Description

Securities Appellate Tribunal order dated December 15, 2025 regarding appeals against SEBI's disgorgement, penalty and debarment order in front running case involving Fidelity Group funds.

Summary

The Securities Appellate Tribunal (SAT) issued an order on December 15, 2025, addressing three appeals (Appeal No.459 of 2022, Appeal No.556 of 2022, and Appeal No.557 of 2022) filed against SEBI’s Whole Time Member (WTM) order dated June 3, 2022. The appeals challenge SEBI’s directions requiring disgorgement of amounts, payment of penalties, and debarment from accessing securities markets in connection with front running activities involving various funds of Fidelity Group. The appellants include Sumit Kanungo, Riya Jain, Alka Dhadda, Arushi Dhadda, and Vaibhav Dhadda.

Key Points

  • Three appeals filed against common SEBI order dated June 3, 2022
  • Appellants: Sumit Kanungo, Riya Jain (Appeal No.459/2022); Alka Dhadda, Arushi Dhadda (Appeal No.556/2022); Vaibhav Dhadda (Appeal No.557/2022)
  • SAT bench comprised Justice P.S. Dinesh Kumar (Presiding Officer), Ms. Meera Swarup (Technical Member), and Dr. Dheeraj Bhatnagar (Technical Member)
  • Original SEBI order directed disgorgement, penalties, and market debarment for specified periods
  • Appeals heard simultaneously on August 6, 2025 and order pronounced on December 15, 2025
  • Matter relates to front running activities involving Fidelity Group funds

Regulatory Changes

No new regulatory changes introduced. This circular communicates a SAT order reviewing existing SEBI enforcement actions.

Compliance Requirements

Market participants should note:

  • SEBI’s enforcement actions regarding front running remain subject to appellate review
  • Entities and individuals must comply with SEBI orders unless modified or set aside by SAT
  • The final outcome of these appeals will determine the enforcement obligations for the named appellants

Important Dates

  • June 3, 2022: Original SEBI WTM order passed
  • 2022: Appeals filed (Appeal No.459, 556, and 557)
  • August 6, 2025: Appeals heard and reserved for orders
  • December 15, 2025: SAT order pronounced
  • February 6, 2026: BSE circular disseminating SAT order

Impact Assessment

Market Impact: Low - The order pertains to specific individuals and does not introduce market-wide regulatory changes.

Enforcement Precedent: Medium - SAT’s decision in front running cases provides guidance on disgorgement, penalties, and debarment measures, which may influence future enforcement actions.

Individual Impact: High - The appellants face significant consequences including potential disgorgement obligations, monetary penalties, and market access restrictions depending on SAT’s final determination.

Note: The circular provides the SAT order header and preliminary information but does not include the complete tribunal decision or outcome of the appeals. Market participants should refer to the full order for complete details on SAT’s findings and directions.

Impact Justification

SAT order pertaining to specific individuals in front running case; limited direct market-wide impact but significant for enforcement precedent