In Brief
MBL & Company Limited, a stock broker, placed thousands of self-trades in Gujarat NRE Coke Limited shares between December 2011 and February 2012, predominantly through single-share orders executed from the same terminal. The Whole Time Member of SEBI found this constituted market manipulation under Section 12A of the SEBI Act and the PFUTP Regulations, despite minimal absolute profit (₹2.61 lakhs) and trading volume (0.04% of market). The WTM debarred MBL from proprietary trading for four years. The Supreme Court dismissed MBL's appeal, holding that market manipulation must be assessed on market integrity impact, not manipulator gain alone. Single-share repetitive order placement can constitute valid manipulation if intentionally designed to artificially elevate prices and breach market integrity."
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