SEBI adjudication orders on illiquid stock options at BSE (2025 batch)

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 adjudicating officers issued 136 orders in 2025 on reversal trades in illiquid BSE stock options in 2014-15. The four sampled orders each impose Rs 5,00,000 under section 15HA, whether the alleged artificial volume was 80,000 units or more than 34 lakh units.

The record

What was ordered

Civil penalty

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Disgorgement

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Prejudgment interest

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Total relief

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Alleged gain

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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.

What is alleged to have happened

This record groups 136 separate SEBI adjudication orders published between 2025-01-27 and 2025-12-19, each issued by an adjudicating officer to one noticee (or a small group) in the matter of dealings in illiquid stock options at BSE. It is read from a sample of orders, not from all 136; the individual noticees beyond the sample are not named here.

SEBI's investigation covered stock options trading on BSE between April 2014 and September 2015. It found that most trades in that segment, roughly 2.9 lakh trades or more than 81 percent, were reversals: a client bought or sold a contract and then took the opposite position with the same counterparty on the same day, often at prices that differed sharply. SEBI treated these trades as non-genuine because ownership did not meaningfully change hands, and said they inflated reported volume in contracts that otherwise barely traded. The investigation identified about 14,720 entities that executed such trades, and each was pursued in a separate adjudication proceeding.

In each order SEBI alleged that the noticee's trades created a false or misleading appearance of trading and breached Regulations 3(a) to (d), 4(1) and 4(2)(a) of the PFUTP Regulations 2003, and the adjudicating officer, after a show cause notice and a hearing opportunity, found the violation proved and penalised the noticee under section 15HA of the SEBI Act. Several of the later orders note that the noticee had first been offered SEBI's settlement scheme. Four orders were sampled. Accentuate Tradecom Private Limited (20 March 2025) was alleged to have made 2 non-genuine trades in one contract on 9 March 2015, creating 80,000 units of artificial volume. Sudha Jain (26 March 2025) was alleged to have made reversal trades in the same segment. Nimisha Hemani (14 October 2025) was alleged to have made 2 trades in one contract creating 1,04,000 units. Ashirwad Tie Up Private Limited (17 December 2025) was alleged to have made 11 trades in 3 contracts totalling 34,60,000 units, and the order records that it did not use the settlement scheme.

Each sampled order imposes Rs 5,00,000 under section 15HA. Across the four orders the volumes alleged range from 80,000 units to 34,60,000 units, yet the penalty does not scale with volume. The record does not show whether other orders in the 2025 batch carry a different figure.

The record does not show the outcome of any appeal to the Securities Appellate Tribunal, whether penalties were paid, the profit or loss of any noticee, or the circumstances of noticees outside the sample. Because the penalties are set by statute for each noticee, no total for the batch is stated here.

This library tags the batch as matched orders, because the conduct found was pre-arranged reversal trades between the same parties. 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.

• Matched orders — see how it works, what statute it engages, and every other action tagged the same way.

Timeline

1. 2025-01-27 First order of the year in the batch published
2. 2025-12-19 Last order of the year in the batch published (136 orders in 2025)

Primary documents

Everything on this page derives from the documents below. Where our summary and the primary document disagree, the primary document is right.

• First order in the batch (SEBI order page)
• Last order in the batch (SEBI order page)
• SEBI adjudication orders listing

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.