SEBI ordered Nishaan Singh of Sanbun Investments to refund ₹4.72 crore to investors for operating an illegal Portfolio Management Service (PMS) without proper registration. This enforcement action highlights SEBI's crackdown on unauthorized investment advisory services. PMS requires SEBI registration under SEBI (Portfolio Managers) Regulations, 2020. Unregistered operators face disgorgement orders, penalties, and debarment from capital markets. The case demonstrates regulatory vigilance in protecting retail investors from fraudulent investment schemes operating without mandatory compliance frameworks.

Portfolio Management Service (PMS) is a professional investment service where qualified portfolio managers make investment decisions on behalf of clients with minimum investment thresholds. SEBI mandates registration under Portfolio Managers Regulations to ensure investor protection through compliance requirements including capital adequacy, risk management systems, and disclosure norms. Nishaan Singh's case represents a classic enforcement scenario where individuals collect investor funds promising portfolio management without meeting regulatory standards. Such illegal operations typically involve higher promised returns, lack of proper documentation, and absence of investor grievance mechanisms. The ₹4.72 crore refund order demonstrates SEBI's disgorgement powers under Section 11B of SEBI Act, allowing recovery of wrongful gains plus interest. This enforcement aligns with SEBI's broader mandate to protect investors from unregistered intermediaries who exploit regulatory gaps. The case underscores importance of due diligence by investors to verify SEBI registration status before investing. Such violations often involve Ponzi-like structures where early investors are paid from new investor funds rather than genuine investment returns.