Order Number: Summary Settlement Applications SS-5/2026 (Kae Capital Fund II), SS-6/2026 (Kae Capital Management Private Limited), SS-7/2026 (Sasha Gulu Mirchandani).
Order Date: The Settlement Order was digitally signed by Whole Time Members on June 4, 2026.
Period of Violation: The non-compliance was observed from the quarters ended March 31, 2024, and June 30, 2024.
Rectification Date: The violation was rectified on February 9, 2026.
Financial Impact: A joint settlement amount of ₹12,75,000 (Rupees Twelve Lakhs Seventy Five Thousand only) was paid to SEBI.
Persons Involved
Kae Capital Fund II: The Alternative Investment Fund (AIF) itself, which was the entity found to be non-compliant.
Kae Capital Management Private Limited: The Manager of the Fund, responsible for compliance with AIF Regulations.
Sasha Gulu Mirchandani: Identified as the Key Managerial Personnel, held responsible for the conduct of the business of the Manager.
Violations and Allegations
The Manager or Sponsor of Kae Capital Fund II failed to maintain the minimum continuing interest in the Fund.
The continuing interest was observed to be 2.44% of the corpus of the Fund.
This was below the minimum requirement of 2.5% of the corpus or five crore rupees, whichever is lesser, as specified under Regulation 10(d) of the Securities and Exchange Board of India (Alternative Investment Funds) Regulations, 2012 (AIF Regulations).
The specific violations cited are:
For Kae Capital Fund II and Kae Capital Management Private Limited: Violation of Regulation 10(d) read with Regulation 20(1) and Clause 1(e) of the Code of Conduct in the Fourth Schedule of the AIF Regulations.
For Kae Capital Management Private Limited and Sasha Gulu Mirchandani: Violation of Regulation 20(1) read with Clause 2(a) and 2(c) of the Code of Conduct in the Fourth Schedule of the AIF Regulations.
Penalties, Settlement Terms & Rulings
'Notices of Summary Settlement' dated March 16, 2026, were issued to the Applicants (the Fund, the Manager, and the Key Managerial Personnel).
The notices proposed settling the enforcement proceedings for a payment of ₹12,75,000, payable jointly and severally within 30 calendar days from the receipt of the notices.
The Applicants filed the settlement application and remitted the full settlement amount of ₹12,75,000, which SEBI confirmed receiving.
The specified proceedings are settled on the terms that SEBI will not initiate any enforcement action for the said violations.
Final Ruling and Enforcement
The Settlement Order was passed in exercise of powers under Section 15JB read with Section 19 of the SEBI Act, 1992, and in terms of Regulation 23 of the SEBI (Settlement Proceedings) Regulations, 2018.
The order is without prejudice to SEBI's right under Regulations 28 and 31 of the Settlement Regulations to initiate action if:
(a) Any representation made by the Applicants is subsequently found to be untrue.
(b) The Applicants breach any clauses/conditions of undertakings/waivers filed.
(c) There is a discrepancy found while arriving at the settlement terms.
The order came into force immediately and is to be published on SEBI's website.
The order was signed by Shri Kamlesh C. Varshney, Whole Time Member and Shri K.V.R. Murty, Whole Time Member of SEBI.
