New Delhi, Oct. 12 -- The Securities Markets Code Bill, 2025 (Code), promises a cleaner and more accountable enforcement architecture for India's securities markets. It separates investigation from adjudication, times out stale cases, and requires adjudicating officers (AOs) to consider prescribed factors before imposing a penalty.

Clause 21 sits uneasily within this architecture. It carries the provision over from the Sebi Act, but expands it. The earlier provision allowed the Securities and Exchange Board of India (Sebi) to revise only the quantum of a monetary penalty.

Clause 21 permits it to call for the record of any order passed by its AO within 30 days and, if it considers that order "not in the interest of the securities markets...