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    <title>SEBI investigation report disclosure to accused in securities prosecution, fair-trial Article 21 duties upheld; report must be shared</title>
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    <description>Disclosure obligations in SEBI-initiated prosecution and allied proceedings were examined in light of the right to a fair trial under Article 21 and the duty of fairness/natural justice. It was held that disclosure is not confined to documents formally relied upon, but extends to material necessary or desirable for the accused/noticee to prepare an effective defence and to contest even the existence of a prima facie case. The Investigation Report prepared under the relevant regulations was held to be the basis for forming the regulator&#039;s opinion and initiating further action, and therefore cannot be withheld as a mere internal document, subject only to redaction of third-party or confidential market information. The Investigation Report was directed to be furnished, and the petition was allowed. - HC</description>
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      <description>Disclosure obligations in SEBI-initiated prosecution and allied proceedings were examined in light of the right to a fair trial under Article 21 and the duty of fairness/natural justice. It was held that disclosure is not confined to documents formally relied upon, but extends to material necessary or desirable for the accused/noticee to prepare an effective defence and to contest even the existence of a prima facie case. The Investigation Report prepared under the relevant regulations was held to be the basis for forming the regulator&#039;s opinion and initiating further action, and therefore cannot be withheld as a mere internal document, subject only to redaction of third-party or confidential market information. The Investigation Report was directed to be furnished, and the petition was allowed. - HC</description>
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