Authority: Amarjeet Singh, Whole Time Member, Securities and Exchange Board of India

Order Date: July 24, 2026

Case Overview

The order was issued against five entities: Surabhi Chauhan (PAN: AOFPC0570C), Zahin Ismail Jessani (PAN: AGNPJ2499P), Stark Investments (PAN: AEJFS2830K), Starkblue Ventures LLP (PAN: AERFS0106E), and Shakuntala Davendra Singh (PAN: DVJPS6011P). SEBI received 16 unique complaints alleging unregistered investment advisory (UIA) and unregistered portfolio management services (UPMS) activities by these entities.

The examination revealed a structured modus operandi:

  • From September 2020, entities onboarded clients through "mandate agreements" offering investment advisory services with fees ranging from ₹15-30 lakhs minimum investment
  • Provided specific buy/sell recommendations via WhatsApp chats (e.g., recommending GMR Infra at ₹126, UPL worth ₹1-1.25 lakhs) and Excel spreadsheets
  • Offered account handling services by procuring client trading credentials (user IDs, passwords, OTPs) from brokers like IIFL and Zerodha
  • In February 2022, incorporated Starkblue Ventures LLP with Chauhan and Jessani as designated partners, offering exclusive partnerships under "SQAR" (Stark Quantitative Absolute Return) strategy claiming 16-18% returns with "assured downside protection"
  • Mobilized funds through multiple bank accounts: Stark Investments (Axis: ₹6.23 crore), Zahin Jessani (Axis: ₹1.30 crore), Surabhi Chauhan (SBI: ₹1.12 crore; HDFC: ₹57.86 lakh), and Starkblue Ventures LLP (ICICI: ₹15.86 crore)
  • Total identified mobilization: ₹25.08 crore from at least 40 investors including Tapasya and Geeta Obhrai (₹2.06 crore), Hiren Joshi (₹1.05 crore), Swati Jain (₹83 lakh)

Prima Facie Findings

The entities violated:

  • Section 12(1) of SEBI Act read with Regulation 3(1) of IA Regulations by providing unregistered investment advice through specific security recommendations and financial planning services
  • Section 12(1) of SEBI Act read with Regulation 3(1) of PMS Regulations by managing client portfolios through discretionary trading and pooled LLP structure
  • Regulations 3(b),(c),(d) and 4(1),(2)(k),(2)(s) of PFUTP Regulations by making misleading claims about proprietary quantitative models, algorithm-based trading, and downside protection

Final Outcome

SEBI issued immediate interim directions:

  • All entities restrained from buying/selling securities or associating with securities market
  • Open derivative positions allowed to be closed within 3 months
  • Complete freeze on all bank and demat accounts (no debits without SEBI permission)
  • Entities must provide full inventory of all assets within 7 working days
  • Cease all unregistered investment advisory and portfolio management activities
  • Order remains in force until further notice

Topics: Unregistered Investment Advisory, Portfolio Management Services, Regulatory Action