Separate statutory investigations may not justify impleadment where one regulator's order is based on its own inquiry.

The Tribunal considered whether SFIO was a necessary party to an appeal concerning SEBI's order and whether it could be impleaded because of its separate investigation. It noted that SEBI's impugned order rested on its own investigation under the SEBI Act, while SFIO's investigation proceeded under a different statutory framework and could, if completed, lead to a report to the Central Government and then prosecution before the designated court. Treating the two investigations as distinct, the Tribunal held that SFIO's presence was not required for adjudication of the appeal and rejected the impleadment request.

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Issues: Whether SFIO was a necessary party to the appeal and could be impleaded in view of its separate investigation.

Analysis: The application sought impleadment of SFIO on the ground that its ongoing investigation would assist adjudication of the appeal. The Tribunal noted that SEBI's impugned order was based on its own investigation under the SEBI Act, whereas SFIO's investigation operated under a different statutory regime and could only culminate, if completed, in a report to the Central Government and thereafter a prosecution before the designated court. On that basis, the Tribunal treated the two investigations as distinct and held that SFIO's presence was not required for deciding the appeal.

Conclusion: SFIO was held not to be a necessary party, and the impleadment application was dismissed.

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