Indian securities law faces a critical ambiguity: reconciling statutory minimum penalties with adjudicators’ discretion to reduce them based on mitigating circumstances. The SAT’s split decision highlights this tension. While statutes prescribe minimums, Section 15J mandates considering factors like investor loss. Current interpretation leads to inconsistency, undermining predictability. The authors argue this is a legislative design flaw, not an interpretive one. They criticize the proposed Securities Market Code for failing to clarify whether minimum penalties are absolute or if proportionality allows deviation. Parliament must provide clear guidance to ensure both deterrence and fairness, enhancing regulatory predictability in India’s market.