SEBI v. Gottumukkala Subha Satya Pramila and another (insider trading allegation, Apex Frozen Foods, 2023)

Dismissed

✓ 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 closed an insider trading case against the purchase manager of Apex Frozen Foods Ltd and his wife without any penalty. He found nothing to show that a purchase manager who was not involved in preparing the results had access to them.

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

—

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.

What is alleged to have happened

This order sits alongside a separate SEBI order of the same date against the chairman and relatives of Apex Frozen Foods Ltd (AFF) for trading before its November 2017 results announcement. Here the noticees were G. V. Raghava Raju, AFF's purchase manager, and his wife, Gottumukkala Subha Satya Pramila. SEBI's October 2022 notice treated the company's financial results for the September 2017 quarter as unpublished price sensitive information from 3 October to 14 November 2017, the date of the announcement.

SEBI alleged that Mr Raju, who the company had named as a designated person and key managerial person under its insider trading code, was a connected person reasonably expected to hold the information, and that his wife, as a relative, was an insider who traded on it. The company had given a list of ten people it said were privy to the results, which did not include him.

The executive director applied a Securities Appellate Tribunal ruling that proving someone is an insider and traded on such information needs probability judged on a higher scale. He held that Mr Raju's designation did not itself justify inferring access, that the company's own email said he was not involved in preparing the results, and that the investigation showed neither access by virtue of his post nor communication from any insider. Because Mrs Pramila's status depended on her husband's, her charge fell with his.

He therefore did not reach the questions of whether they traded or what sanctions would apply, and disposed of the notice without directions or penalty, while stating that SEBI or other authorities remained free to act under the law.

This record is a dismissal. It does not show whether SEBI appealed, and 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 order disposing of the show cause notice without directions

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.