Subsequently, the WTM issued an additional order dated 16-12-2014, directing the Investigations Department to examine the feasibility of ill-gotten gains for the purpose of disgorgement. Eventually, a WTM order dated 29-8-2018 (2018 Disgorgement Order) mandated VCL and its Directors, promoters and other entities to jointly and severally disgorge the ill-gotten gains. However, it was noted that restitution for appellants was beyond SEBI's authority. Multiple appeals were filed against the 2018 Disgorgement Order, including by the appellants, which was disposed of by SAT vide order dated 2-8-2019. SAT while partly allowing the appeal directed SEBI to pay compensation to the appellants from the amount disgorged from VCL and connected entities or from its Investor Protection and Education Fund. This was stayed by the Supreme Court on 18-10-2019. VCL and others also filed appeal before SAT against the direction for disgorgement, which was disposed of by SAT vide order dated 20-12-2021.