Authority: Appellate Authority under RTI Act, Securities and Exchange Board of India

Order Date: August 14, 2026

Case Overview

The appeal was filed by Neeraj Sisodia against the CPIO, SEBI, Mumbai regarding an RTI application dated July 02, 2026 (received through RTI MIS portal) seeking extensive information about Hindustan Petroleum Corporation Limited's (HPCL) compliance with SEBI LODR Regulations during FY 2022-23, FY 2023-24, and FY 2024-25.

The appellant sought 13 specific items including copies of all notices, communications, orders, or emails issued by SEBI, NSE, and BSE to HPCL regarding non-compliance; regulation-wise and date-wise details of violations; details of fines or penalties imposed; payment details; waiver applications; status of waiver requests mentioned in HPCL's Integrated Annual Report 2024-25; copies of representations submitted by HPCL; information about further action against HPCL; quarterly Corporate Governance Reports; and details of whether violations were placed before any SEBI committee.

The respondent (CPIO, SEBI) denied most information citing multiple grounds: (1) Information pertaining to third party (HPCL) held in fiduciary capacity exempt under Section 8(1)(e) of RTI Act (queries 1, 9); (2) Information not maintained in the manner/format specified (queries 2, 3, 4, 5, 6, 7, 8); (3) Queries in nature of seeking clarification/opinion not constituting 'information' under Section 2(f) of RTI Act (queries 10, 12, 13); (4) Information regarding NSE/BSE communications not maintained by SEBI; (5) Corporate Governance Reports being public documents accessible on stock exchange websites (query 11).

The Appellate Authority upheld the CPIO's responses, citing several precedents including Hon'ble Supreme Court in Institute of Chartered Accountants of India Vs. Shaunak H. Satya and Ors. (Civil Appeal No. 7571 of 2011) which established that information given and taken in confidence expecting confidentiality constitutes information available in fiduciary relationship. The Authority also referenced Hon'ble CIC decisions in Mr. Ashok Kumar Rajak vs. CPIO, SEBI (2021) and Mehmood Mehboob Shaikh vs. CPIO, SEBI (2025) which upheld denial of third-party information. For queries seeking information in specific format, the Authority cited Prateek Tewari v. CPIO, SEBI (2023) where CIC observed that information cannot be directed to be disclosed if not available in the requested format.

Final Outcome

The appeal was dismissed, upholding the CPIO's decision to deny information. The Appellate Authority found no deficiency in the response and concluded there was no need to interfere with the decision of the respondent.

Topics: RTI Appeal, SEBI LODR Compliance, Third-Party Information