Description

SEBI 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 recovery proceedings against Four Season Farms Limited for refund of Rs. 15.20 crore collected in violation of CIS Regulations.

Summary

SEBI Recovery Officer issued Order No. 006 of 2025 dated November 10, 2025 under Recovery Certificate No. 0436 of 2014 in the matter of M/s Four Season Farms Limited. The order pertains to recovery proceedings initiated against the company for failing to refund Rs. 15.20 crore collected from investors in violation of SEBI (Collective Investment Schemes) Regulations, 1999. The original SEBI order directing refund was issued on February 13, 2002. Recovery proceedings were formally initiated in September 2014, with notices of demand and attachment of bank/demat accounts. A Prohibitory Order was issued on November 21, 2014 prohibiting the defaulter from disposing of immovable and movable properties.

Key Points

  • Recovery Certificate No. 0436 of 2014 issued on September 19, 2014 against Four Season Farms Limited
  • Original SEBI order dated February 13, 2002 directed refund of Rs. 15.20 crore collected in violation of CIS Regulations, 1999
  • Notice of Demand issued on September 19, 2014 directing payment within 15 days
  • Bank/demat accounts and mutual fund folios attached via Notices of Attachment dated September 19, 2014
  • Prohibitory Order dated November 21, 2014 issued under Section 28A of SEBI Act, 1992 read with Rule 16 and 48 of Second Schedule of Income-Tax Act, 1961
  • Properties prohibited from disposal include 17 flats in Vasundhara Building, Goregaon (East), Mumbai; 252.06 acres agricultural land in Mahad and Mangaon with cashew and teakwood trees; and Prawns Hatchery Plant in Raigad
  • Defaulter challenged recovery proceedings in Appeal No. 62 of 2015 before Securities Appellate Tribunal
  • SAT disposed of appeal on August 4, 2016
  • Applicant: Mr. Radheshyam Sharma

Regulatory Changes

No new regulatory changes introduced. This is an enforcement order in ongoing recovery proceedings under existing provisions of Section 28A of SEBI Act, 1992 and Second Schedule of 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
  • Provide copies of all title deeds and valuation reports of all properties within two weeks
  • Submit list of all schemes floated with brochures/scheme information documents and details of activities within two weeks
  • Provide complete list of all investors with address, 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. 0436 of 2014 issued; Notice of Demand issued; Notices of Attachment issued
  • November 21, 2014: Prohibitory Order issued
  • August 4, 2016: Securities Appellate Tribunal disposed of Appeal No. 62 of 2015
  • November 10, 2025: Current Order No. 006 of 2025 issued

Impact Assessment

Market Impact: Minimal direct market impact as this relates to specific recovery proceedings against one defaulter company.

Investor Impact: Significant for investors of Four Season Farms Limited who are awaiting refund of Rs. 15.20 crore plus assured returns and interest. The continuing recovery proceedings demonstrate SEBI’s commitment to investor protection.

Operational Impact: Four Season Farms Limited remains subject to prohibitory orders preventing disposal of substantial assets including real estate properties (17 flats, 252+ acres agricultural land), hatchery operations, and other movable/immovable properties. The company’s ability to operate and dispose of assets is severely restricted pending resolution of recovery proceedings.

Enforcement Precedent: Demonstrates SEBI’s persistent enforcement action in CIS violations spanning over two decades, reinforcing deterrence against unauthorized collective investment schemes.

Impact Justification

Recovery order in ongoing enforcement proceedings against Four Season Farms Limited for CIS violations. Relates to historical case (2002 order) with continuing recovery efforts. Medium importance as it affects specific defaulter and applicant rather than broader market.