SEBI Slaps Rs5 Lakh Penalty on Narendra Ramshankar Dubey for Manipulating MHIL Stock Price

Moneylife Digital Team 29 September 2025

Investor Interest

Market regulator Securities and Exchange Board of India (SEBI) has imposed a penalty of Rs5 lakh on Narendra Ramshankar Dubey for manipulating the share price of Max Heights Infrastructure Ltd (MHIL), a company listed on the Bombay Stock Exchange (BSE).

The case arose after an internal alert triggered a BSE investigation, later extended by SEBI, covering trades between 31 October 2022 and 15 March 2023.

It was found that Mr Dubey placed 176 small buy orders of just 1–10 shares, despite the presence of large sell orders in the market. Out of these, 171 trades contributed to a positive last traded price (LTP) of Rs346.57, accounting for 16.56% of market-wide price impact.

Overall, he was among the top-10 contributors to positive LTP in MHIL, influencing Rs399.71 which was 19.10 of market movement during the period. While small trades are not inherently manipulative, SEBI held that repeatedly placing such orders above LTP, despite prevailing sell pressure was an abnormal trading pattern.

This conduct created a misleading appearance of demand and artificially pushed up MHIL’s stock price, violating Section 12A of the SEBI Act, 1992 and multiple provisions of the Prohibition of Fraudulent and Unfair Trade Practices (PFUTP) Regulations, 2003.

Mr Dubey argued that his trades were genuine, conducted via the choice app and motivated by MHIL’s stock split proposal. He also claimed that his overall trading volume was negligible and that he neither made wrongful gains nor caused investor losses.

However, SEBI rejected these contentions, observing that his trades began 17 days after the stock split announcement and were executed in unusually small quantities, designed to influence market sentiment rather than reflect genuine demand.

SEBI further noted that while factors such as gains, losses or repeat defaults are considered while deciding the penalty quantum under Section 15J of the SEBI Act, they do not negate the violation itself. Citing past rulings of the Supreme Court and the securities appellate tribunal (SAT), SEBI reiterated that penalties are mandatory once a contravention is established, regardless of intent or actual investor harm.

Accordingly, SEBI concluded that Mr Dubey actions amounted to market manipulation and the regulator levied a penalty of Rs5 lakh under Section 15HA of the SEBI Act.

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