Description

Appellate Authority order on RTI appeal seeking trading data, PAN-wise volume concentration, surveillance flags, and enforcement details for NSE-listed Addictive Learning Technology Limited (ADDICTIVE). SEBI denied most queries citing fiduciary exemption under Section 8(1)(e) of the RTI Act.

Summary

The SEBI Appellate Authority is hearing Appeal No. 6838 of 2026 filed by Ankit Maheshwari against the CPIO, SEBI, Mumbai. The appellant had sought detailed trading data and regulatory information on Addictive Learning Technology Limited (NSE: ADDICTIVE) via an RTI application dated March 22, 2026. SEBI’s response denied or deflected most queries, prompting the appeal on grounds of incomplete, misleading, or false information.

Key Points

  • Appellant sought five categories of data: unique PAN counts trading ADDICTIVE (Jan 2024–Mar 2026), volume concentration by top 5/10/20 PANs, registered shareholder counts at six-month intervals, NSE surveillance flags, and any SEBI enforcement under PFUTP Regulations 2003.
  • SEBI denied queries Q1 and Q2 (PAN counts and volume concentration) citing Section 8(1)(e) of the RTI Act — information received in a fiduciary capacity from Stock Exchanges.
  • For Q3 (shareholder count), SEBI stated the data is not maintained by it in the normal course but directed the appellant to NSE’s public website.
  • For Q4 (surveillance flags), SEBI stated the information does not pertain to SEBI.
  • For Q5 (enforcement/investigation), SEBI acknowledged it receives market intelligence and complaints, examines them, and that any regulatory action taken is available on the SEBI website.
  • The appellant filed the appeal dated April 17, 2026 (Reg. No. SEBIH/A/E/26/00137) alleging the response was incomplete, misleading, or false.
  • The order references multiple High Court Writ Petitions (Civil Nos. 8396/2009, 16907/2006, 4788/2008, 9914/2009, 6085/2008, 7304/2007, 7930/2009, and 3607/2007) in the context of the fiduciary exemption — the document is truncated at page 2 of 4.

Regulatory Changes

No new regulatory changes are introduced by this order. The matter pertains to the application of existing RTI Act exemptions — specifically Section 8(1)(e) (fiduciary information) and Section 8(1)(h) (information that would impede investigation/prosecution) — to market surveillance and trading data held by SEBI.

Compliance Requirements

No new compliance requirements for market participants arise from this order. The order is procedural and confined to the RTI appellate process between the appellant and SEBI’s CPIO.

Important Dates

  • March 22, 2026: Original RTI application filed by Ankit Maheshwari.
  • April 16, 2026: SEBI (Respondent/CPIO) responded to the RTI application.
  • April 17, 2026: Appellant filed the first appeal (Reg. No. SEBIH/A/E/26/00137).
  • Data period requested: January 2024 – March 2026 (trading data); shareholder snapshots at Mar 2024, Sep 2024, Mar 2025, Sep 2025, Mar 2026.
  • ADDICTIVE listing date: January 30, 2024 (referenced in Q4).

Impact Assessment

This order has negligible market or operational impact. It is a routine RTI appellate proceeding concerning one individual’s request for trading and surveillance data on a single small-cap stock (Addictive Learning Technology Limited). The outcome may provide procedural clarity on how SEBI applies the fiduciary exemption under Section 8(1)(e) to stock exchange-sourced trading data, but does not alter regulatory obligations for any market participant. Investors or analysts seeking trading concentration or surveillance data on listed securities should note SEBI’s position that such data is exempt from RTI disclosure as fiduciary information received from exchanges.

Impact Justification

Routine RTI appellate order with no new regulatory guidance or market-wide compliance requirements; limited to individual information request dispute regarding one small-cap stock.