SEBI v. Gautham Lokande and Ajay Kalia (DLF joint venture information, 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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On 31 October 2022 a SEBI adjudicating officer disposed of an insider trading case against Gautham Lokande, an adviser's employee, and Ajay Kalia, a DLF project manager, without any penalty. The order accepts that Mr Kalia was not an insider and that Mr Lokande's trade was not motivated by the confidential information.

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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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

SEBI investigated trading in DLF Ltd, listed on BSE and NSE, between November 2014 and September 2015. The information at issue was talks between DLF and Singapore's GIC about an investment in a joint venture covering DLF's Capital Greens and SIEL projects, which the order treats as confidential from 6 March 2015 until it became public. The two noticees were Gautham Lokande, an employee of BMR Advisors, which advised GIC's investment vehicles on tax matters in March 2015, and Ajay Kalia, a general manager for projects at DLF.

SEBI alleged that both traded on the basis of the information, in breach of section 12A(d) and (e) of the SEBI Act and Regulation 4(1) of the insider trading regulations, with penalty proposed under section 15G(i). The case against Mr Kalia rested on his presence at site visits for GIC's team in December 2014 and February 2015. The case against Mr Lokande was that, as part of the BMR team, he possessed the information when he traded.

The officer found for both. Mr Kalia's role was technical, the site visits fell before the information existed, he took no part in the deal discussions, and there was nothing to show he was a connected person or held the information, so he was not an insider when he traded. Mr Lokande, the officer accepted, had made a single futures trade on 4 August 2015, bought and sold the same day for a loss of Rs 34,500, was a habitual and high-volume trader in DLF and the derivatives segment before and after the period, and would have held the position until the announcement if he were acting on the information. The trade was therefore found not motivated by the information.

The proceeding was disposed of without any penalty.

The record does not show whether SEBI appealed, or whether Mr Lokande had the information, which the order does not decide.

This library tags the matter as insider trading (alleged, not established). 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. 2022-10-31 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.