Interlocutory SEBI tribunal orders not affecting substantive rights are not appealable under section 15Z.

Purely procedural and interlocutory orders of the Securities Appellate Tribunal that do not affect substantive rights are not appealable under section 15Z of the Securities and Exchange Board of India Act, 1992. The appellate provision was read in light of the statutory scheme as covering decisions or orders that determine questions of fact or law affecting the parties' rights, not directions that merely regulate the conduct of proceedings. The distinction between orders affecting substantive rights and steps toward final adjudication was applied, and grievances against such procedural matters were held to be capable of being raised, if necessary, in an appeal from the final order.

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Issues: Whether purely procedural and interlocutory orders of the Securities Appellate Tribunal, which do not affect substantive rights, are appealable under section 15Z of the Securities and Exchange Board of India Act, 1992.

Analysis: The appellate provision was construed in the context of the scheme of the Securities and Exchange Board of India Act, 1992, which provides for appellate review of decisions or orders that determine questions of fact or law affecting rights of the parties. The Court applied the settled principle that wide words such as "any decision or order" do not extend to merely procedural or interlocutory directions that regulate the course of proceedings but do not finally adjudicate rights or liabilities. Reliance was placed on the distinction between orders affecting substantive rights and those that are only steps toward final adjudication. The Court also noted that grievances against such procedural matters can be raised in an appeal from the final order, if one is ultimately passed.

Conclusion: Purely procedural orders that do not affect substantive rights are not appealable under section 15Z of the Securities and Exchange Board of India Act, 1992; the appeals were therefore not maintainable.

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