Description

SAT order dated 17.12.2025 in Appeal No. 535 of 2025 directing appellants to deposit Rs. 15 Crore and provide property lien worth Rs. 12 Crore against SEBI's interim order impounding Rs. 43.76 Crore for insider trading in IEX scrip.

Summary

The Securities Appellate Tribunal (SAT) passed an order on December 17, 2025 in Appeal No. 535 of 2025 filed by Narendra Kumar and three others (Virender Singh, Bindu Sharma, and Sanjeev Kumar) against SEBI’s ex-parte interim order dated October 15, 2025. The SEBI interim order had directed impounding of Rs. 43.76 Crores and restrained the appellants from accessing the securities market for alleged insider trading in the scrip of IEX (Indian Energy Exchange). SAT has granted conditional interim relief requiring deposit of Rs. 15 Crore in cash and lien on immovable properties worth Rs. 12 Crore.

Key Points

  • Four appellants challenged SEBI’s ex-parte interim order impounding Rs. 43.76 Crore for insider trading in IEX scrip
  • Original SEBI order also imposed securities market access ban on the appellants
  • Appellants initially offered to deposit 50% of impounded amount; later revised to 25% plus property security
  • SEBI opposed the 50% deposit offer and demanded higher security
  • SAT bench comprised Justice P.S. Dinesh Kumar (Presiding Officer), Ms. Meera Swarup (Technical Member), and Dr. Dheeraj Bhatnagar (Technical Member)
  • Final SAT order requires Rs. 15 Crore cash deposit plus lien on Rs. 12 Crore worth immovable properties

Regulatory Changes

No new regulatory changes introduced. This circular informs market participants about SAT’s appellate order modifying the interim enforcement measures in an ongoing insider trading investigation.

Compliance Requirements

For the Appellants (Narendra Kumar, Virender Singh, Bindu Sharma, Sanjeev Kumar):

  • Submit affidavit to SEBI with certificate of valuation of immovable properties by certified valuer empaneled with Income Tax department within one week from December 17, 2025
  • File copy of the same affidavit and valuation certificate with SAT
  • Deposit Rs. 15 Crore in a nationalized bank with lien marked in favour of SEBI
  • Provide lien on immovable properties worth Rs. 12 Crore as additional security
  • Comply with strict timelines for completion of proceedings before SEBI

Important Dates

  • October 15, 2025: SEBI passed ex-parte interim order impounding Rs. 43.76 Crore and market access ban
  • December 17, 2025: SAT passed the appellate order providing conditional interim relief
  • Within one week from December 17, 2025: Deadline for appellants to submit property valuation affidavit to SEBI and SAT
  • Ongoing: SEBI proceedings against the appellants to continue with strict timelines

Impact Assessment

Market Impact: Medium - The case involves insider trading allegations in IEX scrip, a significant market participant. While the individuals are now subject to restrictions and financial security requirements, the SAT order provides some interim relief allowing proceedings to continue.

Enforcement Impact: High - Demonstrates SEBI’s aggressive stance on insider trading with large impounding amounts (Rs. 43.76 Crore) and market access restrictions. However, SAT’s appellate relief shows judicial oversight balancing enforcement with fairness.

Precedent Value: This order establishes parameters for interim relief in large insider trading cases, where appellants can secure partial relief through combination of cash deposits and property liens rather than full impounding amounts.

Investor Awareness: The circular serves as a warning about serious consequences of insider trading, including substantial financial penalties, market access bans, and requirement to provide significant security even during appellate proceedings.

Impact Justification

Major insider trading enforcement action involving Rs. 43.76 Crore impounding order and market access restrictions. SAT appellate order provides interim relief while maintaining significant financial and property security requirements.