Description
Recovery order issued by SEBI against Four Season Farms Limited for refund of Rs. 15.20 crore collected in violation of Collective Investment Schemes Regulations, 1999, with proceedings against directors Jitendra Hiralal Mehtra and Pravinchandra Hiralal Mehtra.
Summary
SEBI Recovery Officer issued Order No. 007 of 2025 on November 10, 2025 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 M/s Four Season Farms Limited. The order relates to Recovery Certificate No. 0436 of 2014, with applicants Jitendra Hiralal Mehtra and Pravinchandra Hiralal Mehtra. The company was originally directed in February 2002 to refund Rs. 15.20 crore collected in violation of SEBI Collective Investment Schemes Regulations, 1999.
Key Points
- SEBI ordered Four Season Farms Limited to refund Rs. 15.20 crore collected illegally under CIS Regulations in February 2002
- Recovery proceedings initiated under Recovery Certificate No. 436 of 2014 dated September 19, 2014
- Notice of Demand and Notices of Attachment issued on September 19, 2014
- Bank/demat accounts and mutual fund folios of defaulter were attached
- Prohibitory Order issued on November 21, 2014 preventing disposal of all movable and immovable properties
- Properties include 17 flats in Vasundhara Building, Mumbai; 252.06 acres agricultural land in Mahad and Mangaon; and Prawns Hatchery Plant
- Defaulter challenged recovery proceedings in Appeal No. 62 of 2015 before Securities Appellate Tribunal
- SAT disposed of appeal on August 4, 2016
- Directors Jitendra Hiralal Mehtra and Pravinchandra Hiralal Mehtra are applicants in current proceedings
Regulatory Changes
No new regulatory changes introduced. This order enforces existing provisions under:
- SEBI (Collective Investment Schemes) Regulations, 1999
- Section 28A of SEBI Act, 1992
- Rule 11, Rule 16 and Rule 48 of the Second Schedule to the Income-Tax Act, 1961
Compliance Requirements
- Four Season Farms Limited prohibited from disposing, transferring, alienating or charging any immovable or movable properties
- Defaulter required to furnish complete details of all movable and immovable properties with charges within one week
- Title deeds and valuation reports for all properties to be submitted within two weeks
- List of all schemes floated with brochures and scheme information documents within two weeks
- Complete investor list with contact details, investment amounts, and amounts due within one month
- All documents to be certified by Board of Directors
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 preventing property disposal
- 2015: Appeal No. 62 of 2015 filed before Securities Appellate Tribunal
- August 4, 2016: SAT disposed of appeal
- November 10, 2025: Current Order No. 007 of 2025 issued
Impact Assessment
Investors: Significant impact on investors of Four Season Farms Limited who are owed Rs. 15.20 crore plus assured returns and interest. The ongoing recovery proceedings demonstrate SEBI’s commitment to investor protection, though recovery timeline has extended over two decades.
Company and Directors: Severe operational impact with all properties under prohibitory order. Directors Jitendra Hiralal Mehtra and Pravinchandra Hiralal Mehtra face continued enforcement action. Properties frozen include 17 Mumbai flats, 252+ acres agricultural land, and commercial assets.
Market: Limited broader market impact as this is an entity-specific enforcement action. However, serves as precedent for SEBI’s persistent pursuit of recovery even after extended periods, reinforcing deterrence against CIS violations.
Legal Precedent: Demonstrates effectiveness of recovery mechanisms under Section 28A of SEBI Act and coordination with Income-Tax Act provisions for asset attachment and recovery.
Impact Justification
Recovery order against a specific defaulter company for violations dating back to 2002. While significant for the company and its investors, has limited broader market impact. Demonstrates SEBI's continued enforcement of investor protection regulations.