deltin55 Publish time 1970-1-1 05:00:00

The NSE Scam Didn't Collapse. The Investigation Did.

While millions of retail investors waited for justice, the officers investigating India's biggest stock market scandal in two decades were collecting medals.

In 2023, one CBI officer probing the NSE co-location case was promoted to Deputy Inspector General. His colleague received the Union Home Ministry Medal for Excellence in Investigation. The awards were given while court records showed the probe was piecemeal, incomplete, and contradicted itself. They were given while the Delhi High Court had already rebuked the CBI for filing a chargesheet that did not relate to the offences in its own FIR. They were given while the biggest allegations in the case — bribery of regulators, hawala networks, stolen government documents, algorithmic software built on pilfered exchange data — had not been investigated at all.

Seven years have now passed. On April 29, 2026, a Delhi court issued summons to 44 accused in the NSE co-location case. Headlines called it a reckoning. It is not. Read the court order carefully and a different story emerges — not of justice arriving late, but of justice being methodically reduced until almost nothing meaningful remains.

The supplementary chargesheet the CBI filed on September 17, 2025 is not a document of prosecutorial ambition. It is a document of institutional surrender.
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Seven Years Ago, The CBI Promised Everything

The FIR registered on May 28, 2018, was a sweeping indictment of systemic corruption at the heart of Indian finance.

It alleged that certain broker entities, including OPG Securities, had in criminal conspiracy with NSE officials abused the exchange's server architecture to gain illegal trading advantages. It alleged that brokers had been secretly tipped off about server start times. That select firms had been allowed to connect to faster backup servers, gaining speed advantages that translated into enormous profits at the cost of other traders and retail investors. That tick-by-tick data — revealing the entire order book in real time, a view unavailable to ordinary investors — had been shared with insiders who used it for profit. That bribe money had passed between brokers and officials at both NSE and SEBI. That a former Finance Ministry consultant named Ajay Narottam Shah had collected NSE's sensitive trade data under the cover of research, passed it to private parties who built an algorithmic trading software called Chanakya, and sold that software to select brokers. (The same came out in another forensic audit of commodity exchange MCX where the report revealed how Ajay Shah's accomplices were collecting data secretly. CBI let go of all this).

The FIR further alleged the existence of hawala-linked financial transactions and suspicious overseas trading activity spanning jurisdictions including Dubai, Ghana, Singapore, Hong Kong and China. The FIR read like the opening of a historic prosecution.
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The Surrender

Now read what the CBI's supplementary chargesheet, filed seven years later, says about each of those promises.

On Ajay Shah and the Chanakya software: "This allegation could not be proved beyond reasonable doubt in the course of investigation."

On hawala transactions: "Despite exhaustive scrutiny the allegations in this regard could not be substantiated."

On illegal overseas trading: "No prosecutable evidence in this regard surfaced throughout the investigation."

On bribery of SEBI and NSE officials: Absent. Without explanation. The "unknown officials of SEBI" promised in the FIR have never been named, never been charged, never been summoned.

What happened to the most explosive allegations in India's biggest market fraud? They vanished. Not because the accused were proven innocent. Not because evidence was examined and found wanting. They vanished because the investigation that promised to pursue them quietly stopped pursuing them.

This is not merely the story of market manipulation. It is the story of an investigation that progressively abandoned its own most serious allegations.
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The Man Who Was Named In The FIR And Never Charged

No single failure in this seven-year investigation is more consequential — or more difficult to explain — than what happened to Ajay Narottam Shah.

Shah was no minor figure. A former consultant to the Finance Ministry under P. Chidambaram, he occupied a position of extraordinary access: to power, to policy, and to the inner workings of India's financial markets. His partner Susan Thomas — whose claimed PhD from the University of Southern California turned out to be fake, a credential she had used for years to present herself as a credible academic researcher — was the promoter of a company that developed and sold algorithmic trading software. That Thomas's brother-in-law simultaneously headed NSE's own surveillance operations, and never once disclosed this conflict, was either a spectacular coincidence or something far more deliberate.

Together, Shah and Thomas had cultivated relationships of unusual closeness with NSE's two most powerful chiefs — Chitra Ramkrishna and Ravi Narain — as well as senior SEBI officials and Finance Ministry bureaucrats. What did those relationships yield? NSE's sensitive tick-by-tick data. Confidential exchange information. And, revealed by Income Tax raids on Shah, cabinet notes and policy documents whose possession raises serious questions under the Official Secrets Act — documents that could have materially shaped trading positions in a market Shah's ecosystem was simultaneously trying to profit from.

The CBI had this. It had SEBI's documentation of the data-sharing. It had forensic audit findings. It had the IT raid revelations. It had named Shah in its own FIR. It had told courts as recently as 2022 that investigation against Shah "pertaining to unauthorised access to NSE data and its misuse" remained pending.

The September 2025 supplementary chargesheet says the allegation "could not be proved beyond reasonable doubt."

Ajay Shah ultimately faces no criminal charge in the supplementary chargesheet. Susan Thomas walks free. The brother-in-law who ran NSE's surveillance while his family member ran a competing trading software business walks free. The question of what was built from NSE's stolen data, who profited, and what happened to those profits — unanswered. The trail from stolen exchange data to trading software to market manipulation to retail investor losses — uninvestigated.

Investigations fail when evidence does not exist. This investigation had evidence. It had forensic reports, tax raids, seized government documents, SEBI findings, and years of institutional records. Yet one by one, the most serious allegations disappeared from the prosecution record. The resulting case looks dramatically narrower than what investigators originally promised.
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The Himalayan Yogi And The Intelligence SEBI Had That CBI Ignored

When SEBI's investigation unearthed emails between Chitra Ramkrishna and a person she described only as a "Himalayan Baba" or "Yogi" — emails in which she shared confidential NSE board papers, financial data, strategic plans, personnel decisions, and even the exchange's self-listing proposals — it was one of the most extraordinary regulatory discoveries in Indian financial history.

The emails were not ambiguous. They showed the head of India's largest stock exchange conducting her tenure in active consultation with an anonymous external individual who had no formal role, no disclosed identity, and no business receiving documents that SEBI's own regulations demanded be kept strictly confidential. The regulator's own penalty order documented the breach in detail. The damage to market integrity was not hypothetical. Board restructuring, portfolio allocations, key executive decisions — the "Yogi" was being consulted on all of it.

The CBI arrested Ramkrishna in March 2022. It then advanced the theory that the "Yogi" was Anand Subramanian — a former employee of Balmer Lawrie, a mid-tier public sector company — who had supposedly constructed this persona to extend his influence over Ramkrishna. Set aside for a moment that this theory asked the public to believe that a man with no background in financial markets, no institutional gravitas, and no known expertise in corporate governance had somehow presented himself as a mystical Himalayan guide and successfully manipulated the most powerful woman in Indian finance on decisions of national economic consequence. Set aside even that the Delhi High Court, in granting Ramkrishna bail in September 2022, eviscerated the CBI's case as piecemeal and incomplete.

Focus instead on what the seven-year investigation never asked: Who was receiving NSE's most sensitive documents? What did that individual do with them? Did that access — to board deliberations, to strategic plans, to financial data — translate into any market activity?

These questions do not appear in the supplementary chargesheet. The Yogi — whose influence over NSE's leadership SEBI documented in writing — remains officially unidentified. In the criminal proceedings, the most surreal dimension of India's biggest exchange scandal has simply been left unexamined.
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The Secondary Servers: Seven Years To Charge What Deloitte Proved In 2015

Here is the central irony of the April 29, 2026 court order — the irony that turns what looks like a prosecution milestone into something closer to an indictment of the CBI itself.

The charges that survived seven years of investigation — the allegations that form the substantive basis for summoning 44 accused — are the ones that required the least investigation. They were already proven. Not by the CBI. By Deloitte.

The mechanics of the secondary server abuse were simple and devastating. NSE's co-location facility, launched in 2010, allowed brokers to place servers near the exchange's order-matching engine. The architecture used primary servers, available to all, and secondary servers — backup systems, by design reserved for emergencies, and therefore carrying zero load under normal conditions. A connection to a secondary server was effectively a private lane on an empty road while everyone else crawled through traffic. The speed advantage was real, measurable, and worth enormous sums in high-frequency trading.

Select brokers made this connection not occasionally. They did it repeatedly, daily, for years. Deloitte's forensic review of NSE's co-location facility documented it. SEBI's own Technical Advisory Committee — led by an IIT professor — confirmed that OPG Securities had "consistently logged in first on selected TBT servers on most of the trading days during the period 2010 to 2014." The names of firms that had exploited secondary server access were not secrets waiting to be uncovered. They were in reports that existed before the CBI filed its FIR.

The CBI took seven years to file charges for it.

And what did those charges actually allege? That brokers connected to the wrong servers. That two mid-level NSE officials — Mahesh M. Soparkar and Devi Prasad Singh — "failed to enforce compliance or initiate corrective measures against repeated violations." That Chitra Ramkrishna failed to implement a load balancer and a randomizer despite being told she should.

Omissions. Regulatory lapses. The woman who shared NSE's most confidential documents with an unidentified person for years — charged with not installing technical safeguards. The system that enabled Rs 812 crore in illegal profits across 22 firms — explained as a failure of middle management to send strongly worded emails.

The Indian School of Business, commissioned to quantify the illegal profits, calculated that across 22 firms the gains totalled over Rs 812 crore. The largest single beneficiary in the supplementary chargesheet: Tower Research Capital Markets India (formerly Shaastra Research) — a major global high-frequency trading firm — with alleged illegal profits of Rs 182 crore.

None of this required seven years to establish. The forensic auditors established it a decade ago. The regulator's technical experts confirmed it.

If further proof were needed that these facts were never seriously in dispute, even the recent judgment of National Company Law Appellate Tribunal in Manoj K. Sheth v. Competition Commission of India records the same grievance: that certain trading members repeatedly accessed less crowded secondary servers where microsecond latency differences created measurable speed advantages in algorithmic trading. In other words, seven years after the CBI began investigating the co-location scandal, the central factual architecture of the case remains exactly what independent auditors had already documented a decade earlier.

The CBI's contribution was to eventually file charges for what was already documented — while abandoning everything that was not.
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The Nexus Nobody Investigated

The NSE co-location scandal was never only about brokers connecting to wrong servers. From the beginning, the evidence pointed at something larger: a set of overlapping relationships between exchange leadership, regulatory officials, Finance Ministry consultants, and market participants that had made the fraud possible and kept it invisible for years.

NSE launched its co-location facility in 2010 without SEBI's regulatory inspection and approval — a clear and documented fiduciary failure by the regulator then under Chairman C.B. Bhave, whose ties to NSE's leadership were well-known in regulatory circles. The system that SEBI was mandated to inspect before it went live simply went live. Unchecked. For years.

This was not incompetence that required sophisticated investigation to establish. It was documented in SEBI's own records. Yet the CBI's supplementary chargesheet — the culmination of seven years of investigation — charges no SEBI official. Pursues no regulatory failure. Examines no relationship between NSE leadership and the regulator that should have been watching it.

Ravi Narain, NSE's longest-serving chief, the man who was MD for nearly two decades while the co-location infrastructure was conceived, built and exploited, faces no charge in the co-location case. The CBI charged him in a separate phone-tapping matter on the basis that as NSE's head he had knowledge of decisions made under his watch. The same logic — that institutional responsibility follows institutional authority — was apparently unavailable when it came to the infrastructure that generated hundreds of crores in illegal profits on his watch.

The Finance Ministry nexus — the intersection between a regulator, an exchange, a consultant named Ajay Shah, and a finance minister whose office Shah had served — was named in the FIR as a subject of investigation. The supplementary chargesheet does not mention it.

Seven years. Medals. Promotions. And the nexus that made everything possible — untouched.
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The Ledger

Seven years of investigation into India's biggest market fraud. Here is what the CBI produced.

A main chargesheet in April 2022, rebuked by the Delhi High Court as piecemeal, which addressed not the co-location scam but the illegal appointment of Anand Subramanian. A supplementary chargesheet in August 2022 that added a handful of brokers. A supplementary chargesheet in September 2025, filed seven years after the FIR, that charged brokers for secondary server access — already established by Deloitte — while formally abandoning the Chanakya software allegation, the hawala allegation, the foreign trading allegation, and the SEBI bribery allegation.

Ajay Shah: no charge. Susan Thomas: no charge. Any SEBI official: no charge. The Himalayan Yogi: unidentified. The bribery of regulators: unsubstantiated. The overseas financial network: no prosecutable evidence. The data theft that enabled an entire algorithmic ecosystem: could not be proved.

And on the other side of the ledger: promotions for investigating officers. A Home Ministry medal for excellence. A nine-year wait — and counting — for retail investors who traded on an exchange that, per the CBI's own case, was systematically rigged against them.

The NSE co-location scandal may ultimately be remembered as a case where the investigation narrowed so dramatically that the most consequential questions were never answered.
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What A Court Order Reveals

The April 29, 2026 order is 26 pages. It will be reported as a step forward — 44 accused, fresh summons, the wheels of justice turning. Editors will note Tower Research. They will count the brokerages. They will total the illegal profits.

They should instead count what is missing.

Every financial crime prosecution eventually produces a document that tells you who got away and why. In the NSE co-location case, that document is the supplementary chargesheet of September 2025, as reflected in the cognizance order of April 2026. Its omissions are its most important content. Its silences are louder than its charges.

The millions of ordinary Indians who put their savings into a market they believed was fair did not need a perfect investigation. They needed an honest one. One that followed evidence where it led. One that asked why NSE's co-location facility went live without regulatory approval. One that examined the cabinet notes found in the home of a Finance Ministry consultant. One that identified the Himalayan Baba whose influence over NSE's leadership SEBI documented in writing. One that charged the officials at the regulator who looked the other way while the fraud ran for years.

They got seven years of investigation that, in the end, charged brokers for connecting to the wrong servers.

The biggest fraud in India's stock market did not disappear. The allegations did.
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This report is based on the April 29, 2026 order of the Special Judge (PC Act) CBI-02, New Delhi in CC/28/2022 CBI v. Chitra Ramkrishna & Ors.; the Delhi High Court bail order of September 2022 in the same matter; earlier CBI chargesheets; SEBI investigation records and penalty orders; forensic audit findings; and previous reporting on the NSE co-location case.

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