Inordinate unexplained delay without sufficient cause bars condonation and warrants dismissal of the appeal.

The appellant, Mrs. Kuljeet Kaur, challenged the order dated 17 April 2018 passed by the Whole Time Member of SEBI under Section 15T of the SEBI Act, 1992.

She was a director of Mark Builders & Land Developers Limited, which SEBI alleged had collected substantial sums from investors in violation of the SEBI (Collective Investment Schemes) Regulations, 1999.

The appeal was filed with a delay stated by SEBI to be 2,911 days.

The appellant sought condonation on the grounds that she was a woman, her bank account had been frozen, and she was not involved in the company’s day-to-day affairs.

SEBI opposed condonation, contending that the appellant had knowledge of the proceedings much earlier.

It relied particularly on an email dated 31 May 2019 sent by the appellant’s advocate, Mr. Inderjit Paul, complaining about recovery proceedings and attachment of the company’s and directors’ accounts.

Whether the delay in filing the appeal against SEBI’s order dated 17 April 2018 should be condoned on the grounds urged by the appellant.

Whether the appellant had demonstrated sufficient cause or an adequate explanation for the prolonged delay in approaching the Tribunal.

Section 15T of the Securities and Exchange Board of India Act, 1992 provides the statutory basis for an appeal to the Securities Appellate Tribunal against an order of SEBI.

The Tribunal applied the settled principle that condonation of delay is a discretionary relief and cannot be granted unless the applicant establishes “sufficient cause” or an adequate and credible explanation for the entire period of delay.

The Tribunal also considered the legal significance of the appellant’s prior knowledge of the proceedings, as evidenced by correspondence made through her advocate.

The SEBI (Collective Investment Schemes) Regulations, 1999 were relevant to the underlying regulatory proceedings against the company, although the present order primarily concerned limitation and condonation of delay.

The Tribunal rejected the appellant’s assertion that she became aware of the SEBI proceedings only in February 2026 because her advocate had represented her during the WTM proceedings and had, by email dated 31 May 2019, specifically referred to the recovery proceedings, attachment of accounts, alleged legal infirmities, and repayment to investors.

This correspondence demonstrated that the appellant, through her authorised representative, had knowledge of the matter at least by 31 May 2019.

Even when reckoned from that date, the delay remained substantial and unexplained.

The explanations that the appellant was a woman, that her bank account had been frozen, that she was not involved in the company’s day-to-day affairs, and that her advocate was unfamiliar with SEBI procedure did not constitute sufficient cause for the prolonged delay.

The Tribunal therefore declined to exercise its discretion in favour of condonation.

Miscellaneous Application No. 516 of 2026 seeking condonation of delay was rejected, and consequently Appeal No. 176 of 2026 was dismissed.

Pending interlocutory applications, if any, were disposed of, with no order as to costs.