Matter No: NSE-SB-2025-10-745789 Mr.Swamidas Gurunath Dalvi (" Complainant ”) Category of Complainant (Investor) PAN: AABPD7069H Versus M/s Zerodha Broking Ltd. (" Respondent ”) Category of Respondent (Trading Member) CONCILIATOR: Arvind Kumar Pradhan Conciliation Report Erdac Solutions Pvt. Ltd. is an independent institution facilitating and administering electronic Alternative Dispute Resolution via its online platform, CADRE, also referred to as Online Dispute Resolution (" ODR ”) Institution, having its registered office at 42, 12th Main Rd, 4th T Block East, KV Layout, Jayanagar, Bengaluru, Karnataka – 560011. Erdac Solutions Pvt. Ltd. has been empanelled by NSE Limited (“ Exchange ”) in accordance with the SEBI Master Circular No. SEBI/HO/OIAE/OIAE_IAD- 1/P/CIR/2023/145 dated August 11, 2023 (" SEBI Circular ”) as may be amended/modified from time to time, for undertaking time-bound online Conciliation and online Arbitration. The above-mentioned matter was referred Erdac Solutions Pvt. Ltd. via SMARTODR.IN (“ ODR Portal ”), a common Portal established by the Market Infrastructure Institutions (" MII ”) in accordance with the SEBI Circular, for harnessing online Conciliation and online Arbitration for resolution of disputes arising in the Indian Securities Market. Further, the parties have accepted the terms and conditions of ODR Portal. The undersigned has been appointed as a Conciliator by Erdac Solutions Pvt. Ltd. on Nov 10, 2025 2025 in the present matter. During the proceedings, attempts were made for resolving the matter through Conciliation in accordance with the SEBI Circular. In the matter no. NSE-SB-2025-10-745789 raised by the Complainant against the Trading Member, meeting was held on date 19th November, 2025 at time 4 p.m. through Erdac Solutions Pvt. Ltd. via video conferencing. Page 1 of 5 Zoho Sign Document ID: DF9AC547D-9SEUUYGNYGEKJLWYCHQAAIKXT9DYBFKJZ4CY9RZNVAS ISSUES RAISED BY THE PARTIES Issues raised by the Complainant < Mr. Swamidas Gurunath Dalvi > 1. He is having a Trading account with Zerodha Broking Ltd. with client code YXM852. The account is having the facility to add two secondary bank accounts. 2. In July 2025, while using the console platform to add a new secondary bank account, he discovered that the new addition overwrites an existing secondary bank account record instead of a new entry.. 3. He has verified this behavior multiple times and finds that it is still observing the same pattern of overwriting. 4. The secondary account is being overwritten due to a hidden discrepancy on an unrelated use-case ( user interaction with system for specific goal). This occurred when he clicked the ‘Edit’ icon of an existing secondary bank account , closed that screen, and then clicked ‘Add bank Account” to login a new use-case. The overwriting was recorded. The modification request entry shows a bug (unpredictable, non-deterministic behavior). This is a latent defect.. It reflects data integrity issue. Zerodha’s caching mechanism is flawed and needs correction. Zerodha is masking the defect under procedural caution.. 5. Zerodha’s system allowed unintended modification of bank account data which jeopardizes integrity and accuracy in client records. 6. Zerodha have not admitted the existence of the defect. 7. He wants Zerodha’s caching mechanism to be declared defective affecting service accuracy. He also wants directing Zerodha to implement corrective measures in its console platform to prevent unintended overwriting of linked bank accounts and to put up a corrective action report to NSE and SEBI. Response of the Respondent to the issues raised by the Complainant: The Respondent was represented by Mr.Abhishek Singhania. He submitted that Page 2 of 5 Zoho Sign Document ID: DF9AC547D-9SEUUYGNYGEKJLWYCHQAAIKXT9DYBFKJZ4CY9RZNVAS 1. Clients can link upto 3 bank accounts to their Zerodha account- one primary, one secondary and a tertiary account. Secondary bank accounts can only be used for adding funds. A prescribed procedure is to be followed for adding an account. 2. In the case of Complainant, the client first clicked on the ‘Edit’ icon which is meant for editing or modifying the primary bank account details. The client then closed the tab without making any changes and then switched to add bank account option, which is meant for adding a secondary bank account. 3. The Complainant has alleged that there is an unauthorized overwrite of his existing bank account due to these processes. However, no unauthorized changes have happened since the system workflow clearly distinguishes between editing the primary bank account and adding a secondary bank account. 4. The behavior resulting in modification of an existing primary bank account instead of creating a new entry has occurred due to system’s caching mechanism, which was designed to optimize platform performance. 5. They acknowledge that caching mechanism leads to an unintended user experience when customers switch between editing existing accounts and adding new accounts within the same session. Although the situation is extremely rare but they recognize that it does not align with expected user flow and may cause confusion. 6. The process of adding a third bank account (second secondary account) by simply clicking “Add Bank Account” is functioning correctly as the third account has been added successfully without affecting the second account. However, if the existing secondary bank account is modified instead of adding a new one, this typically occurs when the ‘Edit’ button is clicked before selecting “Add Bank Account”. 7. The client requested secondary bank update on 19/07/2025 and repeated the request on 24/07/25. This was approved on 25/07/25 following which he deleted the secondary bank account., effectively the third bank linked, and the deletion was also approved the same day. Later, on 25/07/25, another secondary bank update was approved, and on 29/07/25, he placed a swap request , which was approved as well. Thus, the client was successfully able to modify the bank account on 19/07/25, 24/07/25, 25/07/25, 29/07/25 as per his request types. This Page 3 of 5 Zoho Sign Document ID: DF9AC547D-9SEUUYGNYGEKJLWYCHQAAIKXT9DYBFKJZ4CY9RZNVAS confirms that the client’s requests are being approved as per the modification steps taken from his end. 8. The client is expected to follow the desired process to ensure accurate outcomes. 9. They have appraised the matter to their technical team who are evaluating the options. 10. The issue has not been reported by any other client of theirs. 11. The last System Audit of their platform for the period 01/04/25 to 30/09/25 has been conducted and no discrepancies were reported. 12. There is no discrepancy in the service from their end. They request to close the complaint Observation of Conciliator: It has been observed that 1. Looking to the circumstances and sensitivity towards integrity of data in the case and in view of the the documents produced, the matter relating to overwriting, bug and cache as explained in the submissions of the Complainant needs to be examined. 2. The Respondent has admitted that overwriting in the secondary account , as submitted by the Complainant, took place.. This poses an issue about data integrity. The so called bug as described in the Complainant’s submissions needs to be examined by an expert and removed from the system software.. 3. The Respondent’s caching system also needs to be examined and rectified for any defects. Page 4 of 5 Zoho Sign Document ID: DF9AC547D-9SEUUYGNYGEKJLWYCHQAAIKXT9DYBFKJZ4CY9RZNVAS 4. A certificate from an independent agency about rectification of the issues involved and about ensuring of the data integrity should be submitted by the Respondent to the NSE for their perusal within a month’s time. Whether Conciliation was successful or unsuccessful: Unsuccessful Agreed Settlement Value / terms (in case of Successful Conciliation): NA Admissible Claim Value/ Directions by Conciliator (in case of service-related complaint): The Respondent should get the matter of bug, cache and overwriting of account rectified and examined and then submit a certificate about data integrity from an independent software agency of repute to the NSE within one month.. (Arvind Kumar Pradhan) [Signature of the Conciliator] Dated: 28th November, 2025 Page 5 of 5 Zoho Sign Document ID: DF9AC547D-9SEUUYGNYGEKJLWYCHQAAIKXT9DYBFKJZ4CY9RZNVAS