India · SEBI Proceedings
Replies to SEBI show cause notices, hearings before Adjudicating Officers and Whole Time Members, settlement applications under the new 2026 Regulations, and appeals to the Securities Appellate Tribunal.
A SEBI show cause notice can lead to a monetary penalty imposed by an Adjudicating Officer under section 15-I of the SEBI Act, or to directions by a Whole Time Member under sections 11 and 11B, such as a market ban or disgorgement. Most cases can be settled. From 7 November 2026 the new Settlement Regulations allow 90 days from the show cause notice to apply, up from 60 days under the 2018 Regulations. SEBI orders are appealable to the Securities Appellate Tribunal within 45 days.
Replies to notices under the SEBI Act and the regulations invoked, with the disclosure record, trading data and fund flows analysed.
Reconstruction of trades, connections and money movements that SEBI relies on, which is where many cases are weakest.
Written submissions and hearings before the Adjudicating Officer or the Whole Time Member, including requests for inspection of documents.
Settlement applications, the computation of the likely settlement amount, and negotiation of remedial terms.
Appeals to the Securities Appellate Tribunal, where chartered accountants may appear under section 15V of the SEBI Act.
Corrective disclosures and process changes that support a settlement or a lower penalty.
The regulations invoked, the period, and the data SEBI relies on; ask for inspection of what is not supplied.
Rebuild the trades, connections and disclosures independently.
Contest, settle or both, weighed against the likely outcome and the settlement amount.
SAT within 45 days, and the Supreme Court on a question of law.
SEBI builds its case from data. A defence that does not engage with the data rarely succeeds.
Economic offence and serious fraud investigations against companies and directors.
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Explore →| Stage | Provision | What it means |
|---|---|---|
| Settlement notice (new) | Settlement Regulations 2026, regulation 5 | 60 days to apply for settlement; not issued where interim orders or prosecution are contemplated |
| Show cause notice | SEBI Act and the regulations invoked | Reply within the time given; seek inspection of documents relied on |
| Settlement application | 2018 Regulations until 6 November 2026; 2026 Regulations from 7 November 2026 | 60 days from the notice under the 2018 rules; 90 days under the 2026 rules |
| Adjudication order | Section 15-I | Monetary penalty under Chapter VI-A |
| Directions | Sections 11, 11B and 11D | Market ban, disgorgement, restraint or other directions; interim orders are possible |
| Appeal | Section 15T | Securities Appellate Tribunal within 45 days |
| Further appeal | Section 15Z | Supreme Court within 60 days on a question of law |
Settlement closes the proceeding without admitting or denying the findings, which matters for a director’s record and for parallel proceedings. It is usually right where the facts are against you or the cost of contesting exceeds the likely penalty. It is usually wrong where the case rests on a weak inference from trading data that can be answered. Under the 2026 Regulations the settlement amount follows a formula in which earlier applications attract lower factors, so the decision should be made early. Some cases, such as serious frauds, cannot be settled.
Chartered accountants can represent parties before SEBI and before the Securities Appellate Tribunal under section 15V of the SEBI Act. Supreme Court appeals and criminal prosecutions under section 24 of the SEBI Act need an advocate. LexVerge prepares the analysis and the replies, appears where permitted, and works with counsel where the matter goes to court.
Prepared by the LexVerge editorial team and reviewed by Vijay Dhawan, Managing Partner, on 11 October 2026. Facts checked against the Acts, rules, regulations and judgments cited on this page on 11 October 2026. General information, not legal advice: deadlines run from the date of your notice or order, so confirm them for your matter.
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