Case Details

This document is an order (Appeal No. 6877 of 2026) issued on June 09, 2026, by the Appellate Authority (Under the Right to Information Act, 2005) at the Securities and Exchange Board of India (SEBI). The appellant is Samar Imran, and the respondent is the CPIO, SEBI, Mumbai. The case pertains to an appeal against the response to an RTI application dated April 20, 2026, which was received by SEBI through the RTI MIS portal. The respondent's initial response was provided on May 11, 2026, and the appeal was filed on May 12, 2026 (Reg. No. SEBIH/A/E/26/00174).

Persons Involved

  • Appellant: Samar Imran
  • Respondent: CPIO, SEBI, Mumbai
  • Appellate Authority: Ruchi Chojer, Appellate Authority under the RTI Act, Securities and Exchange Board of India

Violations and Allegations

The appeal was filed on the ground that the appellant was provided "incomplete, misleading or false information" by the CPIO in response to their RTI application. The application sought detailed information on SEBI's procedures and regulations concerning the transmission of securities, specifically focusing on the acceptance of a "Legal Heirship Certificate (or its equivalent certificate)" as mentioned in the SEBI Master Circular for Registrars to an Issue and Share Transfer Agents dated February 06, 2026.

Penalties, Settlement Terms & Rulings

The Appellate Authority, Ruchi Chojer, issued a detailed ruling on each of the eight queries in the original application:

  • Query 1 (Request for a certified copy of Page 168, Point 8 of SEBI Master Circular): The appeal was dismissed. The Authority upheld the CPIO's response that the information is publicly available on the SEBI website, citing precedents from the Delhi High Court and the Central Information Commission (CIC) that there is no obligation to provide information already in the public domain.
  • Query 2 (Request for internal file notings related to the phrase "Legal Heirship Certificate"): The appeal was dismissed. The Authority found the query to be "vague, broad and not specific" but noted the CPIO had guided the appellant to a relevant consultation paper and the master circular.
  • Query 3, 7, and 8 (Requests for guidelines to RTAs, communications to specific RTAs, and internal SOPs): The appeals against the response to these queries were dismissed. The Authority found that the CPIO had adequately addressed them by directing the appellant to the SEBI Master Circular for RTAs & STAs.
  • Query 4 (Request for records defining "equivalent certificate"): The appeal was partly allowed. The Authority found the CPIO's invocation of exemption under Section 8(1)(a) of the RTI Act for this query was without sufficient justification. The application was remanded to the CPIO for de novo consideration and a fresh response within 15 working days.
  • Query 5 (Request for inspection reports and supervisory observations on RTA compliance): The appeal was dismissed. The Authority upheld the denial under Sections 8(1)(a) and 8(1)(d) of the RTI Act, agreeing that such reports contain strategic, regulatory, and commercial information whose disclosure could hamper SEBI's decision-making and harm third-party competitive interests.
  • Query 6 (Request for anonymized complaints concerning heirship certificates): The appeal was dismissed. The Authority upheld the denial under Sections 8(1)(a) and 8(1)(e) of the RTI Act, ruling that complaints are received by SEBI in a fiduciary and confidential capacity. Disclosure could impact SEBI's ability to obtain future inputs and reveal strategic information under consideration.

Actions, Compliance, and Future Obligations

The sole action ordered is for the CPIO, SEBI, to re-examine Query No. 4 and provide a fresh, appropriate response to the appellant within 15 working days from the receipt of this order, in accordance with the provisions of the RTI Act.

Final Ruling and Enforcement

The appeal was disposed of with the above observations and rulings. The order is final regarding all queries except Query No. 4, which must be revisited by the CPIO. No monetary penalties or fines were imposed on any party as this was an appeal against an information request denial.