This marks the firm's first legal move in the matter.
The appeal contends that Sebi denied complete inspection of materials generated during earlier probes by the National Stock Exchange (NSE) in November 2024. Sebi's own Integrated Surveillance Department (ISD), in a December 2024 analysis reviewed by Mint, found no evidence that Jane Street's trades moved index prices in a way that benefited its options positions. The ISD recommended the matter not be pursued further.
Emails sent to Jane Street went unanswered.
In its 3 July interim order, Sebi barred the US trading firm from trading securities in India, saying some of its strategies were manipulative and caused losses for retail investors. Jane Street was given 21 days to respond.
India's markets regulator alleged that Jane Street bought large quantities of constituents in the Bank Nifty index in the cash and futures markets to artificially support the index in morning trade, while simultaneously building large short positions in index options, which were exercised or allowed to expire later in the day.
Jane Street's counter
In its appeal, Jane Street has argued that both the NSE report and the ISD report examined several of the same dates later cited by Sebi. Yet, neither found manipulation. The firm says Sebi has not explained why a new internal team subsequently reached the opposite conclusion on essentially the same data.
"Across 53 patches [time periods], in 48 patches-i.e., in more than 90%-it could not be established that the trading activity of Jane Street Group has attributed to the price movement of the constituents/index in a way which has benefited the open positions of other Group members in derivative segment," the appeal said quoting the ISD's 11 December 2024 findings.
It added that the remaining five patches yielded negligible profits relative to the group's broader trading.
Jane Street has argued that both the NSE report and the ISD report examined several of the same dates later cited by Sebi. Yet, neither found manipulation. The firm says Sebi has not explained why a new internal team subsequently reached the opposite conclusion on essentially the same data.
The appeal asks SAT to direct Sebi to furnish the complete ISD report, the full chain of communication with NSE (including requests to alter or abandon earlier "objective criteria" and analyses tied to a later "Extended Marking the Close" theory), complaint materials that allegedly prompted Sebi's "re-examination," and unmasked order and trade-log data needed to test Sebi's claims patch by patch.
Jane Street has claimed that these records are vital to prepare a formal response. It says Sebi's selective disclosure and redactions deny a fair opportunity to rebut allegations-contrary to Supreme Court rulings that require disclosure of relevant investigative material at adjudication. The rulings also bar "cherry-picking," except for narrow, reasoned exceptions involving third-party confidentiality or market stability.
While Sebi's interim order restrained market access unless ₹4,843.6 crore was placed in escrow, the appeal notes the firm deposited the full amount. It says Jane Street has also refrained from fresh purchases, underscoring cooperation while insisting on access to records needed for due process before the whole-time member hearing.
The appeal also seeks interim directions preventing Sebi from taking further steps until full inspection is granted.