SEBI v. Ashishbhai Prafulbhai Patel (insider trading, 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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On 30 December 2022 a SEBI adjudicating officer penalised the managing director of Radhe Developers (India) Ltd a total of Rs 27 lakh. The order found he dealt in the company's shares ahead of two results announcements while holding unpublished price sensitive information, and also breached disclosure and trading-code rules.

The record

What was ordered

Civil penalty

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Disgorgement

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Prejudgment interest

—

Total relief

—

Alleged gain

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Penalty as published

2.7m 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

The noticee is Ashishbhai Prafulbhai Patel, the managing director of Radhe Developers (India) Ltd, whose shares were listed on the Bombay Stock Exchange. SEBI's investigation covered trading between 1 October 2009 and 30 July 2010 and began with a reference from India's Financial Intelligence Unit. The adjudication was handled by an adjudicating officer under section 15-I of the SEBI Act, after a show cause notice issued in December 2016.

SEBI alleged breaches of the 1992 insider trading regulations (Regulations 3(i) and 4, with section 12A(d) and (e) of the SEBI Act), of the takeover regulations' disclosure rule, of the continual disclosure rule for directors, and of the model code of conduct clauses that bar a director from reversing a trade within six months. The alleged insider trades were sales made on 26 October 2009, 19 January 2010 and 21 January 2010, each shortly before financial results were made public.

The adjudicating officer rejected the takeover-disclosure charge, because every transaction was a sale and the rule applies to acquirers, and rejected the 2 per cent change-in-holding charge because the change fell below that level. She did find that the director failed to make required disclosures for four trades in December 2009 and January 2010, and that he admittedly made opposite trades within six months. On the main charge, she held that publication of results is price sensitive information and that trading shortly before it was enough to show a breach, even if the trading window was open, since the noticee offered no evidence he had not traded as alleged.

The order imposed three penalties: Rs 1,00,000 under section 15A(b) for the disclosure failure, Rs 1,00,000 under section 15HB for the code of conduct breach, and Rs 25,00,000 under section 15G for insider trading, Rs 27,00,000 in total, payable within 45 days. The officer noted mitigating factors, saying the record showed no quantified profit or investor loss and no repetition, but still held the minimum penalty would not do justice.

The record does not show whether the noticee paid, whether he appealed to the Securities Appellate Tribunal, or how much he gained or avoided losing. It describes no criminal case and no market bar.

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.