The Securities and Exchange Board of India’s Appellate Authority under the Right to Information Act has dismissed an appeal filed by Prince Pravin Naiya concerning information related to Credila Financial Services Limited.
The appellant had sought details of material-event disclosures, trustee compliance certificates and any inquiry into the accuracy of data allegedly provided by Credila to credit-rating agencies.
In its order dated September 16, 2026, the appellate authority found no deficiency in the response originally provided by SEBI’s Central Public Information Officer, or CPIO.
The authority observed that part of the request was vague because it did not identify the specific listed security concerned. It further noted that disclosures under the relevant provisions of the SEBI Listing Obligations and Disclosure Requirements Regulations are filed with stock exchanges rather than directly with SEBI.
For the remaining request, the CPIO had stated that the securitisation transactions referred to in the application did not fall within the identified SEBI regulatory framework and that no related information was available in SEBI’s records.
What Information Was Requested?
The appellant filed an RTI application on August 1, 2026. SEBI received it through its RTI Management Information System portal and issued a response on August 17.
The subsequent appeal, dated August 18, challenged the responses to queries 3 and 4 of the original application.
In query 3, the appellant requested information concerning compliance by Credila Financial Services Limited with Regulations 30, 51 and 56 of the SEBI LODR Regulations.
The request included:
- Details of material-event disclosures concerning alleged regulatory non-compliances or show-cause notices issued by the Reserve Bank of India
- Copies of compliance certificates reportedly submitted by trustees
- Information regarding verification of the underlying loan assets held by Credila
In query 4, the appellant asked whether SEBI’s Market Intermediaries Regulation and Supervision Department had conducted any inquiry into the accuracy of loan-default and delinquency data provided by Credila to credit-rating agencies.
The rating agencies named in the application included CRISIL, ICRA, CARE Ratings and India Ratings.
Why SEBI Called Part of the Request Vague
The CPIO informed the appellant that the information requested under query 3 did not identify the specific listed security to which the request related.
This distinction can be important where a company has issued different listed instruments, including multiple series of debt securities. Disclosures, trustee reports and supporting compliance records may be linked to particular securities, stock-exchange filings or reporting periods.
The appellate authority agreed that the request was vague and insufficiently specific.
Under the RTI framework, an applicant must generally identify existing information with enough clarity to allow the public authority to locate the relevant records. A broad request that requires officials to determine what the applicant may have intended can fall outside the scope of a straightforward records request.
The order referred to a Central Information Commission decision in Naresh Kadyan v. CPIO, which observed that vague and indeterminate queries do not conform to the definition of information under Section 2(f) of the RTI Act.
The authority also highlighted that a CPIO is not required to create deductions or draw inferences on behalf of an applicant.
LODR Disclosures Are Filed With Stock Exchanges
The CPIO provided an additional clarification despite finding that the request lacked specificity.
Material-event disclosures under Regulations 30 and 51 of the SEBI LODR Regulations are required to be filed by listed entities with the concerned stock exchanges. Such disclosures are not necessarily submitted to SEBI as the primary filing destination.
Regulation 30 principally concerns disclosure of material events or information by specified listed entities, while Regulation 51 applies to disclosures by entities with listed non-convertible securities, subject to the applicable regulatory framework.
Accordingly, the CPIO advised that relevant disclosures could be accessed through the websites of the concerned stock exchanges.
The appellate authority accepted this response and held that no further intervention was required.
The finding offers an important practical lesson for researchers and investors: the regulator is not always the correct first source for every market disclosure. Depending on the nature of the information, the relevant record may be held by:
- The listed entity
- BSE or the National Stock Exchange
- A debenture trustee
- A credit-rating agency
- A depository
- Another sectoral regulator
An RTI request addressed to SEBI cannot compel it to provide a record that is maintained or published through a different institution unless that record is also available with SEBI.
Why No Information Was Available for Query 4
The appellant’s fourth query concerned whether SEBI had investigated the accuracy of loan-default and delinquency data allegedly supplied to rating agencies for pass-through certificate ratings.
The CPIO responded that the SEBI (Issue and Listing of Securitized Debt Instruments and Security Receipts) Regulations, 2008 did not apply to the securitisation transactions identified in the application.
The CPIO further stated that these transactions did not fall under SEBI’s purview and that no requested information was available with the regulator.
The appellate authority accepted the response. It relied upon the principle that a public authority can only disclose information that exists and is available in its records.
The order referred to the Supreme Court’s decision in Central Board of Secondary Education v. Aditya Bandopadhyay. The judgment clarified that the RTI Act provides access to existing information but does not require a public authority to collect, collate or create information that it does not maintain.
Therefore, if SEBI had no record of the requested inquiry, the CPIO was not required to conduct fresh research, obtain material from another body or prepare an analysis specifically for the applicant.
RTI Proceedings Cannot Decide Whether an Answer Is Correct
The appellant challenged the CPIO’s response on the ground that the information supplied was incomplete, misleading or false.
However, the appellate authority held that a disagreement concerning the correctness of a response cannot ordinarily be adjudicated as a substantive dispute through RTI proceedings.
The order cited the Delhi High Court’s decision in Narendra Tyagi v. Assistant Director (CPIO). That decision explained that the CPIO’s responsibility is to provide information or documents available within the public authority’s access.
The RTI forum is not designed to determine broader controversies about whether an official position is legally or factually correct.
If an applicant believes that a transaction falls within a regulator’s jurisdiction, that underlying jurisdictional disagreement may need to be raised through an appropriate regulatory representation, complaint or legal proceeding. It cannot automatically be resolved merely by disputing the CPIO’s response in an RTI appeal.
What the Dismissal Does—and Does Not—Mean
The appellate authority concluded that there was no need to interfere with the CPIO’s decision and dismissed the appeal.
This order should not be interpreted as a finding regarding the accuracy of Credila’s loan data, the existence of any regulatory non-compliance or the merits of any disclosure concern.
The decision was limited to whether SEBI’s CPIO had adequately responded to the information request under the RTI Act.
The authority determined that the disputed queries were vague, related partly to records filed with stock exchanges and sought other information that was not available with SEBI.
How to Draft a More Effective RTI Application
The order illustrates why precision matters when seeking financial or regulatory information.
An effective application should identify:
- The exact company and listed security
- The ISIN or security series, where available
- The relevant stock exchange
- The precise reporting period
- The regulation or filing being requested
- The date or reference number of any notice
- The specific document believed to exist
- The department likely to hold the record
Applicants should also search publicly available stock-exchange filings before submitting an RTI request. If the information is already published online, directing the applicant to the relevant public source may be considered an adequate response.
The Larger Takeaway
The RTI Act provides access to existing government records; it is not a mechanism for asking regulators to conduct fresh investigations, interpret unclear questions or decide wider disputes.
In securities-market matters, information is distributed across several institutions. The success of a request often depends on first identifying which authority actually holds the relevant document.
Clear drafting, specific security details and prior review of public filings can significantly improve the quality of the response and reduce the risk of an appeal being dismissed.
Shunyatax Global Insights
Regulatory-information requests should form part of a broader compliance and due-diligence process. Before approaching SEBI under the RTI Act, businesses and investors should review stock-exchange disclosures, trustee reports, rating rationales, offer documents and company filings.
If an apparent disclosure gap remains, the request should identify the exact record and its expected custodian. A separate regulatory complaint may be more appropriate where the objective is to seek an investigation rather than obtain an existing document.
If you or your business is facing problems involving an RTI application, SEBI disclosure review, listed-debt compliance, regulatory due diligence or financial-documentation gaps, Shunyatax Global can provide professional guidance to help you move forward with clarity and confidence.
Contact Shunyatax Global
Phone: +91 94615 14198
Email: office@shunyatax.in
Website: www.shunyatax.in
Disclaimer: This article is based on SEBI Appellate Authority Order No. 7053 of 2026 dated September 16, 2026. The order concerns the adequacy of an RTI response and does not make findings regarding any underlying allegation against Credila Financial Services Limited. This content is intended for general information and does not constitute legal, tax, investment or financial advice.