National Stock Exchange of India

Circular
Department: Investigation

Download Ref No: NSE/INVG/67548 Date: July 21, 2025

Circular Ref. No: 458/2025

To All NSE Members,

Sub: SEBI Order in respect of Big Bull trade(Proprietor - Mr. Rajesh Chauhan) .

This has reference to SEBI Order no. QJA/AA/NRO/NRO/31128/2024-25 dated

February 21, 2025 wherein, SEBI has restrained following entities from accessing the securities
market, directly or indirectly and are prohibited from buying, selling or otherwise dealing in the
securities market, directly or indirectly in any manner whatsoever, for a period of Two year from
the date of this order or till the expiry of two year from the date of completion of refunds to
complainants/ investors as directed in paragraph 41 (a) above, whichever is later;
Sr. No. Name PAN
1. Rajesh Chauhan AFBPC2226C

Further, SEBI has directed that during the period of restraint if the above entities have any open
position in any exchange traded derivative contracts, as on the date of this order, broker will
close out/ square off such open positions within 2 day from the date of order or at the expiry
of such contracts, whichever is earlier and will freeze demat account. These Noticees are not
permitted to settle the pay in and pay out obligations in respect of transactions,

The detailed order is available on SEBI website (https://www.sebi.gov.in).

Further, the consolidated list of such entities is available on the Exchange website
http://www.nseindia.com home page at the below mentioned link:
National Stock Exchange of India
Members are advised to take note of the above and ensure compliance.

In case of any further queries, members are requested to email us at dl-invsg-all@nse.co.in

For and on behalf of

National Stock Exchange of India Limited

Kamlesh Chandra Varshney

Senior Manager

Annexure: SEBI Order in respect of Big Bull trade (Proprietor - Mr. Rajesh Chauhan) .
 QJA/GR/WRO/WRO/31128/2024-25

SECURITIES AND EXCHANGE BOARD OF INDIA

ORDER

Under Section 11(1), 11(4), 11(4A), 11B(1) and 11B(2) of the Securities and
Exchange Board of India Act, 1992.

In respect of:

Sr. Name of the Noticee PAN

No.
1. Big Bull trade(Proprietor - Mr. Rajesh Chauhan) AFBPC2226C

In the matter of unregistered investment advisory services by Big Bull trade

(Proprietor - Mr. Rajesh Chauhan)

A. BACKGROUND OF THE CASE

1. Securities and Exchange Board of India (hereinafter referred to as “SEBI”)

had received a complaint dated February 15, 2025 on the SCORES portal against
a SEBI unregistered investment advisor called Big Bull trade, proprietorship of one
Mr. Rajesh Chauhan. Examination revealed that the aforesaid entity Big Bull trade
(hereinafter referred as the “Noticee”) was not registered with SEBI in any
capacity. Thus, examination was taken up separately against the Noticee.

2. The complainant had vide complaint dated February 15, 2025 alleged
that Noticee had lured the complainant into an investment plan and had forwarded
text messages of the whatsapp chats, screenshots of payments made therein to the
Noticee along with a copy of email received from the Noticee on various
investmentplan/s.

Order in the matter of BigBull.trade (Proprietor - Mr. Rajesh Chauhan) Page 1 of 16

3. Based on the examination of the complaint, it was prima facie observed that
the Noticee was engaged in providing guaranteed investment plan services to
investors without obtaining a certificate of registration from SEBI in violation of
Section 12(1) of the Securities and Exchange Board of India Act, 1992 (hereinafter
referred to as “SEBI Act”) read with Regulation 3(1) of the Securities and Exchange
Board of India (Investment Advisers) Regulations, 2013 (hereinafter referred to as
“IA Regulations”). Further, it was also observed that the Noticee promised
unrealistic gains and guaranteed returns through trading in the shares which is in
violation of Regulations 3(a), (b), (c) & (d) and 4(1), 4 (2)(k) and 4(2)(s) of the
Securities and Exchange Board of India (Prohibition of Fraudulent and Unfair Trade
Practices relating to Securities Market) Regulations, 2003 (hereinafter referred to as
“PFUTP Regulations”) read with Section 12A (a), (b) and (c) of the SEBI Act.

B. SHOW CAUSE NOTICE, REPLY AND HEARING

4. A Show Cause Notice dated February 21, 2025 (hereinafter referred to as

“SCN”) was issued to the Noticee calling upon him to show cause as to why suitable
directions including direction for refund of fees/monies collected from the investors
and debarment from securities market should not be issued against the Noticee
under sections 11(1), 11(4), 11(4A),11B(1) and 11B(2) of the SEBI Act. The Noticee
was further called upon to show cause as to why suitable penalty under section
15EB and 15HA of SEBI Act should also not be imposed upon the Noticee for the
violations mentioned in the SCN.

5. The SCN contained the following observations and allegations against the
Noticee:
5.1. The complainant had vide complaint dated February 15, 2025 submitted the
following:
“I have received couple of whatsapp messege mentioning that they are from
BigBull.trade. They have sent me whatsapp messege luring me into an investment
plan I lately realized I got spoofed of the investment plan and its totally fraud.
Please be kind resolve my complaint also please help other people like me so that
these guys are caught and returned their money. Also I have shared my personal
details please see they have no misused the details.”

Order in the matter of BigBull.trade (Proprietor - Mr. Rajesh Chauhan) Page 2 of 16

5.2. From the analysis of the Account Opening Form, KYC documents and
account statements, it was observed that the bank account was opened in
the name of the Noticee viz. Rajesh Chauhan. The bank account was
opened on December 05, 2001. It was observed that various credit entries
were received into the State Bank of india account number
00010089157319 from November 01, 2024 to February 24, 2025.

5.3. It was observed that there were a total of 40 credit transactions constituting a
total amount of Rs 15,94,233/- in the bank account of the Noticee. Out of the
above credit transactions, 27 such credit transactions amounting to
Rs.12,60,000/- contained narrations having keywords such as ‘stock’,
‘investment, ‘trade’, etc. The sample of credit transactions having clear
narrations are reproduced as under for reference:

Txn Date Description Credit Balance

25 Nov BY TRANSFER- 60,000.00 61,875.34

2024 UPI/CR/933167118303/MITHL
ESH/SBIN/9098132006/Payme-
14 Dec BY TRANSFER- 1,00,000.00 1,00,167.16
2024 UPI/CR/151601652470/MsKIR
ANS/ALLA/8115300723/NO RE
-
15 Dec BY TRANSFER- 80,000.00 1,71,338.16
2024 UPI/CR/787850644679/PRADE
EP /BARB/9424487893/Payme-
20 Dec BY TRANSFER- 10,000.00 16,327.34
2024 UPI/CR/473221341613/NEERA
J K/PUNB/neerajmish/Payme-
20 Dec BY TRANSFER- 40,000.00 56,327.34
2024 UPI/CR/805887387101/KRISH
NA /ESFB/krishnagou/Payme-
27 Dec BY TRANSFER- 14,000.00 17,492.34
2024 UPI/CR/772576020259/RAJES
H K/SBIN/intratrade/Payme-

28 Dec BY TRANSFER- 50,000.00 53,492.34

2024 UPI/CR/687853118620/RAGHU
WAR/SBIN/7509973013/Payme
-
29 Dec BY TRANSFER- 20,000.00 73,492.34
2024 UPI/CR/317265328021/RAGHU
WAR/SBIN/7509973013/Payme
-
29 Dec CSH DEP (CDM)- 50,500.00 1,23,992.34
2024 CDM1040103BANDNA HOTEL
SAGAR MP IN-
31 Dec BY TRANSFER- 10,000.00 13,312.34
2024 UPI/CR/079428267239/MITHL
ESH/SBIN/9098132006/niraj-
Order in18the
Jan BY TRANSFER-
matter of BigBull.trade (Proprietor1,00,000.00
- Mr. Rajesh 1,02,753.16
Chauhan) Page 3 of 16
2025 UPI/CR/831667922538/UDAY
BHA/SBIN/9753505425/Payme-
18 Jan BY TRANSFER- 80,000.00 1,82,754.16
2025 UPI/CR/501810556135/PRAVE
EN /PUNB/9783913679/Sent-
19 Jan BY TRANSFER- 20,000.00 53,254.16
2025 UPI/CR/501905597768/PRAVE
 Txn Date Description Credit Balance

28 Dec BY TRANSFER- 50,000.00 53,492.34

2024 UPI/CR/687853118620/RAGHU
WAR/SBIN/7509973013/Payme
-
29 Dec BY TRANSFER- 20,000.00 73,492.34
2024 UPI/CR/317265328021/RAGHU
WAR/SBIN/7509973013/Payme
-
29 Dec CSH DEP (CDM)- 50,500.00 1,23,992.34
2024 CDM1040103BANDNA HOTEL
SAGAR MP IN-
31 Dec BY TRANSFER- 10,000.00 13,312.34
2024 UPI/CR/079428267239/MITHL
ESH/SBIN/9098132006/niraj-
18 Jan BY TRANSFER- 1,00,000.00 1,02,753.16
2025 UPI/CR/831667922538/UDAY
BHA/SBIN/9753505425/Payme-
18 Jan BY TRANSFER- 80,000.00 1,82,754.16
2025 UPI/CR/501810556135/PRAVE
EN /PUNB/9783913679/Sent-
19 Jan BY TRANSFER- 20,000.00 53,254.16
2025 UPI/CR/501905597768/PRAVE
EN /PUNB/9783913679/Sent-
18 Feb BY TRANSFER- 50,000.00 56,653.16
2025 UPI/CR/666322949033/MITHL
ESH/SBIN/9098132006/Payme
18 Feb -BY TRANSFER- 20,000.00 76,653.16
2025 UPI/CR/936744118286/Dheera
nd/SBIN/9098132006/Payme-
18 Feb BY TRANSFER- 10,000.00 86,653.16
2025 UPI/CR/648189679855/MITHL
ESH/KKBK/7987899804/Paym
e
-
5.4. In light thereof, the SCN has alleged the entire credit entries of Rs
12,60,000 received in the account of the Noticee as investment by the
Noticee for providing guaranteed investment plan services.

5.5. Further, from the Noticee’s whatsapp messege dated February 13, 2025
addressed to the complainant, the Noticee was observed to be making the
following assurances and promises along with the claims of assured returns,
as under:
“investment amount : 1lac
(Guaranteed return)”: 1% daily
No of Payout : every Saturday

6. The SCN dated February 21, 2025 was issued to the Noticee by Speed
Post with Acknowledgement Due (SPAD) at the following two addresses of the
Noticee available on record namely - (1) Rajesh Chauhan S/o Narendra singh

Order in the matter of BigBull.trade (Proprietor - Mr. Rajesh Chauhan) Page 4 of 16

Chauhan, Chauhan Computer, First Floor, Nagar Nigam Market, Gujrati Bazar,
Sagar District Sagar, Madhya Pradesh – 470002.

7. The Noticee was granted 30 days’ time to file his reply to the SCN from the
date of receipt of the SCN. Thereafter, an opportunity of personal hearing will
granted to the Noticee.

8. In this regard, the Hon’ble Securities Appellate Tribunal (SAT) in the matter
of Dave Harihar Kirtibhai vs SEBI (Appeal No. 181 of 214 dated December 19, 2014),
observed as under: “...further, it is being increasingly observed by the Tribunal that
many persons/entities do not appear before SEBI (Respondent) to submit reply to SCN or,
even worse, do not accept notices/letters of Respondent and when orders are passed
ex-parte by Respondent, appear before Tribunal in appeal and claim non-receipt of
notice and do not appear and/or submit reply to SCN but claim violation of principles of
natural justice due to not being provided opportunity to reply to SCN or not provided
personal hearing. This leads to unnecessary and avoidable loss of time and resources on
part of all concerned and should be eschewed, to say the least. Hence, this case is being
decided on basis of material before this Tribunal..

Order in the matter of BigBull.trade (Proprietor - Mr. Rajesh Chauhan) Page 5 of 16

C. CONSIDERATION OF ISSUES AND FINDINGS

9. Before dealing with the alleged violation in the extant matter, it would be
appropriate to first refer to the relevant provisions of the SEBI Act, IA Regulations
and the PFUTP Regulations. The relevant extracts of these provisions are as under:

SEBI Act –

REGISTRATION CERTIFICATE
Registration of stock brokers, sub-brokers, share transfer agents, etc.
12. (1) No stock broker, sub-broker, share transfer agent, banker to an issue, trustee of trust
deed, registrar to an issue, merchant banker, underwriter, portfolio manager, investment
adviser and such other intermediary who may be associated with securities market shall
buy, sell or deal in securities except under, and in accordance with, the conditions of a
certificate of registration obtained from the Board in accordance with the regulations made
under this Act:

PROHIBITION OF MANIPULATIVE AND DECEPTIVE DEVICES, INSIDER

TRADING AND SUBSTANTIAL ACQUISITION OF SECURITIES OR CONTROL
Prohibition of manipulative and deceptive devices, insider trading and substantial
acquisition of securities or control.
12A. No person shall directly or indirectly—
(a) use or employ, in connection with the issue, purchase or sale of any securities listed or
proposed to be listed on a recognized stock exchange, any manipulative or deceptive device
or contrivance in contravention of the provisions of this Act or the rules or the regulations
made thereunder;
(b) employ any device, scheme or artifice to defraud in connection with issue or dealing in
securities which are listed or proposed to be listed on a recognised stock exchange;
(c) engage in any act, practice, course of business which operates or would operate as fraud
or deceit upon any person, in connection with the issue, dealing in securities which are listed
or proposed to be listed on a recognised stock exchange, in contravention of the provisions
of this Act or the rules or the regulations made thereunder;

IA Regulations –

REGISTRATION OF INVESTMENT ADVISERS

Application for grant of certificate.3.(1) On and
from the commencement of these regulations, no
person shall act as an investment adviser or hold
itself out as an investment adviser unless he has
obtained a certificate of registration from the Board
under these regulations:

PFUTP Regulations –
PROHIBITION OF FRAUDULENT AND UNFAIRTRADE PRACTICESRELATING
TO THE SECURITIES MARKET
3. Prohibition of certain dealings in securities
No person shall directly or indirectly—
Order in the matter of BigBull.trade (Proprietor - Mr. Rajesh Chauhan) Page 6 of 16
(a) buy, sell or otherwise deal in securities in a fraudulent manner;
(b) use or employ, in connection with issue, purchase or sale of any security listed or
proposed to be listed in a recognized stock exchange, any manipulative or deceptive device
or contrivance in contravention of the provisions of the Act or the rules or the regulations
made there under;
(c) employ any device, scheme or artifice to defraud in connection with dealing in or issue
of securities which are listed or proposed to be listed on a recognized stock exchange;
(d) engage in any act, practice, course of business which operates or would operate as
fraud or deceit upon any person in connection with any dealing in or issue of securities
which are listed or proposed to be listed on a recognized stock exchange in contravention
of the provisions of the Act or the rules and the regulations made there under.

4. Prohibition of manipulative, fraudulent and unfair trade practices

(1) Without prejudice to the provisions of regulation 3, no person shall indulge in a
manipulative, fraudulent or an unfair trade practice in securities markets. [Explanation.–
For the removal of doubts, it is clarified that any act of diversion, misutilisation
or siphoning off of assets or earnings of a company whose securities are listed or any
concealment of such act or any device, scheme or artifice to manipulate the books of
accounts or financial statement of such a company that would directly or indirectly
manipulate the price of securities of that company shall be and shall always be deemed to
have been considered as manipulative, fraudulent and an unfair trade practice in the
securities market.]
(2) Dealing in securities shall be deemed to be a manipulative fraudulent or an unfair trade
practice if it involves any of the following: —
…..
(k) disseminating information or advice through any media, whether physical or digital,
which the disseminator knows to be false or misleading in a reckless or careless manner and
which is designed to, or likely to influence the decision of investors dealing in securities;
….
(s) mis-selling of securities or services relating to securities market;
[Explanation- For the purpose of this clause, “mis-selling” means sale of securities or
services relating to securities market by any person, directly or indirectly, by─
(i) knowingly making a false or misleading statement, or
(ii) knowingly concealing or omitting material facts, or
(iii) knowingly concealing the associated risk, or
(iv) not taking reasonable care to ensure suitability of the securities or service to the
buyer];

Order in the matter of BigBull.trade (Proprietor - Mr. Rajesh Chauhan) Page 7 of 16

10. I have carefully considered the allegation levelled against the Noticee in the
SCN and other relevant documents as available on record. I find that the following
issues emerge for consideration in the present matter:
Issue No. I - Whether the Noticee acted as an unregistered Investment
Advisor in contravention of Section 12(1) of the SEBI Act read with Regulation 3(1)
of the IA Regulations?
Issue No. II - Whether the acts of the Noticee attract the prohibition under
Regulations 3(a), (b), (c) & (d) and 4(1), 4 (2)(k) and 4(2)(s) of the PFUTP
Regulations read with Section 12A (a), (b) and (c) of the SEBI Act?
Issue No. III - If the issue(s) framed above are in affirmative, the directions and/or
penalty that may be levied against the Noticee.

Issue No. I - Whether the Noticee acted as an unregistered Investment

Advisor in contravention of Section 12(1) of the SEBI Act read with Regulation
3(1) of the IA Regulations?

11. Regulation 2(1)(m) of the IA Regulations defines the term ‘investment

adviser’ to mean any person, who is engaged in the business of providing
investment advice to clients or other person or group of persons for consideration.
Further, it includes any person who holds himself out as an ‘investment adviser’. As
Regulation 2(1)(m) of the IA Regulations refer to terms ‘consideration’ and
‘Investment advice’, as per Regulation 2(1)(g) of the IA Regulations, consideration
means any form of economic benefit including non-cash benefit, received or
receivable for providing investment advice. Under Regulation 2(1)(l) of the IA
Regulations, ‘investment advice’ means advice relating to investing in, purchasing,
selling or otherwise dealing in securities or investment products and advice on
investment portfolio containing securities or investment products, whether written,
oral or through any other means of communication for the benefit of the client and
shall include financial planning. However, advice given through newspaper,
magazines, any electronic or broadcasting or telecommunications medium, which
is widely available to the public, shall not be an investment advice within the
meaning of Regulation 2(1)(l) of the IA Regulations.

Order in the matter of BigBull.trade (Proprietor - Mr. Rajesh Chauhan) Page 8 of 16

12. In the extant matter, on perusal of the complaint dated February, 15, 2025
and the copy of the whatsapp screenshot enclosed by the complainant, it is clear
that the Noticee was holding himself out to be an investment advisor and offering his
gauranteed investment plan services through various investment plans. Further,
from the credit transactions observed in the Noticee’s State Bank of India Bank
account number 00010089157319, it is noted that 27 credit entries were made from
different sources constituting a total amount of Rs 12,60,000. Examination has also
revealed that various credit transactions amounted to narrations having keywords
such as ‘stock’, ‘investment,‘trade’, etc. From the aforesaid facts, I find that the
Noticee was engaged in giving investment products in lieu of consideration. The
Noticee has to made any submissions to prove that these funds were earned from
other source of income.

13. In order to protect the interest of investors and to preserve the integrity of
the securities market, IA Regulations have been framed by SEBI to provide various
safeguards to ensure that the interest of the investors who receive investment
advice, are protected. One such safeguard provided under the said regulations
is that any person carrying out investment advisory activities has to first obtain
a certificate of registration from SEBI as mandated under Regulation 3(1) of the IA
Regulations, which, inter alia, provides that, no person shall act as an Investment
Adviser or hold itself out as an Investment Adviser, unless he has obtained a
certificate of registration from SEBI and it has to conduct its activities in accordance
with the provisions of IA Regulations. Further safeguards provided under IA
Regulations include continued minimum professional qualification and compliance
with net-worth requirement for acting as an Investment Adviser, prior disclosure of
all conflicts of interest, prohibition on the Investment Advisor from entering into
transactions in securities himself, which are contrary to the advice given to the
clients at least for 15 days from the date of giving such advice to the clients,
mandatory risk profiling of investors, maintaining documented process for
selecting investment products for clients based on client’s investment objective and
risk profile and understanding of the nature and risks of products or assets selected

Order in the matter of BigBull.trade (Proprietor - Mr. Rajesh Chauhan) Page 9 of 16

for such client, etc. In order to ensure protection of investors’ interest who desire to
receive investment advice from various Investment Advisors, it is imperative that
any person carrying out investment advisory activities has to necessarily obtain a
certificate of registration from SEBI and has to conduct its activities in accordance
with the provisions of the relevant regulations under the SEBI Act.

14. In the extant matter, I note that the Noticee acted as an Investment Advisor,
while not registered with SEBI in the capacity of an Investment Advisor. Hence, the
activities of the Noticee are in violation of Section 12(1) of the SEBI Act read with
Regulation 3(1) of the IA Regulations.

Issue No. II - Whether the acts of the Noticee attract the prohibition under
Regulations 3(a), (b), (c) & (d) and 4(1), 4 (2)(k) and 4(2)(s) of the PFUTP
Regulations read with Section 12A (a), (b) and (c) of the SEBI Act?

15. Regulation 3 of PFUTP Regulations prohibits certain dealings in securities

wherein manipulative or deceptive methods are used, or any entity employs any
devise or scheme or artifice to defraud in connection with dealing in or issuing
securities and also engage in any act, practice, course of business which operate
as fraud or deceit upon any person in connection any dealing in or issue of
securities. Regulation 4(2)(k) of PFUTP Regulations provides that dealing in
securities shall be deemed to be a manipulative fraudulent or an unfair trade
practice if it involves disseminating information or advice through any media,
whether physical or digital, which the disseminator knows to be false or misleading
and which is designed or likely to influence the decision of investors dealing in
securities. Regulation 4(2)(s) of the PFUTP Regulations prohibits mis-selling of
securities or services related to securities market. Mis-selling has further been
explained in the said Regulations to mean knowingly making false or misleading
statements or not taking reasonable care to ensure suitability of the securities or
services to the buyer.

16. I note from the Noticee’s sent whatsapp dated February 13, 2025
addressed to the complainant that the Noticee offered various packages for
investment and under such packages the Noticee assured profit return of 1% daily

Order in the matter of BigBull.trade (Proprietor - Mr. Rajesh Chauhan) Page 10 of 16

of the capital invested. The Noticee had further guaranteed minimum of 1% return
on the capital invested.

17. In this context, I draw reference to the Order of the Hon’ble Securities
Appellate Tribunal (hereinafter referred to as ‘SAT’) in the matter of 24 Carat
Financial Services vs. SEBI decided on January 18, 2023. The Hon’ble SAT while
adjudicating the matter, held as follows: “...Further guaranteed returns were promised
quoting profit percentage or certain amount either monthly or on a daily basis. The action
of promising guaranteed returns is patently against the principles of the securities market
and not only manipulative but also fraudulent and violative of Regulations 3 and 4 of the
PFUTP Regulations...”

18. Drawing parallel from the aforesaid Order of Hon’ble SAT, I note that the
act of promising assured returns is a misrepresentation of the truth. Neither there
exist any grounds for belief of such returns nor can the assured returns be achieved
with any certainty. Such false statement cannot be made without reasonable ground
for believing it to be true. The scheme employed by the Noticee to induce
unsuspecting investors to deal in recommended stocks by guaranteeing assured
returns is fraudulent in nature. The same was done with the sole purpose of
influencing the decision of the prospective clients to avail the services of the
Noticee.

19. In view of the forgoing paragraphs, I conclude that the Noticee has violated
Regulations 3(a), (b), (c) & (d) and 4(1), 4 (2)(k) and 4(2)(s) of the PFUTP
Regulations read with Section 12A (a), (b) and (c) of the SEBI Act.

Issue No. III – In case the issue(s) framed above are in affirmative, the
directions and/or penalty that may be levied against the Noticee.

20. SEBI has a statutory duty to protect the interests of investors in securities
and promote the development of, and to regulate, the securities market. Section 11
of the SEBI Act has empowered it to take such measures as it thinks fit for fulfilling
its legislative mandate. The PFUTP Regulations and the IA Regulations have been

Order in the matter of BigBull.trade (Proprietor - Mr. Rajesh Chauhan) Page 11 of 16

formulated with the main objective of regulating such activities to safeguard the
interests of investors and hence registration of such activities with SEBI has been
made mandatory. The IA Regulations, inter alia, seek to create a structure within
which investment advisers will operate and also make them duly accountable for
their investment advice by requiring investment advisers to comply with the criteria
set out in the relevant provisions of the IA Regulations. The same is imperative for
the protection of interests of investors and to safeguard the integrity of the securities
market. In the instant case, the Noticee has provided investment advice prima facie,
without having the requisite registration/ certification as mandated under the IA
Regulations.

21. I note that the SCN had called upon the Noticee to show cause as to why
suitable directions including direction for refund of fees/monies collected from the
investors and debarment from securities market should not be issued against the
Noticee under sections 11(1), 11(4), 11(4A),11B(1) and 11B(2) of the SEBI Act,
1992. Further, the Noticee is called upon to show cause as to why suitable penalty
under section 15EB and 15HA of SEBI Act, 1992 should not be imposed upon the
Noticee for the violations levied in the SCN.

22. The relevant provisions of Section 15EB and 15HA of the SEBI Act are
reproduced as under: -
Penalty for default in case of investment adviser and research analyst.
15EB. Where an investment adviser or a research analyst fails to comply with the
regulations made by the Board or directions issued by the Board, such investment
adviser or research analyst shall be liable to penalty which shall not be less than one
lakh rupees but which may extend to one lakh rupees for each day during which such
failure continues subject to a maximum of one crore rupees.

Penalty for fraudulent and unfair trade practices.

15HA. If any person indulges in fraudulent and unfair trade practices relating to
securities, he shall be liable to a penalty which shall not be less than five lakh rupees
but which may extend to twenty-five crore rupees or three times the amount of profits
made out of such practices, whichever is higher

23. Section 15J of the SEBI Act provides for factors which are required to be
considered for adjudging quantum of penalty. The provision of Section 15J is as
follows:

Order in the matter of BigBull.trade (Proprietor - Mr. Rajesh Chauhan) Page 12 of 16

 Factors to be taken into account while adjudging quantum of penalty.
15J. While adjudging quantum of penalty under 15-I or section 11 or section 11B, the
Board or the adjudicating officer shall have due regard to the following factors,
namely: —
(a) the amount of disproportionate gain or unfair advantage, wherever quantifiable,
made as a result of the default;
(b) the amount of loss caused to an investor or group of investors as a result of the
default;
(c) the repetitive nature of the default.”
Explanation. —For the removal of doubts, it is clarified that the power to adjudge the
quantum of penalty under sections 15A to 15E, clauses (b) and (c) of section 15F, 15G,
15H and 15HA shall be and shall always be deemed to have been exercised under the
provisions of this section.

24. From the findings above, the Noticee has provided g u a r a n t e e d

investment plan services without holding the certificate of registration from SEBI
which is in violation of Regulation 3(1) of the IA Regulations read with Section 12(1)
of the SEBI Act. Further, the Noticee has also indulged in fraudulent activities of
guaranteeing assured returns thereby violating Regulations 3(a), (b), (c) & (d) and
4(1), 4 (2)(k) and 4(2)(s) of the PFUTP Regulations read with Section 12A (a), (b)
and (c) of the SEBI Act. I therefore find the Noticee liable for penalty under Section
15EB and 15HA of the SEBI Act.

25. As detailed in paragraph 12 of the order, the Noticee had received/collected

a total amount of Rs. 12,60,000/- (Rupees Twelve lakh sixty thousand only) in
its bank. in addition to monetary penalties which are attracted under Sections
15EB and 15HA of the SEBI Act.

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D. DIRECTIONS:

26. In view of the foregoing, I, in exercise of the powers conferred upon me in

terms Sections 11(1), 11(4), 11(4A), 11B (1) and 11B (2) of the SEBI Act read with
Section 19 of the SEBI Act, do hereby issue the following directions:

26.1. The Noticee is prohibited from selling his assets, properties including mutual
funds/shares/securities held by him in demat and physical form. Further, the
banks are directed to not allow debit from the bank accounts of the Noticee.

26.2. T h e Noticee shall file a report with SEBI addressed to the “Division Chief,
Division of Post-Inspection Enforcement Action, Market Intermediaries
Regulation and Supervision Department, SEBI Bhavan II, Plot No. C7, G
Block, Bandra Kurla Complex, Bandra (East) Mumbai –400051”, within a
period of 30 days
26.3 The Noticee is debarred from accessing the securities market, directly or
indirectly and prohibited from buying, selling or otherwise dealing in the
securities market, directly or indirectly in any manner whatsoever, for a
period of two (2) years from the date of this order or till the date of filing of
report, as directed in sub-paragraph 30.5 above, whichever is later;
26.4. The Noticee shall not undertake, either during or after the expiry of the period
of restraint and prohibition, either directly or indirectly, investment advisory
services or any activity in the securities market without obtaining a certificate
of registration from SEBI as required under the securities laws;
26.5. The Noticee is hereby imposed with penalty of Rs. 1,00,000/- (Rupees One
Lakh Only) under Section 15EB of the SEBI Act and Rs. 2,00,000/- (Rupees
Five Lakh Only) under Section 15HA of the SEBI Act;
26.6. The Noticee shall remit / pay the said amount of penalty, within a period of
sixty (60) days from the date of receipt of this order.

Order in the matter of BigBull.trade (Proprietor - Mr. Rajesh Chauhan) Page 14 of 16

27. This order shall come into force with immediate effect.
28. A copy of this order shall be sent to the Noticee, Stock Exchanges, BSE
Administration and Supervision Ltd (BASL), Depositories, Banks, Registrar and
Transfer Agents for information and compliance of the above directions.

Sd/-
Date: February 24, 2025 G RAMAR
Place: Mumbai CHIEF GENERAL MANAGER
SECURITIES AND EXCHANGE BOARD OF INDIA

Order in the matter of BigBull.trade (Proprietor - Mr. Rajesh Chauhan) Page 15 of 16