SEBI

Topic36 PFUTP Definitions Regulation 2 Fraud

Definitions under PFUTP Regulations 2003 — Regulation 2

Topic 36 — Fraud, Fraudulent Practice, Market Manipulation, Misleading Appearance & Connected Persons | SEBI Law Officer

Regulation 2 of the PFUTP Regulations, 2003 contains the definitional framework — defining 'fraud', 'fraudulent practice', 'market manipulation', 'misleading appearance', 'connected person', and related terms. These definitions determine the scope of prohibited conduct under Regulations 3 and 4. The definition of 'fraud' under PFUTP is significantly broader than its common law counterpart, covering a wide range of manipulative, deceptive, and unfair practices that may not constitute fraud under traditional Indian contract law. These definitions are directly tested in SEBI Law Officer MCQs and descriptive papers.

1. Regulation 2(1)(c) — 'Fraud'

Regulation 2(1)(c): 'Fraud' includes any act, expression, omission or concealment committed whether in a deceitful manner or not by a person or by any other person with his connivance or by his agent while dealing in securities in order to induce another person or his agent to deal in securities, whether or not there is any wrongful gain or avoidance of any loss, and shall include — (i) a knowing misrepresentation of the truth or concealment of material fact in order that another person may act to his detriment; (ii) a suggestion as to a fact which is not true by one who does not believe it to be true; (iii) an active concealment of a fact by a person having knowledge or belief of the fact; (iv) a promise made without any intention of performing it; (v) a representation made in a reckless and careless manner whether it be true or false; (vi) any such act or omission as any other law specifically declares to be fraudulent; (vii) deceptive behaviour by a person in a transaction of securities; (viii) a false statement made without reasonable ground for believing it to be true; (ix) the act of an issuer as defined in the Depositories Act, 1996 diverting the funds raised from public or financial institutions for the purpose other than those stated in the offer document or stated as a material fact in the disclosures; (x) manipulation of the price or volume of trading in securities.

Key features of the PFUTP definition of 'fraud':

  • 'Whether in a deceitful manner or not': Unlike common law fraud which requires deliberate deceit, PFUTP fraud does not require the act to be 'deceitful'. Reckless, negligent, or even innocent misrepresentations can constitute fraud.
  • 'Whether or not there is any wrongful gain': Unlike civil fraud, PFUTP fraud does not require proof of profit. A person can be liable for PFUTP fraud even if they did not gain financially.
  • Clause (x) — Price/volume manipulation: Manipulation of price or volume is specifically included as fraud — connecting market manipulation directly to the fraud prohibition.
  • Clause (ix) — Fund diversion: An issuer diverting IPO proceeds to purposes other than stated in the offer document commits fraud — a direct regulatory response to post-IPO fund diversion by promoters.

2. PFUTP Fraud vs Common Law Fraud — Critical Differences

Feature

Common Law Fraud (IPC / Contract Act)

PFUTP Fraud (Regulation 2(1)(c))

Deceitfulness required?

Yes — deliberate misrepresentation required

No — 'whether in a deceitful manner or not'

Wrongful gain required?

Generally yes — must result in loss to victim

No — 'whether or not there is any wrongful gain'

Covers omissions?

Generally no — must be a positive statement

Yes — 'any act, expression, OMISSION or concealment'

Reckless statements

Only deliberate false statements

Yes — clause (v): reckless and careless representations

Abetment / connivance

Separate offence

Expressly included — 'by his connivance or by his agent'

Fund diversion

IPC offences (cheating, criminal breach of trust)

Expressly covered — clause (ix): fund diversion by issuers

3. Regulation 2(1)(e) — 'Fraudulent Practice' (Expanded Definition)

Regulation 2(1)(e): 'Fraudulent practice' means a fraud to which a person is a party and includes — (i) a market manipulation; (ii) a misleading appearance in the market; (iii) creating a false market; (iv) impersonation; (v) creating an illusion of trading; (vi) dissemination of information or statement which is false or misleading relating to securities.

Regulation 2(1)(e) enumerates specific forms of fraudulent practice. Each sub-clause is tested as a standalone MCQ topic:

Sub-clause

Practice

Example

(i)

Market manipulation

Coordinated buying/selling to artificially inflate/deflate price

(ii)

Misleading appearance in market

Creating false impression of high trading activity through wash trades

(iii)

Creating a false market

Spreading false news to move stock prices

(iv)

Impersonation

Placing trades in someone else's name without authority

(v)

Creating illusion of trading

Circular trades — buy and sell same shares between related entities

(vi)

False/misleading information

Spreading rumours; manipulated research reports; fake corporate announcements

4. Regulation 2(1)(g) — 'Misleading Appearance'

Regulation 2(1)(g): 'Misleading appearance' in trading in securities means an appearance which is not genuine and does not reflect genuinely the normal legitimate forces of supply and demand in the securities market.

The 'misleading appearance' concept is central to market manipulation law. Normal price movements reflect genuine supply and demand. A misleading appearance is created when:

  • Trading volume is inflated artificially — wash trades between related parties make a stock appear more liquid than it is.
  • Price moves are driven by coordinated activity rather than genuine investor demand.
  • Order books are manipulated — placing and cancelling large orders to create false depth (spoofing).

5. Regulation 2(1)(b) — 'Connected Persons'

Regulation 2(1)(b): 'Connected persons' means any person who is connected directly or indirectly with the management or administration of a company, either as a director, promoter, employee, banker, advisor, consultant, auditor, chartered accountant, company secretary, cost accountant, or is in a position to obtain unpublished price-sensitive information of the company.

The 'connected persons' definition is broad — it captures anyone with access to inside information, not just formal insiders. Key aspects:

  • Includes directors, promoters, employees of the company.
  • Includes professional advisers — bankers, auditors, CAs, CSs, cost accountants, legal advisers.
  • 'In a position to obtain UPSI' — even a person who might obtain UPSI (not just those who actually have it) is covered.
  • This definition overlaps with — but is broader than — the PIT Regulations' definition of 'insider'.

6. PFUTP Definition of Fraud vs IPC Section 415 (Cheating)

📖 Prakash Gupta v. SEBI SAT Order, 2014

Facts: The accused argued that SEBI's PFUTP action was barred because the conduct amounted to 'cheating' under IPC Section 415 — a criminal offence already prosecuted — and SEBI's civil action was double jeopardy.

Held: SAT held that PFUTP fraud is wider than IPC cheating. PFUTP regulation is a civil/quasi-criminal regulatory framework operating independently of criminal prosecution. SEBI's enforcement under PFUTP for the same facts as an IPC prosecution does not violate double jeopardy — they serve different purposes (regulatory deterrence vs criminal punishment). SEBI v. Ajay Agarwal (2010 SC) confirmed concurrent civil and criminal proceedings are valid.

Ratio: PFUTP fraud is conceptually broader than IPC fraud/cheating. SEBI's PFUTP action and criminal prosecution under IPC/SEBI Act can run concurrently — double jeopardy does not apply to regulatory and criminal proceedings.

7. Model Examination Questions

Q1. Define 'fraud' under Regulation 2(1)(c) of the PFUTP Regulations. How is it broader than common law fraud?

Definition of 'Fraud' under PFUTP — Regulation 2(1)(c)

Model Answer — 'Fraud' under Regulation 2(1)(c) includes any act, expression, omission or concealment — whether in a deceitful manner or not — committed to induce another person to deal in securities, whether or not there is any wrongful gain. The definition is exhaustive — 10 sub-clauses enumerate specific fraudulent acts including: knowingly misrepresenting material facts (i); statements not believed to be true (ii); active concealment of material facts (iii); promises without intention to perform (iv); reckless representations (v); deceptive behaviour (vii); false statements (viii); fund diversion by issuers (ix); and price/volume manipulation (x). Differences from common law fraud: (i) PFUTP fraud does not require deceitfulness — 'whether in a deceitful manner or not'; (ii) no wrongful gain required — 'whether or not there is any wrongful gain'; (iii) covers omissions; (iv) covers reckless (not just deliberate) misstatements; (v) connivance/agency expressly covered. 'Fraudulent practice' under Regulation 2(1)(e) specifically includes: market manipulation, misleading appearances, creating false markets, impersonation, creating illusion of trading, and disseminating false information. In Prakash Gupta v. SEBI (SAT 2014), SAT confirmed that PFUTP fraud is wider than IPC cheating and SEBI's PFUTP action can proceed concurrently with criminal prosecution.

🎯 EXAM POINTERS — Topic 36: PFUTP Definitions [Regulation 2]

  • Regulation 2(1)(c) 'Fraud': ANY act/omission/concealment — whether deceitful or not — to induce dealing in securities.
  • KEY DIFFERENCES from common law fraud: NO deceit required; NO wrongful gain required; covers OMISSIONS; covers RECKLESS statements.
  • Regulation 2(1)(c)(ix): Issuer diverting IPO funds = FRAUD — express provision targeting post-IPO fund diversion.
  • Regulation 2(1)(c)(x): Price/volume manipulation = FRAUD — manipulation and fraud are connected in PFUTP.
  • Regulation 2(1)(e) 'Fraudulent Practice': (i) market manipulation; (ii) misleading appearance; (iii) false market; (iv) impersonation; (v) illusion of trading; (vi) false information.
  • Regulation 2(1)(g) 'Misleading Appearance': appearance not reflecting genuine supply and demand forces.
  • Regulation 2(1)(b) 'Connected Persons': directors, promoters, employees, auditors, CAs, CSs, bankers, advisers + anyone 'in a position to obtain UPSI'.
  • PFUTP fraud > IPC cheating — PFUTP covers reckless and omission-based conduct not covered by IPC.
  • Prakash Gupta v. SEBI (SAT 2014): PFUTP + IPC proceedings concurrent — double jeopardy not applicable.
  • Regulation 2(1)(c): '10 sub-clauses' — learn each individually as they are tested as separate MCQs.

← Topic 35: PFUTP Regulations 2003 — Introduction | Next → Topic 37: Prohibition under PFUTP [Regulations 3-4]

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