Drafting, Pleadings and Appearances · Adjudications and Appeals under SEBI Laws

Appeal to the Supreme Court from a SAT Order

Updated 11 October 2026 · Fact-checked

Any person aggrieved by a decision or order of the Securities Appellate Tribunal (SAT) can appeal to the Supreme Court under section 15Z of the SEBI Act, 1992. The appeal must be filed within 60 days of communication of the order and only on a question of law. The Court may condone a delay of up to 60 more days for sufficient cause.

Understand Appeals to the Supreme Court

SEBI and the stock exchanges take decisions that affect market participants. The first appeal against a SEBI order goes to the Securities Appellate Tribunal (SAT). SAT is a specialised tribunal. Its order is not the end of the road, because the securities laws provide a further appeal.

Under the SEBI Act, 1992, the further appeal lies to the Supreme Court under section 15Z. The Depositories Act, 1996 has an identical provision in section 23F. The Court hears an appeal only on a question of law arising out of the SAT order. It does not re-examine the facts as a fresh trial.

Any person aggrieved by the SAT order may appeal. This is wider than the original party. It can include SEBI, a company, an intermediary or an investor, if the order affects them. The appeal is filed within sixty days from the date of communication of the order to the appellant. The clock does not start from the date the order was passed.

The Supreme Court has a limited power to forgive delay. If it is satisfied that the appellant was prevented by sufficient cause, it may allow the appeal within a further period not exceeding sixty days. So the outer limit is 120 days from communication.

Compare this with the Securities Contracts (Regulation) Act, 1956. Its section 22F gives an appeal from SAT to the High Court, within the same sixty days, on any question of fact or law. So the forum and the scope of the appeal differ. Do not mix them up in an answer.

The older appeals to the Central Government (section 20 of the SEBI Act and section 23 of the Depositories Act) relate only to Board orders made before the Securities Laws (Second Amendment) Act, 1999 commenced. They are not the route today.

Key rules to remember

Right of appeal: SAT order → appeal to Supreme Court (SEBI Act, s. 15Z; Depositories Act, s. 23F); Available to any person aggrieved by a decision or order of SAT.
Ground of appeal: Only a question of law arising out of the SAT order; Facts are not re-argued. Frame the grounds as legal questions.
Limitation: 60 days from the date of communication of the SAT order to the appellant; Time runs from communication, not from the date of the order.
Condonation of delay: Further period ≤ 60 days, if prevented by sufficient cause; Maximum total is 60 + 60 = 120 days. The Supreme Court must be satisfied.
Contrast: SCRA appeal: SAT order under SCRA → High Court, 60 days, question of fact or law (s. 22F); Same time limit, different court and wider scope.

How to solve Appeals to the Supreme Court questions

Use this method for any question on appeal from a SAT order. Keep the answer in provision, analysis, conclusion form.

1Identify the order: confirm that it is a decision or order of SAT, not of SEBI or an adjudicating officer.
2Identify the Act under which the matter arose: SEBI Act (section 15Z), Depositories Act (section 23F) or the Securities Contracts (Regulation) Act (section 22F, High Court).
3State the rule: appeal to the Supreme Court by a person aggrieved, within sixty days of communication, on a question of law.
4Test the facts: is the appellant a person aggrieved, and is the ground a question of law or merely a challenge to findings of fact?
5Compute the time: start from the date the order was communicated to the appellant and count sixty days. Check if delay exists.
6If late, apply the proviso: sufficient cause is needed and the extra period cannot exceed sixty days.
7Conclude clearly: appeal maintainable or not, and the next step, such as drafting the appeal with grounds on questions of law.
8Add practical drafting points: certified copy of the SAT order, date of communication, list of dates, and an application for condonation if needed.

Quickest way: Four-point check: Who, Where, What, When

When to use it: Use this for short case-based questions where you must decide quickly if an appeal lies.

Who: any person aggrieved by the SAT order.
Where: Supreme Court for SEBI and Depositories Act matters. High Court for SCRA matters.
What: question of law only for section 15Z and section 23F.
When: 60 days from communication, plus up to 60 more days for sufficient cause.

Common mistakes in Appeals to the Supreme Court

Saying the appeal lies on questions of fact and law to the Supreme Court.
Students mix section 15Z with section 22F of the SCRA, which allows fact or law.
Fix: Link the Supreme Court with question of law only. Link the High Court under SCRA with fact or law.
Counting sixty days from the date of the SAT order.
Students assume the date of the order is the trigger.
Fix: Count from the date of communication of the order to the appellant, as the section states.
Saying delay can be condoned for any period.
Students remember the condonation proviso but forget its cap.
Fix: State that the Court may allow only a further period not exceeding sixty days, and only for sufficient cause.
Naming the Central Government as the appellate forum after SAT.
Section 20 of the SEBI Act and section 23 of the Depositories Act mention appeals to the Central Government.
Fix: Remember these sections cover only Board orders made before the 1999 amendment commenced. Today SAT is the first appeal and the Supreme Court is the next.
Appealing directly to the Supreme Court from a SEBI order.
Students skip the SAT stage.
Fix: The order appealed to the Supreme Court must be a SAT order. Go to SAT first.

Worked examples

Example 1

SAT dismissed the appeal of Kaveri Securities Ltd against a SEBI order. The order was communicated to the company on 10 March. The company wants to challenge it on the ground that SAT misinterpreted a provision of the SEBI Act. Advise on the remedy and time limit.

Show the solution

The order is a SAT order, so section 15Z of the SEBI Act applies.
Kaveri Securities is a person aggrieved, so it can appeal to the Supreme Court.
The ground is the wrong interpretation of a statutory provision. That is a question of law, so the appeal is maintainable.
The limit is sixty days from communication, which is 10 March. The appeal should be filed within sixty days of that date.
If it misses this period for sufficient cause, the Supreme Court may allow filing within a further period not exceeding sixty days.

Answer: Kaveri Securities may appeal to the Supreme Court under section 15Z on the question of law, within sixty days from 10 March, with a further condonable period of up to sixty days for sufficient cause.

Example 2

Rohan Depository Participants Ltd lost before SAT in a matter under the Depositories Act, 1996. It wishes to challenge SAT's finding that certain transfers took place on a given date, and files the appeal on the 150th day after communication, citing a clerical oversight. Is the appeal sustainable?

Show the solution

The relevant provision is section 23F of the Depositories Act, which mirrors section 15Z of the SEBI Act.
The appeal lies to the Supreme Court only on a question of law arising out of the SAT order.
The challenge to the date of transfers is a finding of fact, so it is not a proper ground.
On time, sixty days is the base period. The proviso allows at most sixty more days, so the outer limit is 120 days.
The 150th day is beyond 120 days. The Court cannot condone the delay, whatever the cause.

Answer: The appeal is not sustainable. The ground is factual, and it is also filed beyond the maximum of 120 days from communication.

Exam tips

Quote the section number with the Act: section 15Z of the SEBI Act and section 23F of the Depositories Act.
Write the three conditions in order: person aggrieved, sixty days from communication, question of law.
Always mention the proviso on delay with its cap of sixty days.
If the facts involve the SCRA, switch to the High Court under section 22F and say it covers fact or law.
Close with practical drafting points: certified copy, date of communication, grounds framed as questions of law.

Practice questions from Adjudications and Appeals under SEBI Laws

Appeals to the Supreme Court in other exams

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

Appeals to the Supreme Court: frequently asked questions

Which section gives the right to appeal from SAT to the Supreme Court?

Section 15Z of the SEBI Act, 1992 gives this right. Section 23F of the Depositories Act, 1996 is worded the same way.

What is the time limit for appealing against a SAT order to the Supreme Court?

Sixty days from the date of communication of the SAT order to the appellant. The Supreme Court may allow a further period not exceeding sixty days if there was sufficient cause for the delay.

Can I challenge findings of fact before the Supreme Court under section 15Z?

No. The appeal lies only on a question of law arising out of the SAT order. Frame your grounds as legal questions.

Where does an appeal from SAT lie under the Securities Contracts (Regulation) Act?

It lies to the High Court under section 22F, within sixty days of communication, on any question of fact or law. The High Court can also allow a further period up to sixty days for sufficient cause.