The M&A market in India is characterized by frequent media leaks with such leaks carrying significant real-world consequences for the parties involved, ranging from disrupted negotiations to accelerated timelines and increased deal premiums.
Against this backdrop, this note examines a recent decision delivered by the Supreme Court of India in December 2025 upholding a penalty imposed by the Securities and Exchange Board of India on Reliance Industries Limited for failing to make timely disclosures following media reports of a possible investment by Facebook Inc. The authors assess the judicial interpretation of disclosure obligations under India’s insider trading framework. The authors further highlight the interplay between two key regulatory regimes governing market disclosures – the PIT Regulations and the LODR.
