SEBI v. Mandar Ulhas Bhatkar and Vikrant Bhimrao Kadam (front running of SVI Consolidated trades, 2025)

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 January 2025 SEBI found that a dealer for a large client, SVI Consolidated Pvt. Ltd., had traded ahead of its orders through his friend's account. The order directed disgorgement of Rs 34,26,342.95, restrained both men for 6 months and imposed penalties of Rs 5,00,000 each.

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

1m 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

SEBI quasi-judicial authority G. Ramar issued the final order on 28 January 2025. The noticees were Mandar Ulhas Bhatkar and Vikrant Bhimrao Kadam. SEBI investigated trading from November 2020 to September 2021 on NSE in the cash and equity derivatives segments.

SEBI alleged that Mr Kadam, a dealer for the 'big client' SVI Consolidated Pvt. Ltd. at its broker, used knowledge of the client's impending orders to trade ahead of them in Mr Bhatkar's account, which Mr Bhatkar made available. A related broker settlement describes the two as childhood friends and Mr Bhatkar as having transferred funds from Mr Kadam to his own broker to enable the trading.

The order finds the front running established over about 11 months and holds both noticees liable to disgorge the wrongful gains made through the account. It treats the dealer as the beneficiary through his friend's account and cites authority that gains can be recovered from any point in the chain.

SEBI directed both to disgorge Rs 34,26,342.95 jointly and severally to the Investor Protection and Education Fund within 45 days, restrained both from the securities market for 6 months with their holdings frozen, froze the bank account of Mr Kadam's mother save for compliance, and imposed section 15HA penalties of Rs 5,00,000 on each, Rs 10,00,000 in all.

The record does not show whether the order was appealed or whether the sums were paid. The broker's separate settlement over its supervision is not part of this record. 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. 2025-01-28 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.