SEBI v. Urmila Kanoria and others (Godfrey Phillips India insider trading, 2022)

Dismissed

✓ 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 April 2022 a SEBI adjudicating officer disposed of insider-trading proceedings against a Mumbai family and their company over purchases of Godfrey Phillips India shares the day before results. The officer found no violation proved and imposed no penalty, because the record did not show how unpublished price-sensitive information reached the first noticee.

The record

What was ordered

Civil penalty

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Disgorgement

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Prejudgment interest

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Total relief

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Alleged gain

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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.

What is alleged to have happened

A SEBI adjudicating officer decided the matter on 29 April 2022. The noticees were Urmila Kanoria, her son Saket Kanoria, and Narmada Fintrade Private Limited, a private company promoted by Ms Kanoria and her husband. The proceedings were under section 15G of the SEBI Act and concerned trading in Godfrey Phillips India Limited between late June and late August 2019.

SEBI alleged that the late K K Modi, the company's managing director and the director in charge of finance, held unpublished price-sensitive information about quarterly results released on 10 August 2019. Ms Kanoria was his sister. SEBI alleged she received the information, passed it to her son and the company, and that all three bought shares on 9 August 2019, the day before the results. The share price then rose by more than 42 per cent over four trading days. The alleged breaches were of Regulations 3(1) and 4(1) of the 2015 Insider Trading Regulations.

The officer found that being a sibling of an insider does not make a person a connected person. Under the regulations a relative counts only if financially dependent on the insider or in the habit of consulting that person on financial decisions, and the notice offered no evidence of either. There were also no call records or other material showing the information moving from Mr Modi to Ms Kanoria. Relying on a 2022 Supreme Court ruling in Balram Garg v SEBI, the officer held that closeness of family ties and a suspicious trading pattern cannot substitute for evidence of communication.

Although the officer remarked that the circumstances were strong and that, on a balance of probabilities, communication and trading on the information seemed likely, the absence of cogent proof led to a finding of no violation by Ms Kanoria. With no proven insider, the case against her son and the company, which depended on her having passed information on, also failed. The notice was disposed of with no penalty.

The record does not show what the noticees actually bought or the profit they made, whether SEBI appealed to the Securities Appellate Tribunal, or any other proceeding against these parties. The order is a disposal of an allegation and should not be read as a finding that anyone committed insider trading.

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. 2022-04-29 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

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.