SEBI v. Satyanarayana Murthy Karuturi and others (insider trading ahead of results, Apex Frozen Foods, 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 March 2023 a SEBI executive director found that the promoter-chairman of Apex Frozen Foods Ltd, his wife and his son-in-law bought shares before the company announced higher quarterly profits in November 2017. They were barred from the market for two years, told to disgorge about Rs 91 lakh with interest, and penalised Rs 32 lakh in total.

The record

What was ordered

Civil penalty

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Disgorgement

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Prejudgment interest

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Total relief

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Alleged gain

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Penalty as published

3.2m 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

Apex Frozen Foods Ltd (AFF), an aquaculture products exporter, listed on the BSE and NSE on 4 September 2017. On 14 November 2017, after market hours, it announced a profit of Rs 2,204.32 lakh for the September quarter, up from Rs 1,664 lakh the previous quarter. The price then hit the 5 per cent upper limit for several days and rose about 74 per cent in 32 trading days.

SEBI investigated trading from 4 September 2017 to 28 February 2018. The noticees were Satyanarayana Murthy Karuturi, promoter and chairman and managing director, his wife Padmavathi Karuturi, also a promoter, and their son-in-law Ravi Kanth Sankuratri. SEBI alleged that financial results are unpublished price sensitive information under the 2015 insider trading regulations, that the three bought shares in the period before the announcement, and that the chairman and his wife also breached the minimum standards of the code of conduct for insiders. A notice was issued in October 2022.

The executive director found the allegations established against all three and said insider trading by promoters and their relatives damages shareholder confidence, particularly as it came in the first quarter after listing. The noticees did not dispute SEBI's calculation of notional gains, measured as the gap between average purchase price and the next day's closing price.

The directions restrain all three from the securities market for two years. They must disgorge Rs 14,62,875 (Mr Karuturi, on 23,500 shares), Rs 40,76,229 (Mrs Karuturi, on 70,183 shares) and Rs 35,67,260 (Mr Sankuratri, on 30,947 shares), about Rs 91.06 lakh in all, with 12 per cent interest from 15 November 2017. Penalties under section 15G are Rs 10 lakh each, and the chairman and his wife are penalised Rs 1 lakh each for the code of conduct breach under section 15HB, Rs 32 lakh in total.

The record does not show appeals, payment, or whether any other person tipped the buyers. 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. 2023-03-28 SEBI final 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.