Supreet Singh Luthra and Ajay Bhatia have settled an insider trading case with market regulator Securities and Exchange Board of India (SEBI) by jointly paying a settlement amount of Rs1.44 crore, along with disgorgement of unlawful gains totalling Rs68.47 lakh, plus 12 % interest per annum. As part of the settlement, both applicants have also undertaken a voluntary six-month debarment from participating in the Indian securities market.
Both Mr Luthra and Mr Bhatia filed suo-motu settlement applications under the SEBI (Settlement Proceedings) Regulations, 2018. They proposed to settle, by neither admitting nor denying the findings of fact and conclusions of law, the enforcement proceedings that could be initiated against them for alleged violations of Sections 12A(d) and 12A(e) of the SEBI Act, 1992. These violations related to trading in securities while in possession of, and communicating, unpublished price sensitive information (UPSI) under the SEBI (Prohibition of Insider Trading) Regulations, 2015.
The case arose from an announcement by Adani Green Energy Ltd (AGEL) on 8 April 2022. AGEL informed BSE about the issuance of 2 crore equity shares to IHC Capital Holding LLC, or its subsidiary or affiliate, on a preferential basis at Rs1,923.25 per share, aggregating Rs3,850 crore.
Shortly thereafter, AGEL issued a press release stating that International Holding Company (IHC) would invest US$2bn (billion) in the Adani group’s green portfolio. Following this, AGEL shares surged, recording a 7.20% close-to-close variation on the National Stock Exchange (NSE).
The information about the preferential issue was classified as UPSI and was deemed applicable not only to AGEL but also to Adani Enterprises Ltd (AEL) and Adani Transmission Ltd (ATL).
Mr Bhatia, as the managing director and chief executive officer (MD&CEO) of QuantLase Lab LLC (a subsidiary of IHC), was considered a ‘connected person’ and ‘insider’ under the PIT Regulations. He was alleged to have received UPSI via emails on 2nd April and 4 April 2022 from insiders of AGEL. He further allegedly communicated this UPSI to Mr Luthra and executed trades in AGEL, AEL, ATL, and AEL futures during the UPSI period. These trades reportedly yielded unlawful gains of Rs55.34 lakh, including both actual and notional profits.
Mr Luthra, who provided VAT consulting services to Mr Bhatia, was in constant telephonic contact with him during the UPSI period. By virtue of this association, he was also considered a ‘connected person’ under the PIT Regulations. He allegedly traded in AGEL, AEL, and ATL during the UPSI period, generating unlawful gains of approximately Rs13.13 lakh.
Both applicants filed settlement applications to resolve potential enforcement proceedings. Mr Bhatia proposed to pay Rs1.04 crore as the settlement amount, along with disgorgement of Rs55.34 lakh plus interest at 12% per annum and voluntary debarment from the securities market for six months. Mr Luthra proposed to pay Rs40 lakh as the settlement amount, along with disgorgement of Rs13.13 lakh plus interest at 12% per annum and a similar six-month voluntary debarment.
SEBI’s internal committee (IC) deliberated on the facts of the case and the proposed settlement terms. The high-powered advisory committee (HPAC), at its meeting on 29 July 2024, recommended that both cases be settled on the revised terms. The panel of whole-time members (WTMs) of SEBI approved the recommendations on 23 June 2025.
Following notices of demand in July 2025, both applicants remitted the settlement and disgorgement amounts with applicable interest. SEBI confirmed receipt of the payments in August 2025. Both applicants also confirmed their undertaking to voluntarily restrain themselves from the Indian securities market for six months from the date of the settlement order.
On 16 September 2025, SEBI, exercising powers under Section 15JB read with Section 19 of the SEBI Act and Regulation 23 of the settlement regulations, passed the settlement order. The order clarified that enforcement proceedings for the alleged insider trading violations stand settled with respect to both Mr Luthra and Mr Bhatia, subject to compliance with the agreed financial terms and market debarment.
The order also noted that it is without prejudice to SEBI’s rights under Regulations 28 and 31 of the settlement regulations to initiate proceedings if any representation made by the applicants is later found untrue, if settlement terms are breached, or if discrepancies in payments arise.
