SEBI v. Gaurav Singhal and Alka Jain (front running of Sapphire Intrex orders, 2024)

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 July 2024 SEBI found that an employee of Sapphire Intrex Limited and a second individual had traded ahead of that company's impending orders during 2021. The order directed disgorgement of Rs 50,51,116 with interest, restrained them from the securities market for 2 years and 1 year, and imposed penalties of Rs 15,00,000 in total.

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

1.5m 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

A SEBI chief general manager, Dr Anitha Anoop, issued the order on 30 July 2024. The noticees were Gaurav Singhal, an employee of Sapphire Intrex Limited, a non-deposit-taking finance company that invests and trades in securities, and Alka Jain. SEBI examined the period January to December 2021 after an alert generated by the National Stock Exchange.

SEBI alleged that the two traded ahead of the impending orders of Sapphire, the 'big client', using non-public knowledge of those orders. It alleged breach of section 12A of the SEBI Act and the fraud and unfair trade practice regulations, including the specific provision on front running by those with advance knowledge of a client's orders.

The order finds that the trades were front running and amounted to fraud and an unfair trade practice under those regulations, yielding unlawful gains it fixes at Rs 50,51,116. It notes that the show cause notice alleged no specific loss to any investor.

SEBI restrained Mr Singhal from the securities market for 2 years and Ms Jain for 1 year, and directed both to disgorge Rs 50,51,116 jointly and severally with interest at 12 per cent a year from 31 December 2021, paid to the Investor Protection and Education Fund within 45 days. It imposed penalties under section 15HA of Rs 10,00,000 on Mr Singhal and Rs 5,00,000 on Ms Jain, Rs 15,00,000 in all.

The record does not show how the information passed between the two, whether the order was appealed or whether the disgorgement and penalties were paid. No criminal case is mentioned.

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. 2024-07-30 SEBI 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
• 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.