On 26 April 2013, a two-judge Bench of the Supreme Court upheld SEBI's market-access debarment and ₹50 lakh adjudicating-officer penalty against a whole-time director of Pyramid Saimira Theatre Ltd. for fraudulent misstatement of financial results under Section 12A of the SEBI Act and the PFUTP Regulations. Directors closely associated with management, the Court held, cannot 'shut their eyes to what must be obvious to everyone' — red flags in revenues, profits, receivables and deposits engage an affirmative duty of inquiry, and passivity is not a defence. The judgment is the foundational SC authority on whole-time-director liability for company-level securities fraud; the proposition has often been read more broadly than the case decides.