SEBI interim order restrains Sanjiv Bhasin over recommendation trades

What the Record Shows

The Securities and Exchange Board of India, acting through Whole Time Member Kamlesh C. Varshney, passed an ex-parte interim order cum show cause notice on 17 June 2025 against market commentator Sanjiv Bhasin and eleven other noticees. The order, reference WTM/KV/ISD/ISD-SEC-6/31471/2025-26, was issued under Sections 11(1), 11(4), 11(4A) and 11B of the SEBI Act, 1992 read with the SEBI (Prohibition of Fraudulent and Unfair Trade Practices) Regulations, 2003. It is an interim order recording a prima facie view, not a final finding; a show cause notice accompanies it and the noticees had not been heard when it was passed.

SEBI directed that the noticees be restrained from the securities market and impounded Rs 11,37,19,170 - about Rs 11.37 crore - which the regulator prima facie treats as unlawful gains, on a joint and several basis. The order groups the twelve noticees by role: Sanjiv Bhasin as the recommender, a set of parties SEBI describes as 'enablers', another set it labels 'information misusers', and a group of entities it calls 'profit makers'.

Because it is an ex-parte order, the noticees' replies to the show cause notice were still due when it was issued, and their defences had not been tested. SEBI's characterisation is that the impounded sum represents gains from a fraudulent and unfair trade practice - a securities-law violation - and the order is a protective interim measure to secure those funds pending adjudication.

How It Worked

Every element of the mechanism below is what SEBI alleges in the interim order, not established fact. SEBI alleges that a widely followed television market commentator, then associated with a large SEBI-registered broking house, took positions in specific scrips through a set of connected entities shortly before recommending those same scrips as a guest expert on business news channels and on a broker-run Telegram channel.

SEBI alleges that once the recommendation was broadcast and generated retail buying, the connected entities sold into that buying, booking the difference. In market-conduct terms this pattern is described as front-running one's own recommendations. The order sets out matched-trade tables that, per SEBI, time the connected entities' entries and exits against the broadcast recommendations to support the prima facie case.

The order attributes distinct functions to the noticee groups. The 'enablers', per SEBI, provided the trading infrastructure and access; the 'information misusers' are alleged to have received or acted on the advance information; and the 'profit makers' are the entities in whose accounts SEBI alleges the gains accrued. The regulator's theory is that the recommender's standing - a director-level role at a well-known broker and a regular guest slot on national business channels - is precisely what gave the recommendations the power to move prices, and thereby made the alleged scheme workable.

It is important to state what SEBI is not alleging. The broking house itself is not a noticee in this order and is not implicated by it. SEBI's case is about the conduct of the named individuals and entities, framed as a PFUTP violation, and not a finding against the broker.

Who Lost Money

On SEBI's prima facie theory, the people who supplied the exit liquidity were retail investors: viewers of business television and subscribers to the broker-run Telegram channel who bought the recommended scrips after the on-air tip and, per the order, were sold into by the connected entities. This makes it the most directly retail-facing matter of its kind - the alleged loss falls on ordinary viewers acting in good faith on what looked like independent expert commentary.

SEBI has not, at this interim stage, quantified individual investor losses; the Rs 11.37 crore figure is the alleged unlawful gain SEBI has impounded, not a measured sum of retail losses. The two are related but not the same - a gain booked by the connected entities corresponds to worse prices paid by the retail buyers, but the order's headline number is the disgorgeable gain SEBI seeks to secure.

No money has been returned to any investor. The impounded amount is being secured, not distributed, and whether any of it is ever paid out depends on the final order after the noticees are heard.

Where It Stands Now

The position has moved since the June 2025 order. Sanjiv Bhasin challenged the interim order before the Securities Appellate Tribunal, and SAT granted partial interim relief, reported on 21 August 2025. SAT directed that Bhasin's trading and demat accounts be unfrozen after he deposits Rs 1 crore with SEBI, and required him to file his reply before SEBI within four weeks and cooperate in the proceedings.

SAT's relief is expressly interim and subject to SEBI's final adjudication; the tribunal recorded that all rights and contentions of both parties remain open until SEBI concludes the matter. In other words, the account freeze on the central noticee was relaxed on a deposit condition, but SEBI's prima facie case has not been set aside and the underlying adjudication continues. Reporting the June 2025 freeze as the current position would be inaccurate - the current position is the SAT-modified, deposit-conditioned one.

Because this remains an interim stage against a person who is contesting the allegations, the presumption of innocence applies in full. An ex-parte interim order is a prima facie view, the show cause notice invites a reply, and due process continues. Nothing SEBI or SAT has recorded is a conclusive finding that Sanjiv Bhasin or any other noticee broke the law.

What It Means

The matter illustrates a specific risk category SEBI has been active on: the on-air or online expert whose recommendations move retail money. Whether the setting is a business-television guest slot, a Telegram channel or a paid course - as in SEBI's action against the Avadhut Sathe Trading Academy - the regulator's concern is the same: an audience acting on a recommendation without knowing what the recommender is doing in the same scrip.

The concrete, non-alarmist takeaway for a viewer is to treat a televised or messaged stock tip as commentary, not as personalised advice, and to be aware that SEBI requires disclosure of a recommender's own interest in a recommended security. A recommendation carries no obligation on the viewer, and a name recognised from television is not a substitute for checking a scrip against one's own plan. Readers can model any single-stock idea against a diversified alternative using the lumpsum investment calculator.

An impounding, finally, is a protective step, not a penalty or a refund - it secures money so that a later disgorgement order, if one is passed, can be satisfied. How these interim measures are tested on appeal is a recurring theme across the enforcement archive at Oquilia's enforcement index, including the far larger Jane Street impounding order.

FAQ

Does this mean Sanjiv Bhasin is guilty?

No. SEBI's order is an ex-parte interim order cum show cause notice - a prima facie view, not a final finding of guilt. Bhasin is contesting the matter, has obtained partial relief from SAT, and the presumption of innocence applies. SEBI's adjudication is still to conclude, and the noticees' replies are yet to be tested.

What exactly did SEBI order?

SEBI restrained twelve noticees, including Sanjiv Bhasin, from the securities market and impounded Rs 11,37,19,170 as alleged unlawful gains on a joint and several basis, under Sections 11(1), 11(4), 11(4A) and 11B of the SEBI Act read with the PFUTP Regulations. A show cause notice accompanies the interim directions.

Has the order been changed on appeal?

Yes. On appeal to the Securities Appellate Tribunal, reported on 21 August 2025, SAT granted partial interim relief: it directed that Bhasin's trading and demat accounts be unfrozen after he deposits Rs 1 crore with SEBI, and required him to reply to SEBI within four weeks. The relief is interim and subject to SEBI's final adjudication, with all rights kept open.

What is front-running of a recommendation?

SEBI alleges that positions were taken in scrips through connected entities shortly before those scrips were recommended publicly, and then sold into the retail buying the recommendation generated. That pattern - trading ahead of one's own advice or recommendation to profit from the price move it causes - is what SEBI has prima facie described here. It remains an allegation pending adjudication.

Is the broking house implicated?

No. The broking house with which the commentator was associated is not a noticee in this order and is not the subject of SEBI's findings here. The order concerns the conduct of the named individuals and entities.

Where can I read the official order?

The full ex-parte interim order cum show cause notice dated 17 June 2025 is published on SEBI's website under its enforcement orders, reference WTM/KV/ISD/ISD-SEC-6/31471/2025-26.

This report is based on the SEBI ex-parte interim order dated 17 June 2025 in the Sanjiv Bhasin recommendation matter and the subsequent Securities Appellate Tribunal relief reported on 21 August 2025, reviewed on 29 July 2026.