SAT received 429 appeals during the year, down from 533 in FY25. It disposed of 323 appeals during the year, yet pending appeals increased to 1,066 at the end of March 2026 from 960 a year ago
The Securities Appellate Tribunal (SAT) set aside 47 SEBI orders in 2025-26, more than double the 23 appeals it allowed in the previous year, while the number of orders modified by the tribunal also more than doubled to 88 from 42.SAT received 429 appeals during the year, down from 533 in FY25. It disposed of 323 appeals during the year, yet pending appeals increased to 1,066 at the end of March 2026 from 960 a year ago. Of the appeals disposed of, 148 related to matters under the Prohibition of Fraudulent and Unfair Trade Practices (PFUTP) and insider trading regulations, according to SEBI’s annual report.“SAT appears to be examining whether SEBI’s conclusions are sufficiently tied to evidence, whether directions are proportionate, and whether each noticee’s role is individually established. It is insisting on stronger reasoning, clearer causation and better proportionality before serious market-access restrictions or monetary directions are sustained,” said Soumya Singh, Co-founding Partner at Thistle&Law.Vanya Singh, Partner at Cyril Amarchand Mangaldas, said preliminary issues such as inspection of documents continue to result in matters being remanded, while SAT also modifies orders where it finds penalties or directions to be disproportionate. The proportion of appeals being allowed outright has declined over the past five years since 2021-22 as SEBI’s investigations are now armed with technology and greater inter-regulatory coordination, she said.Regulatory probesDuring FY26, the regulator took up 402 investigations and completed 338, including 224 probes relating to insider trading and takeover regulations, 121 under PFUTP Regulations and 57 involving financial statement fraud.Sumit Agrawal, Founder of Regstreet Law Advisors and former SEBI officer, said SAT is more likely to intervene on the nature and extent of penalties or procedural aspects of an order than on the finding of a violation itself. “In many cases, the regulator’s conclusion is upheld, but the punishment or the reasoning supporting it is refined or recalibrated.”Adjudication ordersAdjudication proceedings against 640 entities were completed through 319 orders during the period. While PFUTP remained the largest enforcement category with action against 233 entities compared with 239 in the previous year, action under the Listing Obligations and Disclosure Requirements (LODR) Regulations rose sharply to 40 entities from seven.Cases involving disclosure violations under takeover and insider trading regulations increased to 10 from four, while proceedings for failure to comply with summons rose to 13 from two. Cases involving non-compliance with SEBI orders declined to five from 19. Penalties were not imposed on 123 entities compared with 107 in FY25.Published on August 7, 2026









