SEBI completes Rs 1.41 crore recovery in The Apex Global advisory case

The Enforcement Action

The Securities and Exchange Board of India (SEBI) has closed its recovery case against Yadunath Singh Thakur, the proprietor of The Apex Global, after recovering Rs 1,41,53,772 that it had sought from him in connection with unregistered investment advisory services. In a completion order dated 4 November 2026, the Recovery Officer at SEBI's Western Regional Office in Ahmedabad recorded that Recovery Certificate No. 7413 of 2023 is "hereby completed" in view of payment of the outstanding amount.

The certificate, dated 30 November 2023, had been drawn for non-payment of the amount SEBI's Whole Time Member directed to be refunded in Order No. WTM/ASB/WRO/WRO/19764/2022-23 dated 28 September 2022, in the matter of The Apex Global. It covered the principal sum along with "further interest, all costs, charges and expenses" of the recovery proceedings.

On the same day, SEBI issued Release Order No. 1512/7413/2023 directing all banks, post offices, mutual funds, NSDL and CDSL to release the accounts and folios attached under Attachment Proceedings Nos. 12543 and 12544 of 2024. The order states that SEBI "has recovered the amount towards full and final settlement" of the demand.

A second release order, No. 1511/6147/2022, closes a separate recovery against The Apex Global in the matter of Covidh Technologies Limited, covered further below. The 2022 order records that the noticee filed no reply and did not appear at either hearing; there is no public response from him to the recovery orders on record.

How the Scheme Worked

The matter began with a single investor complaint. According to the September 2022 order, SEBI received a complaint on 25 August 2017 alleging that the noticee had offered financial investment plans with assured returns. The complainant said they paid Rs 38,000 and, after hearing nothing further, suffered a loss of Rs 30,000.

SEBI then examined the business. The order describes a website, theapexglobal.co.in, no longer active, which SEBI reviewed through archived pages. According to the order, the site described The Apex Global as "a financial advisory company" providing equity and commodity tips across stock cash, Nifty futures, stock futures and F&O, on both intraday and positional calls, along with tips on base metals, precious metals, energy and agricultural commodities.

The order reproduces a menu of paid subscription packages. The stock cash package, priced at Rs 6,000 a month or Rs 43,000 a year, was advertised as providing tips "with accuracy more than 90%". The top-priced MCX premium package was listed at Rs 25,000 a month or Rs 1,83,000 a year. Other packages covered stock futures, Nifty futures, options and metals, and the site also offered HNI and BTST/STBT packs.

Payment was routed to three bank accounts listed on the website, with ICICI Bank, HDFC Bank and Axis Bank. SEBI found these accounts were operated by Yadunath Singh Thakur for The Apex Global. Per the order, total credits into them between 2013 and 6 December 2019 came to Rs 1,23,06,758: Rs 55,620 in the ICICI account, Rs 51,58,895 in the HDFC account and Rs 70,92,243 in the Axis account. SEBI held that all such sums were "consideration received" from clients for investment advice.

The procedural history is long. SEBI issued a show-cause notice dated 5 August 2021 and re-sent it in February 2022; the order records that it was delivered to one of five addresses. Hearings were fixed for 15 July 2022 and 30 August 2022, and the noticee attended neither and filed no reply. The Whole Time Member, Ashwani Bhatia, passed the final order on 28 September 2022. When the refund was not made, the Recovery Officer drew the certificate in November 2023 and attached bank, demat and mutual fund holdings under 2024 proceedings, before recording full recovery this week.

The separate Covidh Technologies recovery, RC No. 6147 of 2022 dated 21 December 2022, sought Rs 10,71,000 for non-payment of a penalty imposed by a SEBI Adjudicating Officer in Order No. Order/BM/UR/2022-23/17225 dated 22 June 2022. The release order states that this amount, too, has been recovered in full and final settlement.

The Law Invoked

SEBI found that the noticee had violated Section 12(1) of the SEBI Act, 1992, read with Regulation 3(1) of the SEBI (Investment Advisers) Regulations, 2013. Section 12(1) bars intermediaries, including investment advisers, from dealing in securities except under a certificate of registration from SEBI. Regulation 3(1) states that no person shall act as, or hold themselves out as, an investment adviser without that registration.

To reach the finding, the order applied the definitions in Regulation 2(m), under which an investment adviser is any person who, for consideration, is in the business of giving investment advice, including anyone who "holds out himself" as one, and Regulation 2(l), which defines investment advice. The order states that the noticee was never registered with SEBI in any capacity.

The directions were issued under Sections 11(1), 11(4) and 11B(1), read with Section 19, of the SEBI Act, which empower SEBI to protect investors and issue remedial directions such as refunds and debarment. The recovery itself ran under Section 28A of the SEBI Act, read with Section 224 and Rule 12 of the Second Schedule to the Income-tax Act, 1961, the provisions the completion order cites.

What Happens Next

The completion order ends this recovery certificate, and the release orders lift the attachments on the noticee's bank accounts, lockers, post office account, demat accounts and mutual fund folios. Both release orders state that they are "without prejudice to any other order of attachment or freeze" by a competent authority under any law.

The market restrictions in the 2022 order are a separate matter. The order debarred the noticee from the securities market for four years from the date of the order, or until four years after the completion of refunds, "whichever is later". It also directs that he may not offer investment advisory services, during or after the debarment, without SEBI registration. Neither recovery document says when the debarment period now ends.

The 2022 order also required a public notice inviting claims and repayments only through traceable banking channels. It noted, however, that the show-cause notice did not identify any particular investor who had suffered losses. The order also states that its refund direction does not stop clients from pursuing other legal remedies, such as a claim for deficiency in service. SEBI orders of this kind are appealable to the Securities Appellate Tribunal; the documents reviewed do not record any appeal.

What It Means

The case shows how long enforcement against unregistered tip providers can take. A 2017 complaint led to a 2021 show-cause notice, a 2022 order, a 2023 recovery certificate, 2024 attachments and full recovery only in November 2026, nine years after the first complaint. SEBI's recovery machinery, which can attach bank accounts, demat holdings and mutual fund folios, did eventually bring in the money, but investors who pay unregistered advisers should not assume that refunds will be quick.

The protective lesson is straightforward. Before paying for stock or derivatives tips, check SEBI's register of intermediaries on sebi.gov.in for a registered investment adviser or research analyst, and match the name, registration number and bank details with what the provider shows you. A pricing page promising tips "with accuracy more than 90%", payments into a proprietor's personal accounts and subscription packages for F&O and MCX calls are all features this order records.

If you have already paid an unregistered adviser, keep receipts and bank statements, file a complaint on SEBI's SCORES portal and note any claims notice that SEBI directs the provider to publish.

FAQ

What exactly did SEBI do on 4 November 2026?

SEBI's Recovery Officer in Ahmedabad issued a completion order closing Recovery Certificate No. 7413 of 2023 for Rs 1,41,53,772 after the outstanding amount was paid. Two release orders, Nos. 1512/7413/2023 and 1511/6147/2022, directed banks, mutual funds and the depositories to release the accounts attached in the two recovery cases, which related to The Apex Global and to Covidh Technologies Limited.

Is this a criminal case?

No. These are civil regulatory proceedings, not a criminal prosecution. SEBI's Whole Time Member found, in an ex-parte order, that the noticee acted as an unregistered investment adviser and directed a refund and a debarment. No court has convicted anyone in this matter, and the recovery documents record a payment, not a criminal finding.

Can the order be appealed?

Orders passed by SEBI under the SEBI Act can be challenged before the Securities Appellate Tribunal, subject to the time limits in the Act. The recovery documents reviewed for this report do not mention any appeal against the September 2022 order, and the completion order records that the amount due has been paid.

How can I check whether an investment adviser is registered?

Use the registered intermediaries search on SEBI's website and look for the investment adviser or research analyst category. Confirm that the registration number, name and contact details match what the provider shows you. Unregistered entities offering paid tips, assured returns or accuracy claims fall outside SEBI's investor protection framework for registered advisers.

What should a client of an unregistered adviser do?

Keep payment records and correspondence, and lodge a complaint with SEBI through the SCORES portal. Where SEBI has ordered a refund, follow any public notice inviting claims. The September 2022 order states that its refund direction does not preclude clients from pursuing other legal remedies, including claims for deficiency in service.

Where can I read the official orders?

All the documents are on SEBI's website: the September 2022 order under Enforcement, Orders, and the completion and release orders under Enforcement, Recovery Proceedings, in the November 2026 listings. The links are given in the source note below.

This report is based on the official SEBI completion order dated 4 November 2026, the release order in the Covidh Technologies matter and the SEBI order dated 28 September 2022.