Corporate and Economic Laws · SEBI Laws and Regulations

SEBI Penalties, Adjudication and Securities Appellate Tribunal

Updated 11 October 2026 · Fact-checked

SEBI can have penalties imposed for securities law violations, mainly through an adjudicating officer who holds an inquiry and passes an order. A person aggrieved appeals to the Securities Appellate Tribunal within 45 days of receiving the order. A further appeal on a question of law goes to the Supreme Court within 60 days.

Understand Penalties, Adjudication and Securities Appellate Tribunal

SEBI laws only work if breaking them has a cost. The SEBI Act, 1992, the Securities Contracts (Regulation) Act, 1956 (SCRA) and the Depositories Act, 1996 each carry penalty provisions. Those penalties are usually decided by an adjudicating officer, who is an officer appointed under the Act to hold an inquiry and decide whether a violation took place and what penalty fits.

The person penalised is not left without a remedy. An order of SEBI or of an adjudicating officer can be challenged before the Securities Appellate Tribunal (SAT). Under Section 15T of the SEBI Act, any person aggrieved by an order of the Board made under that Act, or by an order of an adjudicating officer, may appeal to a SAT having jurisdiction. The same Section also covers orders of IRDA and PFRDA.

The SAT hears the parties and may confirm, modify or set aside the order. It sends a copy of its order to the parties and to the concerned adjudicating officer (and to SEBI, IRDA or PFRDA, as the case may be). It must try to dispose of the appeal finally within six months from receipt of the appeal. This is a duty to endeavour, not a hard bar.

The ladder ends outside SAT. Under Section 15Z of the SEBI Act, a person aggrieved by a SAT decision or order may appeal to the Supreme Court within 60 days of communication, on a question of law arising out of the order. The Depositories Act has the same rule in Section 23F. Under SCRA Section 22F the appeal against a SAT order goes to the High Court, and it can cover questions of fact or law.

So remember the pattern: order, then SAT in 45 days, then the higher court in 60 days. Each stage allows late filing if there is sufficient cause, but the extension limits differ.

Key rules to remember

Appeal to SAT under SEBI Act (Section 15T): Appeal within 45 days from receipt of the copy of the order; Applies to orders of SEBI, adjudicating officers, IRDA and PFRDA. SAT may entertain a late appeal if there was sufficient cause. No outer limit for the delay is stated in the text.
Appeal to SAT under Depositories Act (Section 23A): Appeal within 45 days from receipt of the copy of the order; Covers orders of SEBI (the Board) and of an adjudicating officer under that Act. Late appeal allowed for sufficient cause.
Appeal to SAT under SCRA (Section 23L): Appeal within 45 days from receipt of the order or decision; Covers orders or decisions of a recognised stock exchange, an adjudicating officer, and certain SEBI orders (Section 4B, Section 23-I(3)).
Appeal against refusal to list (SCRA Section 22A): Appeal within 15 days from the date reasons for refusal are furnished; The company is entitled to reasons. Where the exchange fails to dispose of the application in time, 15 days run from expiry of the specified time, extendable by SAT by up to one month for sufficient cause.
Time to dispose of appeal by SAT: Endeavour to dispose of finally within 6 months from receipt; Common to Sections 15T, 23A, 23L and 22A.
Appeal to Supreme Court (SEBI Act Section 15Z; Depositories Act Section 23F): Within 60 days from communication of SAT order; question of law only; condonation up to a further 60 days; The Supreme Court may allow filing within a further period not exceeding 60 days if sufficient cause is shown.
Appeal to High Court (SCRA Section 22F): Within 60 days from communication of SAT order; question of fact or law; condonation up to a further 60 days; Do not mix this with the Supreme Court route under the SEBI and Depositories Acts.

How to solve Penalties, Adjudication and Securities Appellate Tribunal questions

Use this method for any question on penalty, adjudication or appeals under SEBI laws.

1Identify which Act applies: SEBI Act, SCRA or Depositories Act. The forum and wording differ slightly.
2Identify who made the order: SEBI, an adjudicating officer, a stock exchange, or SAT itself.
3Pick the stage of the ladder. An order of SEBI or adjudicating officer goes to SAT. An order of SAT goes to the Supreme Court (SEBI Act, Depositories Act) or the High Court (SCRA).
4Apply the time limit from the right date: 45 days from receipt of the order for SAT; 60 days from communication of the SAT order for the higher court; 15 days for listing refusal under SCRA Section 22A.
5Check delay. If the limit is missed, ask whether sufficient cause exists. SAT can entertain a late appeal. The higher court can allow up to a further 60 days.
6Check the scope: Supreme Court appeal lies only on a question of law under the SEBI Act; SCRA High Court appeal covers fact or law.
7State the outcome SAT may give: confirm, modify or set aside the order, after hearing the parties.
8Close with a clear conclusion that names the forum and the days, with the Section number if you are sure.

Quickest way: Appeal ladder in one line

When to use it: Use it for MCQs and short case questions where you must name the forum or the time limit fast.

Write 45, 60, 6 on your rough sheet: 45 days to SAT, 60 days to the higher court, 6 months for SAT to decide.
Ask: what kind of order is it? SEBI or adjudicating officer order means SAT. SAT order means Supreme Court (SEBI or Depositories Act) or High Court (SCRA).
Spot the exception: refusal to list securities under SCRA Section 22A means 15 days.
Check for a delay with sufficient cause, and decide whether the extension applies to SAT or to the higher court.

Common mistakes in Penalties, Adjudication and Securities Appellate Tribunal

Saying the appeal against a SAT order always goes to the Supreme Court.
Students remember the SEBI Act route and apply it to all three Acts.
Fix: Under the SEBI Act and the Depositories Act it is the Supreme Court. Under SCRA Section 22F it is the High Court.
Mixing up 45 days and 60 days.
Both numbers appear in the same chapter and look alike.
Fix: 45 days is for the first appeal to SAT. 60 days is for the appeal from SAT to the higher court.
Counting the 45 days from the date of the order.
Students read the date on the order as the start date.
Fix: The period runs from the date a copy of the order is received by the appellant.
Saying the Supreme Court hears appeals on facts.
Students treat it like a regular first appeal.
Fix: Under Section 15Z the appeal lies only on a question of law arising out of the SAT order.
Treating the six-month limit for SAT as a fatal deadline.
The word 'within six months' sounds mandatory.
Fix: The text says SAT shall make an endeavour to dispose of the appeal within six months. It is a target.
Applying the 45-day rule to refusal of listing.
Students assume all SAT appeals share one limit.
Fix: For refusal to list by a stock exchange under Section 22A the limit is 15 days from the date the reasons are furnished.

Worked examples

Example 1

An adjudicating officer passes an order against Rajan Textiles Ltd. under the SEBI Act. The company receives the copy on 10 March. Where can it appeal, and by when? What if it files on day 60 citing a genuine hospitalisation of its director?

Show the solution

The order is by an adjudicating officer under the SEBI Act, so Section 15T applies. The forum is the Securities Appellate Tribunal.
The limit is 45 days from the date the copy of the order is received, here 10 March.
Filing on day 60 is late by 15 days.
The proviso lets SAT entertain an appeal after 45 days if it is satisfied that there was sufficient cause for not filing in time.
Whether hospitalisation counts is for SAT to judge on the facts. It is a valid ground to plead.

Answer: Rajan Textiles can appeal to SAT within 45 days of receiving the order on 10 March. A late appeal on day 60 is not barred automatically. SAT may entertain it if it is satisfied there was sufficient cause.

Example 2

SAT dismisses an appeal by Mehta Securities against a SEBI order. Mehta receives the SAT order on 1 June. It wants to challenge the finding on the interpretation of a SEBI regulation. Advise on forum, time limit and scope.

Show the solution

The order to be challenged is a SAT order under the SEBI Act, so Section 15Z applies.
The forum is the Supreme Court.
The time limit is 60 days from communication of the SAT order, here 1 June.
The challenge is about interpreting a regulation, which is a question of law. So it is within the scope of Section 15Z.
If the 60 days are missed, the Supreme Court may allow filing within a further period not exceeding 60 days, if the appellant was prevented by sufficient cause.

Answer: Mehta Securities can appeal to the Supreme Court within 60 days of 1 June, on the question of law about interpreting the regulation. A delay of up to a further 60 days may be allowed for sufficient cause. A challenge on pure facts would not lie.

Exam tips

Learn the three numbers 45, 60 and 6, and what each one belongs to. MCQs often test only this.
Keep a three-column table in your head: SEBI Act, Depositories Act, SCRA. Note the forum above SAT in each: Supreme Court, Supreme Court, High Court.
In case questions, first spot the stage (SEBI order, SAT order or listing refusal) and then state the forum and days.
Mention the proviso on sufficient cause in any question where the appellant is late.
Quote section numbers only for those you are sure of: 15T, 15Z, 23A, 23F, 23L, 22A, 22F.

Practice questions from SEBI Laws and Regulations

Penalties, Adjudication and Securities Appellate Tribunal in other exams

The same ground in other exams, if you are preparing for more than one or want another angle on it.

Penalties, Adjudication and Securities Appellate Tribunal: frequently asked questions

How do I appeal against a SEBI order?

File an appeal before the Securities Appellate Tribunal within 45 days of receiving a copy of the order, in the prescribed form with the prescribed fee. This is under Section 15T of the SEBI Act. SAT may accept a late appeal if there is sufficient cause.

Who can appeal to SAT under the SEBI Act?

Any person aggrieved by an order of SEBI made under the Act, rules or regulations, or by an order of an adjudicating officer. Orders of IRDA and PFRDA can also be appealed to SAT under Section 15T.

What can SAT do with an appeal?

After hearing the parties, SAT may pass orders it thinks fit, confirming, modifying or setting aside the order appealed against. It sends a copy of its order to the parties, the concerned adjudicating officer and the regulator.

Where does the appeal against a SAT order go?

Under Section 15Z of the SEBI Act and Section 23F of the Depositories Act it goes to the Supreme Court within 60 days, on a question of law. Under Section 22F of SCRA it goes to the High Court within 60 days, on a question of fact or law.