Description

SEBI Recovery Officer order in the matter of Four Season Farms Limited for recovery of Rs. 15.20 crore collected in violation of Collective Investment Schemes Regulations, 1999.

Summary

SEBI Recovery Officer issued Order No. 004/2025 dated November 7, 2025 under Recovery Certificate No. 0436 of 2014 in the matter of M/s Four Season Farms Limited. The order relates to recovery proceedings initiated to enforce SEBI’s February 13, 2002 directive requiring the company to refund Rs. 15.20 crore collected from investors in violation of SEBI (Collective Investment Schemes) Regulations, 1999, along with assured returns, interest, and costs.

Key Points

  • SEBI originally ordered Four Season Farms Limited to refund Rs. 15.20 crore collected illegally under CIS Regulations on February 13, 2002
  • Recovery Certificate No. 436 of 2014 was issued on September 19, 2014 after the defaulter failed to refund monies
  • Notice of Demand and Notices of Attachment issued on September 19, 2014 with 15-day payment deadline
  • Bank/demat accounts and mutual fund folios of the defaulter were attached
  • Prohibitory Order dated November 21, 2014 issued preventing disposal of all movable and immovable properties
  • Properties prohibited from transfer include: 17 flats in Vasundhara Building, Goregaon (East), Mumbai; 252.06 acres agricultural land in Mahad and Mangaon with cashew and teakwood trees; Prawns Hatchery Plant at Village Kothrude, Taluka Mahad, District Raigad
  • Applicant in this matter is Mr. Hanif Hussain Sumra
  • Four Season Farms Limited filed Appeal No. 62 of 2015 before Securities Appellate Tribunal claiming amounts already refunded under Maharashtra Protection of Interests of Depositors Act, 1999
  • SAT disposed of Appeal No. 62 of 2015 on August 4, 2016

Regulatory Changes

This order does not introduce new regulatory changes but enforces existing provisions under SEBI (Collective Investment Schemes) Regulations, 1999 and recovery provisions under Section 28A of SEBI Act, 1992 read with the Second Schedule to the Income-tax Act, 1961.

Compliance Requirements

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

  • Complete details of all movable and immovable properties and charges thereon (certified by Board of Directors) within one week
  • Copies of all title deeds and valuation reports of all properties within two weeks
  • List of all schemes floated with brochures/scheme information documents and activity details within two weeks
  • Complete list of all investors with contact details, bank details, investment amounts, and dues in each scheme (electronic and physical form) within one month

Important Dates

  • February 13, 2002: Original SEBI order directing refund of Rs. 15.20 crore
  • September 19, 2014: Recovery Certificate No. 436 of 2014 issued; Notice of Demand and Notices of Attachment issued
  • November 21, 2014: Prohibitory Order issued under Section 28A of SEBI Act, 1992
  • 2015: Appeal No. 62 of 2015 filed before Securities Appellate Tribunal
  • August 4, 2016: SAT disposed of Appeal No. 62 of 2015
  • November 7, 2025: Current Order No. 004/2025 issued

Impact Assessment

Investor Impact: High - Involves recovery of Rs. 15.20 crore collected from investors in violation of CIS regulations. Investors are awaiting refunds with assured returns and interest.

Company Impact: High - Four Season Farms Limited faces comprehensive asset attachment including 17 residential flats, 252.06 acres of agricultural land with plantations, and a prawns hatchery plant. All movable and immovable properties are under prohibitory orders preventing any disposal or transfer.

Market Impact: Medium - Demonstrates SEBI’s continued enforcement of CIS violations and commitment to investor protection through recovery proceedings spanning over two decades.

Legal Precedent: The matter shows the long-term nature of recovery proceedings and SEBI’s persistent efforts to recover investor funds even when companies claim alternative refund mechanisms under state laws like the Maharashtra MPID Act.

Impact Justification

Significant enforcement action involving Rs. 15.20 crore investor refund with property attachment and prohibitory orders against Four Season Farms Limited for CIS violations