Sanghi SEZ Paid ₹3.82 Crore For Sanghi Plantations, But SAT Rejects Its Challenge To Firm’s Recovery Certificate, Citing No SEBI Order Against It

Sanghi Plantations Ltd. operated a collective investment scheme and was directed by SEBI in 2017 to wind it up and repay investors; that order attained finality.

SEBI initiated recovery proceedings against Sanghi Plantations.

In 2024, Sanghi SEZ Pvt. Ltd., describing itself as a minority shareholder, voluntarily paid ₹2.10 crore and a further ₹1.72 crore towards Sanghi Plantations’ liabilities, and undertook to help settle investors’ claims.

The Recovery Officer subsequently issued a modified recovery certificate dated 11 September 2025 for ₹19,24,53,610.

Sanghi SEZ appealed against it, although the underlying SEBI order and recovery proceedings were not directed against Sanghi SEZ.

Section 15T of the SEBI Act, 1992 provides the appellate route invoked by the appellant, while Section 28A concerns recovery proceedings under the Act.

The Tribunal applied the principle that a party seeking to challenge a regulatory order or recovery action must show that it is aggrieved by that action; a person against whom no order has been passed and against whom no recovery proceedings have been initiated lacks standing to challenge them.

The Tribunal found that the scheme funds had been collected by Sanghi Plantations and that SEBI’s winding-up and repayment directions, as well as the recovery proceedings, were against that company—not Sanghi SEZ.

Although Sanghi SEZ made payments and gave an undertaking concerning investor repayments, the record did not show that SEBI had recognised it as liable or called upon it to pay.

Those voluntary acts did not make Sanghi SEZ an aggrieved party entitled to contest the recovery certificate.

It also dismissed the impleadment application and clarified that it had not examined the merits of the underlying SEBI order or recovery certificates.

No costs were awarded.