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Topic81 SEBI Board Constitution Powers Governance

SEBI Board — Constitution, Powers & Governance

Supplementary Topic — SEBI Sections 3-10: Board Composition, Autonomy, Removal & Regulatory Authority | SEBI Law Officer

Sections 3 to 10 of the SEBI Act govern the establishment, constitution, powers, and governance of the SEBI Board — the apex regulatory body. While the SEBI Act's enforcement provisions (Sections 11-30) receive the most examination focus, the Board's composition, the Chairman's powers, the autonomy provisions, and the restrictions on Board conduct are directly tested in both MCQ and descriptive questions. Understanding SEBI as an institution — its status, finances, accountability, and internal governance — rounds out the SEBI Law Officer's knowledge base.

1. Sections 3-4 — Establishment & Constitution of SEBI

Section 3(1): The Central Government shall, by notification in the Official Gazette, establish a Board to be known as the Securities and Exchange Board of India. SEBI shall be a body corporate by the name aforesaid having perpetual succession and a common seal, with power to acquire, hold and dispose of property, both movable and immovable, and to contract, and shall by the said name sue or be sued.

SEBI is a STATUTORY BODY CORPORATE — key implications:

  • Perpetual succession — SEBI continues regardless of changes in membership.
  • Common seal — official signature for all formal documents.
  • Can sue and be sued — SEBI is a legal person; it can be taken to court and can take others to court.
  • Can hold property — SEBI can own assets in its own name.

Section 4 — Composition of SEBI Board: The Board shall consist of: (a) a Chairman; (b) two members from amongst the officials of the Ministries of the Central Government dealing with Finance and Law; (c) one member from amongst the officials of the Reserve Bank of India; (d) five other members, of whom at least three shall be whole-time members.

Member Category

Number

Appointing Authority

Chairman

1

Central Government

Central Government officials (Finance and Law ministries)

2

Central Government

RBI official

1

Central Government (typically nominated by RBI)

Other members (minimum 3 whole-time)

5

Central Government

TOTAL

9 members

All appointed by Central Government

2. Section 5 — Term of Office & Conditions of Service

Term of office for SEBI Board members:

  • Chairman and whole-time members: tenure of 5 years or until age 65, whichever is earlier.
  • Part-time members: tenure of 3 years.
  • Eligibility for reappointment: permitted — but persons above the age limit cannot be reappointed.
  • Salary and allowances: determined by the Central Government.

3. Sections 6 & 7 — Removal of Members

Section 6 prohibits removal of Board members except through a specific process:

  • The Central Government cannot remove a member without giving them an opportunity to be heard.
  • Grounds for removal under Section 6: (a) adjudged as insolvent; (b) convicted of an offence involving moral turpitude; (c) acquired financial/other interest likely to affect their functions; (d) abused their position such that continuation is prejudicial to public interest.
  • Natural justice required — CG must give notice and opportunity before removal.

4. Section 9 — Functions & Powers of the Board

Section 9 empowers the Board to:

  • Make regulations under Section 30.
  • Delegate any of its powers to members, officers, or committees.
  • Constitute committees for any purpose including advisory committees.
  • Appoint officers and employees as required.

5. SEBI's Financial Independence — Sections 13-16

Provision

Subject

Key Content

Section 13

SEBI Fund

SEBI maintains a Fund from: fees and charges; grants from CG; income from investments; any other sources

Section 14

Accounts and Audit

SEBI maintains accounts in the form prescribed by CG; accounts audited by Comptroller & Auditor General of India (CAG)

Section 15

Annual Report

SEBI submits annual report to CG; CG lays it before both Houses of Parliament

Section 16

Directions by CG

CG may give directions to SEBI on questions of policy; SEBI must comply — CG's decision on policy questions is final

⚠️ SEBI's Independence vs CG's Policy Direction Power

Section 16 allows the CG to give policy directions to SEBI — but this applies only to policy questions, not to individual enforcement or adjudicatory decisions. SEBI has quasi-judicial independence in its enforcement and adjudication functions — the CG cannot direct SEBI to dismiss a specific enforcement action or change the outcome of a specific adjudication. This distinction between policy oversight (CG) and operational independence (SEBI) is fundamental.

6. SEBI — Regulatory Architecture Summary

Feature

Details

Legal nature

Statutory body corporate (Section 3) — not a government department; not a company

Accountability

Annual report to CG; CG lays it before Parliament (Section 15)

Financial autonomy

SEBI Fund (Section 13) — fees and charges; not dependent on annual budget appropriations

Policy oversight by CG

Section 16 — CG can give policy directions; but not in individual enforcement matters

Regulatory powers

Quasi-legislative (Section 30); quasi-executive (Sections 11, 11B, 11C, 12); quasi-judicial (Sections 15I, 15J)

Appeals against SEBI

SAT (Section 15T) → Supreme Court (Section 15Z) — not High Court in normal course

7. Model Examination Questions

Q1. Describe the constitution of the SEBI Board under Section 4. What is the significance of SEBI's status as a body corporate?

SEBI Board Constitution & Body Corporate Status

Model Answer — CONSTITUTION (Section 4): SEBI Board consists of 9 members — (a) 1 Chairman; (b) 2 members from CG ministries (Finance and Law); (c) 1 RBI official; (d) 5 other members (minimum 3 whole-time). All appointed by the Central Government. Chairman: 5-year tenure or age 65, whichever earlier. Whole-time members: 5 years/65 years. Part-time members: 3 years. BODY CORPORATE STATUS (Section 3): SEBI is a statutory body corporate with perpetual succession; common seal; power to sue and be sued; power to hold property. This distinguishes SEBI from a government department: SEBI can take legal action independently; has financial autonomy through its own Fund (Section 13); is accountable to Parliament through annual report but not subject to annual budget vote. FINANCIAL INDEPENDENCE: SEBI Fund (Section 13) consists of fees, charges, and grants. CAG audits SEBI's accounts. Annual report laid before Parliament (Section 15). POLICY vs OPERATIONAL INDEPENDENCE: Section 16 permits CG to give policy directions to SEBI — but this is limited to policy matters; SEBI has quasi-judicial independence in individual enforcement and adjudication matters. REGULATORY POWERS: Quasi-legislative (Section 30 — making regulations); quasi-executive (Section 11/11B/12 — enforcement); quasi-judicial (Section 15I/15J — adjudication). Appeal: SAT (Section 15T) → Supreme Court (Section 15Z) — no direct High Court jurisdiction in normal course.

🎯 EXAM POINTERS — Topic 81: SEBI Board — Constitution & Governance

  • Section 3: SEBI = STATUTORY BODY CORPORATE — perpetual succession; common seal; can sue/be sued; hold property.
  • Section 4: Board = 9 members: 1 Chairman + 2 CG officials (Finance+Law) + 1 RBI + 5 others (min 3 whole-time).
  • All Board members appointed by CENTRAL GOVERNMENT.
  • Section 5: Chairman/whole-time members — 5 years OR age 65 (whichever earlier). Part-time — 3 years.
  • Section 6: Removal — only on prescribed grounds (insolvency; conviction; conflicting interest; abuse of position). Natural justice mandatory.
  • Section 13: SEBI Fund — fees, charges, grants. FINANCIAL AUTONOMY.
  • Section 14: CAG audits SEBI accounts. Section 15: Annual report → CG → Both Houses of Parliament.
  • Section 16: CG gives POLICY DIRECTIONS to SEBI. Limitation: not operational/enforcement/individual adjudication matters.
  • SEBI's triple role: quasi-legislative (Section 30) + quasi-executive (Section 11/11B/12) + quasi-judicial (Section 15I/15J).
  • Appeals: SAT → Supreme Court (questions of law). NOT directly to High Court in normal course.

← Topic 80: Securities Laws & Competition Act / IBC | Next → Topic 82: SEBI (Research Analysts) & Investment Adviser Regulations

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