A) Context: SEBI’s Interim Order Sends Shockwaves

On April 15, 2025, the Securities and Exchange Board of India (SEBI) issued a detailed interim order exposing large-scale financial irregularities and corporate governance lapses at Gensol Engineering Limited. The order named Anmol Singh Jaggi and Puneet Singh Jaggi, the promoters of Gensol, for alleged misappropriation of public funds, diversion of loans, and misleading disclosures.

These two individuals are also key stakeholders in Matrix Gas and Renewables Ltd, an unlisted company whose shares are actively traded in the private market.

B) Key Allegations Against the Jaggi Brothers

SEBI’s 29-page order outlines a comprehensive pattern of:

• Diversion of ₹262 Cr+ loan proceeds, meant for EV procurement, to promoter-related entities

• Creation of fake documents to mislead credit rating agencies and investors

• Use of funds for personal expenses, including luxury real estate and foreign currency purchases

• Routing of funds through related entities, one of which is Matrix Gas

C) Direct Mention of Matrix Gas in the SEBI Order

The SEBI order specifically names Matrix Gas and Renewables Ltd. as a beneficiary of diverted funds. According to the investigation:

• Matrix Gas received ₹63.9 Cr from Wellray Solar, a conduit entity used by Gensol promoters

• Additionally, ₹46 Cr of these funds were eventually used for stock market trades, some of which involved the scrip of Gensol itself

• The promoters allegedly used Matrix Gas as one of the vehicles to park or rotate funds, raising serious questions about financial integrity

D) Implications for Unlisted Shareholders

Investors holding Matrix Gas Unlisted Shares must consider the following risks:

1. Reputational Risk

Now that its promoters are under SEBI scanner and barred from capital markets, Matrix Gas’s brand equity and credibility take a significant hit.

2. Regulatory Risk

Being named in an ongoing SEBI investigation could result in further scrutiny, enforcement actions, or funding restrictions for Matrix Gas.

3. Liquidity Risk

As concerns rise, investor appetite in the unlisted market may shrink, reducing liquidity for existing shareholders looking to exit.

4. Corporate Governance Overhang

If similar practices are found within Matrix Gas, its valuation, access to capital, and future listing potential could be compromised.

E) The Bigger Picture

What makes this case critical is that Matrix Gas is not just “associated” with Gensol — it is a directly named recipient of misused funds. This raises concerns not just about past financial practices, but about future operational transparency and investor protection.

F) Our View at UnlistedZone

At UnlistedZone, we believe in identifying high-potential private companies for investors — but transparency and promoter integrity are non-negotiable. The developments around Gensol and Matrix Gas raise red flags that investors must not ignore.

We advise all stakeholders in Matrix Gas to:

• Closely monitor SEBI’s ongoing forensic audit outcomes

• Reassess exposure based on risk tolerance and investment horizon

• Await clarity on management’s response, if any