FROM NATWAR SINGH TO T. TAKANO: REVISITING MATERIAL DISCLOSURE, Regarding disclosure of materials, the Supreme Court in T. Takano Vs. Securities and Exchange Board of India 2022 8 SCC 162 (“Takano”), in the context of a show-cause notice issued under the SEBI (Prohibition of Fraudulent and Unfair Trade Practices) Regulations, 2003, had held that the actual test is not to see whether the material required to be disclosed is relied upon in the show-cause notice, it is to see whether the material is relevant for the purpose of adjudication, since in all probability such material will influence the decision of the authority. The Court had discussed its earlier judgment in Natwar Singh v. Directorate of Enforcement and Anr 2010 SCC OnLine SC 1128 (“Natwar Singh”), which had held that only the documents relied upon in the notice are required to be disclosed. It clarified that the law in Natwar Singh distinguishes between two stages, i.e., the initial and the adjudication stage. In the initial stage, where the authority is deciding whether an enquiry needs to be conducted, only the materials relied upon in the notice may be disclosed. Whereas in the adjudication stage, where the authority adjudicates on allegations of contravention, all material in possession of the authority are required to be disclosed.