For instance, Mr Achuthans orders have been an acute source of embarrassment for SEBI. In recent times SAT has, more often than not, overturned SEBIs decisions in high-profile cases, or exposed the regulators shoddy investigation and presentation of cases. This certainly fulfilled the objective of ensuring that there was fair appeal against SEBIs orders; but it also created an impression that any SEBI order, however correct, had a good chance of being over-turned by SAT. Consequently, few companies or regulated entities ever accepted the regulators orders without a fight and tied SEBI up in unnecessary litigation. A broad-based SAT, headed by a former high court chief justice, would hopefully discourage some of the frivolous appeals. But that would depend on whether the newly re-constituted SAT is able to deal competently with the complicated capital market transactions governed by an even more complex and price-sensitive set of regulations. Ideally, SAT ought to have at least one Member who has some experience in dealing with capital markets in order to ensure a speedy disposal of appeals. This is especially important because the amended SEBI Act also empowers it to levy hefty fines and penalties on intermediaries or stop their business without a hearing. A knowledgeable SAT would play an important role in ensuring that SEBI uses its powers judiciously and backs up preliminary action with evidence which is something that the regulator has often failed to do over the last seven years.