SAT Reduces BSE Penalty on Nam Securities to ₹5,000, Calls PDF Filing Lapse Inadvertent

April 16, 2026 : The Securities Appellate Tribunal (SAT), Mumbai, has held that the omission of two pages in the PDF filing of financial results by Nam Securities Limited was an inadvertent error rather than a wilful regulatory breach. Accordingly, the Tribunal reduced the penalty imposed by BSE Limited from ₹1.77 lakh to ₹5,000.

The order was passed by a Bench comprising Justice P.S. Dinesh Kumar (Presiding Officer), Meera Swarup (Technical Member), and Dr. Dheeraj Bhatnagar (Technical Member) in Appeal No. 398 of 2025, partly allowing the company’s appeal against BSE’s communication dated June 27, 2025.

Background

Nam Securities, a listed entity engaged in securities trading, had approved its audited financial results for the quarter and financial year ending March 2025 on May 30, 2025. The company uploaded the results on the BSE portal within 30 minutes in PDF format and within 24 hours in XBRL format. The results were also published in newspapers on June 1, 2025.

However, BSE later alleged non-compliance with Regulation 33 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, claiming that standalone financial results had not been submitted in PDF format. It was only on July 1, 2025 that the company was informed that two pages containing quarterly figures were missing from the uploaded PDF, following which it promptly re-uploaded the complete document.

Despite this, BSE imposed a penalty of ₹1.77 lakh, which the company paid under protest before approaching SAT.

Tribunal’s Findings

The Tribunal noted that:

• Acknowledgments from BSE confirmed that the PDF filing had been uploaded on May 30, 2025, though content verification was not done at that stage.
• BSE’s initial communications referred to “non-submission” rather than “incomplete submission,” indicating ambiguity in the alleged violation.
• The financial results were fully available in XBRL format within the stipulated timeline and had also been disclosed through newspaper publication, ensuring investor awareness.

On intent, the Tribunal made it clear that there was no mala fide conduct:

“There was no intention on the part of the appellant to contravene Regulation 33… the violation, if any, appears to have taken place inadvertently.”

Relief Granted

Considering the circumstances, the Tribunal held that the penalty imposed by BSE was disproportionate. It reduced the fine to ₹5,000 and directed BSE to refund ₹1.72 lakh to the company within two weeks, as the amount had already been deposited under protest.

The appeal was accordingly partly allowed.

Case Title: Nam Securities Limited v. BSE Limited
Case No.: Appeal No. 398 of 2025
Coram: Justice P.S. Dinesh Kumar, Meera Swarup, Dr. Dheeraj Bhatnagar