SEBI issues recovery notices in Sadhna Broadcast manipulation case

The Enforcement Action

The Securities and Exchange Board of India (SEBI) has moved to recover money from three individuals it has named as defaulters in the matter of Sadhna Broadcast Limited, issuing fresh General Remittance Advices under recovery certificates on 21 September 2026. Per SEBI's recovery notice, the notices cover Rakesh Kumar Gupta (PAN AAEPG2752R) under Recovery Certificate No. 9259 of 2026, Gaurav Gupta (PAN AKHPG5185D) under Recovery Certificate No. 9257 of 2026, and Peeyush Agarwal (PAN AKUPA6832C) under Recovery Certificate No. 9256 of 2026.

A General Remittance Advice is a routine but consequential step in SEBI's recovery machinery. It records amounts the regulator is seeking to collect from a defaulter against dues already crystallised by its orders. The three notices arise from the same underlying matter, the alleged manipulation of the scrip of Sadhna Broadcast Limited, and should be read as one enforcement thread rather than three separate cases.

The recovery notices themselves do not restate the sums involved or the conduct alleged; they reference the recovery certificates and the matter. For the substance, the record points back to SEBI's orders in the case and the appeals they generated before the Securities Appellate Tribunal (SAT). SEBI's action here is enforcement of an existing demand, not a fresh finding.

None of the three named individuals appears to have publicly responded to the September 2026 recovery notices, and this report does not attribute any conduct to them beyond their identification as defaulters in SEBI's own recovery records.

How the Scheme Worked

The Sadhna Broadcast matter began with an ex-parte ad-interim order that SEBI's Whole Time Member passed on 2 March 2023 against 31 noticees, followed by a confirmatory order dated 20 July 2023. Per SEBI's order as recorded by the SAT, the alleged manipulation unfolded in two phases.

In the first phase, roughly 27 April to 14 July 2022, there was a sharp build-up in the price and traded volume of Sadhna Broadcast shares. In the second phase, roughly 15 July to 30 September 2022, SEBI found that "false and misleading videos about the company were uploaded on two YouTube channels" named "The Advisor" and "Moneywise". The regulator described the episode as a classic "pump and dump" scheme intended to induce "unsuspecting investors" to buy the scrip at inflated prices.

As the order describes it, a set of volume creators generated artificial trading activity, while promoters and connected shareholders offloaded their holdings into the demand the videos had manufactured. SEBI quantified the total illegal gains from the episode at about Rs 41.85 crore across the noticees, a figure later modified in the proceedings to roughly Rs 40.61 crore (INR 40,60,66,012). Several noticees were held jointly and severally liable for the cumulative gains.

The matter then moved through the tribunal. In March 2023, SAT modified the harshest of the interim directions for some appellants, requiring instead that a portion of the alleged unlawful gains be placed in an interest-bearing escrow account under SEBI's lien, and directed SEBI to complete its investigation within a fixed timeline. SEBI's confirmatory order of 20 July 2023 kept the core restraints in place.

The recovery certificates issued in September 2026 are the collection stage that follows once such directions crystallise into a monetary demand. They are the point at which an order on paper becomes an active effort to gather the sums SEBI has directed.

The Law Invoked

Per SEBI's orders as recorded by the tribunal, the case was built on the anti-fraud architecture of Indian securities law. SEBI invoked Sections 11(1), 11(4), 11B and 12A of the SEBI Act, 1992. Section 11 sets out SEBI's general duty and powers to protect investors and regulate the market; Section 11(4) lets it pass interim measures such as trading restraints and the impounding of gains; Section 11B empowers it to issue remedial directions, including disgorgement. Section 12A prohibits fraudulent and unfair trade practices in dealing with securities.

Alongside the statute, SEBI relied on Regulations 3 and 4 of the SEBI (Prohibition of Fraudulent and Unfair Trade Practices relating to Securities Market) Regulations, 2003 (PFUTP). Regulation 3 bars the use of manipulative or deceptive devices in dealing with securities; Regulation 4 lists specific manipulative, fraudulent and unfair practices, including the sort of misleading publicity and artificial volume creation SEBI alleged here.

The recovery certificates themselves rest on SEBI's recovery powers, which allow it to collect confirmed dues as if they were arrears of land revenue, including by attaching bank and demat accounts and other assets. These are the specific provisions the record cites; this report does not add any section beyond them.

What Happens Next

SEBI's orders in the matter are the findings of a regulator, and they carry an appeal route. A party aggrieved by a SEBI order can appeal to the Securities Appellate Tribunal, and from SAT to the Supreme Court on a question of law, which is exactly the path several noticees in this matter have already taken. A recovery certificate is the mechanism SEBI uses once a demand is final and unpaid.

At the recovery stage, the recovery officer can attach and sell a defaulter's movable and immovable property, attach bank and demat accounts, and in defined circumstances take further coercive steps to collect the sum. A defaulter who disputes the amount, or believes it has already been paid, can raise that through the recovery process and the appellate route rather than by ignoring the notice.

Because this is a SEBI civil enforcement matter and not a criminal prosecution, there is no chargesheet or trial here; the operative documents are SEBI's orders and the tribunal's rulings on them. Where SEBI's underlying findings remain open to challenge, they are the regulator's conclusions subject to due process, not the verdict of a criminal court.

What It Means

For ordinary investors, the Sadhna Broadcast matter is a textbook illustration of how a "pump and dump" operation is said to work, and why tips delivered through slick YouTube videos deserve deep suspicion. The alleged pattern, a quiet build-up in price and volume, a burst of promotional content promising a specific stock will soar, and insiders selling into the resulting buying frenzy, recurs across enforcement files. When the promotion stops, the price typically collapses, and it is the last buyers who bear the loss.

The practical takeaway is verification. Genuine investment advice in India must come from a SEBI-registered investment adviser or research analyst, and any investor can check a registration on SEBI's website before acting on a recommendation. Anonymous YouTube channels, Telegram groups and WhatsApp tips that push a single small-cap stock with urgency are precisely the vector SEBI described in this case.

The recovery stage also carries a sober lesson: even after gains are impounded and disgorgement is ordered, actually collecting the money can take years and several rounds of notices. That is why prevention, rather than chasing recovery after the fact, remains the only reliable protection for a retail investor.

FAQ

What is the legal status of the people named in the recovery notices?

SEBI's orders are the findings of a market regulator, not a criminal conviction, and they are appealable to the Securities Appellate Tribunal and onward to the Supreme Court. The recovery certificates identify the three individuals as defaulters against dues in the matter; they enforce SEBI's directions rather than establish criminal liability. Due process continues.

What exactly did SEBI order in September 2026?

SEBI issued General Remittance Advices under recovery certificates (Nos. 9256, 9257 and 9259 of 2026) dated 21 September 2026 against Peeyush Agarwal, Gaurav Gupta and Rakesh Kumar Gupta respectively, in the matter of Sadhna Broadcast Limited. These are collection notices within SEBI's recovery process and do not restate the sums on the public page.

Can these SEBI orders be appealed?

Yes. Any party aggrieved by a SEBI order can appeal to the Securities Appellate Tribunal, and several noticees in this matter did so in 2023, with the tribunal modifying some of the interim directions. A recovery certificate is issued once a demand is final; disputes at that stage are handled through the recovery and appellate process.

How can I check if a stock tip or adviser is legitimate?

Only SEBI-registered investment advisers and research analysts may give investment advice for a fee. You can verify a registration number on SEBI's website, and treat anonymous YouTube, Telegram or WhatsApp tips pushing a single small-cap stock as a serious warning sign. SEBI's order in this matter turned on exactly such misleading online promotion.

Where can I read the official record?

SEBI's recovery notices are published on sebi.gov.in, and the Securities Appellate Tribunal orders in the matter are available on Indian Kanoon. Both are linked in this report so readers can consult the primary documents directly.

This report is based on SEBI's official recovery notice dated 21 September 2026 and on the Securities Appellate Tribunal's orders in the matter, available on Indian Kanoon. It was surfaced via SEBI's enforcement feed.