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SEBI: Non-Connected Persons Can Be Insiders Through UPSI Possession

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Summary

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  • SEBI has clarified that a person can be classified as an "insider" even if they are not a connected person, based on possession of unpublished price sensitive information (UPSI).
  • This distinction was highlighted in the Religare Enterprises Limited case, where UPSI originated from the Burman Group, not REL.
  • The ruling emphasizes that a person's position in a company does not automatically confer insider status if the information comes from outside the listed entity.
  • This could significantly impact how insider trading cases are prosecuted, particularly in acquisitions and mergers where UPSI may come from acquirers rather than target companies.

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