Description

Recovery Officer order under Rule 11 of the Second Schedule to the Income-Tax Act, 1961 read with Section 28A of the SEBI Act, 1992 in the matter of Four Season Farms Limited's refund of Rs. 15.20 crore collected in violation of CIS Regulations.

Summary

SEBI’s Recovery Officer issued Order No. 005 of 2025 dated November 7, 2025 under Rule 11 of the Second Schedule to the Income-Tax Act, 1961 read with Section 28A of the SEBI Act, 1992 in ongoing recovery proceedings against M/s Four Season Farms Limited. The company was originally directed by SEBI on February 13, 2002 to refund Rs. 15.20 crore collected in violation of SEBI (Collective Investment Schemes) Regulations, 1999 along with assured returns, interest, and costs to investors.

Key Points

  • Recovery Certificate No. 436 of 2014 was issued on September 19, 2014 against Four Season Farms Limited as defaulter
  • Original SEBI order dated February 13, 2002 directed refund of Rs. 15.20 crore collected in violation of CIS Regulations
  • Notice of Demand issued on September 19, 2014 with 15-day payment deadline
  • Bank/demat accounts and mutual fund folios of the defaulter were attached on September 19, 2014
  • Prohibitory Order dated November 21, 2014 prohibited the defaulter from disposing, transferring, alienating or charging immovable and movable properties
  • Properties prohibited from transfer include: 17 flats in Vasundhara Building, Mumbai; 252.06 acres of agricultural land in Mahad and Mangaon; Prawns Hatchery Plant in Raigad
  • Defaulter challenged recovery proceedings in Appeal No. 62 of 2015 before Securities Appellate Tribunal
  • SAT disposed of the appeal on August 4, 2016
  • Applicant: Ms. Siprapadma Mohopatra

Regulatory Changes

No new regulatory changes introduced. This order relates to enforcement of existing SEBI (Collective Investment Schemes) Regulations, 1999 and recovery proceedings under Section 28A of SEBI Act, 1992.

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, 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 documents and details of activities within two weeks
  • Complete list of all investors with contact details, bank details, investment amounts, and amounts due in 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 issued; Bank/demat accounts attached
  • November 21, 2014: Prohibitory Order issued preventing disposal of properties
  • 2015: Appeal No. 62 of 2015 filed by defaulter before SAT
  • August 4, 2016: SAT disposed of Appeal No. 62 of 2015
  • November 7, 2025: Order No. 005 of 2025 issued by Recovery Officer

Impact Assessment

This recovery order impacts investors of Four Season Farms Limited who are owed refunds of Rs. 15.20 crore plus assured returns and interest for amounts collected in violation of CIS Regulations. The ongoing recovery proceedings since 2014 demonstrate SEBI’s continued efforts to recover investor funds through attachment of properties and bank accounts. The order has limited broader market impact but is significant for affected investors and serves as a precedent for SEBI’s enforcement capabilities in CIS violation cases. The prohibitory order on substantial assets (17 flats, 252+ acres land, hatchery plant) indicates the scale of the defaulter’s operations and SEBI’s comprehensive approach to asset recovery.

Impact Justification

Recovery proceedings against a specific defaulter company for CIS violations. Limited broader market impact but significant for affected investors seeking refunds.