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Clear out junk files and repair common Windows errorsFree Scan →Scan for outdated or missing drivers - takes under a minuteDriver Scan →Repair Windows errors before they cause bigger problemsFix Now →There is no public legal or regulatory finding in the cited record that Madhabi Puri Buch either did or did not recuse herself from SEBI’s Adani investigation. Scroll’s August 12, 2024 headline reflected expert opinion, not an official determination. SEBI said Buch had disclosed relevant interests and recused herself in matters involving potential conflicts; an anonymous SEBI board member later told Scroll she had not recused herself from the Adani probe. The accounts conflict, and the available record does not resolve the specific question.
Why experts said Buch should have recused herself
On August 10, 2024, Hindenburg Research alleged that Madhabi Puri Buch, then chairperson of the Securities and Exchange Board of India (SEBI), and her husband, Dhaval Buch, had invested in an offshore fund structure that Hindenburg linked to entities associated with the Adani Group. The Buchs denied wrongdoing. They said the investment dated to 2015, before Madhabi Buch joined SEBI, was redeemed in 2018, and the fund had not invested in Adani securities. These are the parties’ respective claims and denials, not a single uncontested account. Scroll reported the allegations and responses on August 12, 2024.
In that report, veteran finance journalist Sucheta Dalal said: “We do not know enough yet, so it should be made public what are the disclosures that have been made, when, and to whom.” Former Union Finance Secretary Subhash Garg said: “If there is some conflict of interest in these disclosures, it should be made public.” Dalal also argued that once Buch knew an offshore entity under investigation was part of her investment portfolio, she should have recused herself. The headline captures that expert judgment; it is not a finding by a court, SEBI, or another authority.
What SEBI, the Buchs and an anonymous board member said
| Source | What it said | What it establishes |
|---|---|---|
| SEBI’s public statement, August 11, 2024 | SEBI said Buch had made relevant disclosures and recused herself in matters involving potential conflicts. SEBI’s statement was also reproduced in a filing discussed by the Indian Express. | SEBI’s official account of its position; it does not provide a publicly itemized list of recusals tied to the Adani probe. |
| The Buchs’ statement | They said disclosures and recusals had been diligently followed, and denied wrongdoing over the investment allegations. The Indian Express reported their response. | Their account and denial, not an independent adjudication. |
| Anonymous SEBI board member, as reported by Scroll, August 30, 2024 | The member told Scroll Buch had not recused herself from the Adani investigation or informal discussions about it. The member said SEBI departments carried out the probe, but that the chairperson would know what was happening and that it was discussed informally with her. Scroll’s report attributed the account to an unnamed board member. | An allegation from an anonymous source reported by Scroll, in direct conflict with SEBI’s public position; it is not a formal finding. |
The key distinction is between what SEBI and the Buchs publicly asserted and what the anonymous board member alleged. The latter account does not itself prove that a rule was breached, and the official statement does not disclose enough case-specific detail to independently verify the recusal claim.
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What SEBI’s conflict rules say—and what they do not settle
Scroll quoted clause 7(1) of SEBI’s 2008 Code on Conflict of Interests for Members of the Board: “A member, who is directly or indirectly interested in any matter coming up for consideration at a meeting of the Board, shall disclose the nature of his interest at such meeting.” The next clause says a member “shall not take part in any deliberation or discussion of the Board with respect to such matter except to the extent of professional advice if sought by the Board.” Section 8 states: “No Member shall hear or decide any matter where he has a conflict of interest.”
Scroll also quoted section 9 of the Securities and Exchange Board of India (Procedure for Board Meetings) Regulations, 2001. It requires a member directly or indirectly concerned or interested in a matter before the board to disclose that interest as soon as possible after learning of the relevant circumstances; the disclosure is to be recorded in the proceedings, and the member is not to participate in deliberation or decision on that matter.
These provisions address conflicted members and matters considered at board meetings. The cited sources do not establish whether awareness of, or informal discussion about, a department-led investigation amounted to participation covered by those rules. No independent legal conclusion on that question follows from the reported accounts alone.
What the public record can verify
In September 2024, SEBI told an information requester that records of individual recusals were not readily available for collation. It also declined to disclose Buch’s financial declarations, citing privacy and safety grounds, according to Business Standard’s report on the RTI response. The response limits public verification; it is not proof that recusals did not happen.
In May 2025, the Lokpal dismissed three complaints against Buch, finding no prima facie basis to order a corruption investigation. The order addressed whether the complaints warranted such an investigation, not whether Buch recused herself from the Adani probe. LiveLaw and The Indian Express reported the decision.
SEBI’s public orders listing includes Adani Group Companies orders dated September 28, 2026, and a corrigendum dated September 29, 2026. The listing does not itself state a finding about Buch’s recusal, so it does not settle the historical dispute. SEBI’s orders index shows those entries.
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So, did Madhabi Puri Buch recuse herself?
The publicly described evidence is contradictory: SEBI and the Buchs said relevant disclosures and recusals were made, while an anonymous board member told Scroll Buch had not recused herself from the Adani investigation or informal discussions about it. The RTI response did not supply an itemized record, and the Lokpal’s 2025 decision did not decide the recusal issue. On this record, the specific question remains unresolved.
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