IN THE HIGH COURT OF JUDICATURE FOR THE STATE OF TELANGANA HON’BLE SRI JUSTICE NAGESH BHEEMAPAKA WRIT PETITION No. 19343 OF 2020

06.05.2026 Between:

P.V. Ramprasad Reddy & others ….. Petitioner And Securities and Exchange Board of India ….. Respondent

O R D E R:

Petitioners are individuals and a company forming part of the promoter and promoter group of Aurobindo Pharma Limited, a public limited company whose shares are listed and traded on BSE Ltd. and National Stock Exchange of India Ltd. under the regulatory jurisdiction of the Securities and Exchange Board of India. Petitioners 1, 2 and 3 are citizens of India, while Petitioner No. 4 is a private company limited by shares incorporated under the Companies Act, 1956. It is stated, petitioners are aggrieved by the action of Respondent in issuing the impugned communication dated October 23, 2020 seeking to reopen a concluded settlement arrived at under the SEBI (Settlement Proceedings) Regulations, 2018, despite passing a binding settlement order dated May 6, 2020.

1.1. Petitioners contend that they are promoters and promoter group entities of Aurobindo Pharma Limited and were subjected to regulatory proceedings arising out of an investigation conducted by Respondent into the trading pattern of the scrip of the said company for the period commencing from July 22, 2008 to March 20, 2009, which ultimately culminated in issuance of show cause notice dated September 06, 2017 under Sections 11(1), 11(4) and 11B of the SEBI Act alleging violations of the SEBI (Prohibition of Insider Trading) Regulations, 1992 read with the SEBI (Prohibition of Insider Trading) Regulations, 2015, and parallel adjudication proceedings initiated on June 20, 2018 under Section 15G of the SEBI Act.

1.2. The adjudication proceedings, it is stated, resulted in the order dated September 23, 2019 bearing reference no. Order/MC/VS/2019-20/4550-4556 whereby penalties of approximately Rs.13 crores were imposed on Petitioners, which order was challenged by them before the Securities Appellate Tribunal in Appeal No. 559 of 2019, and during the pendency of the said Appeal as well as the proceedings arising out of the show cause notice dated September 06, 2017, Petitioners filed settlement Applications on October 25, 2019 under Regulation 3 read with Regulation 24 and Regulation 3(4) of the SEBI (Settlement Proceedings) Regulations, 2018 seeking to settle all pending and future proceedings.

1.3. It is further stated, the settlement applications underwent a detailed and rigorous three-tier process of consideration as contemplated under the Settlement Regulations, including examination by the Internal Committee on February 05, 2020, submission of revised settlement terms by letters dated February 07, 2020 and February 12, 2020, consideration by the High Powered Advisory Committee on March 02, 2020 and April 01, 2020, and final approval by the Panel of Whole Time Members, pursuant to which a notice of demand dated April 16, 2020 was issued by Respondent requiring payment of settlement amounts aggregating to Rs. 17,53,05,000/-.

1.4. The said notice of demand dated April 16, 2020 specifically set out the settlement amounts payable by each of petitioners, namely Rs.6,60,00,000/- by Petitioner No.1, Rs.2,64,00,000/- by Petitioner No.2, Rs.34,65,000/- by Petitioner No.3 and Rs.7,92,00,000/- by Petitioner No.4, together with legal costs of Rs.60,000/- each, and did not contain any component or reference whatsoever to disgorgement of alleged ill-gotten gains. In compliance with the said notice of demand, petitioners duly remitted the entire settlement amount along with legal costs, aggregating to Rs. 17,53,05,000/-, by April 30, 2020, with Petitioner No.1 paying Rs.6,60,60,000/-, Petitioner No.2 paying Rs.2,64,60,000/-, Petitioner No.3 paying Rs.35,25,000/- and Petitioner No.4 paying Rs.7,92,60,000/-.

1.5. Thereafter, respondent passed settlement order dated May 6, 2020 under Section 15JB of the SEBI Act read with Regulation 23 a