Satyam Shivam Sundaram Trading Case: SEBI Orders ₹3.17 Crore Refund, Imposes ₹15 Lakh Penalty on Unregistered Advisers

Moneylife Digital Team 28 November 2025

Investor Interest

Market regulator Securities and Exchange Board of India (SEBI) has directed Satyam Shivam Sundaram Trading, operated by proprietor Gagan Choudhury, along with Gagan Choudhary, Satyam Suman Choudhary and Suman Choudhary, to refund ₹3.17 crore collected from investors through unregistered investment advisory activities. SEBI has also imposed a monetary penalty of ₹15 lakh on the noticees after concluding that they violated provisions of the SEBI Act, the Investment Advisers Regulations and the PFUTP Regulations.

SEBI action stems from two complaints received through SCORES in July and September 2022. The complainants alleged that a fake advisor named ‘Satyam’ had caused financial losses by offering paid investment advice through Telegram and WhatsApp, using mobile number XXXXXX0268. Both complainants provided payment details linked to an HDFC Bank account.

Upon seeking information from HDFC Bank, SEBI found that the account belonged to Satyam Shivam Sundaram Trading, operated Gagan Choudhury from Darbhanga, Bihar. Neither was registered as an investment adviser. SEBI’s investigation covering Telegram channels, Google data, Rigi Pay records and chats confirmed that all noticees were running a structured, unregistered advisory business under the name “Satyam.”

SEBI investigation revealed that the noticees operated multiple Telegram channels offering paid advisory services. They advertised subscription plans, provided trading recommendations, and instructed investors to pay through their HDFC account and UPI numbers. SEBI noted that the channels openly provided ‘full guidance’, ‘entry and exit timing’, and ‘live assistance’, proving these were not educational platforms but illegal advisory services.

Further bank records showed that the HDFC account received ₹1.33 crore between April 2022 and March 2023, of which SEBI identified ₹1.08 crore as advisory fees. Another ₹2.09 crore was collected through Rigi Pay via an account linked to Satyam Choudhary, bringing the total illegal collection to ₹3.17 crore.

SEBI also highlighted several misleading claims, including promises of assured profits of ₹4,000 to ₹5,000 daily, which constituted fraudulent inducement under the SEBI Act. The noticees’ defence that their channels were only educational was rejected, as they failed to provide any study material or research content to substantiate the claim. On the contrary, evidence showed specific trading tips, subscription plans, and refunds issued to clients are clear indicators of advisory activity.

While Gagan Choudhary expressed interest in settlement after receiving the show cause notice (SCN), no settlement application was filed within the stipulated 60-day period. Despite SEBI's clear guidance on the settlement process, the noticees failed to act, indicating an attempt to delay proceedings. SEBI therefore proceeded with adjudication.

The regulator concluded that the noticees had violated Section 12(1) of the SEBI Act and Regulation 3(1) of the Investment Adviser Regulations by offering investment advice without being registered. They also engaged in misrepresentation and unfair trade practices, attracting penalties under Sections 15EB and 15HA.

Considering the severity of defaults, SEBI ordered the noticees to refund the full ₹3.17 crore collected illegally after adjusting ₹2 lakh already refunded to all affected investors. A monetary penalty of ₹15 lakh, to be paid jointly and severally by the noticees, was also imposed.

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