SEBI v. Anupam Gupta and Nitin Kumar Garg (insider trading, Nucleus Software Exports, 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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A SEBI adjudicating officer found that an employee of Nucleus Software told his cousin about strong quarterly results before announcement, and that the cousin bought shares, funded partly by the employee, and sold after the price jumped for a profit of about Rs 8.98 lakh. Penalties of Rs 10 lakh and Rs 15 lakh were imposed.

The record

What was ordered

Civil penalty

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Disgorgement

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Prejudgment interest

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Total relief

—

Alleged gain

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Penalty as published

2.5m 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 23 September 2025 a SEBI adjudicating officer issued an order against Anupam Gupta and his cousin Nitin Kumar Garg, an employee of Nucleus Software Exports Limited. The company announced results for the quarter and year to March 2023 on 26 May 2023, with quarterly profit up about 76 per cent, and the share price rose 19.99 per cent that day and 58 per cent in four trading days. SEBI investigated trading from 1 March to 16 June 2023.

SEBI alleged that Mr Garg passed the unpublished results to Mr Gupta, who bought 3,020 shares in three tranches on 13 and 17 April and 25 May 2023 at an average of about Rs 630 and sold them on 26, 29 and 30 May at about Rs 950, making a profit of Rs 8.98 lakh. It pointed to the cousins' admitted talks about the company's performance, WhatsApp chats, and money sent from Mr Garg and his father to Mr Gupta's account that was used to trade the stock.

The officer found it established on a balance of probabilities that Mr Garg communicated the information and that Mr Gupta traded while holding it. The officer was particularly struck by the largest purchase, Rs 13.55 lakh on 25 May 2023, the day before the results, made on the same day as Mr Garg's largest single transfer of Rs 5 lakh to Mr Gupta, and rejected the argument that the timing was chance, since the results date had been public since 18 May.

Under section 15G of the SEBI Act the order imposed a penalty of Rs 10,00,000 on Mr Gupta and Rs 15,00,000 on Mr Garg, Rs 25 lakh in total. It records no investor loss and no earlier violation, and it ordered no disgorgement or market ban.

The record does not show whether either man appealed or paid. It is a civil penalty, not a criminal conviction.

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. 2025-09-23 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.