SEBI v. Madhuben Prafulbhai Patel (Radhe Developers, 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.

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A SEBI adjudicating officer found in December 2022 that a shareholder in Radhe Developers who sold shares the day before the company announced its October 2009 results had traded while holding unpublished price sensitive information. She was fined Rs 5 lakh, below the usual minimum, partly because of her age and her pattern of selling before the information arose.

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

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Penalty as published

500k 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 Sangeeta Rathod of SEBI issued this order on 30 December 2022 against one noticee, Madhuben Prafulbhai Patel, in the matter of Radhe Developers (India) Ltd, listed on BSE. SEBI investigated trading from 1 October 2009 to 30 July 2010 on a reference from the Financial Intelligence Unit.

The order records that she held 76,50,870 shares, 3.04 per cent of the company, on 1 October 2009 and sold large lots on dozens of days between 30 October 2009 and January 2010, including 1.6 lakh shares on 30 October. SEBI alleged that she traded while in possession of unpublished price sensitive information, under regulations 3 and 4 of the 1992 insider-trading regulations and section 12A of the SEBI Act, and that she and people acting with her failed to make disclosures required by the takeover regulations.

The officer rejected the takeover-regulation charge, because the disclosure duty fell on acquirers and all of her transactions were sales. On the insider-trading charge, the officer held that the company's results are price sensitive information, that she gave no proof that she had not traded as alleged, and that selling on 30 October 2009, the day before the company declared results on 31 October, was good enough indication of a breach even though the trading window was open.

The penalty was Rs 5,00,000 under section 15G of the SEBI Act. The officer treated the usual minimum as too harsh, citing no quantifiable gain or investor loss, no repeat violations, her advanced age, and that she had been selling since before she acquired the information, in line with earlier intentions.

The record does not show how she came to hold the information, whether the results were good or bad news, or whether the penalty was paid or appealed. 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.

• Insider trading — see how it works, what statute it engages, and every other action tagged the same way.

Timeline

1. 2022-12-30 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.