Melt ghee in a large skillet over medium-high heat. Add cumin seeds; stir until fragrant and starting to crackle, about 1 minute. Stir in onion, jalapeno pepper, curry, garlic, ginger, and bay leaves. Cook, stirring occasionally, until onion starts to soften, about 5 minutes.

Pour tomatoes into the skillet; stir to combine, about 2 minutes. Add chili powder, cumin, coriander, turmeric, and salt; stir thoroughly. Add beef; cook, stirring with a wooden spoon to break up the meat, until no longer pink, about 5 minutes.

Reduce heat to low, cover, and simmer until flavors combine, about 15 minutes. Add frozen peas, cover, and simmer until heated through, about 10 minutes. For a thicker consistency, increase heat to medium and simmer curry, uncovered, until sauce reduces, about 5 minutes.