SEBI v. Bijal Shah and others (insider trading in Zee Entertainment derivatives, 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In March 2023 a SEBI whole-time member found that an executive of Zee Entertainment Enterprises passed unpublished information to two friends in the finance industry, who traded the company's derivatives before its August 2020 results and a September 2020 product launch. He ordered about Rs 9.6 crore of disgorgement with interest, two-year market bars and Rs 90 lakh in penalties.

The record

What was ordered

Civil penalty

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Disgorgement

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Prejudgment interest

—

Total relief

—

Alleged gain

—

Penalty as published

9m 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

Zee Entertainment Enterprises Ltd (ZEEL) is a listed broadcaster. SEBI passed an interim order in August 2021 against 14 people and a partnership, restraining them from the market and impounding Rs 23.84 crore of suspected proceeds, which led to appeals to the Securities Appellate Tribunal and the Supreme Court before the final order. The investigation concerned two pieces of unpublished information: the results for the quarter to 30 June 2020, announced on 18 August 2020, and the launch of the ZEEPLEX Cinema2Home service, which came into existence about 2 May 2020 and was announced on 1 September 2020.

The core noticees were Bijal Shah, ZEEL's head of strategy, investor relations and financial planning, and Gopal Ritolia and Jatin Chawla, friends from earlier jobs who worked in finance. SEBI alleged Mr Shah passed the information to the two friends, who then bought and sold ZEEL futures and options, partly through accounts in their relatives' names, before each announcement. The other eleven noticees were family members and entities whose accounts were used. Mr Shah denied knowing about the launch or having tipped anyone.

The whole-time member held that the financial results were unpublished price sensitive information and that Mr Shah was an insider who communicated them and the product launch information to Mr Ritolia and Mr Chawla, who traded on it. He found Mr Shah himself did not trade and so was liable for communication and not for insider trading. He disposed of the notice without further directions for noticees 4, 5 and 8 to 14, and revoked the impounding against noticees 8 to 14.

The order restrains Mr Shah, Mr Ritolia and Mr Chawla from the securities market for two years and requires disgorgement of Rs 7,51,99,771.80 by Mr Ritolia and Rs 2,09,77,685 by Mr Chawla, with 12 per cent simple interest from September 2020, paid from the escrow account where sums were already deposited. Each of the three is penalised Rs 30 lakh under section 15G, Rs 90 lakh in all.

The record does not show appeals, payment, or any action against others at the company. It describes no criminal case. The order is lengthy and this summary reflects its conclusions, not the trade-by-trade analysis.

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. 2023-03-31 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.