SEBI v. Rohan Banerjee and Rahul Banerjee (front running of Tusk Investment orders, 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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SEBI found that an equity analyst at Tusk Investment placed trades for himself and his father just ahead of the firm's large orders, earning about Rs 47.2 lakh. The order required disgorgement of that sum, one-year market bans and penalties of Rs 10 lakh and Rs 5 lakh.

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

On 28 March 2025 a SEBI quasi-judicial authority issued an order against Rohan Banerjee, an equity analyst at Tusk Investment Limited, and his father Rahul Banerjee. SEBI had investigated trading between 1 January 2021 and 31 August 2023.

SEBI alleged that the son placed Tusk's orders by phone with dealers at its brokers, so he knew of large orders before they reached the market, and used that knowledge to trade first in his own account and in his father's. It cited 364 instances in equities and 164 in equity derivatives for the son, and 74 equity instances for the father, and said matching IP addresses and devices showed the son placed the father's trades as well. The notice of 19 June 2024 invoked section 12A of the SEBI Act and Regulations 3 and 4 of the PFUTP Regulations. A settlement application filed in July 2024 was later withdrawn.

The authority accepted the account and found wrongful gains of Rs 47,22,325, made up of about Rs 28.5 lakh in equities and Rs 10.4 lakh in derivatives for the son and about Rs 8.3 lakh in equities for the father. The father's trading was treated as part of an arrangement carried out with common knowledge.

The order directed both to disgorge Rs 47,22,325 jointly and severally to the Investor Protection and Education Fund, restrained both from the securities market for one year, and froze their assets other than for paying these sums. Under section 15HA it imposed penalties of Rs 10,00,000 on Rohan Banerjee and Rs 5,00,000 on Rahul Banerjee, Rs 15 lakh in total.

The record does not show what loss Tusk suffered, whether either man appealed, or whether the sums were paid. The order is a regulatory sanction, not a criminal conviction.

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. 2025-03-28 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.