SEBI v. Consortium Capital Pvt Ltd and others (Kotak Mahindra and Axis Bank call options, 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.
A SEBI adjudicating officer closed a case in December 2022 against three entities accused of reversal trading in the thinnest Kotak Mahindra and Axis Bank call options in 2014-15. The officer found the pattern suspicious but not proved, partly because the counterparty trades followed an automated hedging strategy.
The record
| Agency | SEBI (India) |
|---|---|
| Date filed | 2022-12-29 |
| Date resolved | 2022-12-29 |
| Court | SEBI adjudicating officer |
| Status | dismissed |
| Asset class | derivatives |
| Instruments | Kotak Mahindra Bank and Axis Bank stock call options |
| Venue | NSE, BSE |
| Criminal parallel | No |
| Defendants | Consortium Capital Private Ltd ; Pashupati Capital Services Pvt Ltd ; Sachi Investment (proprietor Sarita Devi Choudhary) |
| Techniques | Matched orders |
What was ordered
- Civil penalty
- —
- Disgorgement
- —
- Prejudgment interest
- —
- Total relief
- —
- Alleged gain
- —
What is alleged to have happened
Adjudicating officer Vijayant Kumar Verma of SEBI issued this order on 29 December 2022 on a show cause notice against three entities over trading in call options on Kotak Mahindra Bank and Axis Bank shares between 27 June 2014 and 26 February 2015. The noticees were Consortium Capital Private Limited, Pashupati Capital Services Pvt Ltd and Sachi Investment, a proprietorship of Ms Sarita Devi Choudhary.
SEBI alleged that Consortium sold deep in-the-money call options in contracts so illiquid that it held almost all of the open interest, then shortly before expiry the same few counterparties sold the positions back to it, reversing the trade. In 18 Axis contracts and 11 Kotak contracts Consortium's concentration exceeded half. Two of the counterparties, Pashupati and Sachi, were connected to each other, as the director of one and the proprietor of the other are husband and wife and share an address and email address, though SEBI found no link between them and Consortium.
The officer found the pattern suspicious but concluded that the evidence did not meet the balance-of-probabilities test. Consortium and the two counterparties were not shown to be connected, the trades did not satisfy the tribunal's criteria for a reversal trade, matching among few counterparties in the least liquid contracts was quite possible, and the counterparties' trades formed part of automated, multi-legged hedging strategies. The officer said it could not be known with confidence whether Consortium had a prior meeting of minds with them, and that the allegations would stay doubtful until the multi-legged transactions were investigated in detail.
The notice was therefore disposed of against all three noticees. No penalty or direction was made.
The record does not show whether SEBI appealed or reopened the matter. It does not show what the intended gain from the trades would have been. No criminal case is described.
This library tags the matter as matched orders. 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.
- Matched orders — see how it works, what statute it engages, and every other action tagged the same way.
Timeline
- 2022-12-29 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.
Related actions
Other actions in the library sharing at least one technique tag with this one.
| Action | Agency | Filed | Technique | Penalty | Status |
|---|---|---|---|---|---|
| SEBI v. Shreedhar Yellaiah Kodam (synchronized trades, Well Pack Papers, 2026) | SEBI (India) | 2026-09-22 | Matched Orders , Price Manipulation | — | dismissed |
| SEC v. Corey Ortiz (free riding and parking, 2026) | SEC | 2026-09-03 | Free Riding And Parking , Matched Orders | — | judgment |
| SEBI v. Hanif Shekh and others (price and volume manipulation in five scrips, Mauria Udyog and others, 2026) | SEBI (India) | 2026-06-30 | Matched Orders , Pump And Dump +1 | — | judgment |
| SEC v. Christopher Flagg, Daquan Lloyd and Travis Treusch (free riding and parking, 2026) | SEC | 2026-04-30 | Free Riding And Parking , Matched Orders | — | judgment |
| SEBI v. Harsha Ishvarbhai Solanki and others (trading in ANI Integrated Services, 2026) | SEBI (India) | 2026-02-12 | Price Manipulation , Matched Orders | — | judgment |
| SEBI adjudication orders on illiquid stock options at BSE (2026 batch) | SEBI (India) | 2026-01-05 | Matched Orders | — | judgment |