SEBI v. Arvind Kumar Saraf and others (Arcotech insider trading, 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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On 29 December 2023 a SEBI chief general manager disposed of insider-trading proceedings over share sales in Arcotech Ltd by two promoter-group companies and their two directors, ordering no directions and no penalty. The order found that the information said to be price sensitive was not shown to exist when the shares were sold.

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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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

The order was issued by a chief general manager of the Securities and Exchange Board of India on 29 December 2023. The four noticees were Arvind Kumar Saraf, chairman of Arcotech Ltd, and Rishabh Saraf, a non-executive director, and two promoter-group companies, Vasudha Commercial Pvt. Ltd. and Hiland Enclave Pvt. Ltd., of which both men were directors.

SEBI's investigation, covering February to June 2018, alleged that the two companies sold Arcotech shares while the directors held unpublished price sensitive information about the company's results for the year to March 2018. The alleged information was the discussion at a board meeting on 14 February 2018 about a stalled loan refinancing and tightness in working capital. The results announced on 29 May 2018 showed a quarterly loss, and the share price fell over the following month. The notice also alleged the directors communicated the information to the companies.

The noticees answered that the sales were small relative to their holdings, that the funds were used for stated purposes, and that the notice itself treated the relevant information as arising only from mid-May 2018, after the sales. The order accepted the central point. It found nothing on record showing that the results information existed before 14 May 2018, and noted that the shares were sold in March and April 2018.

Having found that the information did not exist at the time of the trades, the adjudicator treated the remaining questions, including whether the directors were insiders and whether any communication took place, as not requiring decision. The order disposed of the proceedings under the SEBI Act without directions and without any monetary penalty, while leaving open other action by SEBI or other authorities.

The record does not show whether SEBI appealed or revisited the matter, and the order does not describe a criminal case. It does not quantify any gain or loss avoided because no violation was established.

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. 2023-12-29 SEBI order disposing of proceedings 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
• SEBI order
• SEBI order
• SEBI order
• 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.