Fraud, Manipulation and Insider Trading in the Indian Securities Market cited by the Supreme Court of India

Earlier this week the Supreme Court delivered its judgment in Reliance Industries Limited v. Securities and Exchange Board of India (29 May 2026). The Court set aside the finding of fraud under the PFUTP Regulations and the disgorgement of Rs 447 crore, while sustaining the penalty for breach of the position-limit disclosure requirement.

In construing the definition of fraud under Regulation 2(1)(c), the Court observed that the provision, read literally, is so wide as to be unworkable. It relied on the argument in my book, Fraud, Manipulation and Insider Trading in the Indian Securities Market, that on such a reading it is mathematically possible to show that even walking, jogging and cycling are securities frauds. The Court adopted a purposive construction, holding that inducement remains a necessary ingredient of fraud and that concentration of positions is not, by itself, manipulation.

It is a privilege to have the work engaged with at this level. Careful doctrinal writing can, in time, shape how the law is read. My thanks to the Bench for its consideration of the argument.