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Columns 24 min read

One Rulebook for the G-Sec Market: Decoding the RBI's 2026 Draft Master Direction on Secondary Market Transactions in Government Securities

The Reserve Bank's draft Master Direction collapses 36 legacy circulars into one rulebook for secondary market trading in Government securities. T+1 settlement as default, calibrated When Issued limits, short sale codified for all eligible entities, and a defined FEMA pathway for non-residents.

Sushant Shukla
Contributor
Jun 26
Columns 22 min read

From Credit Models to Frontier AI: Inside the RBI's 2026 Draft Guidance on Model Risk Management

The RBI's draft Guidance on Model Risk Management, 2026 puts every model used by India's banks, NBFCs and FIs, statistical, algorithmic and AI alike, under a single Board-owned framework, and writes the regulator's first detailed AI rulebook. A clause-by-clause analysis.

Sushant Shukla
Contributor
Jun 25
03
SEBI

What Are Your Actual Odds of Winning at SAT?

SAT is the busiest single voice in the record at roughly 15,363 orders. It modifies more than it overturns. What the modern pattern from Satyam to NSE to Franklin to RPL actually tells you about the cost and outcome of an appeal.

Sushant Shukla· ·4 min read
04
SEBI

When Is Settling With SEBI Cheaper Than Fighting?

Settlement under Section 15JB and the 2018 Regulations is available, but most matters do not settle. When the math favours closure, when it does not, and what the neither-admit-nor-deny feature is actually worth.

Sushant Shukla· ·5 min read
05
SEBI

How Do You Win a Penalty Reduction at the Securities Appellate Tribunal?

The single most reliable lever on quantum is Section 15J non-engagement; Bhavesh Pabari settled the doctrine; T. Takano added a natural-justice flank. How to structure a SAT appeal that actually reduces the number.

Sushant Shukla· ·5 min read
06
SEBI

What Actually Happens at a SEBI Adjudication Hearing?

Section 15-I plus the 1995 Adjudication Rules: SCN, reply, personal hearing, written submissions, reasoned order. What each step does, and how Takano and Bhavesh Pabari shape what SEBI must put on the record.

Sushant Shukla· ·5 min read
07
SEBI

How Does SEBI Calculate the Disgorgement Number?

How SEBI actually calculates wrongful gain under Section 11B, why the figure is the part most exposed on appeal, and what the Satyam, NSE Co-location and Franklin shrinkages tell us about the inputs that matter.

Sushant Shukla· ·4 min read
08
SEBI

How Should You Respond to a Section 11C Summons from SEBI?

SEBI's Section 11C summons compels you to produce documents, furnish information and attend in person, with criminal exposure for non-compliance. How to comply intelligently while preserving the rights that survive into the show-cause stage.

Sushant Shukla· ·5 min read
09
SEBI

If SEBI Says You Owe 500 Crore, Does the Money Actually Come Back?

Often slowly, often shrunk on appeal, and rarely to the same investors who lost. Disgorgement flows into the IPEF, not direct compensation. Sahara has recovered about 61 per cent thirteen years on; the largest headline directions have been substantially modified.

Sushant Shukla· ·6 min read
010
SEBI

When Did SEBI Become the Regulator It Is Today?

SEBI was quiet through the 1990s, expanded after the 2002 amendments, and recognisably became the modern enforcer after the Securities Laws (Amendment) Act, 2014. Across 35,417 orders, the four tracks now carry very different volumes.

Sushant Shukla· ·5 min read
011
SEBI

Why Did Franklin Templeton Have to Wind Up Six Debt Schemes Overnight?

On 23 April 2020, Franklin Templeton wound up six debt schemes with 25,000 crore across 300,000 unitholders. SEBI's June 2021 order found scheme-categorisation lapses, debarred new debt schemes for two years, ordered 512 crore refund. SAT moderated to 250 crore.

Sushant Shukla· ·5 min read
012
SEBI

Were Yes Bank's AT-1 Bondholders Mis-Sold a Risk They Could Not See?

SEBI found 1,346 retail investors had bought roughly 679 crore of Yes Bank AT-1 bonds, many sold as 'super FDs.' Rana Kapoor penalised 2 crore in 2022. The 8,415-crore write-down challenge is reserved at the Supreme Court.

Sushant Shukla· ·5 min read
013
SEBI

How Did SEBI Crack Down on the GDR Manipulation Cluster?

A cluster of Indian listed companies issued GDRs that were not really subscribed by foreign investors. Vintage FZE, controlled by Arun Panchariya, funded subscriptions with a loan secured by the issuers' own GDR proceeds. SEBI debarred multiple parties for up to ten years.

Sushant Shukla· ·5 min read
014
SEBI

Did Reliance Manipulate Its Own RPL Share Price in 2007?

SEBI says yes, by depressing RPL's settlement price in the closing window of 29 November 2007 to crystallise a gain on a connected short position. SEBI ordered disgorgement of 447 crore in 2017; SAT upheld it in 2020; the Supreme Court appeal is pending.

Sushant Shukla· ·5 min read
015
SEBI

How Did Karvy Force SEBI to Change How Brokers Hold Your Securities?

SEBI's November 2019 ex parte order against Karvy Stock Broking found it had pledged client securities to raise funds for itself. The order changed broker discipline in India, including segregation of client securities and tighter rules on power of attorney.

Sushant Shukla· ·5 min read
016
SEBI

What Was the NSE Co-location Case, and What Did It Actually Find?

The case was widely treated as a 625-crore exchange-side disgorgement. The actual outcome was much narrower: SAT set it aside in 2023, SEBI dropped charges against NSE and seven ex-executives in 2024 for absence of evidence, and only OPG Securities was held to disgorge 85 crore.

Sushant Shukla· ·5 min read
017
SEBI

How Did SEBI Catch DHFL's 14,000-Crore Diversion?

SEBI's 2025 WTM order found that DHFL and the Wadhawans had diverted approximately 14,040 crore to 'Bandra Book Entities' between 2006 and 2019. Five-year debarment, 120-crore penalty, disgorgement to be quantified separately.

Sushant Shukla· ·5 min read
018
SEBI

What Did SEBI Actually Do About the IL&FS Collapse?

SEBI's IL&FS enforcement was narrower than the headlines: the regulator's orders penalised ICRA, CARE Ratings and India Ratings for maintaining investment-grade and AAA ratings past visible balance-sheet stress.

Sushant Shukla· ·5 min read
019
SEBI

How Did the Supreme Court Force Sahara to Return Investor Money?

Sahara's OFCDs raised vast sums from three crore investors in violation of public-issue norms. The Supreme Court's 2012 order to refund with 15 per cent interest is still being unwound thirteen years later.

Sushant Shukla· ·5 min read
020
SEBI

What Did the Satyam Fraud Teach Indian Securities Law?

Ramalinga Raju's 2009 confession exposed a 5,000-crore accounting fraud. SEBI's 2014 disgorgement order has been remanded and recalibrated for over a decade, and the doctrines it pushed into Indian law are still everywhere.

Sushant Shukla· ·5 min read
021
SEBI

When Do an Investor's Protective Rights Become 'Control'?

A minority investor's veto rights are not control. The SAT said so in Subhkam, the Supreme Court declined to settle it, and the market has structured deals around the half-settled doctrine ever since.

Sushant Shukla· ·4 min read
022
SEBI

Can Conduct Be 'Fraud' Without a Lie?

After Kanaiyalal, fraud under SEBI's anti-fraud rulebook is no longer about deceit. It is about effect: did the conduct induce someone to deal? That single shift reshaped market-manipulation enforcement in India.

Sushant Shukla· ·4 min read
023
SEBI

What Continuous Disclosure Does the Law Demand?

LODR is the continuous-disclosure code for every listed company in India. Regulation 30 material events, the post-Satyam governance regime, and the 2023 tightening of timelines.

Sushant Shukla· ·5 min read
024
SEBI

What Are SEBI's Real Powers?

SEBI does not have inherent regulatory authority. Every action traces to a section of the SEBI Act: Section 11 sets the mandate, Section 11(4) holds the sharp tools, Section 11B underwrites forward-looking directions and disgorgement.

Sushant Shukla· ·5 min read