No Review Jurisdiction : Lokpal Refuses To Revisit Order Dismissing Complaints Against Ex-SEBI Chairperson Madhabi Puri Buch
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The Lokpal has refused to revisit its earlier decision dismissing multiple complaints filed against former SEBI Chairperson Madhabi Puri Buch, holding that no express review jurisdiction has been bestowed on the Lokpal under the Lokpal and Lokayuktas Act, 2013.
A bench of Justice AM Khanwilkar (Chairperson), Justice L Narayana Swamy, Justice Sanjay Yadav, Sushil Chandra, Justice Ritu Raj Awasthi, and Ajay Tirkey refused to entertain a petition filed by former IPS officer and presently Azad Adhikar Sena National President, Amitabh Thakur, requesting a review of its May 29 order.
The bench observed that it had become functus officio after passing its order and hence could not entertain a fresh request seeking reconsideration of that order.
Complainant-Thakur, who was one of the original parties in Complaint No. 186/2024, had submitted an application (on July 6, 2025), along with an earlier email (dated June 3, 2025), seeking a revisit of the Lokpal's May 28 order and requesting the quashing of 'indictments' made against the complainant.
Rejecting the request, the Lokpal's order stated:
"With passing of this order we have become functus officio. The attempt of the complainant is to call upon us to review the order passed by the Bench on 28.05.2025, in a disposed of complaint. Indisputably, no express review jurisdiction has been bestowed in the Lokpal under the Lokpal and Lokayuktas Act, 2013".
The Bench added that accepting the complainant's request would amount to exercising a power of review that the Act does not confer. Consequently, the Lokpal clarified that the previous order would remain intact.
The order, however, added that the complainant remains at liberty to pursue any other remedy available under law.
On May 28, the Lokpal had dismissed three complaints filed against Buch after concluding that there was no prima facie case for directing an investigation into allegations of corruption.
The common order dated May 28, 2025, was passed on the complaints dated August 13, 2024, September 11, 2024, and October 8, 2024 filed by different complainants, including Lok Sabha MP Mahua Moitra and Ex-IPS Amitabh Thakur.
The Lokpal further granted liberty to Buch to pursue appropriate remedy against the complainants for surreptitiously obtaining Buch's income tax returns.
More about the order here : Lokpal Dismisses Complaints Against Ex-SEBI Chief Madhabi Puri Buch, Says She Can Pursue Action Against Complainants