Market regulator Securities and Exchange Board of India (SEBI) has directed Nishaan Singh, proprietor of Sanbun Investments and Sanbun Capital Hedge Fund, to refund ₹4.72 crore collected through unregistered portfolio management services (PMS) activities. The market regulator has also barred him from accessing the securities market for three months or until completion of the refund process, whichever is later.
During the proceedings, Mr Singh claimed that a substantial portion of the money credited to his bank accounts represented fees collected for stock market education courses conducted through online platforms. He submitted invoices, course-completion certificates, and login records from the Teachable platform to support his claim that around ₹11.88 crore in course fees was received.
However, SEBI found multiple discrepancies in the material submitted by him. The regulator observed inconsistencies between course fees and actual payments received, questionable course-completion certificates, irregular login patterns, and instances in which students allegedly completed courses despite minimal or no activity on the learning platform.
SEBI also examined bank transaction narrations and found several entries referring to ‘hedge fund’, ‘personal calls’, ‘live trading session’, ‘daily calls’, ‘trading service’ and ‘membership fees’, which indicated investment-related activities rather than educational services.
The regulator further noted that one alleged student shared WhatsApp conversations showing that Mr Singh had attempted to influence responses likely to be provided to SEBI during the investigation. According to the order, Mr Singh allegedly described the regulator’s interaction as a ‘course review’ and guided the individual on how to respond.
A forensic audit report (FAR) had initially concluded that ₹82.65 lakh was collected through unregistered PMS activities. Mr Singh’s authorised representative had even agreed to refund that amount during personal hearings.
SEBI, however, found the forensic audit inconclusive, observing that the auditor relied heavily on sample-based verification and unverifiable telephonic confirmations without sufficient documentary evidence. The regulator subsequently conducted its own detailed examination of the bank accounts and transaction narratives.
After excluding legitimate credits such as rental income, fixed deposit proceeds, mutual fund redemptions, brokerage receipts and certain family transfers, SEBI concluded that ₹4.72 crore had been collected through unregistered PMS activities. Accordingly, it directed Mr Singh to refund the amount to investors within three months.
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