SEBI v. Neeraj Kumar Agarwal (WhatsApp circulation of Tata Consultancy Services Ltd results, 2022)

Dismissed

✓ 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A SEBI adjudicating officer disposed of a show cause notice alleging that unpublished price sensitive information about Tata Consultancy Services Ltd was passed on through WhatsApp messages, imposing no penalty because a tribunal and the Supreme Court had already rejected SEBI's case on materially identical facts in related matters.

The record

What was ordered

Civil penalty

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Disgorgement

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Prejudgment interest

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Total relief

—

Alleged gain

—

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

The adjudicating officer's order of 29 September 2022 closes a proceeding against two noticees, Mr Agarwal and Ms Vora, arising from SEBI's examination of WhatsApp chats seized from members of a group of market contacts after press reports in November 2017 that unpublished price sensitive information was circulating in private chat groups.

SEBI alleged that the chats showed a message with TCS quarterly figures that Mr Agarwal allegedly sent to Ms Vora on 18 April 2017 before the results were announced that evening, which Ms Vora then forwarded to several other contacts and to members of a WhatsApp group. The notice charged a breach of section 12A(d) and (e) of the SEBI Act read with Regulation 3(1) of the Prohibition of Insider Trading Regulations, 2015, and the examined period was 24 March to 18 April 2017. The order does not allege that any noticee traded on the information.

The officer did not rule on whether the message was price sensitive information or whether it came from a person connected with the company. Instead the order records that the Securities Appellate Tribunal had on 22 March 2021 set aside SEBI's findings in a closely similar matter on the same type of evidence, that the Supreme Court on 26 September 2022 declined to interfere with that ruling, and that the facts here were a replica involving a different company.

On that basis the order disposes of the notice without considering the merits and imposes no monetary penalty and no other direction.

The record does not show whether SEBI took any further step, whether the information was in fact non-public when sent, or whether anyone traded; the order contains no finding of loss or gain.

This library tags the matter as insider trading (alleged communication of unpublished price sensitive information). 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. 2022-09-29 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.