Description

RTI first appeal filed by Saurabhi Bharat Rele seeking clarifications on SEBI Circular CIR/IMD/DF/21/2012 regarding mutual fund direct plans pre-January 2013. Appeal dismissed as time-barred and queries held to be opinion/clarification-seeking, not 'information' under RTI Act.

Summary

The Appellate Authority under the Right to Information Act, 2005 has dismissed Appeal No. 6830 of 2026 filed by Saurabhi Bharat Rele against the CPIO, SEBI, Mumbai. The appellant sought information relating to SEBI Circular No. CIR/IMD/DF/21/2012 dated September 13, 2012, concerning the treatment of accumulated corpus AUM in mutual fund direct vs regular plans before January 1, 2013. The appeal was dismissed primarily as time-barred, and on merits the queries were held to be opinion/clarification-seeking in nature, not qualifying as ‘information’ under Section 2(f) of the RTI Act.

Key Points

  • Appeal filed by Saurabhi Bharat Rele against CPIO, SEBI, Mumbai under the RTI Act, 2005
  • Original RTI application was received by SEBI on December 26, 2025; CPIO responded on January 20, 2026
  • First appeal (Reg. No. SEBIH/A/P/26/00022) was received by the Appellate Authority on April 09, 2026, well beyond the 30-day statutory deadline from January 20, 2026
  • Appellant provided no request for condonation of delay and no explanation for the delay
  • Appeal dismissed as time-barred under Section 19(1) of the RTI Act
  • On merits, the Appellate Authority concurred with the CPIO that the queries seek clarification/opinion, not ‘information’ as defined under Section 2(f) of the RTI Act

Regulatory Changes

No regulatory changes. This is a disposal order in an individual RTI appeal and does not amend or introduce any SEBI regulations or circulars.

Compliance Requirements

No new compliance requirements for market participants. The order reaffirms that:

  • RTI first appeals must be filed within 30 days of receipt of the CPIO’s response under Section 19(1) of the RTI Act
  • Requests for clarification or opinion do not constitute ‘information’ under Section 2(f) of the RTI Act and are not required to be furnished by public authorities

Important Dates

  • December 26, 2025: Original RTI application received by SEBI
  • January 20, 2026: CPIO’s response to the RTI application
  • Deadline for first appeal: On or before February 19, 2026 (30 days from January 20, 2026)
  • April 09, 2026: First appeal actually received by Appellate Authority (time-barred)
  • Referenced SEBI Circular: CIR/IMD/DF/21/2012 dated September 13, 2012 (subject of the original RTI queries)

Impact Assessment

This order has no direct market or operational impact. It is a routine administrative disposal of an individual RTI appeal. The underlying subject matter — the transition of directly-invested mutual fund corpus into direct vs regular plans from January 1, 2013 — is of historical investor interest but is not addressed on merits in this order. Investors with similar queries about pre-2013 mutual fund corpus treatment would need to frame their RTI requests as seeking specific recorded documents or data rather than seeking clarifications or opinions from SEBI.

Impact Justification

Routine RTI appellate order with no market-wide regulatory impact; appeal dismissed as time-barred and queries held non-actionable under RTI Act. No new compliance obligations or regulatory changes arise from this order.