SEBI moves to recover dues in Sadhna Broadcast YouTube case

The Enforcement Action

The Securities and Exchange Board of India (SEBI) has moved to recover money in the matter of Sadhna Broadcast Limited, issuing a fresh Notice of Demand dated 8 October 2026 against Manish Mishra (PAN: AMPPM6823L) and Aahuti Rasik Mistry (PAN: AMPPM6823L), named jointly and severally, under Recovery Certificate No. 9300 of 2026. The notice is a recovery step, not a fresh finding: it enforces amounts already determined to be due under SEBI's orders in the matter.

In the same window the regulator posted General Remittance Advices against other parties recorded as defaulters in the same matter. These include Saurabh Gupta under Recovery Certificate No. 9250 of 2026, Sulabh Dikshit under No. 9247 of 2026, Virtual Business Solution Pvt. Ltd. under No. 9245 of 2026, Sadhna Bio Oils Pvt. Ltd. under No. 9244 of 2026 and Shreya Gupta under No. 9240 of 2026. Each advice concerns, in SEBI's words, "trading based stock recommendations using social media YouTube in the scrip of Sadhna Broadcast Ltd."

The recovery flows from SEBI's finding that the share price of Sadhna Broadcast was manipulated through misleading videos circulated on YouTube. Grouped together, these near-identical notices are one enforcement exercise: SEBI collecting the dues crystallised against the entities it held liable. Several noticees contested the regulator's interim action before the Securities Appellate Tribunal (SAT), which granted partial relief to some appellants in 2023, so the matter has been litigated at the tribunal rather than left unanswered.

How the Scheme Worked

The account that follows is drawn from SEBI's ad-interim order dated 2 March 2023, as recorded by the SAT. According to that order, "false and misleading videos about the company were uploaded on two YouTube channels" named 'The Advisor' and 'Moneywise'. The tribunal recorded SEBI's finding that these channels "were created by noticee no. 1", Manish Mishra, and that between them they carried lakhs of subscribers, giving the videos wide reach among retail viewers.

The videos, per the order, contained "false and misleading news recommending that investors should buy the scrip" and were designed to "lure unsuspecting investors to trade in the scrip of Sadhna". SEBI's view, as the tribunal summarised it, was that the noticees "were engaged in the coordinated scheme to induce unsuspecting investors to acquire securities", while certain insiders "off-loaded a significant portion of their shareholding at inflated prices". SAT described the respondent's characterisation of the episode as "a classic case of pump and dump scheme".

SEBI mapped the activity across two periods. In the first patch, from 27 April 2022 to 14 July 2022, the regulator found a spurt in the price and volume of the scrip. In the second patch, from 15 July 2022 to 30 September 2022, the first video was uploaded on 15 July 2022 and, per the order, "led to an increase in the price and trading volume". The order named 31 noticees in all and quantified total alleged unlawful gains at Rs 41.85 crore, cumulative across the noticees, with a set of them held jointly and severally liable for that sum.

The procedural history is important. After the ad-interim order of 2 March 2023, the SAT on 27 March 2023 partly allowed appeals, setting aside some directions against certain appellants subject to a trading restraint and an escrow deposit of 50 per cent of the alleged gains. A further SAT order of 4 October 2023 gave SEBI until 10 December 2023 to complete its investigation. The matter then proceeded to a final order reported to have been passed on 30 May 2024, which barred a group of entities from the securities market for periods of one to five years. The current recovery certificates are the collection stage of that process.

The Law Invoked

The ad-interim order, as recorded by the tribunal, rested on Sections 11(1), 11(4) and 11B of the SEBI Act, 1992. These provisions give SEBI its broad powers to protect investors and to issue directions, including interim directions restraining entities and freezing assets, while an investigation runs.

The alleged violation was framed under Section 12A of the SEBI Act, read with Regulations 3 and 4 of the SEBI (Prohibition of Fraudulent and Unfair Trade Practices relating to Securities Market) Regulations, 2003. Section 12A prohibits the use of manipulative and deceptive devices in dealing with securities. Regulations 3 and 4 of the PFUTP Regulations prohibit fraudulent, manipulative and unfair trade practices, including creating a misleading appearance of trading or inducing dealings through false statements. Together they are the standard toolkit SEBI uses against price manipulation.

The recovery itself runs on SEBI's statutory recovery machinery under Section 28A of the SEBI Act. Under that provision a recovery officer may recover sums due to SEBI as if they were arrears of tax, including by attaching and selling property and bank accounts. A recovery certificate is the formal instrument that sets this in motion.

What Happens Next

With recovery certificates issued, the matter moves to collection. Under Section 28A, a recovery officer can attach and sell movable and immovable property, attach bank accounts and take other steps to realise the dues from the entities named. The General Remittance Advices and the Notice of Demand are part of this machinery.

SEBI's orders are not the last word. A party aggrieved by a SEBI order may appeal to the Securities Appellate Tribunal, ordinarily within 45 days, and may thereafter approach the Supreme Court on a question of law. This matter has already travelled that route at the interim stage, where the SAT set aside some directions and modified others. A SEBI order is a regulatory finding that remains open to challenge; it is not a criminal conviction, and the tribunal has shown it will vary directions where it finds the material insufficient.

For investors who lost money in the scrip, recovery and disgorgement proceeds collected by SEBI are not automatically returned to individuals. Where sums are disgorged, they typically flow to the Investor Protection and Education Fund rather than to a direct refund, so the practical remedy for an individual investor is limited.

What It Means

The episode is a reminder that a stock tip delivered by a glossy YouTube channel carries no regulatory weight, however many subscribers it has. SEBI found that videos recommending a "buy" were timed to a run-up in price and volume, after which insiders are said to have sold. The protective lesson is simple: a sudden, heavily promoted recommendation for a little-known small-cap, paired with an unexplained price spurt, is exactly the pattern SEBI's order describes.

Investors can check two things in minutes. First, whether the person giving advice is a SEBI-registered investment adviser or research analyst, using the registration lists on the SEBI website; only registered persons may lawfully give personalised investment advice. Second, whether a sharp price move is backed by any genuine company development, rather than by social-media chatter alone. Anonymous channels, messages promising guaranteed multibagger returns, and pressure to buy quickly are the recurring markers.

The recovery stage also shows the process is slow but continuing. More than three years after the first interim order, SEBI is still working to collect from the entities it held liable. For ordinary investors, the takeaway is defensive: verify before you act, and treat tips from unregistered sources as marketing, not advice.

FAQ

What exactly did SEBI do this week?

SEBI issued a Notice of Demand and several General Remittance Advices in the matter of Sadhna Broadcast Limited. These are recovery instruments under recovery certificates, used to collect amounts already determined to be due from the entities SEBI held liable. They do not make a new finding; they enforce an existing one.

Does a SEBI order mean the people named are guilty?

No. A SEBI order is a regulatory finding, appealable to the Securities Appellate Tribunal and, on points of law, to the Supreme Court. It is not a criminal conviction. In this matter the SAT set aside or modified some interim directions in 2023, which shows such findings can be and are tested on appeal.

Can a SEBI order be appealed?

Yes. A party aggrieved by a SEBI order may appeal to the Securities Appellate Tribunal, usually within 45 days of receiving the order, and may then approach the Supreme Court on a question of law. Appeal rights are a built-in part of the process.

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

Use the SEBI website to confirm whether the person is a registered investment adviser or research analyst. Only registered persons may lawfully give personalised investment advice. Treat buy calls from anonymous YouTube or messaging channels, especially those promising guaranteed returns, as marketing rather than regulated advice.

Where can I read the official records?

The recovery notices are published on SEBI's website under its recovery-proceedings section. The procedural history and SEBI's description of the alleged scheme appear in the Securities Appellate Tribunal's orders in the matter, which are available on public legal databases such as Indian Kanoon.

This report is based on the official SEBI Notice of Demand dated 8 October 2026 under Recovery Certificate No. 9300 of 2026 and the Securities Appellate Tribunal order dated 27 March 2023 in the matter of Sadhna Broadcast Limited.