Description

SAT grants partial stay on SEBI debarment order for Sandeep Ghate and Instafin Financial Advisors LLP after 50% penalty deposit. Trading and market access restrictions temporarily lifted pending appeal.

Summary

NSE has issued updated directions following Securities Appellate Tribunal (SAT) order dated December 18, 2025, granting partial stay on SEBI’s debarment order for Sandeep Ghate (PAN: AACPG0447M) and Instafin Financial Advisors LLP (PAN: AAGFI3779L). After both entities deposited 50% of the imposed penalty within the stipulated four-week period, the operation of SEBI’s original debarment order has been stayed for these two appellants. The debarment restrictions on four other entities named in the original November 28, 2025 order remain in effect.

Key Points

  • SAT order dated December 18, 2025 grants stay on debarment for Sandeep Ghate and Instafin Financial Advisors LLP
  • Stay is conditional on deposit of 50% penalty amount within four weeks from SAT order date
  • Both entities have successfully deposited the required 50% penalty amount
  • Penalty deposits are held in interest-bearing accounts with lien marked to SEBI
  • Members must immediately comply with SAT order and lift restrictions on these two entities
  • Original SEBI Order No. QJA/SS/CFID/CFID-SEC5/31818/2025-26 dated November 28, 2025 involved six entities
  • Four other entities remain debarred: Droneacharya Aerial Innovations Limited (2 years), Prateek Srivastava (2 years), Nikita Srivastava (2 years), and Micro Infratech Pvt. Ltd. (1 year)
  • Appeals are Appeal No. 542 of 2025 and Appeal No. 543 of 2025 before SAT Mumbai
  • SAT has granted SEBI six weeks to file reply and appellants three weeks thereafter for rejoinder

Regulatory Changes

Partial modification of enforcement action: The original blanket debarment order issued via NSE circular NSE/INVG/71553 dated November 28, 2025 is modified for two specific entities. The stay represents a temporary suspension of market access restrictions pending full adjudication of the appeal. This does not set aside the original SEBI findings but creates interim relief mechanism upon penalty deposit.

Compliance Requirements

  • NSE members must immediately lift all restrictions on market access for Sandeep Ghate and Instafin Financial Advisors LLP
  • Members should allow these two entities to access securities market and engage in buying, selling, or dealing in securities including mutual fund units
  • Members must continue enforcing debarment restrictions on the remaining four entities: Droneacharya Aerial Innovations Limited, Prateek Srivastava, Nikita Srivastava, and Micro Infratech Pvt. Ltd.
  • Members should refer to consolidated list of debarred entities on NSE website at https://www.nseindia.com/regulations/member-sebi-debarred-entities
  • Members with queries should contact NSE at dl-invsg-all@nse.co.in
  • Full SAT order details available at https://satweb.sat.gov.in/orders

Important Dates

  • November 28, 2025: Original SEBI debarment order issued
  • December 18, 2025: SAT order granting conditional stay
  • January 09, 2026: NSE circular issued confirming penalty deposit and directing compliance
  • Four weeks from December 18, 2025: Deadline for 50% penalty deposit (completed)
  • Six weeks from December 18, 2025: SEBI’s deadline to file reply in appeal proceedings
  • Three weeks after SEBI reply: Appellants’ deadline to file rejoinder

Impact Assessment

Market Impact: Limited direct market impact as stay applies only to two of six originally debarred entities. However, establishes important precedent for interim relief mechanism in SEBI enforcement actions.

Operational Impact: NSE members must update their internal compliance systems to remove restrictions on Sandeep Ghate and Instafin Financial Advisors LLP while maintaining vigilance on remaining debarred entities. Creates operational complexity in tracking partial modifications to enforcement orders.

Legal Precedent: Demonstrates SAT’s willingness to grant stays upon substantial penalty deposit (50%), balancing regulatory enforcement with appellants’ rights to appeal. The interest-bearing account mechanism with lien to SEBI protects regulatory interests while allowing market access.

Entity-Specific Impact: Sandeep Ghate and Instafin Financial Advisors LLP can resume securities market activities pending final appeal outcome. Droneacharya Aerial Innovations Limited and associated parties remain restricted from market participation.

Impact Justification

Updates previous debarment order with SAT stay for two entities after penalty deposit. Limited market impact as other entities remain debarred, but significant for affected parties and establishes regulatory precedent.