SEBI

Topic72 PYQ Analysis SEBI Grade A 2018 2024

PYQ Analysis — Securities Laws in SEBI Grade A Exam (2018–2024)

Topic 72 — Pattern Analysis, High-Frequency Topics, Question Types & Strategic Exam Preparation | SEBI Law Officer

The SEBI Grade A (Officer Grade) examination is the primary recruitment mechanism for SEBI Law Officers. The Phase 2 paper includes a dedicated Securities Laws paper — typically 100 marks — covering all six laws in this series. Analysis of papers from 2018 to 2024 reveals consistent patterns in question types, high-frequency topics, and the level of technical detail expected. This topic synthesises those patterns to guide last-mile exam preparation.

1. SEBI Grade A Exam Structure — Phase 2 Paper 2

Component

Details

Paper name

Securities Laws (Paper 2 of Phase 2)

Total marks

100 marks

Sections

Part A: Objective MCQs (typically 50-60 questions × 1 mark each); Part B: Descriptive questions (typically 3-4 questions × 10-15 marks each)

Time

Approximately 60-90 minutes for the objective section; additional time for descriptive

Negative marking

Typically 0.25 marks negative marking for incorrect MCQ answers

Coverage

All six securities laws: SCRA 1956, SEBI Act 1992, Depositories Act 1996, PFUTP 2003, SAST 2011, PIT 2015

2. Topic-Wise Weightage — Based on PYQ Pattern Analysis (2018-2024)

Law / Topic Area

Approximate MCQ Weightage

Approximate Descriptive Weightage

SEBI Act 1992 (Sections 11-24, SAT, penalties)

25-30%

1 full question often from SEBI Act enforcement framework

PIT Regulations 2015 (UPSI, insider, SDD, trading window)

20-25%

1-2 questions from PIT — definitions + case law typically

SAST Regulations 2011 (25% trigger, offer price, exemptions)

18-22%

1 question on takeover procedure or offer price calculation

PFUTP Regulations 2003 (fraud definition, Reg 4(2), cases)

12-15%

Often integrated with PIT — combined insider trading question

Depositories Act 1996 (demat, pledge, fungibility, rights)

8-12%

Shorter descriptive or MCQ-only

SCRA 1956 (definitions, derivatives, recognition)

5-8%

Rarely full descriptive — mostly MCQs

3. High-Frequency MCQ Topics — Tested in 3+ Years

Topic

Law

What is Tested

Section 15G penalty quantum (min ₹10 lakh; max ₹25 crore or 3× profit)

SEBI Act

The mandatory minimum + the dual maximum formula

25% SAST trigger vs 5% creeping limit

SAST

Arithmetic; method restriction for creeping (open market only)

SAT limitation period (45 days from order)

SEBI Act Section 15T

Exact timeline + condonation of delay

UPSI definition — six categories

PIT Regulation 2(1)(n)

Which specific information qualifies; what does NOT qualify

GAI definition — non-discriminatory access

PIT Regulation 2(1)(e)

Exchange filing = GAI; analyst briefing ≠ GAI

Insider definition — two categories

PIT Regulation 2(1)(g)

Connected person OR possessor of UPSI — EITHER qualifies

Connected person six-month look-back

PIT Regulation 2(1)(d)

Former employee/adviser remains connected for 6 months

SDD mandatory requirements

PIT Regulation 3(5)

Who must maintain; what data; technical requirements

Regulation 4(2)(a) PFUTP — misleading appearance

PFUTP

Circular trading, wash trades — the most tested PFUTP provision

Section 11B orders (types)

SEBI Act

Five types: C&D; debarment; disgorgement; impounding; refund

Section 15J factors (mandatory — three)

SEBI Act

Gain; investor loss; repetitiveness — AO MUST consider all three

Beneficial owner vs registered owner (depository)

Depositories Act Sections 2(a), 2(j), 9, 10

Depository = registered owner; investor = beneficial owner; Section 10 rights

Fungibility — Section 9A Depositories Act

Depositories Act

No distinctive numbers; ISIN-based; practical implications

SAST offer price formula (Regulation 8(1))

SAST

Highest of four parameters — numerical questions

Voluntary open offer minimum size

SAST Regulation 6(2)

10% minimum (vs 26% mandatory) — frequently tested distinction

4. High-Frequency Descriptive Topics

Year (Approx.)

Descriptive Questions Asked

2024

UPSI definition and application; trading window and pre-clearance mechanism; SAST offer price formula with calculation

2023

Section 11B orders (types and natural justice); PIT reversal of burden (Explanation to Reg 4(1)); PFUTP Reg 4(2) — enumerate and explain 5 prohibited practices

2022

Insider definition and categories; SAST exemptions under Regulation 10 (5 exemptions); SDD requirements and SEBI investigation

2021

SEBI enforcement mechanism (investigation to prosecution); HUL v. SEBI significance; SAST mandatory open offer procedure and timeline

2020

Connected person definition and six-month look-back; PFUTP fraud definition (Reg 2(1)(c)) vs IPC fraud; SAST creeping acquisition

2019

SAT — constitution, jurisdiction, powers; PIT Code of Conduct (Schedules B and C); PFUTP legitimate purpose vs insider trading

2018

SEBI Act functions (Section 11(2)); Depositories Act beneficial owner rights; SAST definition of control

5. Common MCQ Traps — Know These Before the Exam

Trap

Correct Answer

Law / Section

DPS within '5 WD' not '7 WD'

DPS = 5 WD from PA; PA = 2 WD from trigger

SAST Regulations 13 & 14

Voluntary offer minimum is 10%, not 26%

Mandatory = 26%; Voluntary = 10%

SAST Regs 6(2) and 7(1)

Section 15G has mandatory MINIMUM of ₹10 lakh

₹10 lakh minimum; ₹25 crore or 3× max

SEBI Act Section 15G

Insider = EITHER connected person OR possessor of UPSI

NOT both required — either independently qualifies

PIT Regulation 2(1)(g)

Connected person six-month look-back, NOT three months

SIX months preceding the concerned act

PIT Regulation 2(1)(d)

SDD retention = 8 years, NOT 5 years

8 years as per SEBI circular

PIT Regulation 3(5) + SEBI Circular

SAST 52-week look-back for VOLUNTARY offer (not mandatory)

52-week restriction is only for voluntary offer under Regulation 6(3)

SAST Regulation 6(3)

SAST annual disclosure = April 7 (7 WD of March 31)

NOT April 15 or April 30

SAST Regulation 28

PFUTP Reg 4(2)(a) creates 'misleading appearance' — covers circular trading AND wash sales

Both are sub-types of Reg 4(2)(a)

PFUTP Regulations

Trading plan cooling-off = 6 months, NOT 3 months

MINIMUM 6 months before first trade under plan

PIT Regulation 5

6. Recommended Last-Week Revision Strategy

Days Before Exam

Focus Area

Day 7

Complete reading of all six laws' critical sections (Topic 71 Quick Revision Chart). Focus on section numbers and exact content.

Day 6

PIT Regulations 2015 — all definitions; Regulation 3 (communication); Regulation 4 (trading); SDD; Code of Conduct. Do Topic 68 MCQ set.

Day 5

SAST Regulations 2011 — triggers (3(1), 3(2), 4); offer price formula (Reg 8(1)); exemptions (Reg 10); disclosures. Do Topic 55 MCQ set.

Day 4

PFUTP Regulations 2003 — Regulation 4(2) all sub-clauses; cases (Rakhi Trading; Kanaiyalal Patel; Kishore Ajmera). Do Topic 43 MCQ set.

Day 3

SEBI Act enforcement framework — Sections 11-15Z; Section 11B orders; AO adjudication; SAT. Cross-topic comparison (Topic 70).

Day 2

Depositories Act — Sections 2, 8, 9, 9A, 9B, 10, 11, 16. SCRA — Sections 2(h), 13, 18A, 23, 26. Case law review.

Day 1

Full mock test (Topic 74). Review wrong answers. Final revision of 'trap' questions (Topic 72 Section 5).

🎯 EXAM POINTERS — Topic 72: PYQ Analysis

  • SEBI Act (25-30%) + PIT (20-25%) = highest combined weightage (~50%). Prioritise these two.
  • SAST (18-22%): offer price calculation questions appear regularly — practice the formula with numbers.
  • PFUTP (12-15%): Regulation 4(2)(a) is the single most tested provision. Know all sub-clauses.
  • DA (8-12%): Sections 9A and 9B (fungibility + free transferability) are the most tested.
  • SCRA (5-8%): Section 2(h) definition + Section 18A (derivatives legality) are the most tested.
  • Descriptive: ALWAYS answer with: Issue + Law (exact section) + Analysis + Conclusion. Use case citations.
  • COMMON TRAP: DPS = 5 WD (not 7 WD). Voluntary offer = 10% min (not 26%). Section 15G min = ₹10 lakh.
  • Trading plan cooling-off = 6 months. SDD retention = 8 years. SAST annual disclosure = April 7.
  • Connected person look-back = SIX months (not three). Insider = EITHER connected OR possessor of UPSI.
  • Negative marking: skip questions where you cannot eliminate at least two options confidently.

← Topic 71: Quick Revision Chart — All 6 Laws | Next → Topic 73: 500 MCQ Bank — All Securities Laws

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