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In widely worded insider trading law, most cases by the very nature are debatable with implicit subjectivity. There is a considerable debate on when a UPSI comes into existence, if a person is insider and if a trade or communication is based on UPSI. Rightly or wrongly, there is a presumption that all SEBI cases are right. Many cases SEBI win, and many it loses. And many conclude in settlement statistically.

In a Settlement Order, SEBI has disposed of the pending proceedings, against Big Bull of India and 6 others where all 7 noticees paid a collective amount of Rs. 37 crores in settlement, without accepting or denying the facts & conclusions of law. Settlement is a process without admission or denial of anything.

Regstreet Law Advisors Sumit Agrawal a/w Parinam Law Associates Ravichandra Hegde with their respective teams obtained this Settlement Order successfully for the noticees. Securities law enthusiasts must analyze the legality and consequence of a settlement orders on questions of fact and law – which remain open and buried at the same time.

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