1. Background Securities and Exchange Board of India (“SEBI”) issued an Informal Guidance Note[1] on 2 March 2026, confirming that a ‘cousin’ of a promoter group member does not fall within the definition of a 'relative' under the Companies Act, 2013 (“Act”). As a result, a cousin of a promoter group member is not automatically disqualified from being appointed as an Independent Director ("ID") on the board of a listed company. This article examines the basis for that clari