client ID 11920868) on August 8, 2005. For the purpose of these off- market transfers Karvy DP had used DIS bearing continuous serial numbers. Further in certain of the off-market transactions executed by Karvy DP on NSDL, the transaction number which is generated by the depository system after the execution of the transaction was found to be printed on the DIS. In the ordinary course, a DP executes the depository transactions based on DIS signed by the BO and after execution the depository system generates a transaction number which is written on the DIS by the DP and the DIS is kept by the DP for records. The fact that the transaction number was printed on the DIS used by Karvy DP for making off-market transfers leads to the inference that the DIS did not exist at the time of execution of transactions and was printed by the DP subsequently. This view is strengthened by the fact that the DIS have holes on the left end and right end of the slip indicting that the slip has been printed on a continuous computer stationary.

12.23. In respect of off-market transactions executed by Karvy DP on CDSL it was observed that all the material particulars including the target BO ID and target BO name to be printed on the DIS. In the ordinary course the DP pre-prints onlyl the source BO (its client) details on the DIS and the target details are not known to the DP till the time the BO submits the DIS for execution. The pre-printing of the target details shows that in the instant case Karvy DP was aware of the modus operandi adopted by the key operators for cornering of IPO shares and facilitated the same.

12.24. Thus it may be seen that various entities belonging to the Karvy group were involved in the entire chain of IPO process and Karvy group utilized the same to introduce bank accounts of key operators and fictitious / benami entities, open demat accounts in fictitious / benami names, provide IPO finance to key operators for making applications in fictitious / benami names, enter the bids without receiving application money, make consolidated refunds, make allotment, execute off-market transfers with improper / non-existant DIS and finally sell the IPO shares on the stock exchanges.

12.25. Even assuming for the sake fo argument that Karvy was not aware of the plans and modus operandi of the key operators, the manner in which certain sets of names have been used with change in surnames with systematic regularity for opening either bank account for financing or for opening fresh demat accounts for cornering the shares, which was fully in the knowledge of Karvy, should have definitely alerted them that there was somethihg amiss or untoward about them. But the fact that such operations were carried out with unquestioning ease clearly demonstrates Karvy's complicity in the whole matter.

12.26. It is fairly established that Karvy DP and the group was very much in the thick of the entire process of abuse of IPO process 12.27. On a conspectus of the concatenation of events spanning nearly three years which saw the evolution of the game plan into a full fledged operation of cornering IPO shares till the final denoument in December 2005 / January 2006 resulting in the closure of very same afferent accounts which were opened to get around the public policy in retail quota to the detriment of retail investors, it is fairly established that Karvy Group was very much in the thick of the entire process of IPO abuse and the same warrants a penalty as specified in the Enquiry Regulations.

12.28. The penalty is imposed on the basis of the available materials on record. It is understood that various other investigating agencies are looking into the matter of IPO irregularities. On receipt of the findings of the said agencies, SEBI is at liberty to take appropriate actions against Karvy in accordance with law.

12.29. In the facts and circumstances, inter alia taking into account the prohibition imposed by SEBI vide interim orders dated January 12, 2006 and April 27, 2006 I hereby pass the following order.

13. Order In view of the foregoing, I, in exercise of the powers conferred upon me in terms of Section 19 of the Securities and Exchange Board of India Act, 1992 read with regulation 13(4) of Securities and Exchange Board of India (Procedure for Holding Enquiry by Enquiry Officer and Imposing Penalty) Regulations, 2002, hereby pass the following order:

a. Karvy Stock Broking Ltd., Depository Participant (Registartion nos. IN-DPNSDL- 247-2005 and IN-DP-CDSL-305-2005) is prohibited from opening fresh demat accounts till December 31, 2007. This direction will come into force with immediate effect.

b. The certificate of registration of Karvy Stock Broking Ltd., Member, National Stock Exchange of India Ltd (Reg. no. INB 230770138), Bombay Stock Exchange Ltd. (Reg. no. INB 010770130) and the Hyderabad Stock Exchange Limited (Reg. no. INB 060770139) is suspended for a period of three months. The said order against the said stock broker shall come into force immediately on the expiry of 21 days from the date of this order.

c. Karvy Computershare Pvt. Ltd., the Registrar to the Issue (Reg. No INR 000000221) is prohibited from acting as Registrar to an Issue for a period of nine months. As Karvy Computershare Pvt. Ltd. had already undergone the prohibition for that period vide Securities and Exchange Board of India order dated April 27, 2006, there will be no further directions against Karvy Computershare P Ltd.