Renowned RTI activist Shri Subhash Chandra Aggarwal has filed a detailed Right to Information (RTI) application with the Securities and Exchange Board of India (SEBI), raising pointed questions over the opaque decision-making process behind a potentially significant regulatory reform—Successive Nominations in DEMAT accounts.
The move stems from a 48-page internal SEBI document titled “Amendments in Regulations to Revise and Revamp Nomination Facilities in the Indian Securities Market”, submitted during CIC hearing CIC/SEBIH/A/2025/112459. The document revealed that of four entities consulted on the proposal, two supported and two opposed it—while SEBI itself backed the reform.
Key Information Sought Under RTI by Subhash Chandra Aggarwal
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Disclosure of Support and Opposition
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Names of the two entities that supported and two that opposed the proposal.
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Selection Criteria for Consultation
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Complete transparency on how SEBI selected the four entities consulted.
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Includes request for internal documents, file notings, and related communication.
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Post-Consultation Action
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Details of any follow-up action taken by SEBI after receiving feedback.
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Includes internal memos, correspondence, and updates on implementation.
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Decision-Making Authority
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Clarity on who within SEBI holds final decision-making power to approve or shelve such regulatory amendments.
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RTI File Movement Tracking
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Request for all records detailing internal movement of the RTI file within SEBI’s system.
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Broader Implications: Investor Protection and Regulatory Transparency
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The question of successive nominations is not merely administrative—it impacts:
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Investor succession planning
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Legal clarity for heirs
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Efficiency in ownership transfer, especially in cases where multiple nominees pass away
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The issue gained urgency in the post-COVID scenario, where unexpected deaths highlighted the need for succession clarity.
Concerns Raised:
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Why only four entities?
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What were the selection parameters?
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If SEBI supported the idea, why is it stalled?
These concerns point toward possible procedural gaps and demand greater transparency from India’s capital markets regulator.
Special Note: The Spirit of RTI and Prime Minister Modi’s Words
Shri Aggarwal has anchored his RTI appeal in the spirit of transparency championed by Prime Minister Narendra Modi, who during the inauguration of the new CIC building in 2018, stressed that authorities must uphold both the letter and spirit of the RTI Act.
“Public institutions must be proactive, transparent, and responsive,” the Prime Minister emphasized during the CIC Annual Convention in 2015 as well.
This RTI plea is a reminder of that commitment, aiming to ensure that crucial regulatory decisions are made openly, accountably, and inclusively.
The proposal on Successive Nominations in DEMAT accounts could significantly ease succession hurdles for investors. But unless SEBI reveals its process transparently, questions will persist about regulatory opacity and stakeholder exclusion.
As India deepens its financial inclusion, investor rights and systemic transparency must move hand-in-hand.
