SEBI v. Dilipkumar V. Lakhi and Manish G. Lakhi (Religare Enterprises settlement, 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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On 27 May 2022 SEBI settled insider-trading proceedings against Dilipkumar Lakhi and his nephew Manish Lakhi over Religare Enterprises, for Rs 44,62,500 and a larger sum that included disgorgement, neither admitting nor denying the findings. The pair were alleged to have traded while holding it.

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

Two whole-time members of SEBI, S K Mohanty and Ananta Barua, passed the settlement order on 27 May 2022. The applicants were Dilipkumar V Lakhi and his nephew Manish G Lakhi, who each settled show-cause notices of 9 July 2021 without admitting or denying the findings, under the 2018 settlement regulations.

SEBI's investigation looked at trading in Religare Enterprises Ltd (REL) between October 2017 and May 2018. The notices alleged that Dilipkumar Lakhi was in frequent contact with Siddharth Dinesh Mehta about investing in REL's fund-raising, and that Mr Mehta knew unpublished information that the Singh brothers would step down from REL's board. Frequent contact was said to make Dilipkumar Lakhi a connected person and so an insider. Manish Lakhi was said to share directorships with his uncle, who signed off his trading and investment decisions, and to have traded REL shares indirectly while the information was held, with the uncle placing the orders.

The provisions invoked were section 12A(d) and (e), with Regulations 3(1), 4(1) and 4(2) of the 2015 insider trading regulations for Dilipkumar and Regulations 4(1) and 4(2) for Manish.

On 5 April 2022 SEBI's advisory committee recommended settlement on payment of Rs 44,62,500 by Dilipkumar Lakhi, and by Manish Lakhi of Rs 1,87,34,491 as a settlement amount, with disgorgement of Rs 1,25,94,615 and 12 per cent simple interest on it, stated as Rs 55,40,250. Both paid on 6 May 2022. The order's wording does not make clear how the figures for Manish Lakhi combine, so this record states no single settlement total.

The order closes the proceedings and bars further enforcement for the same default, subject to SEBI's right to resume if a representation proves untrue, an undertaking is breached or the terms were miscalculated. A settlement is not a finding of fact, and the record does not show the details of the trades. The companion orders for Mr Mehta, and for Vipul Modi and his LLP, are separate records.

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. 2022-05-27 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.