THE RETAIL GAMBLE: ARE SEBIS SAFEGUARDS ENOUGH IN INDIAS OPTIONS MARKET? BY - SHIVANESH RAM R R

THE RETAIL GAMBLE: ARE SEBI’S SAFEGUARDS ENOUGH IN INDIA’S OPTIONS MARKET?

 
AUTHORED BY - SHIVANESH RAM R R[1]
 
 

Abstract

The rise of options trading in India has led to increased participation by retail investors, driven by easy market access and the allure of high returns. However, the complexity and inherent risks of options trading have also resulted in substantial financial losses for uninformed investors. In response, the Securities and Exchange Board of India (SEBI) has introduced various safeguards to regulate derivatives trading and protect retail participants.

 

This paper critically examines whether SEBI’s existing regulatory framework is sufficient to safeguard retail investors in the options market. By analyzing key regulations, enforcement mechanisms, and market trends, the study highlights the gaps that persist in SEBI’s approach. A comparative analysis with global regulatory frameworks sheds light on alternative strategies that could enhance investor protection and market integrity.

 

The paper argues that while SEBI has made significant regulatory advancements, loopholes remain in areas such as risk disclosures, margin requirements, algorithmic trading oversight, and investor suitability norms. It calls for stronger enforcement, enhanced investor education, and a more proactive regulatory stance to ensure a fair and transparent derivatives market. The study ultimately provides recommendations for policy reforms that could better align SEBI’s regulatory approach with international best practices, ensuring a safer and more resilient options trading ecosystem in India.

 

Introduction: The Rise of Options Trading and Retail Participation

The Oracle of Omaha, the legendary investor Warren Buffet has said “Derivatives are financial weapons of mass destruction, carrying dangers that, while now latent, are potentially lethal.” The Indian financial markets have witnessed a remarkable surge in options trading, driven primarily by retail investors. Once considered a sophisticated instrument for hedging risks, options have now become a dominant speculative tool, attracting traders with the allure of high returns on limited capital. The rapid expansion of retail participation has been fueled by increased accessibility to online trading platforms, low-cost brokerage services, and aggressive marketing by financial influencers. However, this growing trend raises significant concerns regarding investor awareness, risk exposure, and regulatory oversight.
 
The National Stock Exchange (NSE) has emerged as one of the world’s largest derivatives exchanges, with options trading volumes far exceeding those in other global markets. Despite their complexity, options have become increasingly popular among retail traders, many of whom lack the necessary financial literacy to understand their inherent risks. Unlike traditional stock investments, options are time-sensitive and often speculative, leading to potential financial distress when used without adequate risk management. The presence of high-frequency trading (HFT) and algorithmic strategies further exacerbates retail investors' disadvantages in these markets. SEBI, as the primary regulator, has implemented various safeguards to mitigate risks, including margin requirements, risk disclosures, and trading restrictions. However, concerns remain regarding the effectiveness of these measures in protecting retail investors from excessive speculation and potential financial losses. Many traders continue to engage in high-risk strategies without fully understanding their implications, raising questions about whether the current regulatory framework is sufficient.
This research critically examines SEBI’s approach to options trading regulation, assessing its effectiveness in safeguarding retail investors. By analyzing key risks, comparing global regulatory frameworks, and identifying gaps in SEBI’s oversight, this study aims to explore whether existing protections are adequate or require reform. As options trading reshapes India’s financial landscape, ensuring a balance between market freedom and investor security remains a crucial challenge for policymakers.
 

Regulatory Foundations: SEBI’s Framework for Derivatives Trading

Financial markets function optimally when guided by a robust regulatory framework that ensures transparency, investor protection, and systemic stability. In India, the Securities and Exchange Board of India (SEBI) plays a pivotal role in overseeing the securities market, including derivatives trading. The rise of options trading, particularly among retail investors, has prompted SEBI to introduce and refine regulatory measures aimed at mitigating risks and fostering responsible market participation. However, the complexity and speculative nature of options have raised concerns about whether the existing regulatory safeguards are sufficient to protect investors from excessive financial exposure and systemic instability.
 
Options trading in India operates within a structured framework set by SEBI, governed primarily under the Securities Contracts (Regulation) Act, 1956, and the SEBI (Stock Brokers and Sub-Brokers) Regulations, 1992. The introduction of exchange-traded derivatives in India in 2001 marked a significant shift, enabling greater market depth and liquidity. Unlike in over-the-counter (OTC) derivatives markets, where counterparty risks are high, SEBI mandates that all derivatives, including options, be cleared through exchanges such as the National Stock Exchange (NSE) and the Bombay Stock Exchange (BSE). This ensures better risk management, price discovery, and regulatory oversight[2].
 
A key component of SEBI’s regulatory approach is the margin framework, which requires traders to maintain sufficient collateral before executing trades. The regulator has introduced various margin requirements, including upfront margins, exposure margins, and peak margin norms, to curb excessive speculation and prevent traders from taking unsustainable leveraged positions. However, while margins are intended to enhance market discipline, they have also led to unintended consequences—such as an increased reliance on informal funding sources and the proliferation of unauthorized trading advisory services that claim to help traders bypass these restrictions.
 
In addition to margin regulations, SEBI has implemented risk disclosure norms to enhance investor awareness. Brokers and trading platforms are mandated to issue standardized risk disclosure documents outlining the potential losses associated with options trading. Despite these efforts, many retail investors either overlook or fail to comprehend these disclosures, often influenced by aggressive marketing tactics that emphasize profit potential while downplaying risks. The emergence of financial influencers and social media-based trading communities has exacerbated this issue, raising concerns about the adequacy of SEBI’s enforcement mechanisms in tackling misleading financial advice.
 
SEBI has also sought to regulate algorithmic trading and high-frequency trading (HFT) to ensure a level playing field. Institutional investors and proprietary trading firms leverage sophisticated algorithms to execute trades at high speeds, often creating an asymmetric advantage over retail traders. Recognizing this, SEBI has imposed regulations such as order-to-trade ratio restrictions and latency buffers to curb manipulative trading practices. However, the ability of retail investors to compete in an environment dominated by algorithmic strategies remains questionable, leading to concerns about market fairness and the need for further regulatory interventions.
 
Another significant measure introduced by SEBI is the framework for investor grievance redressal and dispute resolution mechanisms. The SEBI Complaints Redress System (SCORES) provides a digital platform for investors to raise complaints against brokers and trading platforms. Additionally, SEBI has mandated the establishment of investor protection funds (IPFs) by stock exchanges to compensate investors in cases of broker defaults. While these measures offer an avenue for recourse, the effectiveness of redressal mechanisms in addressing retail investor grievances—particularly those related to mis-selling and unauthorized advisory services—remains a matter of debate.
 
Despite SEBI’s regulatory interventions, loopholes and enforcement challenges persist. Many retail investors continue to engage in reckless speculation, often influenced by external factors such as unregulated financial advisors, misleading options trading courses, and social media influencers. The regulator has attempted to curb these trends by issuing warnings and restricting certain types of promotional content, but enforcement remains an ongoing challenge. Additionally, concerns have been raised about whether SEBI’s focus on stringent margin requirements and trading restrictions might inadvertently drive retail traders towards unregulated offshore derivatives markets, thereby increasing systemic risks rather than mitigating them.
 

The Retail Dilemma: Speculation, Risk, and Investor Vulnerabilities

Options trading, while offering strategic flexibility and potential for high returns, carries inherent risks that disproportionately affect retail investors. Unlike institutional participants, who have access to sophisticated risk management tools, high-frequency trading algorithms, and substantial capital reserves, retail investors often engage in options trading with limited financial literacy and inadequate risk assessment capabilities. The growing participation of retail investors in the Indian options market has raised significant concerns about excessive speculation, financial mismanagement, and systemic vulnerabilities. Despite SEBI’s regulatory interventions, numerous risks persist, exposing retail traders to substantial losses and market manipulation.
 
One of the most critical risks in options trading is the leverage effect. Unlike cash market trades, where gains and losses are proportional to the invested amount, options allow traders to control large positions with a fraction of the total contract value. This leverage can magnify both profits and losses, making options an attractive yet highly volatile financial instrument. A single adverse price movement can lead to the total erosion of the premium paid, leaving retail traders with substantial financial losses. The case of Securities and Exchange Board of India v. Rakhi Trading Pvt. Ltd. (2018)[3] is particularly relevant in highlighting the risks of manipulative practices in derivatives trading. The Supreme Court upheld SEBI’s action against traders engaged in non-genuine transactions, reinforcing the importance of regulatory oversight in preventing market abuse. However, similar manipulative practices persist, particularly in options trading, where sudden spikes in implied volatility can cause erratic price movements, disproportionately impacting uninformed retail traders[4].
 
Another significant challenge is the complexity of options pricing and execution. The valuation of options depends on multiple factors, including implied volatility, time decay (theta), and underlying asset price movements. Many retail traders, drawn by the possibility of quick gains, fail to understand these complexities, leading to poor trading decisions. The case of MCX Stock Exchange Ltd. v. SEBI (2012)[5] sheds light on the necessity of ensuring transparency in derivatives pricing. Here, the Securities Appellate Tribunal (SAT) examined the role of exchanges in maintaining fair price discovery mechanisms, an issue that remains crucial in options markets where pricing inefficiencies can be exploited by institutional players at the cost of retail participants.
 
Mis-selling and misleading financial advice pose another serious risk in options trading. The rise of social media-based financial influencers, Telegram and WhatsApp trading groups, and unregistered investment advisors has led to widespread dissemination of unreliable trading strategies. Many of these platforms promote aggressive options trading strategies, such as naked call or put selling, without adequately disclosing the risks involved. SEBI has taken enforcement actions against unauthorized investment advisors under the SEBI (Investment Advisers) Regulations, 2013, yet the issue persists. The recent Anugrah Stock & Broking Pvt. Ltd. case (2020) exposed how fraudulent advisory services misled investors into high-risk derivative trades, ultimately leading to financial distress for thousands of clients. This case underscores the urgent need for stronger enforcement against unregistered advisors and financial influencers.
 
Another major risk factor is the impact of high-frequency trading (HFT) and algorithmic strategies on retail traders. Institutional traders deploy sophisticated algorithms to execute trades at lightning-fast speeds, capitalizing on minor price inefficiencies. Retail investors, who rely on traditional order execution methods, often find themselves at a disadvantage in such an environment. The case of SEBI v. OPG Securities Ltd. (2020)[6] is significant in this context, as it dealt with the misuse of high-frequency trading systems to gain preferential access to stock exchange servers, allowing certain traders to gain an unfair advantage over retail participants. Despite SEBI’s introduction of order-to-trade ratio regulations, concerns remain about whether retail traders can compete on an equal footing in a market dominated by algorithmic strategies.
 
Additionally, regulatory arbitrage and the rise of offshore derivatives trading present emerging challenges. With SEBI tightening margin requirements and risk controls, many traders have turned to offshore platforms offering unregulated options trading. Websites facilitating binary options and exotic derivative contracts have become increasingly popular, operating outside SEBI’s jurisdiction. This regulatory loophole has led to concerns about capital flight and investor vulnerability to fraud. While SEBI has issued warnings against such platforms, legal enforcement remains difficult due to jurisdictional limitations[7].
 
Lastly, systemic risk and financial contagion remain critical concerns in the options market. Unchecked speculative activity can lead to market instability, as seen during the GameStop short squeeze incident (2021) in the United States. Retail traders, leveraging options contracts to drive stock prices higher, triggered a chain reaction that led to broker liquidity crises and regulatory intervention. While India has not witnessed a similar event, the possibility of retail-driven volatility remains a genuine risk, particularly with the rising influence of trading communities and coordinated speculative activity.
 

A Comparative Lens: Global Approaches to Options Market Regulation

The regulation of options trading varies significantly across jurisdictions, with each country adopting a unique approach to balancing market efficiency, investor protection, and systemic stability. While India’s regulatory framework, governed primarily by the Securities and Exchange Board of India (SEBI), has introduced multiple safeguards to protect retail investors, global markets offer diverse perspectives on options trading governance. Analyzing regulatory frameworks from the United States, the European Union, the United Kingdom, and Singapore provides critical insights into how different legal structures address the risks associated with options trading. The comparative approach also highlights potential reforms that India can adopt to enhance its regulatory oversight and investor protection mechanisms[8].
 

The United States: The SEC and CFTC’s Dual Oversight Model

The United States has one of the most developed and liquid options markets in the world, primarily overseen by two regulatory bodies: the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC). The SEC regulates equity options trading on exchanges such as the Chicago Board Options Exchange (CBOE) and the NASDAQ Options Market, while the CFTC oversees derivatives linked to commodities and financial indices.
 
A critical case that shaped U.S. options regulation is SEC v. W.J. Howey Co. (1946)[9], which laid the foundation for determining whether a financial instrument qualifies as a security. The Howey Test, derived from this case, is crucial in regulating complex options contracts that may blur the line between securities and derivatives. Additionally, the case of Commodity Futures Trading Commission v. Schor (1986)[10] reinforced the CFTC’s jurisdiction over derivative instruments, ensuring that financial regulators could effectively oversee speculative trading practices.
 
The U.S. has stringent disclosure requirements and margin regulations to protect retail traders. The Pattern Day Trader (PDT) rule, enforced by the Financial Industry Regulatory Authority (FINRA), requires traders executing more than four day trades in five business days to maintain a minimum account balance of $25,000. Such measures act as a deterrent to excessive speculation among undercapitalized retail investors. Additionally, the Dodd-Frank Wall Street Reform and Consumer Protection Act, 2010, introduced post the 2008 financial crisis, significantly increased oversight of derivative contracts, ensuring greater transparency in options trading.
 
However, despite these regulations, high-profile incidents such as the Robinhood options trading debacle (2021), where a retail trader committed suicide after misinterpreting his trading losses, have highlighted the limitations of U.S. investor protection laws. This case pushed regulators to enforce stricter risk disclosures, enhanced investor education programs, and improved user interface transparency in trading platforms—lessons that India can learn from to improve its own investor protection framework[11].
 

The European Union: Stringent Risk Controls and ESMA’s Oversight

In the European Union (EU), options trading falls under the purview of the European Securities and Markets Authority (ESMA), which ensures harmonized financial regulations across member states. The EU follows a risk-based approach to options trading, focusing on investor suitability assessments and risk-mitigation strategies.
 
One of the landmark regulatory interventions in Europe came in 2018, when ESMA imposed temporary restrictions on binary options trading due to their highly speculative nature. Unlike traditional options, binary options allowed traders to bet on an asset’s price movement with an all-or-nothing payoff, leading to widespread retail investor losses. The case of BaFin v. Option888 (2019) in Germany further highlighted concerns regarding misleading marketing practices in derivatives trading. The German financial regulator, BaFin, took enforcement action against offshore brokers who promoted high-risk options products without adequate disclosures.
 
Another significant legal framework influencing EU options regulation is MiFID II (Markets in Financial Instruments Directive II), which mandates strict pre-trade and post-trade transparency requirements for derivative transactions. The directive enforces stringent leverage limits, margin requirements, and best execution policies to ensure fair treatment of retail investors. These measures, aimed at preventing excessive risk-taking, serve as a potential model for SEBI’s evolving regulatory framework in India.
 

Singapore: A Balanced Approach with Strong Retail Safeguards

Singapore, a leading financial hub in Asia, has developed a well-regulated options market under the supervision of the Monetary Authority of Singapore (MAS). The MAS follows a proactive investor protection approach, requiring retail traders to pass knowledge assessments before accessing complex derivative products.
 
A key regulation in Singapore’s financial markets is the Securities and Futures Act (SFA), 2001, which mandates robust disclosure norms, transaction reporting mechanisms, and fair dealing obligations for brokerage firms. The case of Public Prosecutor v. Soh Chee Wen (2020), where traders engaged in manipulative practices using derivatives, underscored the importance of rigorous enforcement in maintaining market integrity. The MAS’s response to such fraudulent trading practices has set a benchmark for regulatory bodies across Asia, including SEBI, to adopt stricter anti-manipulation frameworks.
 
Additionally, Singapore enforces tiered leverage restrictions, where traders with lower capital reserves face stricter position limits. This prevents excessive speculation and ensures that retail investors engage in options trading within their financial capacity. Such measures could provide valuable insights for SEBI’s regulatory policies, particularly in addressing margin-induced risks in India’s options market.
 
While SEBI has made notable progress in regulating options trading in India, the comparative analysis highlights significant regulatory gaps that need urgent attention. By studying global best practices and enforcement mechanisms, India can enhance investor protection, prevent market manipulation, and promote a more stable options trading environment. The lessons from the United States, the European Union, the United Kingdom, and Singapore underscore the need for a more proactive, investor-centric regulatory approach to safeguard retail traders in India’s rapidly expanding derivatives market.

Regulatory Gaps and the Path to Reform: Rethinking SEBI’s Approach to Investor Protection

The Securities and Exchange Board of India (SEBI) plays a crucial role in overseeing options trading and protecting retail investors from excessive financial risk. Over the years, SEBI has implemented various regulations, such as higher margin requirements, enhanced disclosure norms, and risk mitigation measures, to create a structured and transparent trading environment. However, despite these efforts, systemic loopholes and enforcement challenges persist, exposing retail investors to market volatility, mis-selling, and financial manipulation[12].
 
While SEBI’s regulatory framework is extensive, it has struggled to keep pace with the evolving complexities of options trading, particularly in the wake of increasing retail participation. Several gaps in investor suitability assessments, risk disclosures, algorithmic trading regulations, and enforcement mechanisms have left investors vulnerable to high-risk speculation. This chapter examines these regulatory shortcomings and explores potential reforms that could strengthen SEBI’s approach to investor protection.
 

1. The Absence of a Comprehensive Suitability Framework

One of the most pressing issues in India’s options market is the lack of a robust suitability framework for retail investors. Unlike jurisdictions such as Singapore and the United Kingdom, where retail traders must pass knowledge assessments before trading in derivatives, India has no formal process to evaluate an investor’s understanding of complex financial instruments.
 
In SEBI v. K.K. Patel & Ors. (2014), the Supreme Court acknowledged the need for stricter suitability norms in financial transactions, emphasizing that regulators must ensure that retail investors are adequately informed before engaging in high-risk instruments. Despite such observations, retail traders in India continue to access options markets without clear competency checks, leading to significant losses for inexperienced participants.
 
A potential reform could involve mandatory risk-profiling and certification requirements for investors engaging in options trading, similar to Singapore’s Customer Account Review (CAR) framework. By introducing structured knowledge assessments, SEBI can ensure that only financially literate and risk-aware investors participate in speculative derivatives markets.
 

2. Inadequate Enforcement Against Mis-selling and Manipulation

SEBI’s enforcement mechanisms, though stringent on paper, often fail to deter fraudulent practices such as mis-selling, misleading advertisements, and market manipulation. Numerous brokerage firms and advisory platforms aggressively promote options trading to retail investors without disclosing inherent risks, often misrepresenting it as a low-risk, high-reward opportunity.
 
The case of SEBI v. Rakhi Trading Pvt. Ltd. (2018)[13] exposed how certain market participants manipulated stock options through circular trading—a practice where traders execute buy and sell orders with no real intention of taking positions, thereby distorting market prices. The Supreme Court ruled in favor of SEBI’s enforcement actions, yet such manipulative tactics persist, especially with the rise of social media-based investment groups and unregistered financial advisors.
To address this issue, SEBI could implement:
?       Stronger surveillance measures to detect price manipulation in options markets.
?       Strict penalties for unregistered advisors promoting options trading without appropriate regulatory approvals.
?       Enhanced transparency in brokerage advertisements, ensuring that promotional materials clearly disclose the high risks of derivatives trading.
 

3. The Lack of Negative Balance Protection and Leverage Restrictions

Retail traders in India often engage in leveraged options trading without fully understanding the downside risks, leading to significant financial losses. Unlike in the United Kingdom and the European Union, where negative balance protection ensures that retail traders cannot lose more than their deposited funds, India lacks similar safeguards, exposing traders to the possibility of unlimited losses in highly volatile markets.
 
The collapse of multiple retail traders during the 2020 market crash, when index options experienced extreme volatility, highlighted the urgent need for stricter leverage restrictions. While SEBI has attempted to curb excessive leverage through margin requirements, many brokers continue to offer high-exposure trades, leading to over-leveraged positions among retail investors.
 
A viable solution would be:
?       Implementing tiered margin requirements, where traders with lower capital reserves face stricter leverage limits.
?       Introducing negative balance protection, ensuring that retail traders do not lose more than their available funds in options trading.
?       Enhancing risk warnings and forced liquidation policies, requiring brokers to alert investors when margin requirements are dangerously low.
 

4. The Need for a More Investor-Centric Dispute Resolution Mechanism

Retail investors facing financial disputes in the options market often encounter challenges in seeking legal remedies against brokers and financial advisors. While SEBI has established the Securities Appellate Tribunal (SAT) for resolving investor disputes, the process is often complex, time-consuming, and inaccessible to smaller investors.
 
The case of Karvy Stock Broking Ltd. (2021), where thousands of retail investors suffered losses due to the misuse of their securities by the brokerage firm, exposed the flaws in India’s investor grievance redressal mechanism. Many investors struggled to recover their funds due to prolonged litigation and regulatory delays.
 
To strengthen investor protection, SEBI should:
?       Streamline dispute resolution procedures, making legal recourse faster and more accessible for retail traders.
?       Introduce specialized arbitration mechanisms for options market disputes, modeled after the Financial Ombudsman Service (FOS) in the UK.
?       Mandate compulsory investor compensation funds, ensuring that retail traders recover losses in cases of broker fraud or mismanagement.
India’s options market has witnessed exponential growth, but its regulatory framework has yet to fully adapt to the challenges posed by increased retail participation, algorithmic trading, and leveraged speculation. While SEBI has made commendable strides in strengthening market integrity, key gaps persist in investor suitability norms, risk disclosures, algorithmic trading oversight, and grievance redressal mechanisms[14]. By incorporating global best practices, enhancing enforcement actions, and introducing investor-friendly reforms, SEBI can create a more transparent, resilient, and fair options trading ecosystem. The path to reform requires a proactive regulatory approach, one that prioritizes investor protection over market expansion, ensuring that retail traders engage in options trading with greater financial security and informed decision-making.

 

Conclusion

The rapid expansion of India’s options trading market has brought both opportunities and challenges, particularly concerning retail investor protection. While SEBI has implemented various regulatory safeguards, persistent gaps in suitability norms, risk disclosures, leverage restrictions, and enforcement mechanisms continue to expose retail traders to undue financial risks. Comparative analysis with global regulatory frameworks highlights the need for stricter investor qualification criteria, enhanced surveillance of algorithmic trading, and more efficient dispute resolution mechanisms.
 
To ensure a more resilient and investor-friendly options market, SEBI must move beyond reactive measures and adopt a proactive, risk-based regulatory approach. Strengthening education, enforcement, and oversight will be crucial in safeguarding retail investors while fostering a well-regulated derivatives market. Ultimately, the goal should be to strike a delicate balance between market accessibility and investor protection, ensuring that India’s options market remains a robust and transparent investment avenue for all participants.
 
 
 

[1] The author is an LLM student specializing Corporate and Commercial Law in School of Law, Christ (Deemed to be University)
[2] Umakanth Varottil, The Evolution of Securities Regulation in India: A Historical and Comparative Perspective, 10 J. INDIAN L. & SOC'Y 45 (2019).
[3] Securities & Exch. Bd. of India v. Rakhi Trading Pvt. Ltd., (2018) 13 SCC 753 (India).
[4] Pratik Datta, Retail Investor Protection in India’s Securities Market: Assessing SEBI’s Regulatory Response, 32 NAT’L L. SCH. INDIA REV. 125 (2020).
[5] MCX Stock Exch. Ltd. v. Sec. & Exch. Bd. of India, (2012) 7 SCC 579 (India).
[6] Sec. & Exch. Bd. of India v. OPG Sec. Ltd., (2020) 15 SCC 294 (India)
[7]  Umakanth Varottil, The Evolution of Securities Regulation in India: A Historical and Comparative Perspective, 10 J. INDIAN L. & SOC'Y 45 (2019)
[8] Donald C. Langevoort, Rethinking Retail Investor Protection in Derivatives Markets, 96 CORNELL L. REV. 45 (2011).
[9] SEC v. W.J. Howey Co., 328 U.S. 293 (1946)
[10] Commodity Futures Trading Comm’n v. Schor, 478 U.S. 833 (1986).
[11] Henry T.C. Hu, Misunderstood Derivatives: Options Trading and the Need for Regulatory Reform, 102 YALE L.J. 1457 (1993)
[12] Arun Balasubramanian, Options Trading and Market Manipulation: An Analysis Under Indian Securities Law, 14 NUJS L. REV. 89 (2022).
[13] Sec. & Exch. Bd. of India v. Rakhi Trading Pvt. Ltd., (2018) 13 SCC 753 (India)
[14] Pratik Datta, Retail Investor Protection in India’s Securities Market: Assessing SEBI’s Regulatory Response, 32 NAT’L L. SCH. INDIA REV. 125 (2020).