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Supreme Court of India 2022-02-18 allowed

T. Takano vs Securities and Exchange Board of India & Anr

Bench: 2 — Dhananjaya Y. Chandrachud, Sanjiv Khanna

In Brief

T. Takano, former MD & CEO of Ricoh India, challenged a show cause notice issued by SEBI for alleged fraudulent and unfair trade practices. The central issue was whether SEBI must disclose its investigation report to the notice-holder. The High Court held the report was internal and need not be disclosed. The Supreme Court reversed this, holding that since Regulation 10 of the PFUTP Regulations mandates the Board consider the investigation report before determining violations, principles of natural justice require disclosure. However, the Court balanced this against third-party privacy and market stability, permitting redaction of sensitive information with written reasons. The Court directed SEBI to disclose relevant portions within one month and grant the appellant opportunity to respond before final decision.

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Securities Law Administrative Law Procedural Justice Natural Justice Disclosure SEBI Regulations

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