SEBI Bars 4 Entities Linked to Sarvottam Securities, Orders Disgorgement of ₹2.65 Crore
Moneylife Digital Team 25 March 2026
Market regulator Securities and Exchange Board of India (SEBI) has imposed penalties totalling ₹23 lakh on four individuals in a front-running case linked to Sarvottam Securities Pvt Ltd, while also flagging unlawful gains of about ₹2.65 crore made through misuse of non-public information.
 
In its order, SEBI has directed the noticee, Sunny Bhatia, to disgorge ₹2.65 crore, along with interest at 10%pa (per annum) calculated from 31 December 2022 till the date of the order.
 
The regulator has also barred all four noticees, including Mr Bhatia, his wife Surbhi Chopra Bhatia and his parents, Mamta Rani and Kumar Ashok, from accessing the securities market. They have been prohibited from buying, selling, or dealing in securities, directly or indirectly, for a period of two years.
 
The penalties include ₹8 lakh imposed on Sunny Bhatia, while Surbhi Chopra Bhatia, Mamta Rani and Kumar Ashok have each been fined ₹5 lakh.
 
SEBI investigation found that the four individuals engaged in front-running trades by exploiting advance knowledge of orders placed by a ‘big client’, Sarvottam Securities, in the equity derivatives segment. By trading ahead of these orders and exiting after price movements, the noticees were able to generate significant profits.
 
According to the order, Sunny Bhatia, a dealer at Findoc Investmart Pvt Ltd, had direct access to confidential trading instructions of Sarvottam Securities. The client director reportedly placed orders in person at the broker’s dealing room, giving him early visibility into large trades before they were executed in the market.
 
SEBI observed that Sunny Bhatia used not only his own account but also operated the trading and bank accounts of his wife, Surbhi Bhatia, and his parents, executing trades across multiple accounts in a coordinated manner. The regulator found a clear link between these accounts, with trades driven by the same non-public information source.
 
The investigation highlighted a sustained pattern of suspicious intraday trading over several years. The entities traded on 1,352 days, with 906 instances overlapping with trades of the big client. In most cases, positions were squared off profitably, resulting in gains exceeding ₹3.26 crore, a substantial portion of which was attributed to front-running activity.
 
SEBI noted classic front-running behaviour, where positions were taken before the execution of large client orders and exited after prices moved due to those trades. The substantial size of Sarvottam Securities' orders often influenced market prices within short timeframes, creating predictable profit opportunities.
 
The noticees contended that there was no direct evidence of information sharing, that overlapping trades were coincidental in liquid markets and that some loss-making trades disproved any manipulative intent. However, SEBI rejected these arguments, stating that front-running can be established through circumstantial evidence, trading patterns and sequencing of transactions, even in the absence of direct proof.
 
The regulator concluded that Sunny Bhatia misused his position and access to sensitive client information to trade ahead of orders, while the other noticees facilitated the scheme by allowing their accounts to be used.
 
SEBI held that the conduct violated provisions of the SEBI Act and the Prohibition of Fraudulent and Unfair Trade Practices (PFUTP) Regulations, which prohibit manipulative trading practices and misuse of non-public information.
 
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