Archive · 28 Sep 2026
SAT Disposes Five FPI Appeals After SEBI Agrees Disclosure
Five foreign investment funds had appealed against how SEBI handled a regulatory inquiry.
They wanted to see the full document explaining why the inquiry could continue.
SEBI had earlier given them only a shortened version of that document.
At the hearing, SEBI agreed to provide a true copy of the file noting.
The funds said they were satisfied with this agreement.
Because of that, SAT said there was nothing left to decide in the appeals.
The tribunal did not decide whether the funds had done anything wrong.
It also did not rule on the wider regulatory investigation involving Adani Group companies.
SAT disposed appeals by five FPIs named in the Hindenburg Research report on the Adani Group.
SEBI agreed to provide the FPIs a true copy of the Rule 4(3) file noting.
The FPIs had sought the complete opinion and reasons for proceeding against them.
SEBI had previously provided only a paraphrased extract and disputed whether the opinion was challengeable.
SAT made no findings on the FPIs’ conduct or the underlying Adani-related regulatory proceedings.
- Who
- The Securities Appellate Tribunal, SEBI, and five FPIs: Albula Investment Fund, Asia Investment Corporation (Mauritius), LTS Investment Fund, Cresta Fund, and APMS Investment Fund.
- What
- SAT disposed of five appeals after SEBI agreed to share a true copy of the Rule 4(3) file noting.
- When
- Monday, in proceedings published on September 28, 2026.
- Where
- Before the Securities Appellate Tribunal.
- Why
- The FPIs sought the complete opinion and reasons underlying SEBI’s decision to proceed against them.
Foreign Portfolio Investors
Securities Regulator
Disclosure of the Rule 4(3) opinion
Foreign Portfolio Investors
The FPIs sought the complete opinion and the reasons underlying the decision to proceed against them, rather than only a paraphrased extract.
Securities Regulator
SEBI agreed to provide a true copy of the adjudicating officer’s file noting, while reserving its rights and contentions.
Whether the opinion could be challenged
Foreign Portfolio Investors
The FPIs brought appeals challenging the manner in which SEBI provided the Rule 4(3) opinion.
Securities Regulator
SEBI maintained that the Rule 4(3) opinion was not an order and could not itself be challenged before SAT.
- Appellants
- Albula Investment Fund, Asia Investment Corporation (Mauritius), LTS Investment Fund, Cresta Fund, and APMS Investment Fund
- Regulator
- Securities and Exchange Board of India
- Relevant provision
- Rule 4(3) of the SEBI (Procedure for Holding Inquiry and Imposing Penalties) Rules, 1995
- SEBI’s undertaking
- To provide a true copy of the adjudicating officer’s file noting
- Earlier disclosure
- SEBI had provided a paraphrased extract of the opinion
- Broader context
- The funds were involved in regulatory scrutiny of offshore investors holding positions in Adani Group companies
- Tribunal’s decision
- SAT disposed of the appeals without ruling on the underlying regulatory proceedings