Sources: SEBI Interim Order 28-Feb-2024, SEBI Confirmation Order 30-Jul-2024, Business Standard, Moneylife, Taxguru, V-Marc Annual Secretarial Compliance Report FY26 (19-May-2026), screener.in
⛔ This card carries the v2 Principle 5 HARD STOP. Two material regulatory orders are open against V-Marc's Promoter Chairman/MD Vikas Garg and 13 other connected entities, in V-Marc's own shares.
SEBI matter — full chronology
Date
Event
9-Apr-2021
V-Marc lists on NSE-SME at ₹39 (face value ₹10)
9-30 Apr 2021
Period of alleged price-volume manipulation (22-day window post-listing)
21-Sep-2022
SEBI complaint filed — surveillance-triggered alert
May-2022
SEBI search · Prijesh Kurani's mobile seized containing WhatsApp + signed agreement
28-Feb-2024
SEBI Interim Order — 14 entities banned, ₹6.38 Cr wrongful gains impounded
May-2024
Vikas Garg appealed to Securities Appellate Tribunal (SAT)
May-2024
SAT directed SEBI to issue confirmatory order within 4 weeks (extended to 30-Jul-2024)
30-Jul-2024
SEBI Confirmation Order — order affirmed with modifications; wrongful gains revised to ₹6.30 Cr
2024 → 2025 → 2026
Matter sub judice in SAT
19-May-2026
V-Marc's FY26 Annual Secretarial Compliance Report: "no non-compliance; promoter SEBI matter remains sub judice"
14 noticees named in the SEBI order
Noticee
Role
Modified liability
Vikas Garg
Promoter, Chairman, MD — "devised and orchestrated a scheme for price-volume manipulation"
Jointly/severally liable with Aggarwal, Gupta, Singhal
Sandeep Srivastava
Former Whole-Time Director · facilitated fund transfers · resigned Feb-2022
—
Prijesh Kurani
Market operator engaged "to operate the market"
—
Sudhir Gupta
IPO subscriber + post-listing funder
₹1.89 Cr
Surbhi Aggarwal
Volume / price manipulator
₹3.53 Cr
Rekha Kurani
Connected entity
₹87.74 lakh
Jai Kishorr Singhal
Post-listing funder
₹7.82 lakh (deposited)
Dharini Kurani
IPO subscriber creating artificial volume
—
Pratik Madhukar Sheth
Pre-IPO private placement 8.40 lakh shares + family IPO subs
17.63% of total trading volume (3.03 lakh shares traded among manipulators)
Self-trade price impact
22 self-trades pushed price up by ₹40.60 = 35.41% of gross positive price movement
Connected-entity IPO allocation
30.70% of IPO (18.42 lakh of 60 lakh shares) — suggests pre-planned scheme
Pattern after manipulation
"Six connected entities completely sold holdings; shares offloaded to retail investors oblivious of the manipulative scheme"
Key quotes from SEBI's order
"When promoters such as Vikas Garg themselves indulge in cynical and egregious manipulation...they are striking at the core trust of investors."
"The entire initial public offering of V Marc itself has come under a cloud of suspicion warranting further investigation."
"The promoter and management...devised a scheme prior to listing...orchestrated fraudulent activity of manipulation of volume and price" enabling "sale of shares at inflated prices to unsuspecting investors."
Evidence base
WhatsApp chats from Prijesh Kurani's mobile (seized May-2022) — included a copy of a signed agreement between parties to manipulate price
BENPOS (Beneficial Position Statement) shared with operator showing post-listing shareholder distribution
Pre-listing meeting minutes (Figure 4 of SEBI order) showing Richr Business Services designated as market maker
Trade records — self-trades, pre-arranged off-market deals
Other litigation
Company-level: NO other material litigation disclosed publicly
Tax / regulatory disputes at company level: Not surfaced in this run
Audit qualifications: Annual Secretarial Compliance Report FY26 = "no non-compliance"
Auditor opinion: Not directly captured (deferred to AR deep read)
v2 Principle 5 application
Principle 5 (preserved from v1 in v2):
"Non-ethical = exit — Lawsuit, fraud, regulatory action with material consequence = IMMEDIATE EXIT. No second chances. Hard rule."
V-Marc satisfies every element:
✅ Regulatory action: SEBI order, India's apex market regulator
✅ Material consequence: ₹6.30 Cr wrongful gains impounded; market ban; "cloud over IPO itself"
✅ The promoter is the architect, not a tangential party
✅ The fraud was in V-Marc's own shares, not a parallel business activity
✅ It is not behind us — matter is sub judice in SAT; no exoneration
Sub-judice status does NOT soften the rule. The framework's design is "no second chances" — the rule applies as long as the matter is unresolved against the company.