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

Order Date: June 24, 2026

Case Overview

Dr. A.C. Mittal (Appellant) filed an appeal (No. 6905 of 2026) against the CPIO, SEBI, Mumbai, regarding a response to an RTI application dated April 07, 2026. The appellant had sought specific information from SEBI regarding regulations governing the transfer of physical share certificates under certain conditions. The information requested included: 1) Copies or references to any SEBI Acts, Rules, Regulations, or Circulars from 1992 to present that permit transfer of physical equity shares without submission of original share certificates; 2) Provisions allowing share transfers where Share Certificate Numbers and Distinctive Numbers are missing from transfer documents; 3) Acceptance of Blank Indemnity Bonds (without specific share details) for duplicate share issuance or transfer; and 4) Any special procedure circulars issued to R&T Agents allowing processing of transfers without primary identifiers.

The respondent CPIO, by letter dated April 28, 2026, had directed the appellant to refer to the SEBI Master Circular for Registrars to an Issue and Share Transfer Agents dated February 06, 2026, and Regulation 7 of the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015. Links for accessing these documents were provided.

The appellant filed the appeal on May 27, 2026 (Reg. No. SEBIH/A/E/26/00200) on the grounds that the provided information was incomplete, misleading, or false.

The Appellate Authority perused the application, response, and appeal, noting that all SEBI Regulations, Circulars, and Guidelines are publicly available on the SEBI website. The authority cited the Hon'ble Delhi High Court judgment in Registrar of Companies & ors. Vs. Dharmendra Kumar Garg & anr. and the Hon'ble CIC order in Shri K Lall vs. Shri M K Bagri (CIC/AT/A/2007/00112, dated April 12, 2007), which held that information already available in the public domain cannot be said to be information 'held' by the public authority, and thus there is no obligation to provide it under the RTI Act.

Final Outcome

The Appellate Authority found no need to interfere with the CPIO's decision and dismissed the appeal. The practical consequence is that the appellant must access the requested information directly from the publicly available sources on SEBI's website, as guided by the CPIO.

Topics: RTI Appeal, Share Transfer Regulations, SEBI Compliance