Description

Appellate Authority order dismissing RTI appeals seeking complaint status and action taken against Garware Synthetics Limited, citing fiduciary relationship and third-party exemptions.

Summary

The SEBI Appellate Authority dismissed two RTI appeals (Nos. 6659 & 6660 of 2026) filed by Mayur Mamidwar seeking information about a complaint filed by JPPL against Garware Synthetics Limited. The appellant requested the status of the complaint dated August 14, 2025, actions taken against the company, and responses filed by the entity. The CPIO had denied the information citing Section 8(1)(e) of the RTI Act (fiduciary relationship exemption). The Appellate Authority upheld the denial, noting that the appellant failed to provide authorization from JPPL and was therefore a third party to the complaint.

Key Points

  • Two RTI applications (SEBIH/R/E/25/01513 and SEBIH/R/E/25/01514) filed on November 20, 2025 seeking complaint-related information
  • CPIO denied information on December 16, 2025 under Section 8(1)(e) of RTI Act (fiduciary relationship exemption)
  • Appellant filed appeals on December 16, 2025 claiming refusal of access to information
  • Appellant claimed to be director of JPPL but provided no proof of authorization at time of application
  • Appellate Authority classified appellant as third party due to lack of authorization
  • Order cites precedent from Chandrakant Kantilal Patel vs. CPIO, SEBI (December 27, 2022) regarding third-party information requests
  • Information sought pertained to complaint filed by JPPL against Garware Synthetics Limited

Regulatory Changes

No regulatory changes introduced. This is a procedural order interpreting existing RTI Act provisions.

Compliance Requirements

This order reinforces that:

  • RTI applicants seeking third-party complaint information must provide proof of authorization from the complainant
  • Without proper authorization, applicants are considered third parties and exemptions under Section 8(1)(e) and 8(1)(j) of RTI Act apply
  • Information received by SEBI in fiduciary capacity is exempt from disclosure under RTI Act

Important Dates

  • November 20, 2025: RTI applications filed
  • December 16, 2025: CPIO response denying information
  • December 16, 2025: Appeals filed by appellant
  • December 29, 2025: Appellant’s email claiming directorship of JPPL
  • January 14, 2026: Appellate Authority order issued

Impact Assessment

This order has minimal market impact as it is a procedural RTI matter. It clarifies SEBI’s position on disclosure of complaint-related information received in fiduciary capacity. The order protects confidentiality of regulatory complaints and responses unless the requesting party establishes proper authorization. For Garware Synthetics Limited specifically, no regulatory action or findings are disclosed in this order - it merely addresses information access rights under RTI Act. The precedent reinforces limitations on third-party access to complaint information maintained by SEBI.

Impact Justification

Procedural RTI appeal order with no regulatory changes or market impact; clarifies information disclosure exemptions under fiduciary relationship provisions