Case Details

Entity Involved: Mr. Nishaan Singh, Proprietor of Sanbun Investments and Sanbun Capital Hedge Fund

Order Number: QJA/MN/NRO/NRO-DIV-III/32419/2026-27

Order Date: May 26, 2026

Issuing Authority: N. Murugan, Quasi-Judicial Authority, Securities and Exchange Board of India (SEBI)

Period of Investigation: March 11, 2020 to January 09, 2023 (HDFC A/c No. 50100321994395) and September 26, 2020 to January 08, 2023 (HDFC A/c No. 59213000000010)

Financial Impact: The Noticee is directed to refund ₹4,72,74,671.84 (Four crores seventy-two lakhs seventy-four thousand six hundred seventy-one rupees and eighty-four paise) collected from clients/investors for unregistered portfolio management services.

Persons Involved

Noticee: Mr. Nishaan Singh (Proprietor of Sanbun Investments and Sanbun Capital Hedge Fund), PAN: HCCPS6377H

Key Individuals Mentioned:

  • Mr. Arun Sharma (Payer/Client)
  • Mr. Nehul Nahar (Alleged student/client)
  • Ms. Anu Tiwari (Wife of an employee, Mr. Jaspreet Singh)
  • Mr. Sanjeev Mahajan (Payer/Client)
  • Ms. Muskan Mahajan (Daughter of Mr. Sanjeev Mahajan)
  • Family members of Mr. Nishaan Singh: Sanjana Singh (Mother), Arvinder Singh (Father), Sanjit Kaur Bindra (Maternal Grandmother), Prabhjot Kaur (Paternal Grandmother), Himmat Singh (Brother), Gurucharan Prakash Singh (Grandfather), Chanmeet Singh (Cousin Brother)

SEBI Officer: N. Murugan, Quasi-Judicial Authority

Forensic Auditor: M/s Rajvanshi & Associates, Chartered Accountants (Empaneled SEBI Auditor)

Violations and Allegations

Summary of Violations: Mr. Nishaan Singh was found to be providing unregistered Portfolio Management Services (PMS) under the guise of offering educational courses related to the securities market. This violates Section 12(1) of the SEBI Act, 1992, read with Regulation 3 of the SEBI (Portfolio Managers) Regulations, 2020.

Relevant Regulations: Section 12(1) of the SEBI Act, 1992; Regulation 3 of the SEBI (Portfolio Managers) Regulations, 2020.

Actions Leading to Violation: The Noticee offered courses (e.g., Intermediate Course, Complete Course, FTTP Programme, One-to-One Training) but was found to be "offering Portfolio Management Services and providing recommendations to the clients in private groups and luring investors/ clients to invest in securities market by assuring positive returns." The Hon'ble Securities Appellate Tribunal (SAT) upheld these findings in its order dated December 18, 2024.

Financial Consequences: The unregistered activity led to the collection of fees from investors/clients without the requisite regulatory registration, potentially exposing them to unregulated risk.

Penalties, Settlement Terms & Rulings

Monetary Penalties: The Noticee is directed to refund a total of ₹4,72,74,671.84 to the clients/investors who availed the unregistered PMS services.

Non-Monetary Conditions:

  • The Noticee is debarred from accessing the securities market, directly or indirectly, and is prohibited from buying, selling, or dealing in securities for a period of three months from the date of the order or until full compliance with the refund directions (paragraphs 99(a), (g), and (h)), whichever is later.
  • The Noticee is prevented from selling his assets, properties, and holdings of mutual funds/shares/securities (in demat or physical form) except for the sole purpose of making the refunds.
  • The Noticee must open a dedicated bank account for refund purposes.

Rulings: The order is issued under Sections 11(1), 11(4), and 11B(1) of the SEBI Act, 1992. The findings of the Forensic Audit Report (FAR) dated July 16, 2025, which calculated the unregistered PMS collection at ₹82,65,548.46, were rejected by SEBI as "inconclusive." SEBI recalculated the amount based on the Noticee's own submission dated April 19, 2025, and examination of bank statements.

Actions, Compliance, and Future Obligations

Corrective Actions Required:

  • Refund ₹4,72,74,671.84 within three months from the date of the order.
  • Issue a public notice in all editions of two national dailies (one English and one Hindi) and one local daily with wide circulation, detailing the refund modalities within 15 days from the date of the order.
  • Effect repayments only through bank demand draft, pay order, electronic transfer, or other banking channels ensuring an audit trail.
  • Transfer the refund amount to a dedicated bank account and use it solely for refund purposes.
  • After completing the refund, file a report certified by an independent Chartered Accountant with SEBI's Northern Regional Office within 15 days.
  • Deposit any remaining balance after refunds with SEBI in an interest-bearing escrow account for one year for distribution to eligible clients/investors. Any amount remaining thereafter must be deposited in the Investors Protection and Education Fund.

Associated Costs: The costs associated with public notices, chartered accountant certification, and managing the escrow account will be borne by the Noticee.

Future Obligations: The debarment from the securities market will be lifted only after full compliance with the refund and reporting directives. The Noticee must cease all unregistered PMS activities permanently.

Final Ruling and Enforcement

Final Decision: SEBI has upheld its earlier findings of violation and, post-SAT remand, issued a fresh order with a revised refund amount and debarment period.

Enforcement Actions: The order is immediately effective. Copies have been sent to recognized Stock Exchanges, Banks, Depositories, and Registrar and Transfer Agents of Mutual Funds to ensure strict compliance with the directions.

Future Conditions: The Noticee must comply with all the directives outlined in paragraphs 99(a) to 99(j) of the order. Failure to comply may lead to further enforcement actions under the SEBI Act.

Potential Impact: The order aims to protect investors by ensuring the refund of monies collected illegally and deterring the Noticee and others from engaging in unregistered financial activities. The operational impact on the Noticee is significant, involving asset freezes, market debarment, and substantial financial outflow.