Description
SEBI Appellate Authority dismisses RTI appeal seeking share subscription and allotment documents for Gujarat Godrej Innovative Chemicals Limited, as information not maintained by SEBI.
Summary
The SEBI Appellate Authority dismissed Appeal No. 6627 of 2025 filed by Surinderpal Chananlal Sethi under the Right to Information Act, 2005. The appellant sought certified copies of share subscription application and allotment letter for Gujarat Godrej Innovative Chemicals Limited under promoters quota. SEBI’s CPIO had informed that such information is not maintained by SEBI in the normal course of securities market regulation and suggested approaching the Registrar and Share Transfer Agent. The Appellate Authority upheld this response, citing Supreme Court precedent that RTI does not obligate authorities to create or collate non-existent information.
Key Points
- RTI applications SEBIH/R/P/25/00235 and SEBIH/R/P/25/00236 filed on September 23, 2025 (received September 26, 2025)
- Appellant sought certified copy of share subscription application and allotment letter for Gujarat Godrej Innovative Chemicals Limited under promoters quota
- CPIO responded on October 13, 2025 that information not maintained by SEBI
- Appeal filed November 16, 2025 (received November 20, 2025)
- Appeal dismissed on December 12, 2025 by Appellate Authority Ruchi Chojer
- SEBI directed appellant to approach concerned Registrar and Share Transfer Agent
Regulatory Changes
No regulatory changes introduced. This is an administrative order under the RTI Act.
Compliance Requirements
No compliance requirements. The order reaffirms that:
- SEBI is only obligated to provide information available in its records
- RTI Act does not require public authorities to create, collect or collate non-existent information
- Share-related documents maintained by Registrar and Share Transfer Agents, not SEBI
Important Dates
- September 23, 2025: RTI applications filed
- September 26, 2025: Applications received by SEBI
- October 13, 2025: CPIO response provided
- November 16, 2025: Appeal filed
- November 20, 2025: Appeal received by Appellate Authority
- December 12, 2025: Order passed dismissing appeal
Impact Assessment
Market Impact: None. This is a procedural RTI matter with no implications for securities markets or trading.
Legal Precedent: The order reinforces established RTI jurisprudence from Central Board of Secondary Education vs. Aditya Bandopadhyay (2011) that public authorities need only provide existing information, not create new records. Also cites Central Information Commission ruling in Pattipati Rama Murthy vs. CPIO, SEBI (2013).
Operational Impact: Clarifies that share subscription and allotment records for companies are maintained by Registrar and Share Transfer Agents, not SEBI’s core regulatory records. Investors seeking such historical documentation should approach the appropriate RTA rather than SEBI.
Impact Justification
Administrative RTI appeal with no market impact; procedural matter involving information availability rather than regulatory action