JUDGMENT : Sanjeeb K Panigrahi, J. 1. The petitioner in the present Writ Petition is challenging the order dated 24.09.2018 passed by the Securities and Exchange Board of India and the consequential attachment notices dated 13.04.2023 issued under Section 28A of the SEBI Act, 1992 read with the relevant provisions of the Income-tax Act, 1961, whereby the petitioner’s personal bank accounts as well as Demat and trading accounts have been attached. I. FACTUAL MATRIX OF THE CASE: 2. Succinctly put, the facts of the case are as follows: (i) Seashore Securities Limited is a public company incorporated on 25.04.2008 and registered with the Registrar of Companies, Odisha. (ii) Mr. Prashanta Kumar Dash is the promoter and Managing Director of Seashore Securities Limited. The petitioner was employed with M/s. NAD Pvt. Ltd. at its Raipur Head Office since the year 2007. (iii) The petitioner was appointed as a Director of Seashore Securities Limited on 29.10.2008. (iv) The petitioner resigned from the post of Director on 03.02.2012. The said resignation was approved in the Extra-Ordinary General Meeting held on 05.03.2012 and was filed before the Registrar of Companies, Cuttack on 02.04.2012. (v) An interim order bearing No. WTM/PS/23/ERO/BLO/JULY/2014 dated 23.07.2014 was passed by Opposite Party No.1, namely the Securities and Exchange Board of India, and was served upon the petitioner on 24.08.2014. (vi) Upon receipt of the said interim order, the petitioner submitted his objections, which were received by Opposite Party No.1 on 04.09.2014. (vii) Thereafter, another order bearing No. WTM/PS/84/ERO/BLO/MAR/2015 dated 18.03.2015 was passed by Opposite Party No.1. (viii) Subsequently, Opposite Party No.1 passed a final order bearing No. WTM/MPB/EFD-1-DRA-IV/43/2018 dated 24.09.2018. (ix) Pursuant to the final order dated 24.09.2018, recovery proceedings were initiated and Certificate No. RC-3151 of 2020 was issued under Section 28A of the SEBI Act, 1992. (x) In furtherance thereof, attachment proceedings bearing Nos. 6832 and 6833 of 2021 were initiated by the Recovery Officer. (xi) Consequential attachment notices dated 13.04.2023 were issued, whereby the petitioner’s savings bank accounts maintained with Axis Bank Ltd., Jagatpur Branch, Cuttack, Odisha and Bank of India, Raipur Main Branch, Chhattisgarh, as well as the Demat and trading accounts maintained with Axis Securities Ltd. (Axis Direct), were attached. 6832 and 6833 of 2021 were initiated by the Recovery Officer. (xi) Consequential attachment notices dated 13.04.2023 were issued, whereby the petitioner’s savings bank accounts maintained with Axis Bank Ltd., Jagatpur Branch, Cuttack, Odisha and Bank of India, Raipur Main Branch, Chhattisgarh, as well as the Demat and trading accounts maintained with Axis Securities Ltd. (Axis Direct), were attached. (xii) The allegation against Seashore Securities Limited and its directors pertained to the alleged issue of Redeemable Preference Shares (RPS) without compliance with the provisions of the Companies Act, 1956, the SEBI Act, 1992, and the rules and regulations framed thereunder, including the SEBI (Disclosure and Investor Protection) Guidelines, 2000 and the SEBI (Issue of Capital and Disclosure Requirements) Regulations, 2009. (xiii) Aggrieved by the final order dated 24.09.2018 and the consequential attachment notices dated 13.04.2023, the petitioner has approached this Court by filing the present writ petition under Article 226 of the Constitution of India. II. SUBMISSIONS ON BEHALF OF THE PETITIONER: 3. Learned counsel for the Petitioner earnestly made the following submissions in support of his contentions. (i) The petitioner contended that the impugned action of Opposite Party No.1 in attaching his personal savings bank accounts as well as Demat and trading accounts is without jurisdiction and in violation of the principles of natural justice, inasmuch as the objections filed by him were not taken into consideration. (ii) The petitioner submitted that he was appointed as a Director of Seashore Securities Limited only for the period from 29.10.2008 to 05.03.2012 and that such appointment was solely for the purpose of statutory compliance. During the said period, the petitioner was neither involved in the day-to-day functioning of the company nor in its financial decision-making. (iii) It was further submitted that during the relevant period, the petitioner was employed as Manager (Accounts) with M/s. NAD Pvt. Ltd., Raipur, Chhattisgarh from 09.01.2007 till March, 2013, and had no role whatsoever in the affairs or financial decisions of Seashore Securities Limited. (iv) The petitioner contended that the final order dated 24.09.2018 passed by Opposite Party No.1 does not contain any specific, cogent or legally sustainable allegations establishing his involvement in the alleged violations. (v) It was submitted that mere designation as a Director cannot fasten liability in the absence of specific averments demonstrating how and in what manner the petitioner was responsible for the conduct of the business of the company. (v) It was submitted that mere designation as a Director cannot fasten liability in the absence of specific averments demonstrating how and in what manner the petitioner was responsible for the conduct of the business of the company. In order to buttress this argument, the petitioner placed reliance on the decisions of the Supreme Court in National Small Industries Corporation Ltd. v. Harmeet Singh Paintal , (2010) 3 SCC 330 and State of NCT of Delhi through Prosecuting Officer, Insecticides, Government of NCT, Delhi v. Rajiv Khurana , (2010) 11 SCC 469 (vi) The petitioner submitted that in the absence of any specific role attributed to him in the alleged fraudulent issuance of Redeemable Preference Shares, the attachment of his personal bank accounts as well as Demat and trading accounts is unsustainable. (vii) The petitioner, therefore, submitted that the final order dated 24.09.2018 and the consequential attachment notices dated 13.04.2023 are liable to be set aside, and that the concerned banks and intermediaries be directed to permit him to operate his accounts. III.SUBMISSIONS OF THE OPPOSITE PARTIES: 4. Per contra, the learned counsel for the Opposite Parties earnestly made the following submissions: (i) It was submitted that the petitioner, while working as a Director of Seashore Securities Limited, along with other directors, was instrumental in the issuance of Redeemable Preference Shares (RPS) without complying with the provisions of the Companies Act, 1956, the SEBI Act, 1992 and the rules, regulations and guidelines framed thereunder, including the SEBI (Disclosure and Investor Protection) Guidelines, 2000 read with the SEBI (Issue of Capital and Disclosure Requirements) Regulations, 2009. (ii) It was further submitted that the company was found to be involved in a ponzi scam and, upon investigation, Opposite Party No.1 initiated recovery proceedings for an amount of Rs.503,22,80,600/- along with interest at actuals. In this connection, attachment proceedings bearing Nos. 6832 and 6833 of 2021 pursuant to Certificate No. RC-3151 of 2020 were initiated, culminating in the issuance of attachment orders dated 13.04.2023. (iii) Learned counsel submitted that even earlier, vide order dated 18.03.2015 bearing No. WTM/PS/84/ERO/BLO/MAR/2015, Opposite Party No.1 had attached the properties, bank accounts, assets, Demat accounts and holdings of shares and securities of the company as well as its directors, including the petitioner. (iii) Learned counsel submitted that even earlier, vide order dated 18.03.2015 bearing No. WTM/PS/84/ERO/BLO/MAR/2015, Opposite Party No.1 had attached the properties, bank accounts, assets, Demat accounts and holdings of shares and securities of the company as well as its directors, including the petitioner. (iv) It was contended that the petitioner, being a Director of a company involved in a ponzi scam, is liable for recovery of the amount allegedly duped from investors, quantified at Rs.503,22,80,600/- along with interest at actuals. (v) It was further submitted that the impugned order is appealable under Section 28A read with Section 15T of the SEBI Act, 1992, and that an efficacious alternative remedy is available before the Securities Appellate Tribunal. On this ground, the writ petition is not maintainable, as the High Court ought not to entertain a petition under Article 226 of the Constitution of India when a statutory alternative remedy exists. (vi) Learned counsel submitted that under Sections 11B and 28A of the SEBI Act, 1992, Opposite Party No.1 is empowered to issue directions and to recover amounts due by adopting measures including attachment and sale of movable and immovable properties, attachment of bank accounts, arrest and detention, and appointment of a receiver, and that for this purpose the provisions of Sections 220 to 227, 228A, 229 and 232 and the Second and Third Schedules to the Income-tax Act, 1961 and the Income-tax (Certificate Proceedings) Rules, 1962 are applicable. IV. COU RT’S ANALYSIS AND REASONING 5. Heard learned counsel for the parties and perused the materials placed on record. 6. The petitioner has assailed the final order dated 24.09.2018 passed by Opposite Party No.1, namely the Securities and Exchange Board of India, and the consequential attachment notices dated 13.04.2023 issued under Section 28A of the SEBI Act, 1992, primarily on the ground that the attachment of his personal bank accounts as well as Demat and trading accounts is illegal and violative of the principles of natural justice. The foundation of the petitioner’s challenge rests on the assertion that he was only an erstwhile director of the company, that his role was limited in nature, and that no role-specific findings have been recorded against him so as to justify recovery proceedings against his personal assets. 7. At the outset, it is necessary to note that the broad factual backdrop giving rise to the present proceedings is not in serious dispute. 7. At the outset, it is necessary to note that the broad factual backdrop giving rise to the present proceedings is not in serious dispute. Seashore Securities Limited was found, upon investigation, to have issued Redeemable Preference Shares to the public in violation of the statutory framework governing public issues of securities. The regulatory action initiated by Opposite Party No.1 culminated in the passing of the final order dated 24.09.2018, followed by recovery proceedings under Section 28A of the SEBI Act, 1992. The attachment orders impugned in the present writ petition are consequential to the said recovery proceedings. 8. The record further discloses that the petitioner was a Director of the company during a part of the period when the illegal issuance of Redeemable Preference Shares is alleged to have taken place. The interim order as well as the final order passed by Opposite Party No.1 refer to the role of promoters and directors of the company and record findings to the effect that they were instrumental in the formulation and execution of the scheme relating to the said issuance. The petitioner has been expressly named in the regulatory orders as one of the directors against whom directions have been issued. 9. The principal contention advanced on behalf of the petitioner is that the findings recorded by Opposite Party No.1 are generic in nature and do not disclose any role-specific analysis with respect to the petitioner. It has been urged that, in the absence of such findings, the attachment of the petitioner’s personal bank accounts and Demat and trading accounts is legally unsustainable. This Court has carefully considered the said contention. 10. There can be no dispute with the settled legal position that personal liability cannot be fastened merely on the basis of designation, and that a director cannot be held vicariously liable in the absence of specific averments or findings demonstrating his role in the conduct of the business of the company. At the same time, it is equally well settled that proceedings under regulatory statutes such as the SEBI Act, 1992 often deal with collective conduct of the management, particularly where the alleged violation arises out of a course of action undertaken by the company and its directors acting in concert. 11. At the same time, it is equally well settled that proceedings under regulatory statutes such as the SEBI Act, 1992 often deal with collective conduct of the management, particularly where the alleged violation arises out of a course of action undertaken by the company and its directors acting in concert. 11. The correctness or adequacy of the findings recorded by the regulatory authority, the extent of individual involvement of a particular director, and the question whether such involvement was merely nominal or substantive are matters that would necessarily require an examination of facts, appreciation of evidence and scrutiny of the conclusions drawn by the regulator. Such an exercise would entail a detailed factual enquiry, which this Court does not ordinarily undertake in exercise of its jurisdiction under Article 226 of the Constitution of India. 12. The scope of judicial review under Article 226 is limited. This Court does not sit in appeal over the findings recorded by a statutory regulator acting within the bounds of its jurisdiction. Interference is warranted only where the impugned action is shown to be perverse, wholly unsupported by material on record, vitiated by manifest arbitrariness, or in violation of the principles of natural justice. 13. On a careful reading of the impugned orders, this Court is not persuaded to hold that the conclusions recorded by Opposite Party No.1 suffer from a total absence of reasons or non-application of mind. The orders deal with the nature of the violations alleged, the statutory provisions invoked, and the basis on which directions have been issued against the company and its directors. Whether such findings ultimately withstand appellate scrutiny is a matter beyond the scope of the present proceedings. 14. It is also of relevance that the SEBI Act, 1992 provides a comprehensive statutory mechanism for redressal of grievances arising from orders passed by the Board. Section 15T of the Act provides for an appeal to the Securities Appellate Tribunal against orders passed under the Act, including orders relating to recovery under Section 28A. 15. 14. It is also of relevance that the SEBI Act, 1992 provides a comprehensive statutory mechanism for redressal of grievances arising from orders passed by the Board. Section 15T of the Act provides for an appeal to the Securities Appellate Tribunal against orders passed under the Act, including orders relating to recovery under Section 28A. 15. While the existence of an efficacious alternative remedy does not, by itself, operate as an absolute bar to the exercise of writ jurisdiction, it is well settled that where the impugned action is taken in exercise of statutory powers, the orders are reasoned, and the challenge involves disputed questions of fact and evaluation of regulatory findings, this Court would ordinarily decline to exercise jurisdiction under Article 226 of the Constitution of India. The present case does not present circumstances warranting a departure from the said restraint. 16. This Court, therefore, is of the considered view that the petitioner ought to pursue the statutory remedy available under the SEBI Act, 1992. All contentions raised by the petitioner are left open to be urged before the appropriate forum, which shall consider the same on their own merits, in accordance with law. V. CONCLUSION: 17. For the reasons stated above, this Court declines to entertain the present Writ Petition. The Writ Petition is, accordingly, disposed of, granting liberty to the petitioner to avail the alternative statutory remedy in accordance with law. No opinion is expressed on the merits of the case. 18. Interim order, if any, passed earlier stands vacated.