Authority: Adjudicating Officer, Securities and Exchange Board of India (Jai Sebastian)

Order Date: October 07, 2026

Case Overview

The adjudication proceedings were initiated against Rashi Equisearch Private Limited (SEBI Registration Number: INZ000276636) following a thematic inspection conducted by SEBI and NSE on November 27, 2025, covering the period from April 01, 2024 to November 27, 2025. The inspection revealed two primary violations: (1) failure to maintain evidence of clients' pre-order confirmations or authorizations, and (2) failure to capture Internet Protocol (IP) addresses for Internet Based Trading (IBT) and Securities Trading using Wireless Technology (STWT) orders.

The Noticee admitted to the violations but characterized them as technical and curable lapses without any unauthorized trading, misuse of client funds/securities, or investor loss. For the pre-order confirmation violation, the Noticee explained that for 4 clients, voice call recordings were provided and accepted; for 2 clients, orders were placed in person; and for the remaining 36 clients, orders were placed via WhatsApp where the "Disappearing Messages" feature resulted in auto-deletion of records. The Noticee emphasized that all trades were confirmed via Electronic Contract Notes, clients honored settlement obligations, and no complaints were registered via SCORES.

For the IP address violation, the Noticee attributed the failure to limitations in the BSE BOLTPlusOnWeb trading terminal infrastructure, stating that the facility to capture IP addresses wasn't available at their end during the relevant period. They subsequently retrieved the data from BSE and implemented corrective measures by April 27, 2026.

The Adjudicating Officer rejected the Noticee's arguments, noting that 76% of the sampled trades (38 out of 50) lacked proper order placement evidence, constituting a serious lapse. The Officer emphasized that post-trade ratification through contract notes and settlement does not absolve the broker of the mandatory pre-order evidence requirement. Similarly, the inability to capture IP addresses independently represented a failure of core regulatory obligations, regardless of terminal limitations.

Final Outcome

The Adjudicating Officer imposed a monetary penalty of ₹1,00,000 (Rupees One Lakh) under Section 15HB of the SEBI Act. The penalty must be paid within 45 days of order receipt through SEBI's online payment facility. Failure to pay may lead to recovery proceedings under Section 28A of the SEBI Act.

Topics: SEBI Enforcement, Broker Compliance, Record-Keeping Requirements