Description

RTI appeal by RTI Baba seeking SMART-wise details of investor awareness programs conducted by Market Infrastructure Institutions (BSE, NSE, MSE, NSDL, CDSL, MCX, NCDEX) during Q1-Q3 FY 2025-26. Appeal dismissed as SEBI does not maintain the information in the requested format.

Summary

This is an appellate order under the Right to Information Act, 2005 in Appeal No. 6783 of 2026. The appellant, RTI Baba, had sought SMART-wise (both individual and organizational) details of investor awareness programs conducted by seven Market Infrastructure Institutions (MIIs) — BSE, NSE, MSE, NSDL, CDSL, MCX, and NCDEX — during Q1, Q2, and Q3 of FY 2025-26. SEBI’s CPIO responded that the information is not maintained in the manner/format specified, though number of SMART programs conducted by MIIs from April 2025 to December 2025 was provided. The appellant challenged this as incomplete, misleading, or false information.

Key Points

  • Appellant filed RTI application on January 27, 2026 seeking SMART-wise investor awareness program data from MIIs for Q1-Q3 FY 2025-26
  • SEBI CPIO responded on February 16, 2026 stating the information is not maintained in the requested format
  • SEBI did provide the total number of SMART programs conducted by MIIs from April–December 2025
  • Appellant appealed (Reg. No. SEBIH/A/E/26/00095) on February 28, 2026, alleging incomplete/misleading response
  • Appellate Authority referred to Delhi High Court judgment (W.P.(C) No. 6634/2011) affirming that public authorities cannot be compelled to provide information not maintained in their records

Regulatory Changes

No regulatory changes introduced. This is an appellate order resolving an RTI information access dispute.

Compliance Requirements

No new compliance requirements for market participants. The order reaffirms the established legal position that a public authority is only obligated to provide information available in its records, and cannot be required to compile or reformat data it does not maintain in a specific manner.

Important Dates

  • January 27, 2026: Original RTI application filed by appellant
  • February 16, 2026: CPIO response to RTI application
  • February 28, 2026: First appeal filed (Reg. No. SEBIH/A/E/26/00095)
  • March 24, 2026: Appellate Authority order issued

Impact Assessment

No market or operational impact. This is a routine RTI appellate order with no implications for trading, listing, or compliance obligations. The order reinforces SEBI’s position that investor awareness program data submitted by MIIs is not maintained by SEBI in a SMART-wise disaggregated format, which may be informative for future RTI applicants seeking similar data.

Impact Justification

Routine RTI appellate order with no new regulatory changes or market-wide compliance requirements. Limited to information access dispute regarding investor awareness program data.