A Listed Company was awarded three contracts of drilling rigs. The value of contracts are substantial to the revenue of the Company. As per the normal procedure for bidding there was a time gap between the dates of decla

The Securities Exchange Board of India (SEBI) by its order in the matter of Deep Industries Limited (DIL) has held that Sujay is an insider by way of his association with any officer of the company (in the given case the Managing Director) by way of frequent communication with him in their social capacity as evident in this case by frequent interactions including likes on the social media. Further in the said case it was also held that by virtue of this association and frequent communication, Sujay was reasonably expected to have access to the UPSI of DIL at the relevant period. Therefore, as per Regulation 2(1)(d)(i) of the Prohibition of Insider Trading Regulations, 2015, Sujay is a connected person and consequently is an Insider with respect to DIL. (i) Yes, in view of the case law discussed above and Regulation 2(1)(d)(i) of the Prohibition of Insider Trading Regulations, 2015, the posting of the information on Facebook by the Managing Director, does made other Facebook friends a 'connected person' on the basis of Social Association. (ii) Yes, in view of the above discussion, this meant the connected person are reasonably expected to have, directly or indirectly, an access to 'Unpublished Price Sensitive Information' by virtue of their association and frequent communication as evident in this case by likes on the social media, unpublished price sensitive information.