SEBI v. Sandeep Tulsiram Agrawal and others (insider trading, Kushal Ltd, 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A SEBI whole-time member found that members of the Agrawal promoter family traded Kushal Ltd shares while holding unpublished information about quarterly results and an interim dividend. He ordered disgorgement of about Rs 53 lakh with interest, penalties of Rs 1.8 crore in total and a one-year market bar.

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

18m 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 29 July 2022 by a whole-time member of the Securities and Exchange Board of India. The six noticees were members of the family that promotes Kushal Ltd, a company listed on the BSE: Sandeep Tulsiram Agrawal, its managing director, his wife Namrata, his mother Pushpadevi, his brother Mahendra and Mahendra's wife Sudha, and another brother, Manoj, the executive director.

SEBI's case was that the company's results for the quarter ended September 2017 and a second interim dividend, announced on 14 December 2017, were unpublished price-sensitive information from 1 October 2017. It alleged that the managing director and executive director had access to that information, that the other noticees were connected persons or dependants, and that four of them traded in Kushal shares before the announcement. SEBI also alleged that Rs 40 lakh was passed from one brother to a family member to fund her purchases.

The order finds that the insiders and connected persons breached Regulation 4(1) of the PIT Regulations and section 12A(d) and (e) of the SEBI Act through trading while in possession of the information, and that the two executive directors breached Regulation 3(1) by communicating it.

Four noticees were directed to disgorge wrongful gains of Rs 14,18,853, Rs 24,05,503, Rs 9,37,500 and Rs 5,55,706.95, about Rs 53.2 lakh in all, with 12 percent annual interest from 15 December 2017. All six were restrained from the securities market for one year and from dealing in Kushal securities for two years, running concurrently. Penalties under section 15G were Rs 50 lakh, three of Rs 30 lakh, and two of Rs 20 lakh, Rs 1.8 crore in total.

The record does not show whether any noticee appealed, whether the money was paid, or any loss to a particular investor, which the order says the notice did not identify. It describes no criminal case.

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. 2022-07-29 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.