SEBI v. RHC Holding Pvt Ltd and others (Religare fund diversion and false accounts, 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 whole-time member found that about Rs 2,300 crore was moved out of Religare Finvest and Religare Enterprises to promoter-linked entities and that false financial statements hid it, in breach of the PFUTP Regulations. He fined ten noticees Rs 60 crore in total and restrained the two former promoters for three years.

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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Penalty as published

600m 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

The order was issued on 28 July 2022 by a whole-time member of SEBI. It follows an ex-parte interim order of 14 March 2019 and a confirmatory order of 11 September 2019, both issued after a forensic audit commissioned by SEBI. The noticees include the former promoters Malvinder Mohan Singh and Shivinder Mohan Singh, a group of promoter-connected companies, the former executives Sunil Godhwani and Anil Saxena, and the listed company Religare Enterprises Limited and its subsidiary Religare Finvest Limited.

SEBI alleged that money was taken from Religare Finvest, in the form of corporate loans routed through intermediary borrowers, for the ultimate benefit of promoter-controlled entities. The show cause notice put the diverted figure at about Rs 2,473 crore, while the interim directions had referred to about Rs 2,315 crore. SEBI also alleged that the group's accounts were misstated so that the position was not shown fairly to the market.

The order finds that PFUTP Regulations 3(d) and 4(1) and section 12A(c) of the SEBI Act were breached by ten of the noticees. As one example of the false accounts, it finds that the profits of Religare Finvest for 2016-17 were overstated by about Rs 343 crore because delinquent loans were kept classified as standard. It also finds that two executives approved or certified those statements without objection, and separately finds breaches of listing-disclosure and governance rules by some noticees.

The sanctions are a penalty of Rs 5 crore each on eight noticees and Rs 10 crore each on the two former promoters, Rs 60 crore in total, under sections 15HA and 15HB of the SEBI Act. The two former promoters are restrained from the securities market for three years or until the money is recovered, whichever is later, and eight others for two years. The two Religare companies are directed to keep pursuing recovery of the money with interest, and the order notes that civil and criminal recovery steps had already been started.

The record does not show whether any noticee appealed this order, how much has actually been recovered, or the outcome of the parallel criminal complaints the order mentions. This record treats the fund-diversion and false-accounts conduct as fraud on investors in a listed company rather than as trading-based manipulation, which is why it is a borderline fit for this library.

This library tags the matter as misleading issuer disclosure. 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.

• Misleading issuer disclosure — see how it works, what statute it engages, and every other action tagged the same way.

Timeline

1. 2022-07-28 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

The linked release is published by the issuing regulator under its own terms. Our summary and narrative above are our own writing.

Same matter

The library links these 2 records because they appear to concern one matter: the same lead defendant, an overlapping technique tag and close filing dates, or a shared court docket or a release that cites the other. Records are listed by date filed.

This grouping is the library's, made by matching names, techniques, dates and citations when the site is built. It is not the regulator's or a court's determination that the records are one case, and it errs towards missing a link rather than making a false one.

Related actions

Other actions in the library sharing at least one technique tag with this one.

Record added October 8, 2026. submit a correction.