SEBI v. S. Madhavan (insider trading settlement, UFO Moviez India, 2022)

Settled

✓ Checked against the primary document on October 8, 2026. The library's summary, tags and figures for this record were compared with the regulator's own document by an AI model (Claude) following written instructions, in a single reading of the order; an independent second reading of 60 SEBI records agreed on every field for 56, the four misses being penalty amounts; a later sample of 50 of the SEBI records added on 9 October agreed on every field for 46. No lawyer has reviewed them. A checked record can still contain errors, and checked does not mean endorsed. See how we check records or report a correction.

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An independent director of UFO Moviez India settled SEBI's allegation that he traded on unpublished information about a merger with Qube Cinema Technologies, without admitting or denying it. The January 2022 settlement order records a settlement amount of Rs 19,12,500 plus disgorgement and interest.

The record

What was ordered

Civil penalty

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Disgorgement

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Prejudgment interest

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Total relief

—

Alleged gain

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Penalty as published

1.9m INR

A dash means the release did not state a figure we could extract, not that the figure is zero. Penalty and disgorgement are stored separately so aggregates across the library do not double-count the same dollars. This regulator states penalties in INR. The figure is recorded as published and is not converted, so it does not appear in the USD totals or medians used elsewhere on this site.

What is alleged to have happened

The settlement order of 20 January 2022 was signed by two SEBI whole-time members under the SEBI (Settlement Proceedings) Regulations, 2018. It concerns S. Madhavan, who served as an independent director of UFO Moviez India Limited from November 2014 to September 2019.

A show-cause notice of 27 July 2021 alleged that the composite scheme of arrangement and amalgamation between UFO Moviez and Qube Cinema Technologies Private Limited, made public by a press release of 1 November 2017, was price-sensitive information; that Mr Madhavan, as a director, came into possession of it; and that he traded in the company's shares while holding it. SEBI alleged breach of Regulation 4(1) of the Insider Trading Regulations, 2015 and Sections 12A(d) and 12A(e) of the SEBI Act. The order does not state the size or dates of the trades.

Mr Madhavan applied to settle without admitting or denying the findings of fact or conclusions of law. After a meeting with SEBI's internal committee on 8 October 2021 and revised terms on 20 October, the high powered advisory committee recommended settlement on 9 November 2021 against payment of a settlement amount of Rs 19,12,500, a disgorgement amount of Rs 1,59,499 and simple interest of 12 percent on the disgorgement, amounting to Rs 76,140. He paid on 13 December 2021.

On that payment SEBI agreed not to start enforcement action over the alleged default, and the order disposes of proceedings over it, while keeping the right to act if his representations prove untrue or the settlement terms are breached. The order imposes no market restraint.

Because this is a settlement, the order makes no finding of violation. The record does not show the profit the trades earned beyond the disgorgement figure, and it describes no criminal case.

This library tags the matter as insider trading. The tagging is ours, not the regulator's.

For the regulator's own account of the facts, read the primary document linked above. This page deliberately summarises the structured record rather than reproducing the order.

What technique is this, and how does it work?

This action is tagged with one technique in our taxonomy. The tagging is ours: regulators charge statutory provisions, not technique names, so the mapping is an editorial judgement described in our editorial policy.

• Insider trading — see how it works, what statute it engages, and every other action tagged the same way.

Timeline

1. 2022-01-20 SEBI settlement order

Primary documents

Everything on this page derives from the documents below. Where our summary and the primary document disagree, the primary document is right.

• SEBI order
• Order (PDF)

The linked release is published by the issuing regulator under its own terms. Our summary and narrative above are our own writing.

Related actions

Other actions in the library sharing at least one technique tag with this one.

Record added October 8, 2026. submit a correction.