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SEBI v. Karuturi Subrahmanya Chowdary and others (Apex Frozen Foods, 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-66762-insider-trading-2022) by email

A SEBI adjudicating officer found in December 2022 that a director of Apex Frozen Foods, his father-in-law, an employee he lent money to, and one other person bought shares before the company's strong September 2017 quarter results were published. Four were penalised Rs 51.14 lakh in total; the charges against an independent director and the company were not made out.

The record

Structured fields for this action, as recorded in our case library.
Agency SEBI (India)
Date filed 2022-12-29
Date resolved 2022-12-29
Court SEBI adjudicating officer
Status judgment
Asset class equities
Instruments Apex Frozen Foods Ltd shares
Venue BSE, NSE
Criminal parallel No
Defendants Karuturi Subrahmanya Chowdary (individual) ; Lakshmipathi Raju Mantena (individual) ; Vallepalli Hanumantha Rao (individual) ; Devalla Satya Madhavi (individual) ; P Durga Prasad (individual) ; Apex Frozen Foods Ltd (entity)
Techniques Insider trading

What was ordered

Civil penalty
—
Disgorgement
—
Prejudgment interest
—
Total relief
—
Alleged gain
—
Penalty as published
5.1m 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

Adjudicating officer Barnali Mukherjee of SEBI issued this order on 29 December 2022 in the matter of Apex Frozen Foods Limited, listed on NSE and BSE. The six noticees were Karuturi Subrahmanya Chowdary (promoter and whole-time director), independent director Lakshmipathi Raju Mantena, Vallepalli Hanumantha Rao (a promoter and Mr Chowdary's father-in-law), Devalla Satya Madhavi (a quality assurance manager and designated employee), P Durga Prasad and the company itself.

The information at issue was the company's results for the quarter ended 30 September 2017, published on 14 November 2017 at about 16:36 to 16:45 hours. Profit was Rs 2,204 lakh. The share price, which had closed at Rs 461.85 on 14 November, then hit successive circuit limits to reach Rs 608.60 by 22 November and Rs 740.70 by 30 November. SEBI examined trading from 4 September 2017 to 28 February 2018 and alleged that those with access bought between 3 October and 14 November 2017.

The officer found that Mr Chowdary, Mr Rao, Ms Madhavi and Mr Durga Prasad were insiders in possession of the information, that they traded and applied for pre-clearance while holding it, and that Mr Chowdary communicated it and Mr Rao and Ms Madhavi procured it. Ms Madhavi had said she borrowed Rs 80 lakh from Mr Chowdary to buy shares and later sold him land for Rs 95 lakh. The order puts the unlawful gains at Rs 1,00,000 for Mr Chowdary, Rs 2,69,146 for Mr Rao, Rs 8,57,076 for Ms Madhavi and Rs 1,11,148 for Mr Durga Prasad. The charge against Mr Mantena failed because he also traded before the information period and in other stocks, and the company was cleared of the information-sharing charge.

Penalties under sections 15G and 15HB of the SEBI Act were Rs 11,00,000 each on Mr Chowdary, Mr Rao and Mr Durga Prasad and Rs 18,14,000 on Ms Madhavi, Rs 51,14,000 in all. No disgorgement is directed in this order.

The record does not show whether the penalties were paid or appealed, or where the proceeds of the gains went. The order notes no investor loss was identified. No criminal case is described.

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.

Timeline

  1. 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.

The linked release is published by the issuing regulator under its own terms. Our summary and narrative above are our own writing.

Other actions in the library sharing at least one technique tag with this one.

Action Agency Filed Technique Penalty Status
SEC v. Trijya Vakil and Neeraj Visen (insider trading, 2026) SEC 2026-09-04 Insider Trading $109k settled
CFTC v. Gabriel Perez (insider trading, 2026) CFTC 2026-08-28 Insider Trading $65k judgment
SEC v. Gavin Wolfe and others (insider trading, 2026) SEC 2026-08-21 Insider Trading — filed
SEC v. Jesse R. Mitchell (insider trading, 2026) SEC 2026-08-21 Insider Trading — filed
SEBI v. Arun Kumar Somani and others (insider trading review, Indian Oil Corporation, 2026) SEBI (India) 2026-08-13 Insider Trading — dismissed
SEC v. Benjamin Tesfaye (insider trading, 2026) SEC 2026-08-11 Insider Trading $18.7k settled

Record added October 8, 2026. submit a correction.