SEBI v. Amalendu Mukherjee (insider trading, Ricoh India, 2022)

Judgment entered

✓ 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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A SEBI adjudicating officer found that Amalendu Mukherjee, a promoter and managing director of a Ricoh India vendor company, traded Ricoh shares for that company while knowing the issuer's financial statements were misstated. The January 2022 order imposed a penalty of Rs 20 lakh on top of an earlier restraint and disgorgement order.

The record

What was ordered

Civil penalty

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Disgorgement

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Prejudgment interest

—

Total relief

—

Alleged gain

—

Penalty as published

2m 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 adjudication order of 31 January 2022 was passed by a SEBI adjudicating officer under Section 15-I of the SEBI Act against Amalendu Mukherjee, in the matter of Ricoh India Limited. SEBI examined dealings between August 2014 and November 2015, under both the 1992 and 2015 insider trading regulations.

SEBI alleged, on the basis of a forensic audit report of October 2019, that Ricoh's financial statements had been misstated from 2012-13, so that unpublished price-sensitive information existed until Ricoh's announcement of 22 April 2016. Mr Mukherjee was managing director and promoter of Fourth Dimension Solutions Ltd (FDSL), which dealt with Ricoh, and was authorised to place FDSL's orders. SEBI alleged that he knew of the misstatement, was therefore an insider, and traded Ricoh shares for FDSL while holding that information, ending by selling the remaining 22,828 shares on 17 November 2015, two days after Ricoh adjourned its board meeting on quarterly results.

The officer rejected the noticee's challenge to the forensic report as beside the point, found that he satisfied the definition of an insider, and held that his trading in FDSL's account on the basis of the information was established. The order computes a gain of Rs 1,13,56,118 on the market and off-market trades and a loss avoided of Rs 1,16,77,892 on the last sale, together Rs 2,30,34,010.

The order notes that a SEBI whole-time member had already directed him, by a final order of 6 July 2020 in the same matter, to disgorge that Rs 2,30,34,010 with 12 percent simple interest and had restrained him from the market and from association with listed companies for seven years. In this order the officer imposed a further penalty of Rs 20,00,000 under Section 15G of the SEBI Act.

The record does not show whether Mr Mukherjee appealed either order or how much has been paid. It describes no criminal case. The company FDSL is described as the trading account holder, but the order penalises only Mr Mukherjee.

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. 2022-01-31 SEBI adjudication order imposing a penalty

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.