Absence of valid cause for eight-year delay precludes condonation of delay in challenging SEBI orders.

The appellant, a Director of Secure Success Plan Private Limited, filed an appeal under Section 15T of the SEBI Act, 1992, challenging an order passed by the Whole Time Member (WTM) of SEBI dated April 25, 2018

The impugned order directed a refund of ₹3.99 Crore with interest

The appeal was filed on January 8, 2026, resulting in a delay of 2692 days (approximately 8 years)

The appellant contended she was a nominal director, her bank accounts were frozen, and the delay was due to lack of knowledge, medical exigencies, and family circumstances

She also argued that her liability was partially satisfied through the attachment of her husband's property

1. Whether the appellant has shown sufficient cause to condone the delay of 2692 days in filing the appeal

2. Whether the alleged merit of the appeal and the partial recovery of dues warrant a lenient consideration of the limitation period

The Tribunal considered Section 15T of the SEBI Act regarding the limitation period for filing appeals.

The Tribunal also noted the distinction between individual liability for refund and the collective liability of directors under SEBI enforcement directions

principles of condonation of delay, referencing the precedent Collector, Land Acquisition, Anantnag vs. Mst. Katiji, which suggests that while delay may be considered leniently if a case is strong on merits, such condonation depends on the specific facts of each case

The Tribunal found the explanation for the 8-year delay unsatisfactory. It noted that while the appellant claimed medical exigencies, the records provided were from 2020, failing to account for the entire period of delay since 2018

Regarding the merits, the Tribunal observed that the appellant was an admitted Director and the total refund ordered was ₹3.99 Crore plus interest, not merely the smaller amounts mentioned in the Recovery Certificate

The Tribunal held that "merit" can only be a factor for leniency when supported by evidence; here, no material was placed to prove the actual quantum of recovery made or to refute the underlying liability

The Tribunal concluded that the appellant failed to provide a valid legal cause for the extraordinary delay.

the appeal was dismissed as barred by limitation

The Tribunal clarified that the appellant remains at liberty to approach the Recovery Officer regarding the freezing of bank accounts and pension-related grievances

No costs were awarded