The Securities Appellate Tribunal’s (SAT) case backlog has hit a six-year high even as the flow of new appeals has slowed, pointing to a system struggling to clear its accumulated workload.
Cases pending before SAT rose to 1,066 in fiscal year 2026 (FY26), an 11% increase from a year earlier and 122.5% higher than the 479 cases pending in FY20, according to annual reports of the Securities and Exchange Board of India (Sebi). Fresh appeals fell to 429 in FY26 from 533 in FY25. A total of 630 appeals were added in FY20.
The divergence indicates that the tribunal’s current workload is being driven less by new filings than by cases carried forward from previous years. At the same time, disposals have slowed. Appeals dismissed fell to 135 in FY26, less than half the number dismissed in FY25.
“While there has been an increase, most of the pendency pertains to carry over of cases from earlier periods,” said Vasudha Goenka, partner, Cyril Amarchand Mangaldas.
A significant portion of the backlog comprises cases carried over from previous years, rather than recent appeals awaiting disposal. A portion of the docket comprises matters that have carried over across multiple years, limiting the extent to which a decline in fresh filings can translate into lower overall pendency.
For instance, in 2022, the market regulator alleged that Bombay Dyeing & Manufacturing Company Ltd, its promoters, and related entities had misrepresented financial statements. Sebi had barred 10 entities, including Bombay Dyeing and its promoters Nusli N. Wadia, Ness Wadia and Jehangir Wadia, from accessing the securities market and imposed cumulative penalties of ₹15.75 crore.
However, in January 2026, four years after the Sebi order, SAT set aside the penalties imposed on the company, members of the Wadia family and others, and directed that any amounts already paid be refunded within four weeks.
Lawyers also attribute the rising pendency to the tribunal’s ability to constitute benches.
“The primary reason is a persistent shortage of judicial and technical members, which limits the number of benches that can sit and hear matters,” said Alay Razvi, managing partner, Accord Juris, a boutique law firm. “The absence of additional benches despite rising caseload means that even as older matters are disposed of, fresh appeals keep accumulating, pushing overall pendency to record levels.”
SAT comprises a presiding officer and judicial and technical members, with a structure intended to allow multiple benches to operate simultaneously. Vacancies, however, have sometimes restricted its functioning.
The current bench comprises Justice P.S. Dinesh Kumar as presiding officer, Dr. Dheeraj Bhatnagar as technical member and Meera Swarup as technical member. Mint reported in 2024 that the position of presiding officer remained vacant for more than three months after Justice Tarun Agarwala retired in December 2023. Meera Swarup was then the only technical member on the bench.
The need for greater capacity at the appellate tribunal has previously been flagged by the judiciary. In 2024, then Chief Justice of India D.Y. Chandrachud said that more SAT benches were required due to the rapid growth of the market and the high volume of financial transactions. He also called for vacancies at SAT to be filled without delay.
The capacity constraint comes at a time when Sebi’s enforcement cases themselves are becoming more extensive and complex. Mint reported in December 2025 that the market regulator has taken a more detailed approach to investigations and enforcement orders.
The cost of the resulting delay extends beyond the tribunal’s docket. Prolonged litigation increases legal and advisory expenses and creates uncertainty about potential financial exposure, said Yogesh Chande, partner at Shardul Amarchand Mangaldas. Companies may also have to periodically reassess provisions and contingent liability disclosures.
“For example: In a matter involving an allegation of insider trading or front running against an individual, prolonged pendency of the proceedings may result in the individual losing existing employment and, notwithstanding that the allegations remain unresolved, may also make it difficult for such individual to pursue or secure new employment opportunities, particularly where prospective employers undertake regulatory, compliance or reputational due diligence,” said Chande.
For smaller individual investors, the impact may be severe, too. “In large enforcement matters, cumulative legal and advisory costs over several years can run into several lakhs or even crores of rupees, apart from the underlying penalty or exposure. For individual investors and smaller entities, even smaller absolute amounts can be significant relative to the stakes involved, and the delay itself can erode the value of any eventual relief,” said Razvi.
Queries mailed to SAT and the finance ministry remained unanswered till press time.