SEBI v. Pankaj Agarwal (selective disclosure, Manappuram Finance, 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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In February 2022 a SEBI adjudicating officer fined a research analyst Rs 15,00,000 for passing on unpublished price-sensitive information about Manappuram Finance in a research report issued the morning after a management meeting. The fraud-on-investors charge was held not established.

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

—

Penalty as published

1.5m 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

A SEBI adjudicating officer, Vijayant Kumar Verma, decided the matter on 28 February 2022. The sole noticee is Pankaj Agarwal, an analyst at the brokerage Ambit Capital, and the issuer concerned is Manappuram Finance Limited.

SEBI alleged that at a meeting on 18 March 2013 the analyst obtained unpublished price-sensitive information from company officials, namely that the quarter to March 2013 might show a loss rather than a profit, and then communicated it through a research report to clients. The report was circulated by email on the morning of 19 March 2013, before the company said anything publicly about the results, and the share price fell in the following days.

The order finds that the report was a direct product of the management meeting and that the analyst failed to keep the information confidential, breaching the insider-trading code of conduct and the prohibition on communicating such information. It rejected the argument that the content was already public or merely inferred. It did not find the separate fraud charge made out, reasoning that once the report reached about 2,000 email addresses and news services the information was no longer unpublished before the market opened.

The adjudicating officer imposed Rs 10,00,000 under section 15G(ii) and (iii) of the SEBI Act and Rs 5,00,000 under section 15HB, a total of Rs 15,00,000. The order notes that the analyst's gain and investors' losses could not be quantified. The order also records that the analyst had earlier applied to settle the matter.

The record does not show whether the analyst appealed, whether the penalty was paid, or whether any person traded on the report.

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. 2022-02-28 SEBI 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.