Central Information Commission
Kusum Gupta vs Securities And Exchange Board Of India ... on 27 June, 2024
के ीय सूचना आयोग
Central Information Commission
बाबा गंगनाथ माग ,मुिनरका
Baba Gangnath Marg, Munirka
नई द ली, New Delhi - 110067
ि तीय अपील सं या / Second Appeal No. (As per annexure)
Kusum Gupta ... अपीलकता /Appellant
VERSUS
बनाम
CPIO:
Securities and Exchange Board of ... ितवादीगण/Respondents
India,
Mumbai
Relevant dates emerging from the appeals:
Sl. Second Date of Date of Date of Date of Date of
No. Appeal RTI CPIO's Reply First FAA's Second
No. Application Appeal Order Appeal
1. 616672 24.09.2022 18.10.2022 24.11.2022 26.12.2022 22.03.2023
2. 615295 22.09.2022 18.10.2022 21.11.2022 20.12.2022 22.03.2023
3. 615072 22.09.2022 18.10.2022 22.11.2022 20.12.2022 22.03.2023
4. 615030 22.09.2022 18.10.2022 22.11.2022 21.12.2022 22.03.2023
5. 615031 22.09.2022 18.10.2022 22.11.2022 21.12.2022 22.03.2023
6. 615297 22.09.2022 18.10.2022 21.11.2022 16.12.2022 21.03.2023
7. 614881 22.09.2022 18.10.2022 22.11.2022 21.12.2022 22.03.2023
Note - The above-mentioned Appeals have been clubbed together for decision as
these are based on similar RTI Applications.
Date of Hearing: 24.06.2024
Date of Decision: 26.06.2024
CORAM:
Hon'ble Commissioner
_ANANDI RAMALINGAM
ORDER
Second Appeal No. CIC/SEBIH/A/2023/616672 Page 1 of 37
1. The Appellant filed an RTI application dated 24.09.2022 seeking information on the following points:
(i) Provide two certified hard copies of information pertaining to all the communications (including emails, letters, notices sent by you, reply of notices received from SMART to you etc.) pertaining to IAP scheduling, IAP approval, Web meeting link sharing and claim/bill submitted & paid/unpaid for the Online IAPs Webinar scheduled & conducted by the SEBI Recognized Organization SMART (Ambition Learning Solutions) and also provide additional information in the below format:
Online IAP Online Online IAP Name of Total Tot Claim Webinar IAP Webinar Topic the SEBI durat al settleme Date Webinar Recognized ion of num nt (DD/MM/Y Time Organizati the ber amount YYY) (HH:MM) on SMART IAP of (bill) traini part raised ng icip by sessio ants SMART n (In (Indian (Hrs: figu Rupees) Mins) res) 06/01/2022 11:00 am How to buy and Ambition - - -
sell shares Learning
Solutions
07/01/2022 11:00 am Introduction to Ambition - - -
Mutual Fund Learning
Investing Solutions
08/01/2022 09:30 am Introduction to Ambition - - -
Securities Learning
Markets Solutions
Page 2 of 37
13/01/2022 02:00 pm How to Invest in Ambition - - -
Right Issue Learning
Solutions
14/01/2022 02:00 pm Corporate Ambition - - -
Actions - Learning
Dividends, Solutions
Bonus, Splits,
etc.
15/01/2022 02:00 pm Buy Back of Ambition - - -
Securities and Learning
Open Offer of Solutions
Shares
(ii) Provide two certified copies of information pertaining to the name/s of SEBI official present as invigilator and other information for the Online IAPs Webinar scheduled by the SEBI Recognized Organization SMART. Kindly provide information in the below mentioned format:
Online IAP Online Online Name of SEBI Name of Name of Webinar IAP IAP the SEBI Invigila the the SEBI Date Webinar Webinar Recognize tor employee employee/ (DD/MM/Y Time Topic d name, present/c person YYY) (HH:MM) Organizat designa oordinati who has ion tion, ng on started SMART timing behalf of the Cisco of the SEBI Webex present Recogniz meeting?
and ed
duratio Organiza
n tion
SMART?
06/01/2022 11:00 am How to Ambition - - -
buy and Learning
Solutions
Page 3 of 37
sell
shares
07/01/2022 11:00 am Introduct Ambition - - -
ion to Learning
Mutual Solutions
Fund
Investing
08/01/2022 09:30 am Introduct Ambition - - -
ion to Learning
Securitie Solutions
s
Markets
13/01/2022 02:00 pm How to Ambition - - -
Invest in Learning
Right Solutions
Issue
14/01/2022 02:00 pm Corporat Ambition - - -
e Actions Learning
- Solutions
Dividend
s, Bonus,
Splits,
etc.
15/01/2022 02:00 pm Buy Back Ambition - - -
of Learning
Securitie Solutions
s and
Open
Offer of
Shares
(iii) Provide two certified copies of the information pertaining to the below mentioned IAPs Webinar conducted by the SEBI Recognized Organization SMART (Ambition Learning Solutions):Page 4 of 37
Online IAP Online Online IAP Total Total Tot Total SEBI Webinar IAP Webinar Topic Duration Num al number Invigilat Date Webinar of each ber of Nu of other or Time IAP Parti mbe categor name, session cipan r of y of designat ts Stu particip ion, (All den ants timings Cate t (excludi of gorie Par ng present
s) tici students during pan ) the ts session 06/01/2022 11:00 am How to buy and - - - - -
sell shares 07/01/2022 11:00 am Introduction to - - - - -
Mutual Fund
Investing
08/01/2022 09:30 am Introduction to - - - - -
Securities
Markets
13/01/2022 02:00 pm How to Invest in - - - - -
Right Issue
Page 5 of 37
14/01/2022 02:00 pm Corporate - - - - -
Actions -
Dividends,
Bonus, Splits,
etc.
15/01/2022 02:00 pm Buy Back of - - - - -
Securities and
Open Offer of
Shares
(iv) Provide a certified copy of information from your/SEBI record for the below mentioned IAPs Webinar conducted by the SEBI Recognized Organization SMART (Ambition Learning Solutions):
Online IAP Webinar Online IAP Webinar Online IAP Webinar Topic Date Time 06/01/2022 11:00 am How to buy and sell shares 07/01/2022 11:00 am Introduction to Mutual Fund Investing 08/01/2022 09:30 am Introduction to Securities Markets 13/01/2022 02:00 pm How to Invest in Right Issue 14/01/2022 02:00 pm Corporate Actions - Dividends, Bonus, Splits, etc. 15/01/2022 02:00 pm Buy Back of Securities and Open Offer of Shares A. Kindly provide the official address of the SEBI Recognized Organization SMART (Ambition Learning Solutions, Mumbai) in your record.Page 6 of 37
B. The Operational Guidelines on Securities Market Trainers (SMARTs) applicable to the SEBI Recognized Organization SMART (Ambition Learning Solutions, Mumbai).
C. Provide two certified copies of the signed empanelment letter (including terms and conditions) issued to the SEBI Recognized Organization SMART (Ambition Learning Solutions, Mumbai) by SEBI.
D. Full video recording of the above mentioned all six webinars conducted by the SEBI Recognized Organization SMART (Ambition Learning Solutions, Mumbai).
E. Provide two certified copies of all the participants data (name, login time, email id, mobile number etc. captured by Cisco Webex online training platform) during the IAPs session of the above mentioned all six webinars conducted by the SEBI Recognized Organization SMART (Ambition Learning Solutions, Mumbai).
F. The role, rights and responsibilities, authority, obligations of the SEBI Recognized Organization SMART (Ambition Learning Solutions, Mumbai) during conducting the above mentioned IAPs.
G. List of employees (name, email id, mobile number, address) associate and coordinate on behalf of the SEBI Recognized Organization SMART (Ambition Learning Solutions, Mumbai).
1.1. The CPIO replied vide letter dated 18.10.2022 and the same is reproduced as under:-
Reply to queries i, iii & iv:
The information sought by you is available to SEBI in fiduciary capacity and there is no larger public interest involved in disclosure of the said information, hence is exempt u/s 8(1)(e) of RTI Act, 2005.Page 7 of 37
Further, the information sought relates to personal information of SMART, the disclosure of which has no relationship to any public activity or interest and may cause unwarranted invasion into the privacy of the individual and may also endanger the life or physical safety of the person(s). The same is, therefore, exempt in terms of Section 8(1) (g) and 8(1)(j) of the RTI Act, 2005.
Reply to query ii:
The information sought relates to personal information of SEBI employees, the disclosure of which has no relationship to any public activity or interest and may cause unwarranted invasion into the privacy of the individual and may also endanger the life or physical safely of the person(s). The same is, therefore, exempt in terms of Section 8(1)(g) and 8(1)(j) of the RTI Act, 2005.
Reply to query (iv A):
Communication Address: Ambition Learning Solutions- 506, 5th Floor, Paradise Tower, Besides McDonald, Gokhale Road , Near Thane Railway Station Thane west- 400602.
Registered Address: Ambition Learning Solutions 1st Floor, Balwantrao Madgaonkar Building Court Lane, Next io Borivali Court, Above Borivali Post Office, Borivali (West, Mumbai - 400082.
Reply to query (iv C & E) The information sought relates to personal information of SMART, the disclosure of which has no relationship to any public activity or interest and may cause unwarranted invasion into the privacy of the individual and may also endanger the life or physical safety of a person(s). The same is, therefore, exempt in terms of Section 8(1) (g) and 8(1)(j) of the RTI Act, 2005.
However, the applicant may refer to the SEBI Investor Website to get the email ID of the SEBI recognized organisation SMART (Ambition Learning Solution, Mumbai) Page 8 of 37 Reply to query (iv B):
You may refer to the SEBI Investor Website for the Operational Guidelines on SMARTs at https://investor.sebi.gov.in/join-us/smrtspanel.html.
Reply to query (iv D & G):
The information sought by you is available to SEBI in fiduciary capacity and there is no larger public interest involved in disclosure of the said information, hence is exempt u/s 8(1)(e) of RTI Act, 2005, Reply to query (iv F):
You may refer to the SEB! Operational Guidelines on Securities Market Trainers (SMARTS) available on the SEBI Investor Website at https://investor.sebi.gov.in/join-us/smrtspanel.html.
1.2. Dissatisfied with the response received from the CPIO, the Appellant filed a First Appeal dated 24.11.2022 alleging that the information provided was incomplete, false and misleading. The FAA vide order dated 26.12.2022 stated that:
I have perused the query and the response provided thereto. As regards the non- disclosure of information relating to SEBI officials, I find that a similar issue was settled in H.E. Rajeshekarappa vs. State Public Information Officer and Ors, (Order dated July 01, 2008), wherein the Hon'ble High Court of Karnataka had ruled that: "...it cannot be said that section 2(f) of the Act (the RTI Act encompasses the personal information of the officials of the public authority. The intention of the legislation is to provide right to information to a citizen pertaining to public affairs of the public authority". Further, I note that the Hon'ble CIC, in the matter of Prerit Misra vs, CPIO, SEBI (order dated November 21, 2022) held that- 'it is pertinent to mention here that the appellant in a similar case which was dealt in File no. CIC/SEBIE/ A/2019/660770 dated 10.08.2021 whereby he had sought information regarding the names of the officers who had blocked his email address, the Commission, while passing an Page 9 of 37 order had held that such information is exempted u/s 8(1)(g) & 8(1)(j) of the RIT Act. The Commission after considering the submissions of the appellant finds no merit in his case, and also is in agreement with the order of the FAA and concludes that the information is exempt u/s 8(1)(g) & 8(1)(j) of the RTI Act, hence, no relief can be given." In view of these observations, I find that the requested information is exempt from disclosure under sections 8(1)(g) and 8(1)(j) of the RTI Act.
Aggrieved with the FAA's order, the Appellant approached the Commission with the instant Second Appeal dated 22.03.2023.
1.3. The appellant's representative Mr. Amit Gupta remained present through video conference and on behalf of the respondent Mr. Santosh Kumar Sharma, CPIO and Mr. Mohd. Atif Alvi, General Manager attended the hearing through video conference.
1.4. The appellant's representative inter alia submitted that they requested for detailed information regarding the Investor Awareness Programs (IAP) conducted by the SEBI Recognized Organization SMART (Ambition Learning Solutions). The main grievance of the Appellant is the alleged malafide denial of this information by the Respondent authority, which he argues is misinterpreted and incorrectly applied. He asserted that as the information pertains to public records and activities funded by public money, it should be disclosed to promote transparency and accountability in SEBI's operations.
1.5. The respondent while defending their case inter alia submitted that Mr. Amit Gupta has been recognized as a trainer by SEBI to conduct Investor Awareness Program but due to certain irregularities- he was promoting some other forums by using SEBI's name, SEBI de-recognized him by cancelling his empanelment with SEBI. Subsequent to which they started receiving multiple RTI Applications with his name or other names. The information sought by the Appellant Smt. Kusum Gupta the present matter is nowhere related her. Even in the RTI Application the Appellant has not disclosed her relationship with Mr. Amit Gupta who is representing this Application. Moreover, the information has been denied under the ambit of Section 8(1)(e) and (j) as certain information received in Page 10 of 37 fiduciary capacity from other SMART's who conduct the Investor Awareness Programs (IAP) cannot be shared with the third parties.
When queried by the Commission regarding point No. 4B and 4F of the RTI Application, the Respondent informed that the operational guidelines have been provided to the Appellant on receipt of the fees in Second Appeal No. CIC/SEBIH/A/2023/615031. In revert to, point No. 4F, the Respondent stated that the roles, rights and responsibility are a part of operational/general guidelines, made available to the Appellant in the aforementioned matter. He further clarified that all the information is provided in generic form and not in the particular format requested by the Appellant in the RTI Application, as the same is not maintained in such format.
1.6. The Commission after adverting to the facts and circumstances of the case, hearing both parties and perusal of records, observes that the Respondent has provided an appropriate reply to the RTI Application. Therefore, the Commission finds no scope of intervention in the matter. With this observation, the appeal is dismissed.
Second Appeal No. CIC/SEBIH/A/2023/615295
2. The Appellant filed an RTI application dated 22.09.2022 seeking information on the following points:
(i) Provide five certified hard copies of information from your record pertaining to the intimation letter (physical/ via email) issued by SEBI to Individual/ Organization SMARTs pertaining to the appointment of Mr. Manjesh Roy Stephen (General Manager, OIAEIAD, SEBI) in place of Mr. Prasad Jagadale (General Manager, OIAE-IAD, SEBI), Mumbai.
(ii) Provide two certified copies of information from your record pertaining to letter/notice/email/oral communication/video message sent related to penalty, ban, or de-empanelment imposed on either or both SMART entities, CIEL Learning Foundation, Mumbai (An Organization SMART) and Ambition Page 11 of 37 Learning Solutions, Mumbai (An Organization SMART) during 01st Jan 2022 to till today.
(iii) Provide two certified hard copies of information from your record pertaining to the appointment letter/s or making In-charge to a particular role/s or issued an assignment letter/s pertaining to their job roles and responsibilities, duties, compliances/ non-compliances during work period (01 November 2020 to till today) for all the employees of the department of Investor Awareness Division -
Office of Investor Assistance and Education (IAD-OIAE, SEBI), Bandra - BKC office), Mumbai.
(iv) Provide two certified hard copies of information from record pertaining to all/any of the employee/s of the department of Investor Awareness Division - Office of Investor Assistance and Education (IAD-OIAE, SEBI), Bandra - BKC office, Mumbai about the Show Cause Notice/Warning Letter/Suspension Letter/Termination Letter etc. issued pertaining to their job roles and responsibilities, non-performing duties, non-compliances during work period (01 November 2020 to till today).
2.1. The CPIO replied vide letter dated 18.10.2022 and the same is reproduced as under:-
Reply to query (i):
No such letter is issued Reply to query (ii & iv):
Your query is not clear and specific. Accordingly, the same cannot be construed as "information", as defined u/s 2(f) of the RTI Act, 2005, Reply to query (iii):
The information sought by you pertains to the internal functioning of SEBI and is strategic in nature, disclosure of which may hamper the decision making by Page 12 of 37 SEBI in its supervisory and regulatory role. In view of the same, the information sought is exempt u/s 8(1)(a) of RTI Act, 2005.
You may however refer the SEBI website for the employees of the Investor Awareness Division of SEBI at the following link: https://www.sebi.gov.in/sebiweb/home/directory-of-sebi.jsp 2.2. Dissatisfied with the response received from the CPIO, the Appellant filed a First Appeal dated 21.11.2022 alleging that the information provided was incomplete, false and misleading. The FAA vide order dated 20.12.2022 stated as under:-
I have perused the query and the response provided thereto. On consideration, I agree with the response of the respondent that the requested information pertains to internal functioning of SEBI and is strategic in nature. I also note that providing the requested information regarding appointment of employees in particular role/s may entail disclosure of personal information including names etc. of SEBI officials handling the matters. Further, I note that the decision-making process in SEBI is a collective affair in which officers of different levels contribute and hence information regarding the names of SEBI officials handling the matters relates to personal information, the disclosure of which has no relation to any public activity. As regards the non-disclosure of information relating to name of officer/s authorizing certain action, I find that a similar issue was settled by the in H. E. Rajashekarappa vs. State Public Information Officer and Ors. (Order dated July 01, 2008), wherein the Hon'ble High Court of Karnataka had ruled that: "..it cannot be said that section 2() of the Act (the RTI Act encompasses the personal information of the officials of the public authority. The intention of the legislation is 10 provide right to information to a citizen pertaining to public affairs of the public autbority". Further, I note that the Hon'ble CIC, in the matter of Prerit Misra vs, CPIO, SEBI (order dated November 21, 2022) held that- "It is pertinent to mention here that the appellant in a similar case which was dealt in File no. CIC SEBIE/A/2019/660770 dated 10.08.2021 whereby he had sought information Page 13 of 37 regarding the names of the officers who had blocked bis email address, the Commission, while passing an order had held that such information is exempted u/s 8(1)(g) & 8(1)(j) of the RTI Act. The Commission after considering the submissions of the appellant finds no merit in his case, and alto is in agreement with the order of the FAA and concludes that the information is exempt u/s 8(1)(g) & 8(1)(j) of the RTI Act, hence, no relief can be given." In view of these observations, I find that the requested information is exempt from disclosure under sections 8(1)(a), 8(1)(g) and 8(1)(j) of the RTT Act.
Aggrieved with the FAA's order, the Appellant approached the Commission with the instant Second Appeal dated 22.03.2023.
2.3. The appellant's representative Mr. Amit Gupta remained present through video conference and on behalf of the respondent Mr. Santosh Kumar Sharma, CPIO and Mr. Mohd. Atif Alvi, General Manager attended the hearing through video conference.
2.4. The appellant's representative inter alia submitted that they primarily sought detailed information regarding several aspects of SEBI's (Securities and Exchange Board of India) operations. Specifically, the application asks for certified copies of communication related to the appointment of Mr. Manjesh Roy Stephen as General Manager in place of Mr. Prasad Jagadale, details of penalties or de-empanelment actions against two entities (CIEL Learning Foundation and Ambition Learning Solutions), and information about show cause notices, warning letters, suspension letters, or termination letters issued to employees in the Investor Awareness Division of SEBI. The main grievance of the complainant is the alleged illegal refusal or denial of this information by the Respondent authority, which he claimed is done with malafide intentions. He stated that Mr. Prasad Jagadale was the in charge and later on when he died it was not intimated, rather his email id was active to receive all the communication from SMART's, it was not informed that new in-charge Mr. Manjesh Roy has been appointed, hence he required copy of intimation letter if, any.Page 14 of 37
2.5. The respondent while defending their case inter alia submitted that the Appellant had sought certain information regarding certified copies pertaining to the letter issued by SEBI to individual organizations. It is categorically informed that no such letter was issued. Further certain information sought by the appellant is not very specific and clear.
The information pertaining to appointment, transfers are internal communication of SEBI etc. When queried by the Commission regarding point No. 3, he informed that the information is strategic in nature as they are performing a work which is related to economic security of the country. Therefore, internal functioning information cannot be divulged. Moreover, the information sought being the related to the employees working with SEBI cannot be furnished being a third-party information.
2.6. The Commission after adverting to the facts and circumstances of the case, hearing both parties and perusal of records, observes that during the hearing the Respondent has accurately denied the information being non-specific and pertaining to third-party. Therefore, the Commission finds no scope of intervention in the matter. With this observation, the appeal is dismissed.
Second Appeal No. CIC/SEBIH/A/2023/615072
3. The Appellant filed an RTI application dated 22.09.2022 seeking information on the following points:
(i) Provide two certified hard copies of information from your records, pertaining to the SEBI Operational Guidelines on Securities Market Trainers (SMARTs) issued in the year 2020. Mention the applicability/validity of this operational guideline (from DD/MM/YYYY to DD/MM/YYYY format).
(ii) Provide two certified hard copies of information from your records, pertaining to the SEBI Operational Guidelines on Securities Market Trainers (SMARTs) amended as on August 18, 2021. Mention the applicability/validity of this operational guideline (from DD/MM/YYYY to DD/MM/YYYY format).Page 15 of 37
(iii) Provide two certified hard copies of information from your records, pertaining to the employees' name with designation, address, contact number and email id in the hierarchy wise (From First Level to End Level) for escalating complaints to resolve pertaining to Investor Awareness Programs (IAPs) conduct by SMARTs.
(iv) Provide two certified hard copies of information pertaining to the details (name of employee/s, address, contact numbers, email ids etc.) of complaint handling higher authority against dissatisfying with SEBI actions (pertaining to IAPs-
SMART matters of SEBI).
3.1. The CPIO replied vide letter dated 18.10.2022 and the same is reproduced as under:-
Reply to query (i):
You may refer to SEBI Operational Guidelines on Securities Market Trainers (SMARTs) made effective from September 9, 2020 till August 31, 2021, the copy of which will be available on payment of fees as prescribed under the RTI Act 2005.
Reply to query (ii):
The information sought by you is available on SEBI Investor Website at https://investor.sebi.gov.in/join-us/smrtspanel.html.
Reply to queries (iii & iv):
The details of the employees in the Investor Awareness Division of SEBI are available on the SEBI website at https://www.sebiweb/home/directory-of- sebi.jsp.
3.2. Dissatisfied with the response received from the CPIO, the Appellant filed a First Appeal dated 22.11.2022 alleging that the information provided was incomplete, false and misleading. The FAA vide order dated 20.12.2022 upheld the reply given by the CPIO.Page 16 of 37
I have perused the queries and the response provided thereto. On consideration, I find that the answer to such queries can be found out by the appellant by accessing the information available on the SEBI website which is in the public domain. Further, if the relevant information is already available in the public domain, the same cannot be said to be information held by the public authority and consequently there is no obligation to provide such information to an applicant under the RTT Act. In view of these observations, I find that the respondent cannot be obliged to research information which is already available in the public domain and then provide the same to the appellant. Notwithstanding the same, I note that the respondent has adequately guided the appellant to refer to the SEBI website where the relevant details regarding SEBI employees posted in the Investor Awareness Division of SEBI, is disclosed by SEBI. Accordingly, I do not find any deficiency in the response.
Aggrieved with the FAA's order, the Appellant approached the Commission with the instant Second Appeal dated 22.03.2023.
3.3. The appellant's representative Mr. Amit Gupta remained present through video conference and on behalf of the respondent Mr. Santosh Kumar Sharma, CPIO and Mr. Mohd. Atif Alvi, General Manager attended the hearing through video conference.
3.4. The appellant inter alia submitted that the information sought is not available on the link provided by the Respondent authority.
3.5. The respondent while defending their case inter alia submitted that SEBI Investor website link has been provided to the Appellant. The respondent assured to assist the Appellant in case he visits their office 3.6. The Commission after adverting to the facts and circumstances of the case, hearing both parties and perusal of records, advises the Respondent to assist the Appellant in browsing the website to get the information sought in the RTI Application. In case, the information is not available on the website, the Respondent is directed to provide the copy Page 17 of 37 of information free of cost to the appellant within 30 days of the receipt of this order, under intimation to the Commission. With this direction, the appeal is disposed of.
Second Appeal No. CIC/SEBIH/A/2023/615030
4. The Appellant filed an RTI application dated 22.09.2022 seeking information on the following points:
(i) Provide two certified hard copies of the details of Investor Awareness Programs (IAPs) sessions conducted by SEBI Individual SMART (Mr. Amit Gupta, location
- Thane) in the below mentioned format (recommended):
Sr. Date AP Name Total Stat Provide Provide the Provi SEBI Nam Doe No of IAP Sche of the duratio us of the claim date on de the Invigil e of s the (DD- dule topic of n of the 'Co amount which date ator the Secu MMY d IAP IAP mpli credited( complaint/g on prese admi ritie YYY) Time session ance paid) rievance which nce nistr s conduct ' date by raised by compl status ator Mar ed. with SEBI in SMART (Mr aint/g (name who ket (HH:M the the SEBI Amit Gupta) rievan , has Trai M) Ope Empanel pertaining ce design start ner ratio led to the claim resolv ation, ed (SM nal SMART's settlement ed time the ART Guid bank process and which & Cisc ) eline account amount was durati o cont s on against raised on) Web rol Secu each IAP by ex the ritie session SMAR onli parti s wise. T (Mr ne cipa Mar Amit webi nts ket Gupta nar? to Trai ) join Page 18 of 37 ners pertai (ente (SM ning r in) ART to the the
s). claim parti Kind settle cula ly ment r ment proce IAP ion ss and sessi Com amou on?
plia nt (Yes/
nce No)
or
Non-
Com
plia
nce
for
each
IAP
sessi
on
wise.
1 30- 11:0 - - - - - - - -
11- 0
2020 AM
2 06- 11:0 - - - - - - - -
12- 0
2020 AM
Page 19 of 37
3 11- 4:00 - - - - - - - -
12- PM
2020
4 12- 6:00 - - - - - - - -
12- PM
2020
5 18- 4:00 - - - - - - - -
12- PM
2020
- - - - - - - - - -
- - - - - - - - - -
234 30- 11:0 Amit - - - - - - - -
09- 0 Gupta
2021 AM
etc.
(ii) Provide the Full Video Recordings, Participants Registrations and Chat Box
Messages information pertaining to all the above mentioned 234 online Investor Awareness Programs (IAPs) Webinar conducted by the SMART (Mr. Amit Gupta from Thane location). You can provide these details in a Pen Drive/ Storage Disk.
4.1. The CPIO replied vide letter dated 18.10.2022 and the same is reproduced as under:-
Reply to queries i & ii:
The information sought relates to personal information of SMART, the disclosure of which has no relationship to any public activity or interest and may cause unwarranted invasion into the privacy of the individual and may also Page 20 of 37 endanger the life or physical safety of the person(s). The same is, therefore, exempt in terms of Section 8(1) (g) and 8(1)(j) of the RTI Act, 2005.
4.2. Dissatisfied with the response received from the CPIO, the Appellant filed a First Appeal dated 22.11.2022 alleging that the information provided was incomplete, false and misleading. The FAA vide order dated 21.12.2022 upheld the reply given by the CPIO.
I have perused the queries and the response provided thereto. I note that the respondent denied disclosure of the requested information in terms of Section 8(1)(g) and 8(1)(j) of the RTI Act as the same pertains to personal information of a SMART. In this contest, reference is made to the judgment of the Hon'ble Supreme Court of India in the matter of Central Public Information Officer, Supreme Court of India Vs. Subhash Chandra Agarwal in Civil Appeal No. 10044 of 2010 with Civil Appeal No. 10045 of 2010 and Civil Appeal No. 2683 of 2010 judgement dated November 13, 2019) wherein the import of "personal information" envisaged under Section 8(1)() of RTT Act has been exemplified in the context of earlier ratios laid down by the same Court in other matter(s). The Hon'ble Supreme Court held that: "59. Reading of the aforesaid judicial precedents, in our opinion, would indicate that personal records, including name, address, physical, mental and psychological status, marks obtained, grades and answer sheets, are all treated as personal information. Similarly, professional records, including qualification, performance, evaluation reports, ACR, disciplinary proceedings, etc. are all personal information, medical records, treatment, choice of medicine, list of hospitals and doctors visited, findings recorded, including that of the family members, information relating to assets, liabilities, income tax returns, details of investments, lending and borrowing et, are personal information. Such personal information is entitled to protection from unwarranted invasion of privacy and conditional access is available when stipulation of larger public interest is satisfied. This list is indicative and not exhaustive." In view of these observations, I agree with the response of the respondent that the requested information relates to personal information of third Page 21 of 37 parties, the disclosure of which has no relationship to any public activity or interest and may cause unwarranted invasion into the privacy of the individual and may also endanger the life or physical safety of the person(s). Accordingly, no further intervention is warranted at this stage.
Aggrieved with the FAA's order, the Appellant approached the Commission with the instant Second Appeal dated 22.03.2023.
4.3. The appellant's representative Mr. Amit Gupta remained present through video conference and on behalf of the respondent Mr. Santosh Kumar Sharma, CPIO and Mr. Mohd. Atif Alvi, General Manager attended the hearing through video conference.
4.4. The appellant inter alia submitted that the information sought related to Mr. Amit Gupta and that the Respondent did not ask Mr. Amit Gupta whether he wanted to provide or deny the information as per Sec 11 of the RTI Act.
4.5. The respondent while defending their case inter alia submitted that the Appellant had asked certified copies of the details of investor awareness sessions conducted by Mr. Amit Gupta, and to provide the full video recording. Since Smt. Kusum Gupta nowhere clarified her relationship with Mr. Amit Gupta in the RTI Application, hence the information was denied being a third-party detail, claiming the exemptions of Section 8(1)(g) and (j).
4.6. The Commission after adverting to the facts and circumstances of the case, hearing both parties and perusal of records, observes that it is the discretion of the Respondent to get consent of the third-party concerned for divulging information or not. The information being correctly denied under Section 8 (1)(g) and (j) of the RTI Act, the Commission finds no scope of intervention in the matter. With this observation, the appeal is dismissed.
Second Appeal No. CIC/SEBIH/A/2023/615031
5. The Appellant filed an RTI application dated 22.09.2022 seeking information on the following points:
Page 22 of 37(i) Provide a certified hard copy of the information pertaining to all the documents (as per the empanelment guidelines/requirements) submitted during the empanelment process (including selection remarks, evaluation, notifications and communication by SEBI/NISM team) in the year 2020 by Organization category SEBI recognized SMARTs. The list of Recognized Organization SMARTs is available on https://investor.sebi.gov.in/recognized-smart-organization.html.
(ii) Provide a certified hard copy of the information pertaining to the signed empanelment letter by all Recognized Organization SMARTs.
(iii) Provide two certified hard copies of information pertaining to all the emails/letters issued/communicated by SEBI officials of the Investor Awareness Division, Office of Investor Assistance and Education (IAD-OIAE) to SMARTs pertaining to amendments/ changes in the Operational Guidelines on Securities Market Trainers (SMARTs) during 01st Nov 2020 to till today.
(iv) Provide a certified hard copy of the information (for mentioned points (A) to (D)) from the first Operational Guidelines on Securities Market Trainers (SMARTs), applicable from September 2020 to August 2021, pertaining to:
(A) SEBI Invigilator role and frequency to visit etc. during an online IAP webinar session conducted by a Securities Market Trainer (SMART). (B) Settlement duration of claim reimbursement by SEBI for an online IAP webinar session conducted by a Securities Market Trainer (SMART). (C) Time period/days of resolution of a grievance raised by a Securities Market Trainer (SMART).
(D) Time period/days for communicating by SEBI to Securities Market Trainer (SMART) about analysis, review, compliance or non-compliance of an online IAP webinar session conducted by a Securities Market Trainer (SMART).Page 23 of 37
(v) Provide two certified hard copies of the IT audited reports (covering the period from 01 Nov 2020 to till today) of below mentioned email ids particular to employees of OIAE department of SEBI, Mumbai.
A. [email protected] B. [email protected] C. [email protected] D. [email protected] E. [email protected] F. [email protected] G. [email protected] 5.1. The CPIO replied vide letter dated 18.10.2022 and the same is reproduced as under:-
Reply to queries (i-iii):
The information sought by you relates to personal information of a SMART, the disclosure of which has no relationship to any public activity or interest and may cause unwarranted invasion into the privacy of the individual and may also endanger the life or physical safety of the person(s). The same is, therefore, exempt in terms of Section 8(1) (g) and 8(1)(j) of the RTI Act, 2005.
Reply to query (iv A-D):
Copy of the earlier Operational Guidelines made effective from September 9, 2020 till August 31, 2021 will be available on payment of fees under RTI Act 2005.
Reply to query (v):
SEBI does not conduct any audit with reference to user specific mailboxes. Hence no such information is available.Page 24 of 37
5.2. Dissatisfied with the response received from the CPIO, the Appellant filed a First Appeal dated 22.11.2022 alleging that the information provided was incomplete, false and misleading. The FAA vide order dated 21.12.2022 stated that:
I have perused the query and the response provided thereto. On consideration, I find that no respondent has adequately addressed the query by informing the appellant regarding non-availability of the requested information. Accordingly, I do not find any deficiency in the response.
Aggrieved with the FAA's order, the Appellant approached the Commission with the instant Second Appeal dated 22.03.2023.
5.3. The appellant's representative Mr. Amit Gupta remained present through video conference and on behalf of the respondent Mr. Santosh Kumar Sharma, CPIO and Mr. Mohd. Atif Alvi, General Manager attended the hearing through video conference.
5.4. The appellant's representative inter alia submitted that the Appellant had sought detailed information regarding the empanelment process and related documents for SEBI recognized Securities Market Trainers (SMARTs) from the year 2020. The main grievance of the Appellant is the alleged malafide denial of information by the Respondent, which he argues is unjustified as the requested information pertains to public records and does not infringe on any individual's privacy or safety.
5.5. The respondent while defending their case inter alia submitted that the Appellant had sought the certified copy of all the documents submitted during the empanelment process in the selection of SMART's and the same was denied being protected under third-
party and fiduciary information. Moreover, the Appellant had asked the information pertaining to all the documents without specifying any particular document, thus non- specific information cannot be divulged.
5.6. The Commission after adverting to the facts and circumstances of the case, hearing both parties and perusal of records, observes that the Respondent has appropriately denied the personal information related to the third party under Section 8(1)(j) of the RTI Act. In this regard, the attention of the Appellant is drawn towards a judgment of the Hon'ble Page 25 of 37 Supreme Court in the matter of Central Public Information Officer, Supreme Court of India Vs. Subhash Chandra Agarwal in Civil Appeal No. 10044 of 2010 with Civil Appeal No. 10045 of 2010 and Civil Appeal No. 2683 of 2010 wherein the import of "personal information" envisaged under Section 8(1)(j) of RTI Act has been exemplified in the context of earlier ratios laid down by the same Court in the matter(s) of Canara Bank Vs. C.S. Shyam in Civil Appeal No.22 of 2009; Girish Ramchandra Deshpande vs. Central Information Commissioner & Ors., (2013) 1 SCC 212 and R.K. Jain vs. Union of India & Anr., (2013) 14 SCC 794. The following was thus held:
"59. Reading of the aforesaid judicial precedents, in our opinion, would indicate that personal records, including name, address, physical, mental and psychological status, marks obtained, grades and answer sheets, are all treated as personal information. Similarly, professional records, including qualification, performance, evaluation reports, ACRs, disciplinary proceedings, etc. are all personal information. Medical records, treatment, choice of medicine, list of hospitals and doctors visited, findings recorded, including that of the family members, information relating to assets, liabilities, income tax returns, details of investments, lending and borrowing, etc. are personal information. Such personal information is entitled to protection from unwarranted invasion of privacy and conditional access is available when stipulation of larger public interest is satisfied. This list is indicative and not exhaustive..."
Having observed as above, the Commission finds no scope of relief to be ordered in the matter. The appeal is dismissed accordingly.
Second Appeal No. CIC/SEBIH/A/2023/615297
6. The Appellant filed an RTI application dated 22.09.2022 seeking information on the following points:
(i) Provide two certified hard copies of information from records pertaining to the letter number SEBI/HO/OIAE/IAD/P/OW/2022/09037/1 issued on 27th April Page 26 of 37 2022 by Assistant Manager, Investor Awareness Division, Office of Investor Assistance and Education, Tel No.: 022-26449964, Email: [email protected], pertaining to the subject - "Clarification required on non-compliances and irregularities while conducting Investor Awareness Programs."
(ii) Provide two certified copies of information pertaining to the response/ reply ( by email/ letter/oral communication/video recording/ etc.) received to SEBI pertaining to the letter number SEBI/HO/OIAE/IAD/P/OW/2022/09037/1 issued on 27th April 2022 by Assistant Manager, Investor Awareness Division, Office of Investor Assistance and Education, Tel No.: 022-26449964, Email:
[email protected], pertaining to the subject - "Clarification required on non- compliances and irregularities while conducting Investor Awareness Programs."
(iii) Provide two certified hard copies of information pertaining to the letter/notice issued to CIEL Learning Foundation, Mumbai (An Organization SMART) by Assistant Manager, Investor Awareness Division, Office of Investor Assistance and Education, Tel No.: 022- 26449964, Email: [email protected] during Feb-April, 2022 pertaining to the IAPs conducted (during October 2021 to January 2022), having Subject - "Clarification required on non-compliances and irregularities while conducting Investor Awareness Programs."
(iv) Provide two certified hard copies of information from record pertaining to the reply/response ( by email/ letter/oral communication/video recording/ etc.) received from CIEL Learning Foundation, Mumbai (A Recognized Organization SMART) against the letter/notice issued to CIEL Learning Foundation (A Recognized Organization SMARTs) by Ms Komal Mahajan, Assistant Manager, Investor Awareness Division, Office of Investor Assistance and Education, Tel No.: 022-26449964, Email: [email protected], during Feb-April, 2022 pertaining to the IAPs conducted (during October 2021 to January 2022), Page 27 of 37 subject - "Clarification required on non-compliances and irregularities while conducting Investor Awareness Programs."
6.1. The CPIO replied vide letter dated 18.10.2022 and the same is reproduced as under:-
Reply to queries (i & iii):
The information sought does not pertain to you and relates to personal information of a SMART, the disclosure of which has no relationship to any public activity or interest and may cause unwarranted invasion into the privacy of the individual and may also endanger the life or physical safety of the person(s). The same is, therefore, exempt in terms of Section 8(1) (g) and 8(1)(j) of the RTI Act, 2005 Reply to query (ii):
No reply was received from the person to whom the referred letter was addressed. Hence no such information is available with SEBI.
Reply to query (iv):
The information sought by you is available to SEBI in fiduciary capacity and there is no larger public interest involved in disclosure of the said information, hence is exempt u/s 8(1)(e) of RTI Act, 2005. Further, the information sought relates to personal information, the disclosure of which has no relationship to any public activity or interest and may cause unwarranted invasion into the privacy of the individual and may also endanger the life or physical safety of the person(s). The same is, therefore, exempt in terms of Section 8(1) (g) and 8(1)(j) of the RTI Act, 2005.
6.2. Dissatisfied with the response received from the CPIO, the Appellant filed a First Appeal dated 21.11.2022 alleging that the information provided was incomplete, false and misleading. The FAA vide order dated 16.12.2022 stated that:Page 28 of 37
I have perused the aforesaid query and the response provided thereto. I note that the requested information is available to SEBI in fiduciary capacity. In this context, I note that the Hon'ble High Court of Delhi, in Writ Petition (Civil) Nos. 8396/2009, 16907/2006, 4788/2008, 9914/2009, 6085/2008, 7304/2007, 7930/2009 and 3607 of 2007, (order dated November 30, 2009) held that the 'person' referred to in section 8(1) (¢) of the RTI Act will include a public authority. It also held that: "In a fiduciary relationship, the principal emphasis is on trust, and reliance, the fiduciary's superior power and corresponding dependence of the beneficiary om the fiduciary. It requires a dominant position, integrity and responsibility of the fiduciary to act in good faith and for the benefit of and to protect the beneficiary and not oneself". Further, I note that the Hon'ble CIC, in the matter of Manish Goel vs. CPIO, SEBI (order dated November 15, 2022), accepted the submission of SEBI that the requested information with respect to Inspection Advisers and Research Analysts was available to SEBI in fiduciary capacity and includes commercial confidential information. Further, in the said matter, the Hon'ble CIC disposed of the appeal with the observation that there was no ground to admit the second appeal. I find that SEBI, being the regulatory authority for the securities market, gets various references/documents from market participants and intermediaries and the information contained therein are received in fiduciary capacity. I, therefore, find that the requested information is exempt from disclosure under section 8(1)(e) of the RTI Act. Further, I note that the appellant has not established that the information is sought in larger public interest. Accordingly, I do not find any deficiency in the response.
Aggrieved with the FAA's order, the Appellant approached the Commission with the instant Second Appeal dated 21.03.2023.
6.3. The appellant's representative Mr. Amit Gupta remained present through video conference and on behalf of the respondent Mr. Santosh Kumar Sharma, CPIO and Mr. Mohd. Atif Alvi, General Manager attended the hearing through video conference.Page 29 of 37
6.4. The appellant's representative inter alia submitted that the Appellant had sought information related to a letter issued by SEBI on April 27, 2022, which pertains to clarifications on non-compliances and irregularities in conducting Investor Awareness Programs. The application requests detailed records and responses involving SEBI's communications with the CIEL Learning Foundation regarding these programs, which has not been provided by the Respondent.
6.5. The respondent while defending their case inter alia submitted that the appellant had sought personal information of SEBI's Assistant Manager along with certain clarifications and third-party information's, which has been point-wise denied.
6.6. The Commission after adverting to the facts and circumstances of the case, hearing both parties and perusal of records, observes that the Appellant had sought certain clarification and third-party details which cannot be provided as per the RTI Act. For better understanding of the mandate of the RTI Act, the Appellant shall note that outstretching the interpretation of Section 2(f) of the RTI Act to include deductions and inferences to be drawn by the CPIO is unwarranted as it casts immense pressure on the CPIOs to ensure that they provide the correct deduction/inference to avoid being subject to penal provisions under the RTI Act.
In this regard, the Appellant's attention is drawn towards a judgment of the Hon'ble Supreme Court on the scope and ambit of Section 2(f) of RTI Act in the matter of CBSE vs. Aditya Bandopadhyay & Ors.[CIVIL APPEAL NO.6454 of 2011] wherein it was held as under:
"35. At this juncture, it is necessary to clear some misconceptions about the RTI Act. The RTI Act provides access to all information that is available and existing.........A public authority is also not required to furnish information which require drawing of inferences and/or making of assumptions. It is also not required to provide `advice' or `opinion' to an applicant, nor required to obtain and furnish any `opinion' or `advice' to an applicant. The reference to `opinion' or `advice' in the definition of `information' in section 2(f) of the Act, only refers to such material available in the records of the public authority. Many public authorities have, as a Page 30 of 37 public relation exercise, provide advice, guidance and opinion to the citizens. But that is purely voluntary and should not be confused with any obligation under the RTI Act." (Emphasis Supplied) Having observed as above, the Commission finds no scope of relief to be ordered in the matter. The appeal is dismissed accordingly.
Second Appeal No. CIC/SEBIH/A/2023/614881
7. The Appellant filed an RTI application dated 22.09.2022 seeking information on the following points:
(i) Provide two certified hard copies of information pertaining to total numbers (in counts) of online investor awareness programs (IAPs) WEBINARs conducted/delivered under the aegis of SEBI-IPEF) by both Individual Category and Organization Category SEBI empanelled/recognized Securities Market Trainers (SMARTs) during period 24th November 2020 to 31st March 2022:
Full Category The District/Loc Numbe Numbe Numbe Numbe Numbe Numbe Name of a SMART ation of a r of r of r of r of r of r of of a SMART Empanel SMART IAPs IAPs IAPs in IAPs IAPs IAPs in SMA (Individua ment empanelmen conduct claims which conduc claims which RT l/ Number t ed (and fully SEBI ted and fully SEBI Organizat claims rejecte Official claims rejecte Official ion) submitt d (No s submitt d (No s ed) Payme present ed Payme present during nt) as during nt) as FY2020 during invigila FY202 during invigila
-21. (In FY tor 1-22. FY tor Figures 2020- during (In 2021- during ) 21. (In the IAP Figures 22. (In the IAP webina ) webina Page 31 of 37 Figure r Figure r
s) session s) session s in s in FY202 FY2021 0-21. -22. (In (In Figures Figures ) )
- - - - - - - - - -
(ii) Provide three certified hard copies of information pertaining to total numbers (in counts/ figures) of offline investor awareness programs (IAPs) conducted/delivered under the aegis of SEBI-IPEF) by both Individual Category and Organization Category SEBI empanelled Securities Market Trainers (SMARTs) during period 24th November 2020 to 31st March 2022:
Full Category SMART District of Number Numbe Numbe Number Numbe Number Name of a Empanelm a SMART of IAPs r of r of of IAPs r of of IAPs of a SMART ent empanelm conduct IAPs IAPs in conduct IAPs in SMA (Individual Number ent ed (and claims which ed and claims which RT / claims fully SEBI claims fully SEBI Organizati submitt rejecte Official submitt rejecte Official on) ed) d (No s ed d (No s during Payme present during Payme present FY2020 nt) as FY2021 nt) as
-21. (In during invigila -22. (In during invigila Figures FY tor Figures FY tor ) 2020- during ) 2021- during
21. (In the 22. (In the Page 32 of 37 Figure offline Figure offline
s) IAP s) IAP session sessions s in in FY202 FY2021 0-21. -22. (In (In Figures Figures ) )
- - - - - - - - - -
(iii) Provide three certified hard copies of information pertaining to total numbers (in counts/ figures) of offline investor awareness programs (IAPs) conducted/delivered under the aegis of SEBI-IPEF) by both Individual Category and Organization Category SEBI empanelled Securities Market Trainers (SMARTs) during period 01st April 2022 to 19th September 2022 (or till today of the RTI reply):
Full Category SMART District of Number Numbe Numbe Number Numbe Number Name of a Empanelm a SMART of IAPs r of r of of IAPs r of of IAPs of a SMART ent empanelm conduct IAPs IAPs in conduct IAPs in SMA (Individual Number ent ed (and claims which ed and claims which RT / claims fully SEBI claims fully SEBI Organizati submitt rejecte Official submitt rejecte Official on) ed) d (No s ed d (No s during Payme present during Payme present FY2020 nt) as FY2021 nt) as
-21. (In during invigila -22. (In during invigila FY tor FY tor Page 33 of 37 Figures 2020- during Figures 2021- during ) 21. (In the ) 22. (In the Figure offline Figure offline
s) IAP s) IAP session sessions s in in FY202 FY2021 0-21. -22. (In (In Figures Figures ) )
- - - - - - - - - -
(iv) Kindly provide information pertaining to the details of Indian Panel Code (IPC) section applicable, if your information is false.
(v) Kindly provide information pertaining to the details of criminal/civil Indian Panel Code (IPC) section applicable, if the delay/denial into providing information with malicious intention.
7.1. The CPIO replied vide letter dated 18.10.2022 and the same is reproduced as under:-
Reply to queries i-ii:
The approximate Investor Awareness programs conducted by SMARTs during the period November 24, 2020 to March 31, 2022 till August 2022 is given below:-
SMARTs Online Offline Individual 1446 207 Page 34 of 37 Organization 349 82 Reply to query iii:
The approximate Investor Awareness programs conducted by SMARTs during the period 1st April, 2022 to 19th September, 2022 is given below:-
SMARTs Online Offline Individual 1 380 Organization 349 318 Reply to iv & v:
The information sought is not available with SEBI.
7.2. Dissatisfied with the response received from the CPIO, the Appellant filed a First Appeal dated 22.11.2022 alleging that the information provided was incomplete, false and misleading. The FAA vide order dated 21.12.2022 stated that:
I have perused the queries and the response provided thereto. I note that the appellant has informed regarding non-availability of the requested information. On consideration, I find that the queries of the appellant are more in the nature of seeking clarification/opinion from the respondent. I note that the respondent is not supposed to create information; or to interpret information; or to furnish clarification to the appellant under the ambit of the RIT Act. I find that the said query cannot be construed as seeking 'information' as defined under section 2 (6) of the RTI Act. Consequently, the respondent did not have an obligation to provide such clarification or opinion under the RTI Act. Accordingly, no further intervention is warranted at this stage.
Aggrieved with the FAA's order, the Appellant approached the Commission with the instant Second Appeal dated 22.03.2023.
Page 35 of 377.3. The appellant's representative Mr. Amit Gupta remained present through video conference and on behalf of the respondent Mr. Santosh Kumar Sharma, CPIO and Mr. Mohd. Atif Alvi, General Manager attended the hearing through video conference.
7.4. The appellant inter alia submitted that incomplete information has been provided by the Respondent.
7.5. The respondent while defending their case inter alia submitted that the Appellant had sought certified copies of information pertaining to numbers of online and offline investor awareness programs, accordingly the numbers have been provided. He clarified that the information on point No 4 and 5 is not available.
7.6. The Commission after adverting to the facts and circumstances of the case, hearing both parties and perusal of records, observes that the Respondent has provided an appropriate reply to the RTI Application. Therefore, the Commission finds no scope of intervention in the matter. With this observation, the appeal is dismissed.
Copy of the decision be provided free of cost to the parties.
Sd/-
आनंदी राम लंगम)
(Anandi Ramalingam) (आनं म
सूचना आयु )
Information Commissioner (सू
दनांक/Date: 26.06.2024
Authenticated true copy
Col S S Chhikara (Retd) कन ल एस एस िछकारा, ( रटायड ) Dy. Registrar (उप पंजीयक) 011-26180514 Addresses of the parties:
1. The CPIO Securities and Exchange Board of India, Nodal CPIO, RTI Cell, Sebi Bhawan, Plot No.C4-A, "G" Block, Bandra-Kurla Complex, Bandra-East, Mumbai-400051
2. Kusum Gupta Page 36 of 37 Annexure of Second Appeals Sl. No. Second Appeal No.
1. CIC/SEBIH/A/2023/616672
2. CIC/SEBIH/A/2023/615295
3. CIC/SEBIH/A/2023/615072
4. CIC/SEBIH/A/2023/615030
5. CIC/SEBIH/A/2023/615031
6. CIC/SEBIH/A/2023/615297
7. CIC/SEBIH/A/2023/614881 Page 37 of 37 Recomendation(s) to PA under section 25(5) of the RTI Act, 2005:-
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