SEBI v. Bhavesh Gadhavi (Sterling Group front-running, 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 fined Bhavesh Gadhavi Rs 8 lakh in April 2022 for lending his trading account to a front-running scheme that traded ahead of orders from the Sterling Group. The order treats him as having aided Manish Chaturvedi's front-running.

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

800k 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, Suresh B Menon, decided the matter on 29 April 2022. It is one of several orders in the matter of front-running by Manish Chaturvedi and others. The noticee here is Bhavesh Gadhavi, whose trading account at Sharekhan was used in the activity.

SEBI said NSE surveillance reports in 2010 and 2011 flagged suspected front-running of trades by about ten companies and entities, the Sterling Group, between January 2010 and March 2011. An investigation covering March 2009 to March 2011 followed. SEBI alleged that persons connected to the Chaturvedi family placed trades in accounts like Mr Gadhavi's just ahead of the group's large orders and profited as the market moved.

The order finds that Mr Gadhavi's account was used for that purpose, that the order indicates he handed the account to Manish Chaturvedi knowing the consequences, and that a mobile number given on his account-opening papers was shared with Laxmi Chaturvedi, Manish's mother. The officer found violations of section 12A and Regulations 3 and 4(1) of the 2003 fraudulent and unfair trade practices regulations, and treated the repeated trades as aggravating. The investigation put overall profit from the activity through his account at about Rs 1.16 crore.

The officer imposed a penalty of Rs 8,00,000 (Rs 8 lakh) under section 15HA, payable within 45 days. The order notes that a separate SEBI final order of 18 December 2020 had already debarred him from the securities market for five years and directed disgorgement of the unlawful gains against Manish Chaturvedi, because that account was used by him.

The record does not show whether any appeal was filed, how much of the disgorgement has been recovered or whether any criminal case exists.

This library tags the matter as front running. 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.

• Front running — 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.