Dolphin Infotek

Enforcement

Supreme Court to SAT: Profit Motive Is Irrelevant Under the 2015 PIT Regulations — The Tara Jewels Ruling

Primary source: Securities and Exchange Board of India v. Rajeev Vasant Sheth & Ors., 2026 INSC 826, Civil Appeal No. 4905 of 2022, decided by the Supreme Court (Sanjay Karol and Nongmeikapam Kotiswar Singh, JJ.) on August 11, 2026, reversing the SAT's judgment dated April 19, 2022 in

Case Law

Supreme Court: Purpose and Profit Are Irrelevant Once UPSI Trading Is Shown

Primary source: Supreme Court of India, Securities and Exchange Board of India v. Rajeev Vasant Sheth & Ors., 2026 INSC 826 (decided 11 August 2026, Bench: Justice Sanjay Karol and Justice Nongmeikapam Kotiswar Singh). Verify against the official judgment on main.sci.gov.in once uploaded. On 11 August 2026,

PIT Enforcement

RHI Magnesita Order: When 'Frequent Communication' Doesn't Make You a Connected Person

Primary source: Adjudication Order in the matter of insider trading activities in the scrip of RHI Magnesita India Ltd., Order No. Order/JS/YK/2026-27/32473, dated July 7, 2026 (Adjudicating Officer: Jai Sebastian). Why this matters Most of the enforcement orders we've covered on this blog

Enforcement

SEBI's Warning to Reliance's Compliance Officer: When Monitoring Duty Becomes the Violation

This post is based on SEBI's administrative warning letter dated June 24, 2026 (Ref. No. 1/14806/2026), addressed to the Company Secretary & Compliance Officer of Reliance Industries Limited, and on RIL's disclosure to BSE and NSE dated July 6, 2026, which carries the SEBI

Enforcement

SEBI Warns Reliance's Compliance Officer Over a Rs. 6,385 Trade: What It Means for Every Compliance Officer

Primary source: SEBI Administrative Warning Letter Ref. No. 1/14806/2026 dated June 24, 2026, issued to the Company Secretary & Compliance Officer of Reliance Industries Limited, disclosed by RIL under Regulation 30 of the LODR Regulations on July 6, 2026. The disclosure and the full text of SEBI'

Enforcement

When 'Frequent Communication' Isn't Enough: SEBI Exonerates a Noticee in the RHI Magnesita Insider Trading Case

Primary source: Adjudication Order No. Order/JS/YK/2026-27/32473 in the matter of insider trading activities in the scrip of RHI Magnesita India Ltd., dated July 7, 2026, published by SEBI's Adjudicating Officer, Mr. Jai Sebastian. Read the full order on sebi.gov.in. Why this

Enforcement

SEBI Warns Reliance's Compliance Officer: A Regulation 9(3) Monitoring Failure, Not a Tipping Case

Primary source: SEBI Administrative Warning Letter Ref. No. 1/14806/2026, dated June 24, 2026, issued to the Company Secretary & Compliance Officer of Reliance Industries Limited, disclosed via RIL's Regulation 30 filing dated July 6, 2026 (news coverage; letter filed with BSE/NSE). Every FAQ post on

Enforcement

SEBI Exonerates in RHI Magnesita Case: What the Order Reveals About the Evidentiary Bar for Insider Trading

Primary source: SEBI Adjudication Order No. Order/JS/YK/2026-27/32473, In the matter of insider trading activities in the scrip of RHI Magnesita India Ltd., dated July 7, 2026 (SEBI order page). Most of what compliance officers read out of SEBI's enforcement docket is a penalty

Panel Recap

From experts panel - Demystifying Insider Trading Regulations: A Masterclass on Compliance and the Structured Digital Database

Insider trading compliance has evolved from a basic regulatory checklist into a highly scrutinized, data-driven framework. In a recent masterclass hosted by the Institute of Company Secretaries of India (ICSI), experts from the Securities and Exchange Board of India (SEBI), the National Stock Exchange (NSE), and industry veterans broke

SDD

Designing an Audit Trail That Survives a SEBI Inspection

Every compliance vendor's pitch deck has a slide about audit trails, and most of them mean "we log things" — a table somewhere with a timestamp and a user ID. That's not what actually survives an inspection. Having built the audit layer under our insider-

UPSI

How We Model UPSI Data

The last post was about proving nothing's been tampered with after the fact. This one is upstream of that — before you can build a trustworthy audit trail around UPSI (Unpublished Price Sensitive Information), you have to decide how to model the data itself, and that turns out to

Esops

Vesting Schedules Are a State Machine, Not a Formula

ESOP management sounds like the easiest module in our whole compliance suite until you actually sit down to encode a vesting schedule. On paper it's "25% per year over four years." In practice it's a small state machine with more edge cases than the

Case Law

Reliance, the Jio-Facebook Leak, and What 'Prompt' Disclosure Actually Means

Source: SEBI's original adjudication order dated June 20, 2022 in the matter of Reliance Industries Limited, which we read directly. The 2025 Securities Appellate Tribunal (SAT) appeal outcome and December 2025 Supreme Court dismissal are reported here based on secondary legal commentary and news coverage, which we have

Case Law

SEBI's Infosys Order: The First Real-World Test of the 'Frequent Communication' Connected-Person Test

Source: SEBI's Final Order dated January 31, 2025 in the matter of insider trading activities in the scrip of Infosys Limited, read directly from the published order. Why this case matters We've already covered, in a companion article, how the December 2024 amendment wrote "frequent

Designing an Audit Trail That Survives a SEBI Inspection

Every compliance vendor's pitch deck has a slide about audit trails, and most of them mean "we log things" — a table somewhere with a timestamp and a user ID. That's not what actually survives an inspection. Having built the audit layer under our insider-

Amendments

SEBI's 2025 PIT Amendment: UPSI Expands to 16 Categories, Plus SDD and Trading Window Changes

Source: Securities and Exchange Board of India (Prohibition of Insider Trading) (Amendment) Regulations, 2025 — SEBI/LAD-NRO/GN/2025/235, notified in the Gazette of India on March 11, 2025, coming into force on the ninetieth day after publication (i.e., June 9, 2025). This is the most substantive change

Amendments

Casting a Wider Net: SEBI's December 2024 Redefinition of 'Connected Person' and 'Relative'

Source: Securities and Exchange Board of India (Prohibition of Insider Trading) (Third Amendment) Regulations, 2024 — SEBI/LAD-NRO/GN/2024/215, notified in the Gazette of India on December 4, 2024, effective the same day. Why this amendment matters Everything in the PIT Regulations — disclosure, pre-clearance, contra-trade, trading

Case Law

Kunal Kashyap v. SEBI: How Frequent Communication Became Evidence of Insider Trading

Source: This article is based on SEBI's original order dated July 8, 2021 in the matter of Mr. Kunal Kashyap and Allegro Capital Pvt. Ltd. (Biocon Ltd.), and on the Securities Appellate Tribunal's subsequent ruling upholding that order, as analyzed in "Redefining Insider Trading? Unpacking

Enforcement

Four SEBI Orders From 2025: What Recent Insider Trading Enforcement Actually Penalizes

Source: This roundup is based on four SEBI adjudication orders issued between August and December 2025 — Mastek Ltd., Swan Energy Ltd., Nucleus Software Exports Ltd., and Refex Industries Ltd. — read directly from the published orders. Why a roundup, and why these four together Reading a handful of adjudication orders side

Trading Related

SEBI's Trading-Related FAQs: What Actually Counts as 'Trading' Under PIT Regulations

Source: SEBI's Comprehensive FAQs on SEBI (PIT) Regulations, 2015, dated December 31, 2024 — Section A, "Trading Related" (Q.1–Q.4). Why this section matters Before any of the machinery of the PIT Regulations — pre-clearance, trading windows, contra-trade — can apply, you need a settled

Pledge

SEBI's FAQs on Pledging Shares: Bona Fide Defense, Valuation, and Form C Reporting

Source: SEBI's Comprehensive FAQs on SEBI (PIT) Regulations, 2015, dated December 31, 2024 — Section C, "Pledge" (Q.13–Q.15). Why this section matters Having established (Section A, Q1) that pledge/invoke/revoke is "trading," SEBI's FAQ turns to the practical mechanics:

Disclosures

SEBI's Disclosure FAQs: Getting System Driven Disclosures and Thresholds Right

Source: SEBI's Comprehensive FAQs on SEBI (PIT) Regulations, 2015, dated December 31, 2024 — Section E, "Disclosures including System Driven Disclosures" (Q.17–Q.24). Why this section matters Disclosure obligations under Regulation 7 are where insider trading compliance meets the exchange's automated System Driven

Pre-clearance

SEBI's Pre-clearance FAQs: Where ESOP and Off-Market Exemptions Actually End

Source: SEBI's Comprehensive FAQs on SEBI (PIT) Regulations, 2015, dated December 31, 2024 — Section F, "Pre-clearance" (Q.25–Q.28). Why this section matters Pre-clearance is the day-to-day compliance mechanism most designated persons actually interact with, so ambiguity here creates friction constantly

Trading Window Closure

SEBI's Trading Window Closure FAQs: Why Silence Isn't Compliance

Source: SEBI's Comprehensive FAQs on SEBI (PIT) Regulations, 2015, dated December 31, 2024 — Section G, "Trading Window Closure" (Q.29–Q.35). Why this section matters Trading window closure is the blunt instrument of PIT compliance — it stops trading for a defined class of people during

Contra-trade

SEBI's Contra-Trade FAQs, Decoded: ESOPs, Corporate Actions, and the Six-Month Clock

Source: SEBI's Comprehensive FAQs on SEBI (PIT) Regulations, 2015, dated December 31, 2024 — Section H, "Contra-trade" (Q.36–Q.47, including Q.42A and Q.44A). This is the largest section of SEBI's FAQ document, which itself signals how many edge cases this