In Brief
SEBI investigated alleged insider trading involving three individuals trading on information about Passport India Investment's market orders between 2007 and 2009. The Adjudicating Officer imposed penalties on all three; the Appellate Tribunal upheld these penalties. SEBI appealed the reduced penalty on one respondent (Anandkumar Patel). The Supreme Court held that the Appellate Tribunal failed to record independent findings and conclusions regarding Anandkumar's liability—instead merely merging the adjudication order without separate analysis. The Court remanded the matter for the Tribunal to conduct de novo review with independent findings on charges like front running and aiding-abetting specific to this respondent.
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