Arun Panchariya vs SEBI on 7 October 2026

O R D E R

Per : Justice P. S. Dinesh Kumar, Presiding Officer (Oral)

The following appeals are directed against orders passed by the WTM1, SEBI2 restraining the appellant from accessing the securities market and from holding any position as a KMP3 or a Director in any listed company or a public company intending to raise money from the public or any SEBI registered intermediary in India.

Sr.No. Appeal No. Date of the Impugned Order

26.10.2021

14.10.2021

14.10.2021

06.10.2021

2. Review Application No.3 of 2025 in Appeal No.16 of 2023, has been filed by SEBI with a prayer to treat Arun Panchariya’s period of restraint from holding any position as a KMP or a Director to end on 21.10.2031.

3. We have heard Mr. Sandeep Wadhawan, learned Advocate for the appellants and Mr. J. P. Sen, learned Senior Advocate and Mr. Sumit Rai, learned Advocate for the respondent-SEBI in respective appeals. Parties in Review Application No.3 of 2025 are referred as per their status in Appeal No.16 of 2023.

1 Whole Time Member 2 Securities and Exchange Board of India 3 Key Managerial Personnel

4. Learned Advocates on both sides are in consensus ad idem that in these appeals, the subject matter for consideration is period of debarment restraining the appellant from accessing the Indian securities market and from holding any position as a KMP or a Director in any listed company or any public company intending to raise money from the public or any SEBI registered intermediary in India.

5. Mr. Wadhawan, learned Advocate for Arun Panchariya, the appellant submitted that during the course of hearing in 2025, based on appellant’s instructions, he had submitted before this Tribunal that the appellant was ready and willing to file an affidavit with a voluntary undertaking that the appellant shall not access the securities market or be a KMP /Director in any listed company in India and had prayed that this Tribunal may pass appropriate orders giving quietus to these appeals as hearing these appeals individually will consume substantial time of this Tribunal. Today, he renewed his request and placed on record an affidavit dated 19.03.2025 executed by Arun Panchariya in London. Arun Panchariya also appeared online and submitted that he shall be bound by the undertaking in the said affidavit. He was duly identified by Mr. Wadhawan.

6. Mr. Sen and Mr. Rai, learned Advocates for the respondent-SEBI, on instructions, submitted that this Tribunal may pass appropriate orders keeping in view the fact that consideration of the individual appeals will consume considerable time of this Tribunal and appellant’s undertaking.

7. We have considered the submission of Mr. Wadhawan for the appellant and MR. J. P. Sen and Mr. Sumit Rai, learned advocate for the respondent.

8. Admitted position is, the only aspect for consideration in these appeals is the period of debarment imposed by the SEBI restraining the appellant from accessing the securities market and holding any position as a KMP or a Director in any listed company or any company desirous of raising money from public or any SEBI registered intermediary in India. There are in all four appeals and one review application filed by the SEBI in this batch.

9. Mr. Wadhawan’s contention is that though the appellant has case on merit, he has agreed to furnish the undertaking by way of an affidavit to give quietus. Keeping in view the fact that the direction in the orders passed by the SEBI impugned in the appeals is debarment and the appellant has voluntarily come forward not to access the Indian securities market and not to accept any position as a KMP or a Director in any listed company in India, or any public company intending to raise money from the public or any SEBI registered intermediary in India. In our view, the submission of Mr. Wadhawan can be considered and these appeals can be disposed of by recording appellant’s undertaking and reserving liberty to SEBI to approach this Tribunal in the event of any breach of undertaking.

10. Accordingly, these appeals are disposed of by placing the following undertaking of Arun Panchariya contained in paragraph Nos.5 and 6 of the affidavit dated 19.03.2025 on record, which read as follows:

“5. That be that as it may, without prejudice to the rights and contentions of the appellant in the above said appeals against the

debarment and restraint orders, the appellant categorically undertakes that he shall not access the Indian Securities Market; shall not buy or sell or otherwise deal in any securities related to the Indian Securities Market and shall not hold any position as a Director or Key Managerial personnel in any listed company of Republic of India or intermediatory registered with the SEBI during the period of the above said orders.

6. That the above said undertaking of the appellant is only restricted to the Indian Securities Market and shall not have any effect on the Overseas Securities Markets of other countries.”

11. In R.A.No.3 of 2025 in Appeal No.16 of 2023, SEBI has prayed to hold Arun Panchariya’s period of restraint from holding any position as a KMP or a Director in any listed entity restraint to be in force till 21.10.2031. The period of restraint in the connected appeals is beyond 21.10.2031. Hence, R.A. is rendered unnecessary.

12. Registry shall place the original affidavit in Appeal No.542 of 2022 and a photocopy thereof in another appeal records.

13. The appeals and the review application stand disposed of in above terms. SEBI will be at liberty to approach this Tribunal in the event of any breach of the undertaking. Pending interlocutory application(s), if any, stand disposed of. No costs.

Justice P. S. Dinesh Kumar Presiding Officer

Ms. Meera Swarup Technical Member

Dr. Dheeraj Bhatnagar Technical Member 07.10.2026 PTM

MRS PRAMILA Digitally signed by MRS PRAMILA Date: 2026.10.13 16:21:09 +05'30'