Description

Recovery proceedings order against Four Season Farms Limited for refunding Rs. 15.20 crore collected in violation of SEBI Collective Investment Schemes Regulations, 1999.

Summary

SEBI Recovery Officer issued Order No. 003 of 2025 under Recovery Certificate No. 0436 of 2014 against M/s Four Season Farms Limited. The order relates to recovery proceedings for Rs. 15.20 crore collected by the company in violation of SEBI (Collective Investment Schemes) Regulations, 1999. The original SEBI order was passed on February 13, 2002, directing refund to investors with assured returns, interest, and costs.

Key Points

  • Recovery Certificate No. 0436 of 2014 was issued on September 19, 2014 against Four Season Farms Limited
  • Notice of Demand dated September 19, 2014 issued directing payment within 15 days
  • Bank/demat accounts and mutual fund folios of the defaulter were attached on September 19, 2014
  • Prohibitory Order dated November 21, 2014 issued prohibiting disposal, transfer, alienation or charging of all movable and immovable properties
  • Properties attached include 17 flats in Vasundhara Building, Mumbai; 252.06 acres of agricultural land in Mahad and Mangaon; and Prawns Hatchery Plant in Raigad
  • Defaulter challenged recovery proceedings in Appeal No. 62 of 2015 before Securities Appellate Tribunal
  • SAT disposed of Appeal No. 62 of 2015 on August 4, 2016

Regulatory Changes

No new regulatory changes. This order implements existing recovery provisions under Section 28A of SEBI Act, 1992 read with Rule 11 of the Second Schedule to the Income-Tax Act, 1961.

Compliance Requirements

The Prohibitory Order dated November 21, 2014 required Four Season Farms Limited to furnish:

  • Complete details of all movable and immovable properties with charges within one week
  • Copies of all title deeds and valuation reports within two weeks
  • List of all schemes floated with brochures and scheme documents within two weeks
  • Complete investor list with contact details, investment amounts, and dues within one month

Important Dates

  • February 13, 2002: Original SEBI order directing refund
  • September 19, 2014: Recovery Certificate issued, Notice of Demand issued, attachment notices issued
  • November 21, 2014: Prohibitory Order issued
  • August 4, 2016: SAT disposed of Appeal No. 62 of 2015
  • November 6, 2025: Current Order No. 003 of 2025 issued

Impact Assessment

This order has limited market-wide impact as it pertains to specific recovery proceedings against a single entity for violations dating back to 2002. The enforcement action demonstrates SEBI’s continued pursuit of recovery from defaulters under Collective Investment Schemes regulations. The case involves attachment of significant assets including real estate and agricultural land valued in crores. For investors in Four Season Farms schemes, this represents ongoing efforts to recover their funds, though recovery timeline remains uncertain given the multi-year nature of proceedings.

Impact Justification

High severity enforcement action but low market impact as it relates to a specific entity's recovery proceedings from 2002 violations. Medium importance for compliance precedent.