The Securities and Exchange Board of India (Sebi) took up 400 investigations and completed 301 in the financial year 2024-25, according to data from Sebi’s Handbook of Statistics for the year. That compares with 342 fresh probes and 197 completed in FY24, and 144 new investigations and 152 finished in FY23.
While the number of probes completed has risen in absolute terms, the regulator is opening far more new investigations since the fiscal 2024. The use of technology, and artificial intelligence in particular, is enabling Sebi to track more cases. The regulator has also expanded its investigations wing and is learning from cases that are being held up or overturned at the appellate tribunal.
“Sebi investigations are becoming more watertight and thorough," said KC Jacob, partner at Economic Laws Practice. “It is asking for a lot more things in their notices."
That is evident in Sebi’s recent interim orders. In the Avadhut Sathe case, the market watchdog issued a 125-page interim order that read like a case study. The regulator analyzed video recordings of Sathe’s trading lessons, reproduced screenshots of sessions with date-wise details and verbatim statements, examined WhatsApp chats, and scrutinised the trading accounts of investors advertised as success stories. Sebi also analysed the social media influencer’s own trading records to show that he and his firm were incurring losses, undermining claims that they were in a position to advise others.
The market regulator barred Sathe and his firm from the securities market and asked them to deposit the alleged illegal gains of ₹546 crore into a fixed deposit account, with a lien marked in favour of Sebi. Sathe and his trading academy challenged the regulator’s order in the Securities Appellate Tribunal (SAT), denying the allegations. SAT granted him temporary relief by allowing the company to access funds.
A similar investigative intensity was seen in the 105-page Jane Street order. Sebi devoted sections to explaining the basics of indices, futures, and options, with detailed illustrations of how these different instruments interact. The order outlined the methodology used to identify impugned trading days, presented tabular flowcharts of intraday strategies, and included charts and tables that mapped each relevant trade in Bank Nifty contracts. A QR code was even generated to allow easier access to voluminous data.
Sebi barred Jane Street for allegedly manipulating indices and ordered it to disgorge illegal gains worth more than ₹4,800 crore. The high-frequency trading firm denied the charges and has appealed to the SAT against Sebi’s move.
The level of depth seen in investigations was not always there. A 96-page interim order-cum-show cause notice issued in 2023 in the Axis Mutual Fund front-running case, while detailed for its time, largely set out Sebi’s findings rather than walking through the investigative logic and evidentiary trail.
While the order was extensive and evidence-heavy, it largely presented Sebi’s prima facie conclusions upfront and then incorporated material to support those findings, rather than methodically walking the reader through the investigative reasoning. The document relied on reproductions of Bloomberg chats and trade tables with limited explanations on how individual facts connected to the alleged scheme. Concepts such as opportunity, access and connection were asserted more than analytically demonstrated.
However, in the Jane Street and Avadhut Sathe interim orders, Sebi relied on more specific instances of when and how the alleged violations occurred. It included the reproduction of excerpts from Avadhut Sathe's classes, and price charts and tables to illustrate alleged market manipulation by Jane Street. Both orders extensively explained the alleged violations, their meaning, and why the enforcement order was necessary.
A query emailed to Sebi did not elicit a response.
Sebi’s orders have turned more exhaustive as its probe team expanded. The Investigations Department (IVD), which probes potential violations in the securities market, collects evidence and identifies wrongdoers for enforcement actions, has grown rapidly. In 2023, Sebi largely operated with a single investigations vertical comprising about five or six investigation divisions. By 2025, this has expanded to three investigation verticals with 23 divisions, headed by senior officers.
Another factor shaping this change is Sebi’s experience before SAT, which has criticised the regulator for loopholes in investigations.
“Sebi is also learning from its appellate experiences before SAT and other judicial forums," said Sidharth Kumar, senior associate at BTG Advaya and a former Sebi official. “Its enforcement orders have become more detailed and academic, explaining all nuances related to a case."
In October 2023, SAT set aside Sebi’s interim order that had barred Punit Goenka, managing director and chief executive of Zee Entertainment Enterprises Ltd, from holding key managerial and directorial positions after allegations of diversion of funds. The tribunal’s decision allowed Goenka to resume his role and cleared the way for him to potentially lead the proposed merged entity of Zee and Sony Pictures Networks India, a transaction that ultimately didn't occur.
In August 2025, SAT intervened in another high-profile enforcement matter involving Sanjiv Bhasin, the former director of IIFL Securities, who had been barred from accessing the securities market by Sebi over allegations of manipulation in connection with his public stock recommendations. Sebi had also directed to impound alleged unlawful gains worth around ₹11 crore. SAT allowed trading accounts to be unfrozen after Bhasin complied with a directive to deposit ₹1 crore, effectively overturning the market access ban. The case continues to be heard.
The tribunal also overturned the regulator’s decision and allowed businessman Rohit Salgaocar to cross-examine Ketan Parekh in an insider trading case, with alleged illegal gains of ₹66 crore. Sebi said that its order does not solely rely on Parekh’s testimony, but the SAT set aside Sebi’s decision.
Goenka, Bhasin and Salgaocar denied allegations.
Meanwhile, in the Balram Garg vs Sebi matter in 2022, even the Supreme Court cautioned the regulator against presuming insider trading merely on the basis of proximity between parties.
Since then, Sebi has invested far more effort in establishing actual communication.
In its ex parte interim order issued in 2025 against eight noticees in the Indian Energy Exchange case, Sebi relied on WhatsApp chats, shared documents and message trails recovered during search and seizure operations, and mapped these communications to trading activity to demonstrate the flow of unpublished price-sensitive information (UPSI).
“Equally important is the feedback loop created by the Securities Appellate Tribunal—observations on deficiencies in older matters are taken constructively by Sebi and reflected in subsequent investigations and orders, leading to greater evidentiary rigour and detail," said Abhiraj Arora, Partner at Saraf and Partners and a former Sebi officer.
New appeals against Sebi's orders at the SAT fell to 533 in FY25 from 821 in the year prior, according to the regulator’s latest annual report.
“Sebi’s investigative framework has become markedly more efficient in recent years, driven by improved use of technology for data retrieval and analysis, as well as clearer internal timelines and accountability," said Arora.
“Investigative teams are now assigned defined targets, with progress closely monitored through periodic MIS reviews," he said, adding that investigations are now completed within one to two years, compared with the older timeline of four to five years.
The longer duration of investigations is also a result of a rise in frauds, which typically take place in the form of stock recommendations or investment advisory given out by entities that are not registered with Sebi as investment advisors or research analysts.
“Evidence collection is difficult when it involves search and seizure in remote areas. That itself makes investigations longer, but also more robust," said Kumar.
Despite an improvement in the regulator’s timeline to close investigations and the expansion of its investigation team, the number of pending cases under Section 11 of the Sebi Act increased to 169 in fiscal 2025 compared to 145 in FY24.
Section 11 empowers the regulator to protect investor interests and regulate and develop the securities market, granting it wide-ranging preventive, regulatory, and remedial powers.