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

Order Date: September 11, 2026

Case Overview

The appellant, Richa Kohli, filed an application under the Right to Information Act, 2005, on July 22, 2026 (received by SEBI on July 25, 2026). The application sought specific information regarding Paisalo Digital Ltd (formerly S.E. Investments Limited), a registered NBFC listed on the Bombay Stock Exchange. The queries were:

1. Whether Paisalo Digital had ever publicly disclosed declaring four specific accounts as Non-Performing Assets (NPAs): Goldmine Global Medicare Private Limited, Indo Gulf Diagnostic & Research Centre Private Limited, Quit Castle Hotels Private Limited, and Elecon Buildwell Private Limited.

2. Whether the company had complied with its disclosure obligations under Regulations 30 and 51 of the SEBI (Listing Obligation and Disclosure Requirements) Regulations, 2015 regarding the declaration of these entities as NPA/fraud/willful default/loss asset. The appellant also requested any available information on this.

3. Whether SEBI had ever imposed any penalty or taken punitive action against Paisalo Digital Ltd since its listing date, and to provide details of the same.

The CPIO, SEBI, Mumbai, responded on August 06, 2026. The respondent stated that the queries were in the nature of seeking clarification and could not be construed as 'information' as defined under Section 2(f) of the RTI Act. Notwithstanding this, for query no. 1, the respondent informed that all material disclosures required under Regulation 30 of LODR are available on stock exchange websites. For query no. 3, the respondent stated that details of regulatory actions are available in the public domain on the SEBI website.

The appellant, dissatisfied with this response, filed a first appeal dated August 11, 2026 (Registration No. SEBIH/A/E/26/00058), which was received by the Appellate Authority on August 19, 2026.

The Appellate Authority concurred with the CPIO's response, ruling that the appellant's queries sought confirmation or clarification from SEBI. The authority found that these queries did not constitute a request for 'information' as per the RTI Act and that the CPIO is not obligated to provide such clarifications, interpret information, or create new information. The authority cited a precedent from the Central Information Commission (CIC) in the matter of Azad Singh vs. CPIO, Oriental Insurance Company Limited (order dated March 23, 2021) to support this interpretation of the law.

Final Outcome

The appeal was dismissed. The Appellate Authority found no deficiency in the CPIO's response and upheld the decision that SEBI was not obligated to answer the specific clarifications sought under the RTI Act. The appellant was directed to the existing public sources (stock exchange and SEBI websites) for the information.

Topics: RTI Act, SEBI LODR Regulations, NBFC Disclosures