SEBI v. National Stock Exchange of India and others (TAP network architecture, settlement, 2024)

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. 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-87337-market-abuse-2024) by email

In October 2024 SEBI approved a settlement under which the National Stock Exchange of India paid Rs 643.05 crore, for itself and nine current or former officials, to close proceedings over the design and oversight of its Trading Access Point network software. The applicants neither admitted nor denied the allegations, and eight of the ten also undertook community service.

The record

Structured fields for this action, as recorded in our case library.
Agency	SEBI (India)
Date filed	2024-10-04
Date resolved	2024-10-04
Status	settled
Asset class	equities
Instruments	NSE trading system access
Venue	NSE
Criminal parallel	No
Defendants	National Stock Exchange of India Limited (entity) ; Vikram Limaye (individual) ; Umesh Jain (individual) ; G. M. Shenoy (individual) ; Narayan Neelakantan (individual) ; V. R. Narasimhan (individual) ; Kamala K. (individual) ; Nilesh Tinaikar (individual) ; R. Nandakumar (individual) ; Mayur Sindhwad (individual)
Also named elsewhere	National Stock Exchange of India Limited is named in 2 other matters
Techniques

What was ordered

Civil penalty: —
Disgorgement: —
Prejudgment interest: —
Total relief: —
Alleged gain: —
Penalty as published: 6.4bn 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 October 2024. The applicants are the National Stock Exchange of India and nine current or former officers, including Vikram Limaye, Umesh Jain, G. M. Shenoy and Nilesh Tinaikar. The matter concerned the Trading Access Point, software NSE placed on trading members' servers from 2008 to manage their connection to the exchange's trading system.

SEBI had examined whether members could bypass that software, how NSE handled a complaint of 20 November 2013, and whether lapses by the exchange breached securities law. A show cause notice of 28 February 2023 alleged that NSE did not act to prevent a possible bypass, did not bring the complaint and the system's deficiencies to its technology committee, delayed appointing a chief information security officer, did not implement encryption in the software and did not designate its technology head as key management personnel. The notice invoked regulation 4(1) of the PFUTP Regulations together with exchange-regulation and code-of-ethics provisions, and sought directions and penalties.

While the proceedings were pending, the applicants applied to settle without admitting or denying findings. After several rounds of talks, SEBI's advisory committee asked for the amount to be re-examined against the revenue and profit earned from the software subscriptions, and a panel of whole-time members accepted a composite payment of Rs 643.05 crore (Rs 6,43,05,30,000) by NSE for itself and the other applicants. All applicants except NSE and Mr Shenoy also undertook at least 14 days of pro bono community service. NSE paid the sum on 25 September 2024.

The order disposes of the notice but allows SEBI to restore proceedings if disclosure was not full and true or an undertaking is breached.

The record does not show SEBI's findings on the merits, because a settlement order makes none, nor any investor loss or any link to specific manipulative trading.

This library has no technique that fits exchange system design and oversight failures, so the matter is tagged with none. It is included because the notice invoked the fraud regulation. 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.

Timeline

2024-10-04 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.

The linked release is published by the issuing regulator under its own terms. Our summary and narrative above are our own writing.

Record added October 8, 2026. submit a correction.