SEBI v. Lashit Sanghvi and Neha Sanghvi (insider trading, Aptech Limited, 2023)

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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In February 2023 a SEBI whole-time member found that a fund manager and his wife bought Aptech Limited shares ahead of its September 2016 announcement of a move into preschools, having been tipped off. He ordered each to disgorge about Rs 49.9 lakh with interest, restrained them from the market for a year, and penalised them Rs 25 lakh together.

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

2.5m 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

Aptech Limited is a listed education and training company. On 7 September 2016, after market hours, it announced a move into preschools, and its share price rose by 9.99 per cent the next day. SEBI treated the plan as unpublished price sensitive information from 14 March 2016, when Aptech signed a non-disclosure agreement with a preschool operator, Montana International Preschool, until the announcement. The investigation period ran from 14 March to 7 September 2016.

The order covers only two of nine original noticees: Lashit Sanghvi and his wife, Neha Lashit Sanghvi. The others, who included Aptech's then chairman, the investor Rakesh Jhunjhunwala, settled with SEBI in July 2021. The notice alleged that Mr Jhunjhunwala, as chairman, was a connected person holding the information, that he and Mr Sanghvi, who were co-founders of Alchemy Capital Management and had known each other for decades, shared it, and that Mr Sanghvi passed it on to his wife. Each bought shares on 19 August 2016 and on 7 September 2016, the day of the announcement, with about 125,000 NSE shares and 25,000 BSE shares apiece.

The whole-time member found insider trading substantially established against both, holding that Mr Sanghvi communicated the information to Mrs Sanghvi and that both traded on it during the period. He calculated notional gains of Rs 49,87,276 for Mr Sanghvi and Rs 49,84,886 for Mrs Sanghvi, based on the next day's price.

The directions restrain both from the securities market for one year and from dealing in Aptech securities for two years. Each must disgorge the notional profit with simple interest at 9 per cent a year from 7 September 2016 to the Investor Protection and Education Fund. Under section 15G the penalties are Rs 15 lakh for Mr Sanghvi and Rs 10 lakh for Mrs Sanghvi, Rs 25 lakh in all. The order also requires each to give SEBI an inventory of their assets.

The record does not show appeals, payment, or the terms on which the other noticees settled, which this order mentions only briefly. It describes no criminal case.

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. 2023-02-28 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.