In one of its most extensive enforcement actions to date, the Securities and Exchange Board of India (SEBI) has barred 59 individuals and entities, including the company promoters, Bollywood actor Arshad Warsi and his wife, Maria Goretti from the markets for up to five years in connection with a coordinated pump-and-dump operation in the shares of Sadhna Broadcast Ltd, now known as Crystal Business System Ltd. SEBI also imposed a total penalty of Rs21.45 crore on these entities. The order, issued under Sections 11(1), 11(4) and 11B of the SEBI Act, outlines how Sadhna Broadcast promoters conspired to inflate the company’s share price through false YouTube videos, structured trades and widespread retail misdirection before offloading their holdings at artificially high prices. SEBI has banned seven people from trading for five years and another 54 for one year.
In a strongly-worded order, Ashwani Bhatia, whole-time member (WTM) of SEBI, says, "The overall conduct of the noticees has revealed a classic pump-and-dump scheme. The price was systematically pushed upward through collusive trading, followed by aggressive promotional activity to draw in retail investors, and finally, a coordinated sell-off by the promoters. The retail investors, misled by this staged market activity, were left holding the shares at distorted valuations once the manipulators that included the promoters had exited. The shares of SBL (now Crystal Business System) trade at around Rs2.60 per share against a peak of above Rs33 at the height of the pump phase. The fact that the company, without changing its object clause or stated business, has changed its name is indicative of attempts made by the promoters to cover their tracks."
"The moot point from what we have seen is the manner in which the promoters brought down their shareholding at the cost of innocent retail shareholders, thereby making huge profits for themselves," Mr Bhatia says. "A question that needs to be asked of the promoters is why would any promoter, in their right mind, sell their holding if theirs was a well-managed and profitable company. The use of multiple YouTube channels to influence and mislead innocent investors in this case was well thought out by the perpetrators of the scheme or arrangement in connivance with the promoters. Such posts on social media would have led to emotional and spontaneous investment decisions. Not surprisingly, the number of retail investors jumped as a consequence thereof. In a way, the investors got caught in the crossfire and they only absorbed the liquidity on account of the distribution of shareholding by the promoters."
"The events narrated in this order also paint a disturbing picture regarding the increasing use of social media platforms, which have immense reach and influence in the digital age, as tools for market manipulation. Paid advertising campaigns are undertaken through such platforms to reach a wide audience. These platforms—while benefiting from massive advertising revenues—appear not to have taken proactive steps in curbing such deceptive content. Given the magnitude of public money at stake and the growing trend of retail investors relying on social media for investment advice, it is imperative that these companies take greater responsibility for the material they host and promote. Their algorithms and monetisation models must not end up amplifying manipulation resulting in retail investors losing huge sums of money," the WTM added.
The case originated from complaints received by SEBI in mid-2022 from a whistle-blower who alleged that misleading promotional videos had been uploaded to YouTube channels in a bid to lure retail investors into buying shares of Sadhna Broadcast. These videos falsely claimed that the company was the subject of a major takeover by the Adani group, had secured a Rs1,100 crore deal with an American company to produce devotional films and was set to become a multi-bagger stock.
SEBI’s investigation confirmed that the videos contained false and misleading information designed to influence unsuspecting investors. The regulator linked the content to a group of YouTubers and digital marketers, including Manish Mishra, Dipak Dwivedi and Vivek Chauhan, who collectively managed and operated several YouTube channels such as ‘The Advisor’, ‘Moneywise’, ‘Profit Yatra’, and ‘Midcap Calls’, among others.
SEBI categorised these noticees as misleading message disseminators (MMD), net sellers or promoters and profit makers (NSs), volume creators (VCs) and information carriers (ICs).
According to SEBI’s findings, Manish Mishra, who was the MMD and VC, and his associates paid over Rs3.39 crore from personal and affiliated accounts towards Google Ads to boost the reach of these deceptive videos. Other connected individuals such as Purav Patel and Dipak Dwivedi also contributed Rs1.50 crore and Rs92.54 lakh, respectively to support the ad campaigns.
"These efforts were highly successful, as many of the videos racked up millions of views within days. While retail investors flocked to purchase shares of Sadhna Broadcast, the accused group executed structured trades to inflate both price and volume, creating an illusion of demand," the market regulator observed.
SEBI investigation further revealed that several promoter-linked entities and their associates sold massive quantities of shares at inflated prices during the period of heightened interest. SEBI identified the pattern of offloading across three key video promotion phases, with coordinated selling timed to follow each wave of deceptive content.
Some of the largest beneficiaries of the scam included: Sadhna Bio Oils Pvt Ltd, which sold over 40 lakh shares worth Rs9.8 crore, Virtual Business Solution Pvt Ltd, which sold 20 lakh shares, and individuals such as Rajshree Goel, Sulabh Dikshit and Sunil Goel. Many of these sales coincided with videos being uploaded or heavily promoted online.
Here are the names of key entities and individuals involved in the Sadhna Broadcast case, along with the profits they unlawfully earned through the pump-and-dump operation as determined by SEBI:
Gaurav Gupta (Rs18.33 crore), Shreya Gupta (Rs3.28 crore), Saurabh Gupta (Rs17,602), Arpan Gupta (Rs7.39 lakh), Sadhna Bio Oils (Rs9.41 crore), Virtual Business Solution (Rs2.52 crore), Varun Media Pvt Ltd (Rs1.14 crore), Madhu Render Singh (Rs3.60 crore), Sulabh Dikshit (Rs1.50 crore), Pooja Aggarwal (Rs1.49 crore), Yogesh Kumar Gupta (Rs1.33 crore), Magnesh Bala (Rs1.18 crore), Rajshree Goel (Rs5.05 crore), Sunil Goel (Rs3.38 crore), Reena Goel (Rs7.70 lakh), Bhim Singh Chaudhary (Rs1.36 crore), Kavita Shah (Rs19.33 lakh), High Spirits Sales Agencies Pvt Ltd (Rs15.88 lakh), Chinnu (Rs10.53 lakh), Dipak Dwiwedi (Rs41.88 lakh), Swati Agarwal (Rs22.97 lakh), Mayank Kumar Agarwal (Rs21.38 lakh), Maria Goretti Warsi (Rs50.36 lakh), Arshad Hussain Warsi (Rs41.70 lakh), Aahuti Rasik Mistry (Rs57.83 lakh), Iqbal Hussain Warsi (Rs12.62 lakh), Heli Jatin Shah (Rs7.29 lakh), Karavan Tradelink OPC Pvt Ltd (Rs5.25 lakh), Angad Rathod (Rs5.64 lakh), Sachinkumar Bhagvandas Sahu (Rs4.18 lakh), Vijay Sureshbhai Udhani (Rs24.85 lakh), Ayushi Udhani (Rs2.31 lakh) and Krunal Chavda (Rs1.69 lakh).
Some individuals and entities were noted as participants in the manipulation scheme but either did not trade or earned negligible profits and were not assigned a specific profit amount in the SEBI order.
Using detailed analysis of call records, common addresses, WhatsApp conversations, trading data and KYC documents, SEBI was able to link the activities of the individuals involved and classify them into four main roles: those who created and disseminated misleading messages, those who offloaded shares (net sellers-NSs), those who executed trades to simulate volume (volume creators-VCs), and intermediaries who coordinated among the other groups. The manipulation spanned from March to November 2022 and was split into six time periods, each marked by either a spike or crash in the share price of Sadhna Broadcast, directly influenced by the group’s activities.
The share price rose dramatically from Rs2.55 to Rs33.15 between March and October 2022 before collapsing, hitting lower circuits on multiple consecutive days as the fraudulent interest vanished. SEBI's data showed that retail investors bore the brunt of the losses as those behind the manipulation exited with significant profits. In total, over 1.6 crore shares were offloaded during the key promotional phases, yielding gains exceeding Rs33 crore for the perpetrators.
In its final order, SEBI held that the 64 named individuals and entities had violated the SEBI Act and the SEBI (Prohibition of Fraudulent and Unfair Trade Practices Relating to Securities Market) Regulations, 2003. The regulator not only imposed a monetary penalty totalling Rs21.45 crore but also barred the individuals from accessing or associating with the securities market, some permanently and others for fixed durations. Prominent among those penalised and barred are Manish Mishra, Vivek Chauhan, Dipak Dwivedi, Shreya Gupta, Subhash Agarwal, and multiple promoter-linked entities and shell companies.
SEBI imposed penalties on several individuals and entities involved in the Sadhna Broadcast market manipulation case. Gaurav Gupta was fined Rs1.6 crore, Shreya Gupta Rs28 lakh, Saurabh Gupta Rs2 lakh, and Arpan Gupta Rs6 lakh. Sadhna Bio Oils Pvt Ltd faced a penalty of Rs82 lakh, while Virtual Business Solution Pvt Ltd and Varun Media Pvt Ltd were fined Rs22 lakh and Rs10 lakh, respectively. Madhu Render Singh was penalised Rs31 lakh, Sulabh Dikshit and Pooja Aggarwal Rs13 lakh each, Yogesh Kumar Gupta Rs11 lakh, and Magnesh Bala Rs10 lakh. Promoter-linked individuals Rajshree Goel and Sunil Goel were fined Rs44 lakh and Rs29 lakh, respectively, while Reena Goel was fined Rs67,000. Bhim Singh Chaudhary received a penalty of Rs12 lakh, Kavita Shah Rs1.7 lakh, and High Spirits Sales Agencies Pvt Ltd Rs1.4 lakh. Chinnu was fined Rs92,000, Dipak Dwiwedi Rs3.7 lakh, Swati Agarwal Rs2 lakh, and Mayank Kumar Agarwal Rs1.9 lakh. Maria Goretti Warsi and Arshad Hussain Warsi were fined Rs4.4 lakh and Rs3.6 lakh, respectively. Aahuti Rasik Mistry faced a penalty of Rs5 lakh, Iqbal Hussain Warsi Rs1.1 lakh, Heli Jatin Shah Rs64,000, and Karavan Tradelink OPC Pvt Ltd Rs46,000. Angad Rathod was fined Rs49,000, Sachinkumar Bhagvandas Sahu Rs36,000, Vijay Sureshbhai Udhani Rs2.2 lakh, Ayushi Udhani Rs20,000, and Krunal Chavda Rs14,000.
Seven individuals—Gaurav Gupta, Rakesh Kumar Gupta, Subhash Agarwal, Peeyush Agrawal, Lokesh Shah, Jatin Manubhai Shah, and Manish Mishra—have been restrained from the securities market for five years. The remaining 52 entities, including Mr Warsi and his wife Ms Goretti, have been barred from markets for one year.
Additionally, proceedings against three noticees—Neha Aggarwal, Kishansinh Mansinh Rajput and Paresh Dhirajlal Shah were disposed of without any directions.
The case marks a major precedent in tackling digital-era stock manipulation and sets a benchmark for regulatory vigilance in the face of tech-driven market abuse. In its concluding remarks, the regulator noted that the coordinated actions of these noticees had severely damaged investor confidence and market integrity and reiterated the need for public awareness and caution when relying on unverified financial advice online.
This action reinforces SEBI’s message that the use of digital platforms to mislead investors and manipulate markets will be met with stringent consequences. The crackdown is expected to serve as a deterrent to others who may seek to misuse technology for illicit gain in the securities market.
