SEBI v. National Stock Exchange Limited, Ravi Narain and others (NSE data sharing, 2022)
Judgment entered
Checked against the primary document on October 9, 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.
In June 2022 a SEBI adjudicating officer fined eight noticees Rs 11 crore in total in the NSE corporate governance matter, finding that confidential NSE data was shared with researchers and a firm that used it to build algorithmic trading software. Fraud penalties of Rs 1 to 2 crore fell on the data recipients and one NSE officer, while NSE and its two chief executives were fined only for governance lapses.
The record
| Agency | SEBI (India) |
|---|---|
| Date filed | 2022-06-30 |
| Date resolved | 2022-06-30 |
| Court | SEBI adjudicating officer |
| Status | judgment |
| Asset class | equities |
| Instruments | NSE market data and volatility and liquidity index data |
| Venue | NSE |
| Criminal parallel | No |
| Defendants | National Stock Exchange Limited ; Ravi Narain ; Chitra Ramakrishna ; Ajay Shah ; Infotech Financial Services Private Limited ; Sunita Thomas ; Krishna Dagli ; Suprabhat Lala |
| Techniques |
What was ordered
- Civil penalty
- —
- Disgorgement
- —
- Prejudgment interest
- —
- Total relief
- —
- Alleged gain
- —
- Penalty as published
- 110m INR
What is alleged to have happened
The order of 30 June 2022 follows complaints of 2017 about the National Stock Exchange of India and relates to the period 2009 to 2016. SEBI examined whether market data held by the exchange was misused by Ajay Shah, Sunita Thomas, Krishna Dagli and the firm Infotech Financial Services Private Limited with the connivance of senior NSE figures Ravi Narain, Chitra Ramakrishna and Suprabhat Lala. It looked separately at the years before 2012, when there was no formal data-sharing agreement, and the years after.
SEBI alleged that data meant for research on volatility and liquidity indices was used by Infotech, which also developed and sold algorithmic trading software to brokers, and that the exchange and its leaders shared confidential data without proper agreements, due diligence or conflict-of-interest controls. The charges were fraud under section 12A of the SEBI Act and the PFUTP Regulations, and breaches of an exchange governance circular.
The adjudicating officer found that Ajay Shah, Infotech, Sunita Thomas, Krishna Dagli and Suprabhat Lala breached the fraud provisions in section 12A(b) and (c) of the SEBI Act and PFUTP Regulations 3(c), 3(d) and 4(1), reasoning that they obtained an unfair advantage through software built on data not available to other investors. For NSE, Mr Narain and Ms Ramakrishna the penalties rest on the governance circular alone, so the order does not itself find a PFUTP breach by them.
The penalties are Rs 1 crore each on NSE, Mr Narain and Ms Ramakrishna under section 15HB; Rs 2 crore under section 15HA and Rs 1 crore under section 15HB on Mr Shah; Rs 2 crore on Infotech; and Rs 1 crore each on Ms Thomas, Mr Dagli and Mr Lala under section 15HA. They add up to Rs 11 crore. The order says SEBI's report did not quantify the illicit gain or investor loss.
The record does not show whether the penalties were paid or appealed, what profits the software produced, or how this order relates to the separate co-location and governance proceedings against NSE. SEBI penalises here and does not convict.
This library tags the matter as no specific technique, because the findings concern misuse of an exchange's confidential data rather than one of the library's trading methods. 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.
Timeline
- 2022-06-30 SEBI adjudication order (30 June 2022)
Primary documents
Everything on this page derives from the documents below. Where our summary and the primary document disagree, the primary document is right.