SEBI v. Dhruv Agrawal and another (insider trading, Manpasand Beverages, 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.

Report an error in this record (sebi-62130-insider-trading-2022) by email

A SEBI adjudicating officer fined Dhruv Agrawal, an audit committee member at Manpasand Beverages, and his wife Rs 10 lakh jointly for selling shares before the statutory auditor's resignation became public in May 2018. The order says they avoided losses of about Rs 2.25 lakh between them.

The record

What was ordered

Civil penalty

—

Disgorgement

—

Prejudgment interest

—

Total relief

—

Alleged gain

—

Penalty as published

1m 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 adjudicating officer of the Securities and Exchange Board of India decided the matter on 18 August 2022. The noticees were Dhruv Agrawal and Nishi Agrawal, who held a joint demat account. SEBI investigated trading in shares of Manpasand Beverages Ltd between 2 April and 29 June 2018.

SEBI alleged that the company's statutory auditor, Deloitte Haskins & Sells, began the 2017-18 audit in March 2018 but could not finish it because the company did not supply information it had asked for. After a meeting with company officials that included Mr Agrawal as an audit committee member, the auditor resigned on 26 May 2018 and the company announced this to the exchanges on 27 May 2018. SEBI alleged that the resignation and the circumstances behind it were unpublished price-sensitive information, that Mr Agrawal knew of them as an insider, and that shares were sold from the joint account before disclosure.

The order treats the information as price-sensitive, noting that the share price fell about 20 percent in a single day after the announcement, and finds that the sales avoided losses of Rs 1,30,191.53 for the account holder who traded and Rs 94,785.60 for the other. It finds breaches of Regulations 3(1) and 4(1) of the PIT Regulations and section 15G of the SEBI Act.

Treating the joint account as making both liable, the adjudicating officer imposed the statutory minimum penalty, Rs 10 lakh payable jointly and severally, within 45 days. No disgorgement or market bar is ordered.

The record does not show whether the noticees appealed or paid, or what happened to Manpasand's auditing. 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. 2022-08-18 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.