के (cid:574)ीय सूचना आयोग Central Information Commission बाबा गंगनाथ माग१,मुिनरका

Baba Gangnath Marg, Munirka नई िद(cid:671)ी, New Delhi – 110067 ि(cid:554)तीय अपील संূा / Second Appeal No. CIC/SEBIH/A/2024/646269 Mohit Bansal … अपीलकता१/Appellant VERSUS बनाम CPIO: Securities And Exchange Board …ঋितवादीगण/Respondents Of India, Mumbai Relevant dates emerging from the appeal:

RTI : 09.09.2024 FA : 24.09.2024 SA : 18.10.2024 CPIO : 20.09.2024 FAO : 17.10.2024 Hearing : 28.10.2025 Date of Decision: 31.10.2025 CORAM:

Hon’ble Commissioner _ANANDI RAMALINGAM O R D E R

1. The Appellant filed an RTI application dated 09.09.2024 seeking information on the following points:

1. SEBI Policies and Procedures:

Please provide details regarding current policies or guidelines followed by SEBI in place for identifying, investigating, and addressing stock market manipulation. This includes:

- Mechanisms for surveillance of unusual price movements.

- Procedures for addressing complaints of stock price manipulation.

- Tools and technologies used for market surveillance.

2. Specific Guidelines for Conflict of Interest and Fund Manipulation:

Please provide documentation on the procedures or frameworks in place to detect and address conflicts of interest, fund rotation, or other financial irregularities involving company stakeholders.

3. Internal Process for Handling Investor Complaints:

Please provide a step-by-step outline of the process SEBI follows upon receiving a complaint or grievance related to stock manipulation, such as the investigation timeline and enforcement actions.

2. The CPIO replied vide letter dated 20.09.2024 and the same is reproduced as under :-

“The information sought by you pertains to the internal functioning of SEBI and relates to the systems and procedures followed at SEBI. Further, the said information is strategic in nature, disclosure of which may result in revealing the mind of the regulator and may hamper the decision making by SEBI in its supervisory and regulatory role. In view of the same, the information sought by you is exempt u/s 8(1)(a) of the RTI Act, 2005.

Further, investigation timelines and enforcement actions, depend upon facts and/or circumstances of each case. Regulatory action, if any, taken by SEBI, is available in public domain, on SEBI website www.sebi.gov.in under the head: Enforcement. You may like to refer to this website for updated information from time to time.”

3. Dissatisfied with the response received from the CPIO, the Appellant filed a First Appeal dated 24.09.2024 alleging that the information provided was incomplete, false and misleading. The FAA vide order dated 17.10.2024 upheld the reply given by the CPIO.

4. Aggrieved with the FAA’s order, the Appellant approached the Commission with the instant Second Appeal dated 18.10.2024.

5. The appellant and on behalf of the respondent Pranjal Jaiswal, CPIO, attended the hearing through video conference.

6. The appellant inter alia submitted that the invocation of Section 8(1)(a) by SEBI is unjustified. He contended that the information requested pertains to SEBI’s public regulatory activities, which are crucial for ensuring market integrity. The term "strategic" in this context does not align with the exemptions provided under Section 8(1)(a), which primarily concern matters of national security or economic stability. He relied upon the Hon'ble Supreme Court’s verdict in “Central Board of Secondary Education v. Aditya Bandopadhyay” [(2011) 8 SCC 497] wherein it has been held that transparency should be the norm, especially in cases where public interest is involved. In this case, the information requested does not endanger SEBI’s supervisory role but would, in fact, enhance public confidence in its functioning by promoting transparency.

7. The respondent while defending their case inter alia relied upon their additional written submissions dated 10.10.2025, extracted below:

“The respondent, in response to the application had informed the appellant that the informatio