SEBI v. Pawan N Agarwal (front running of Aequitas client trades, settlement, 2023)

Settled

✓ Checked against the primary document on October 9, 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.

Report an error in this record (sebi-73433-market-abuse-2023) by email

On 4 July 2023 SEBI settled proceedings against Pawan N Agarwal, accused on a complaint from Finsec Law Advisors of front running and mirror trading of its Aequitas clients' trades, for a payment of Rs 44.20 lakh.

The record

What was ordered

Civil penalty

—

Disgorgement

—

Prejudgment interest

—

Total relief

—

Alleged gain

—

Penalty as published

4.4m 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

This is a settlement order dated 4 July 2023, signed by SEBI adjudicating officer Geetha G. The applicant is Pawan N Agarwal. The matter began with a complaint from Finsec Law Advisors Ltd, which alleged that Mr Agarwal and two others had front run or mirror traded the trades of its clients at Aequitas.

SEBI investigated and concluded, for the purposes of the notice, that Mr Agarwal had breached section 12A(c) of the SEBI Act and Regulations 3(a), 3(d) and 4(1) of the PFUTP Regulations 2003. An adjudicating officer was appointed in November 2021 and a show cause notice followed in April 2022, seeking a penalty under section 15HA. These are allegations from the notice; the settlement order records no finding.

In June 2022 Mr Agarwal applied to settle under SEBI's settlement regulations. The internal committee recommended an indicative amount of Rs 44.20 lakh in February 2023. A high-powered advisory committee recommended settlement on that sum in March 2023, SEBI's whole-time members approved it on 24 April 2023, and the applicant paid it in May 2023. The proceedings were disposed of on those terms.

The order imposes no restriction on trading. SEBI keeps the right to restore the proceedings if a representation in the settlement turns out to be untrue or the settlement undertakings are breached.

The record does not show the trades involved, the profits made, the identities of the two other persons named in the complaint, or what became of them.

This library tags the matter as front running. 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.

• Front running — see how it works, what statute it engages, and every other action tagged the same way.

Timeline

1. 2023-07-04 SEBI settlement 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
• SEBI order (PDF)

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.