SEBI v. Sunny Bhatia and others (front running Sarvottam Securities trades, 2026)

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 March 2026 SEBI order found that a broker's dealer and three relatives traded ahead of a large client's orders in equity derivatives over several years. It directs disgorgement of about Rs 2.65 crore from the dealer, two-year market restraints on all four and penalties totalling Rs 23 lakh.

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

2.3m 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

The order of 24 March 2026 was issued by a SEBI chief general manager as quasi-judicial authority. The four noticees are Sunny Bhatia, who worked as a dealer at the broker Findoc Investmart Private Limited, and members of his family: his wife Surbhi Chopra Bhatia, his mother Mamta Rani and his father Kumar Ashok. The trades concerned were in the equity derivatives segment, placed through Findoc and Kotak Securities.

SEBI acted on a report from NSE that the noticees were placing orders just before those of a large client, Sarvottam Securities Pvt. Ltd., and squaring them off against the client's orders. The show-cause notice of 28 November 2025 alleged that Mr Bhatia had advance knowledge of Sarvottam's orders, managed the accounts of his relatives and traded for them, that the group front-ran the client over 2018 to 2022, and that the three relatives aided him. It alleged unlawful gains of about Rs 2.65 crore and breaches of section 12A of the SEBI Act and the PFUTP Regulations.

The noticees replied that front running needs proof of prior knowledge and misuse of confidential information, and that the overlap in trading could be explained by liquidity and market signals. The order does not accept that reply. It holds the allegations proved against all four noticees, and records that an earlier adjudication order of October 2025 had already imposed a joint penalty on the same four in a separate front-running matter involving another large client.

The directions require Mr Bhatia to disgorge Rs 2,64,79,000 with interest at 10 per cent a year from 31 December 2022, payable to the Investor Protection and Education Fund, and restrain all four from the securities market for two years. Penalties under section 15HA are Rs 8 lakh on Mr Bhatia and Rs 5 lakh on each relative, Rs 23 lakh in all.

The record does not show an appeal, whether the disgorgement was paid, or the loss to the client, which the order does not quantify. It describes no criminal case.

This library tags the matter as front running. 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.

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

Timeline

1. 2026-03-24 SEBI final order with disgorgement, restraint and penalties

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
• SEBI 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.