Philip Rubens, partner at Finers Stephens Innocent, said: "This was an unusual case in that it was brought by the [Department of Trade and Industry] rather than the Financial Services Authority. What it does demonstrate is that such cases have broader implications and are not just tied to the market."

Mr Justice Jack Beatson, sitting at St Albans Crown Court, said that the case raised important legal questions about how share-tipping columnists could mislead their readers. Bhoyrul only avoided a prison sentence because of his guilty plea at the beginning of the trial, the judge said. James Hipwell, Bhoyrul's co-conspirator, made £41,000 from the scam but has had his sentencing adjourned for medical reasons. He is likely to receive a prison term, however, commentators have suggested.
Bhoyrul and Hipwell ramped up share values by publishing tips in companies through their "City Slickers" column. They bought shares in the companies prior to publication and later sold them at a profit. Prosecutors claimed this was an abuse of trust, citing that the articles were "factually inaccurate" and "deceptive in tone". Terry Shepherd, a private investor, was recruited by Hipwell and Bhoyrul to take part in the scam; he has been given a three-month prison sentence after the jury convicted him.

The Financial Services Authority gained some expertise in criminal actions with its appointment of Margaret Cole as director of enforcement last July. Further criminal prosecutions for market manipulation are therefore possible, compliance officers have warned. The burden of proof in these cases is extremely difficult to overcome, however, they noted.

Rubens said: "In the absence of evidence, it's hard to bring a criminal conviction. The FSA is not a natural prosecutor. I believe that criminal prosecutions will remain a very small part of the enforcement work done by the FSA."