A frugal DIY air quality monitor

by Ayush Patnaik.

Particulate matter pollution creates a public health crisis in India and other emerging economies. Yet individuals lack access to immediate, localised air quality data. This data matters for personal decisions: whether to exercise outdoors, wear a mask, or run an air purifier. It also helps test whether air cleaning devices work by comparing inlet and outlet readings.

Air quality varies dramatically across short distances, making hyperlocal measurement essential. Government monitoring stations are sparse and report delayed data. In Haryana, all state AQI stations went offline in April 2025 and remained down for months (Times of India, 2025). Even where stations exist, authorities sometimes relocate them to cleaner areas (Hindustan Times, 2023). Portable commercial devices like the Laser Egg offer an alternative but present barriers to widespread adoption. They cost around Rs. 10,000, are heavy and bulky, and require regular charging.

The Aqui project addresses these gaps. It demonstrates that a DIY product which can enable citizen-led data collection and improve public understanding of local air quality dynamics.

This article updates an earlier version published at LEAP Blog.

Project website: https://ayushpatnaikgit.github.io/aqui/

Design approach

The design follows radical frugality through functional delegation to the host device. It centres on the SDS011 sensor, which costs around Rs. 1,200, for real-time measurement of PM2.5 and PM10 concentrations.

This class of low-cost optical sensor has limitations. It degrades within weeks under continuous operation as particles trap in its mechanism (World Air Quality Index, 2025). But the design objective focuses on intermittent monitoring driven by citizen curiosity and spot measurements. This mitigates the degradation issue.

The sensor interfaces directly with Android devices via USB Serial Cable and USB-OTG adapter. This eliminates the need for microcontrollers, displays, batteries, and wireless modules. These components drive cost and bulk in commercial devices. Delegating processing and power to the user's smartphone cuts both.

The Aqui Android companion app is open-source on GitHub. It connects to the sensor over USB serial and streams the live particulate data (PM2.5 / PM10) to your phone.

The physical enclosure uses 3D printing for low-cost replication. The entire project is released under Creative Commons CC0 (Public Domain) dedication. All design files and code are freely accessible for scrutiny, replication, and modification.

Results

Total component cost for a complete Aqui sensor is approximately Rs. 2,000. This includes the SDS011, cables, and 3D-printed enclosure. The cost represents an order-of-magnitude reduction compared to commercial-grade monitors.

The sensor streams live PM data via the companion Android application. Response time is seconds. In controlled demonstrations, the device measured clear differences in PM2.5 readings between a busy road and a park 50 metres away. This immediate visualisation captures real-time pollution gradients missing from centralised data.

People understand air quality differently when they see their own numbers. Abstract government statistics become personal, actionable information that influences health decisions.

Discussion

Aqui addresses practical gaps in air quality monitoring by providing an accessible, data-generating tool. Delegating key functions to smartphones achieves the frugality needed for mass citizen adoption. This fills data gaps created by sparse and delayed government monitoring.

The SDS011 sensor choice remains optimal for intermittent, curiosity-driven spot-checking despite its continuous operation constraints. The policy impact lies in making citizens aware by turning abstract statistics into personal information that directly influences health decisions.

The hands-on nature provides a pathway for scientific curiosity and learning. Users transition from passive news consumers to active environmental investigators. This citizen science mindset, driven by curiosity and enabled by affordable technology, anchors a more responsive and engaged air quality strategy.

Dense networks of distributed Aqui sensors could create curiosity-driven air quality maps. Future work should focus on methodologies for crowdsourcing and aggregating such data.

Resources and build guide

The Aqui project is open-source. All files, documentation, and videos are available:

• Demo video: Aqui in action
• Assembly tutorial: Step-by-step assembly
• Android app: Download APK for sideloading
• Source code: Android app on GitHub
• SDS011 sensor: Example parts link
• 3D print files: Top shell, Base shell
• Full assembly model: STEP file for remixing
• Complete build guide: Parts list and instructions

References

Hindustan Times (2023). "Now, BMC Seeks to Shift Air Quality Monitors to 'Cleaner' Areas." 5 February 2023. https://www.hindustantimes.com/cities/mumbai-news/now-bmc-seeks-to-shift-air-quality-monitors-to-cleaner-areas-101675537753172.html.

Times of India (2025). "No Pollution Data from Haryana as All State AQI Stations Offline since April." 29 July 2025. https://timesofindia.indiatimes.com/india/no-pollution-data-from-haryana-as-all-state-aqi-stations-offline-since-april/articleshow/122963786.cms.

World Air Quality Index (2025). "The SDS011 Air Quality Sensor Experiment." Accessed 7 October 2025. https://aqicn.org/sensor/sds011/.

Ayush Patnaik is a Senior Research Associate at xKDR Forum. Special thanks to Saurabh Nandedkar for help building the app.

Beyond Pendency: Counting Cases Correctly

by Pavithra Manivannan, Siddarth Raman and Bhargavi Zaveri-Shah.

The discourse on Indian judicial reform is dominated by questions of pendency and the workload of courts. However, official sources of caseload estimates in India have been found to be deficient in terms of both the methodology used, and the quality of underlying data (Jain and Reddy, 2025; Damle and Anand 2020). This leads to miscalculation of the caseload of courts and renders it unamenable for comparison across courts. In this article, we propose a new approach for estimating the caseload at Indian courts. We apply this to analyse the caseload at the Original Side of the Bombay High Court, which accounts for 35% of the total caseload of the Court. Our analysis yields three main findings. First, the caseload at the Original Side of the Bombay High Court (the Court) is being overcounted by 66%. Second, the caseload composition of the Court has remained largely stable over the 7-year period of our study with two case-types, namely, inheritance cases, and writ petitions filed against the government, accounting for half the cases filed in the Court. Third, suits as a case-type generates the most number of sub or interim cases.

In India, there are two official sources that publish information on caseloads - the annual report of the Supreme Court and the National Judicial Data Grid (NJDG). Apart from the quality of the data, there are two specific problems with the estimation methodology used by these sources. First, as a case progresses in a court of law, it generates multiple sub-cases. For instance, if a case is filed as a "Suit" for recovery of money, several interlocutory applications may be filed through which the main money suit (the 'main case') progresses. Such sub-cases could range from simple applications seeking the addition of a new party to the proceedings to an interim injunction seeking a stay on the transfer of assets of the respondent. Currently, the NJDG counts such sub-cases as distinct cases. This leads to overestimation of the caseload, inflating pendency and disposal rates. This is because the hearings for sub-cases are held as part of the main case proceedings. Further, a reading of the orders of cases suggests that more often than not, the final disposal order is common for both the main case and its sub-cases. Second, the taxonomy for case-type categorisation is inconsistent across official sources. The Bombay High Court's website lists 142 case-types on its Original Side. On the other hand, the NJDG reports only 19 case-types for the Original Side of the Bombay High Court. This includes an 'Original' and an 'Other' category, which provides little to no information on the case-type filed in the court. Further, the annual report of the Supreme Court has an altogether different classification system, which cannot be readily mapped to the other two official sources. It has a large bucket under 'Other' which does not have a clear definition. Our approach attempts to address these problems.

We count sub-cases as part of its corresponding main case. That is, we adopt the 'family of cases' as the unit of analysis for caseload estimation. This involves collapsing the 142 case-types on the Original Side of the Court into 17 main case-types and two sub case-types, based on their subject. For example, of the 142 case-types, 80 case-types are in the nature of sub-cases such as "Interim Applications", "Leave Petitions", "Chamber Order Lodging" and "Notice of Motion". We classify these as "Interim Applications" and count these as sub-cases. Similarly, "Arbitration Petitions" and "Arbitration Applications" are categorised as "Arbitration cases". This standardisation of case-types makes the caseload estimation exercise scalable and amenable to comparison across similar courts. The list of the 142 case-types and the classification assigned by us can be accessed here.

Data and Methodology

We collect the life-cycle data of 2,36,953 cases filed at the Original Side of the Court between the period January 2017 to December 2024 (Study Period). The Bombay High Court exercises original jurisdiction or jurisdiction over first time civil cases, and appellate jurisdiction or jurisdiction over cases that come before it as appeals from lower courts. We source the information on the life-cycle of cases filed at the Court's original jurisdiction from its website, and it is comprehensive to the extent the Court has made the data available.

As on the date of our data collection exercise (February 2025), the Court's website reported 1,43,514 (61%) cases as disposed of and 93,254 (39%) cases as pending. If the status of a case was unknown or marked as transferred, we classify it into the 'Other' category (185 cases).

We tag each case in our dataset as a main case or a sub-case. Next, we create a family of cases using the CNR number assigned by the Court as the unique identifier. This family of cases becomes our unit of analysis. Finally, each family of case is classified into one of the 17 case types.

Finding 1: Official sources overestimate caseload

The Court's website shows that about 2.5 lakh cases are filed before its Original Side during our Study Period. That is, on an average, about 30,000 cases are filed every year. However, we find that about 40% of these cases are sub-cases (Table 1 below). Viewed in this light, the 30,000 new cases per year can be understood as an overestimate. The annual average of new main cases filed before the Original Side of the Court is about 18,000, almost half of the original estimate.

Table 1: No. of filings

Nature	Count	Average per-year	% of total
Main cases	1,41,608	17,850	60
Sub-cases	95,435	11,769	40
Total	2,36,953	29,619	100

Finding 2: Six case-types dominate caseload

On applying our categorisation framework, we find that six case-types contribute to about 95% of the caseload at the Original Side of the Court (Table 2). In that, Inheritance cases and Writ petitions constitute half the caseload. We also find that the share of case filings across years for these categories do not vary significantly.

Table 2: No. of filings per case-type

Case Category	Count	% of Total
Writs	36,145	25.5
Inheritance and Succession cases	32,979	23.3
Execution cases	19,779	14.0
Tax cases	19,665	13.9
Arbitration cases	16,529	11.7
Suits	8,652	6.1
Other	7,859	5.6
Total	1,41,608	100.0

Finding 3: Suits generate the most sub-cases

We take a closer look at the number of sub-cases per main case in Table 4 for the top six case-types. We find that, while Inheritance cases and Writ petitions are the highest contributor to the caseload of the Court, Suits that is at the bottom of Table 2, has the highest number of sub-cases per main case. 50% of Suits have upto two sub-cases, suggesting that on a per-case basis, Suits may generate more workload for judges compared to Writ petitions and Inheritance cases.

Table 3: Sub-cases per case-type

Case category	Sub-cases per main case (in %)
	0	1-2	3-5	6-10	>10
Writs	86	13	1	0	0
Inheritance and Succession cases	77	21	2	0	0
Execution cases	86	13	1	0	0
Tax cases	84	16	0	0	0
Arbitration cases	84	15	1	0	0
Suits	31	52	14	3	0

Conclusion

Our finding that the caseload of the Bombay High Court is overestimated by about 66% likely means other courts across India are overreporting caseloads as well. When official sources like the NJDG count sub-cases as distinct new filings, it exaggerates the problem of pendency. This prompts the policymakers to focus on solutions like increasing the number of judges, and creating more courts or courtrooms. Such a sole focus on this metric not only neglects the underlying data quality issues leading to inefficient resource allocation but also ignores the unique challenges that each type of case filed in the court face.

Measures of the economy such as GDP, inflation, and employment rate, took decades to be built and continue to be challenged and improved, by researchers and policy-makers alike. Similar sound systems for the measurement of court metrics, of which caseload is only one part, need to be developed. Such systems are imperative for any meaningful discussion on court reform.

References

Chitrakshi Jain and Prashant Reddy T. Tareekh Pe Justice: Reforms for India's District Courts. Simon and Schuster India, 2025.

Devendra Damle and Tushar Anand. Problems with the e-Courts data. NIPFP WP Series, 314, 2020.

Mugdha Mohapatra, Siddarth Raman and Susan Thomas. Get them to the court on time: bumps in the road to justice. The Leap Blog, 2025.

The authors are researchers at XKDR Forum, Bombay.

Return to sender: The misuse of remand orders by appellate tribunals

by Natasha Aggarwal and Bhavin Patel.

Appellate tribunals were established to ensure speedy and expert adjudication of appeals from regulators' orders. A defining feature of their institutional design is the inclusion of both judicial and technical members. Judicial members possess legal training and skills and can ensure the application of, and compliance with, judicial principles, such as the principles of natural justice. Technical members are expected to bring sector-specific knowledge relevant to the domain of the tribunal's work. As such, tribunals are 'expert' bodies that are well-equipped to provide speedy and efficient resolution and it would be incorrect to assume that they lack the technical expertise necessary to decide a matter on merits.

However, tribunals in India frequently remand matters to regulators. Our analysis of 764 cases disposed of by the Securities Appellate Tribunal (SAT) from 2009 - 23 reveals that 76 cases (10%) resulted in a remand (Aggarwal and others, 2025). Further, our analysis of 919 cases disposed of by the the Appellate Tribunal for Electricity (APTEL) from 2013 - 22 reveals that 200 cases (21.7%) resulted in a remand (Jain, Patel and Sane, 2025). The fact that one in ten instances before the SAT and a staggering one in five instances before the APTEL are remanded is a matter of concern. Remands result in additional time and resources being spent on resolving a matter, since the dispute is first heard by the regulator, then in challenge by the tribunal, and then, once again by the regulator. Therefore, it is important to study the reasons provided by the tribunal when it remands a matter.

In a recent paper, titled "Return to sender: The misuse of remand orders by appellate tribunals", we study orders issued by the SAT and the APTEL in 2024, evaluate the instances in which the SAT and the APTEL remanded matters, and examine whether these remands are consistent with recognised legal principles regarding when a remand may be ordered. The paper was also included in Daksh's "The State of Tribunals Report", which was released on 25 September 2025.

Our paper addresses three questions:

• What costs do remands impose on the parties and the adjudicatory infrastructure of regulators?

  Our examination of two matters, one originating at SEBI and the other originating at the Kerala Electricity Regulatory Commission, shows that remands cause delays that span up to 14 years. This defeats one of the primary reasons for establishing tribunals, that is, to ensure speedy justice.

• What reasons does the law recognise as valid for remands by tribunals?

  Our earlier studies demonstrate frequent remands by SAT and APTEL. Indian law circumscribes the instances in which courts may order remands. These boundaries are set in the Code of Civil Procedure, 1908 (CPC) and in judicial decisions of superior courts. The CPC, parent statutes that establish tribunals, and rules of procedure framed by tribunals for themselves do not, however, clearly identify when tribunals may remand matters. There is limited guidance on this in superior court decisions. We argue that the reasons for which courts can order remands should also limit the discretion of tribunals in remanding matters. We call these reasons "Permissible Reasons" for remand, and classify any other reasons provided by tribunals when remanding matters as "Other Reasons".

• How many matters were remanded by SAT and APTEL in 2024? What reasons were provided? Are the reasons permissible under law?

  We study the orders of SAT and APTEL for 2024, in which there are 13/228 (5.7%) remands ordered by SAT and 28/171 (16.4%) remands ordered by APTEL. We find that the SAT ordered a remand for Permissible Reasons in 21 appeals and for Other Reasons in four appeals. The APTEL remanded the matter for Permissible Reasons in 26 appeals and for Other Reasons in 37 appeals.

We find that remands are often ordered for reasons that are not included in the CPC and applicable common law. Unnecessary remands add time and cost to regulatory proceedings. They undermine investor confidence in regulated sectors, since it is difficult to take business decisions in the face of uncertainty about whether a regulator's orders will have to be reconsidered and modified. This also adversely affects the rule of law requirements of predicability and certainty in regulatory proceedings.

There may be several ways to reduce this problem, including, possibly, by improving order writing practices at the regulators whose orders are challenged in appeal before tribunals. We suggest that it is also useful to consider how this problem can be addressed at tribunals, and therefore recommend that:

• Clear rules determining the scope of the power of ordering a remand should be made applicable to all tribunals. These rules should apply in a consistent manner across tribunals, rather than being framed by each tribunal for itself. This will help ensure consistency and predictability, and limit the discretion of tribunals in this matter.
• These rules should be incorporated in the parent statutes of tribunals.
• In the absence of any reason to deviate from the rules on remand provided in the CPC and applicable common law, the scope of remanding power for tribunals should be the same as that available to courts.

Providing this clarity would help avoid unnecessary and unreasonable orders of remand, and help ensure that the core rule of law principles of consistency, predictability, and clarity are satisfied in the procedural aspects of the functioning of tribunals.

References

Natasha Aggarwal, Amol Kulkarni, Bhavin Patel, Sonam Patel, and Renuka Sane, "Balancing Power and Accountability: An Evaluation of SEBI's Adjudication of Insider Trading" [2025] (13) Trustbridge Rule of Law Foundation Working Papers.

Chitrakshi Jain, Bhavin Patel, and Renuka Sane, "Examining the performance of ERCs at APTEL" [2025] The Leap Blog.

The authors are researchers at the TrustBridge Rule of Law Foundation.

A Review of Outage Reporting by Indian DISCOMs

by Upasa Borah and Renuka Sane.

In 2023, 99.5% of India's population had access to electricity. This statistic, however, should be measured along with the data on consistency and quality of electricity supply. Frequent power outages and low and fluctuating voltage can adversely affect appliances, reduce productivity, increase the cost of production and reduce standards of living (Jha et al., 2021). It adds a financial burden on both households and firms, who are forced to invest in costly backup options like inverters and diesel generators (Pargal and Banerjee, 2014). As India expands its electricity access, it is useful to measure how it is faring on the quality of its electricity supply. The aggregate data does not appear promising. According to the 2019 Global Competitiveness Index by the World Economic Forum, India ranked 108 out of 141 countries in electricity supply quality.

A response to the question of quality should first begin with assessing its measurement. In this article, we examine the availability of outage data in India. Outages refer to any interruptions in the supply of electricity to end consumers, and are classified into three types, depending on the location of the interruption in either generation, transmission or the distribution segments of the electricity system. We focus on outages happening in the distribution system, as it captures the final impact on consumers and takes into account upstream interruptions. These fall under the purview of distribution companies (DISCOMs), so we study all the DISCOMs in the country, and ask:

1. How many DISCOMs report data on outages?
2. Is the format of available data consistent across DISCOMs on
1. methodology,
2. period of data availability, and
3. the spatial unit of reporting?
3. Is there consistency in the reporting of outage data across states?
4. Is there a relationship between DISCOM characteristics like fiscal health and ranking, ownership and location and the availability of outage data?

Measuring outages

The quality and reliability of electricity supply are estimated by relying on a measure of either frequency or duration, or a combination of both, of interruptions faced by consumers. Feeders, which could be underground or overhead wires connecting substations to service areas, are the backbone of the distribution network, and distribution outages are typically measured using data from these feeders.

Two of the most widely used reliability indices are the System Average Interruption Frequency Index (SAIFI), and the System Average Interruption Duration Index (SAIDI). The former measures how often an average customer experiences an interruption, while the latter denotes the total minutes (or hours) of interruption an average customer faces. For example, as an illustration, if a distribution network serves 1,000 customers and experiences 200 supply interruptions in a given year, SAIFI would be 200/1000, or 0.2, interruptions per customer. If the total duration of interruptions in the same network were 3,000 minutes, then SAIDI would be 3000/1000, i.e. 3 minutes of interruptions per customer.

Supply interruptions or outages can be planned or unplanned, where planned outages are those that have been scheduled in advance, like maintenance work, which the DISCOM is supposed to disclose to customers in advance. Unforeseen outages due to disruptions, faults in the distribution system, extreme weather events, etc., are unplanned outages. From the perspective of the consumer, however, both planned and unplanned outages disrupt daily consumption and production activities and thereby have costs associated with them. Moreover, many households report not receiving prior information on planned outages (Agrawal et al., 2020), and it is often unclear which specific events are categorised as planned.

Methods

As per the Electricity Act 2003 and the National Electricity Policy 2005, the Central Electricity Authority (CEA) is tasked with collecting and publishing reliability indices for DISCOMs. However, this is not a statutory mandate, and compliance remains voluntary (Sekhar et al., 2016). The State Electricity Regulation Commissions have Standards of Performance regulations that outline metrics for reliable supply and guidelines such as time taken to restore supply, penalties, etc. (Athawale, 2021) Further, the Electricity (Rights of Consumers) Rules, 2020 mandate that DISCOMs should supply power 24x7 as the norm, with the State Commissions specifying the acceptable levels of SAIDI and SAIFI values for unavoidable interruptions. It also states that DISCOMs should have a mechanism to monitor and restore outages and disclose feeder-wise outage data and efforts made to minimise outages. The Service Rating of DISCOMs by the Ministry of Power & Rural Electrification Corporation Limited factors outages in its rating of DISCOMs; however, this data on actual outages is not publicly available.

We compiled a list of all the DISCOMs in the country using the annual ranking of DISCOMs by the Ministry of Power. While the CEA publishes annual reliability indices, not all DISCOMs are included in their lists. Moreover, such annual data masks the granular, day-to-day variations needed to meaningfully study the reliability of electricity supply.

We reviewed each DISCOMs official website to assess their current reporting practices. We restricted our search to official websites, and on encountering broken or unsafe links, we considered the data to be unavailable.

Findings: Availability of data

As per the Ministry of Power, there are a total of 72 DISCOMs in the country, all of which are included in our dataset. Among them, 36 (50%) have some form of outage data available on their websites, although irregular. The remaining 36 DICSOMs have no mention of outage or interruption data anywhere on their websites. Among the DISCOMs for which data is available, a closer look reveals the inconsistency and sporadic nature of the reported data. Broadly, there are three types of inconsistencies: i) the type of data reported and the methodology used, ii) the time period for which data is available, and iii) the spatial unit of measurement.

Reporting of data

The first inconsistency lies in the way outage data is reported. 17 out of the 36 DISCOMs use the SAIFI and SAIDI indices. The rest report interruptions by date and time, without noting how many customers were affected. Among the ones that report SAIFI and SAIDI, there is an inconsistency in the way the reliability indices are calculated. For instance, the Delhi Standard of Supply Code states that planned outages and outages less than five minutes shall not be included in calculating the reliability indices. On the other hand, the Haryana Standard of Supply Code includes planned outages in the calculation of the indices, while excluding outages of less than three minutes. DISCOMs like Karnataka's Chamundeshwari Electricity Supply Corporation (CESC) reference a "Reliability Index" without specifying which one. Other Karnataka DISCOMs provide feeder or area-wise frequency and duration of interruptions without calculating the SAIFI and SAIDI indices. Yet others, like Adani Electricity Mumbai Limited (AEML), report only the number of complaints registered and the duration taken to resolve them. Additionally, six of the 36 DISCOMs only reported scheduled or planned outages, and there was no data on unplanned outages.

Time period for which data is available

The second inconsistency concerns the time for which the data is reported. Only eight out of the 36 DISCOMs had data going back at least five years. For the rest, data availability was patchy and lacked any clear patterns. Some have data only for the past year, while others have data for sporadic years like 2022, or 2019 to 2024 and so on. Five DISCOMs had outage data only for the current date (as of visiting the website), and past archives were not available. In another instance, like that of West Bengal State Electricity Distribution Company (WBSEDCL), viewing outage data was allowed only for 60 days prior to the current date. Table 1 summarises the time period covered by the DISCOMs. There are also variations in the frequency of reporting outage data; some publish daily figures, others have data weekly, monthly or quarterly. 15 DISCOMs reported monthly SAIDI and SAIFI data, while two reported them daily.

Table 1: Coverage period of outage data

Time period covered	No. of DISCOMs
Last five years	8
Sporadic years	23
Current day	5

Spatial unit of measurement

The final inconsistency relates to the spatial unit of reporting, summarised in Table 2. 16 DISCOMs report interruptions both by feeders and areas, while four reported only feeder-wise data. Among these, some report outages in 33kV and 11kV feeders separately, while others club them together. The distinction is important because 33kV feeders carry electricity from high-voltage substations to 33/11kV substations where voltage is stepped down, and 11kV feeders then deliver power to local service areas through distribution transformers that further reduce voltage for end-users. 16 DISCOMs report outages in terms of geographic area, like zones, divisions or areas affected. However, it is unclear if these area lists are comprehensive; for instance, Assam Power Distribution Company (APDCL) reported district-wise data, but did not include all districts.

Table 2: Spatial units used in reporting outages

Unit of reporting	No. of DISCOMs
Area and feeder	16
Only feeder	4
Circles, divisions, towns, cities	13
Zones	2
Areas affected	1

Findings: Does DISCOM ranking, ownership, or state matter?

Next, we examined whether a DISCOM's characteristics, like the state where it is located, its ownership and ranking are correlated with the availability of outage data.

There were no visible patterns of data availability observed across states. In states with multiple DISCOMs like Uttar Pradesh, Gujarat and Maharashtra, most did not report outage data. In contrast, all four DISCOMs of Odisha and all three of Andhra Pradesh had outage data available on their websites. The three inconsistencies discussed earlier were also evident within states. For instance, among the four DISCOMs in Delhi, only three had data available, and among them, there were variations in the spatial units used (area vs feeder) and the time period for which data were reported.

We used the 13th DISCOM ranking by the Ministry of Power to see if better-performing DISCOMs tended to have better data availability. However, there was no clear correlation; both high-ranking and low-ranking DICSOMs seemed equally likely or unlikely to make outage data available. There was also no correlation between ownership and data availability.

Finally, we compared the DISCOMs that publish outage data on their websites to those for whom CEA has compiled annual reliability indices. Of the 49 DISCOMs included in CEA's 2021-22 list, only 26 had data available on their websites. Alternatively, among the 23 DISCOMs not included in the CEA list, 10 had outage data available on their websites. It is worth noting that for eight of these 10 DISCOMs, the data was available for sporadic years, which may explain their exclusion from the CEA's lists. Nonetheless, these findings point to the disconnect between the CEA and DISCOMs reporting practices.

Accuracy of reported data

The availability of data does not guarantee its accuracy. Several studies have raised concerns about the unreliability of outage data reporting, particularly in developing countries (Min et al., 2017). For instance, in January 2017, the National Load Dispatch Centre reported only a 0.9% shortfall in power supply in Uttar Pradesh, while Prayas Energy Group recorded a daily average of nine hours of power outages in rural areas and two hours in urban areas. Other studies point to similar discrepancies: scheduled power cuts in India often last longer than officially noted (Baskaran et al., 2015), there are logical inaccuracies in reported data (Mandal et al., 2019), and household survey data do not align with government-reported outage statistics (Agrawal et al., 2020).

These findings suggest that simple reporting of outage data is not sufficient. There is an urgent need for independent and transparent monitoring systems that complement official reporting and allow for verification of accuracy. Independent studies have attempted to fill this gap, using surveys (Agrawal et al., 2020; Bigerna et al., 2024; Khanna & Rowe, 2024), satellite night-light data (Min et al., 2017; Dugoua et al., 2022) or initiatives like the Supply Monitoring Initiative (ESMI) by Prayas Energy Group, but these efforts are usually restricted to specific regions and limited time periods. The lack of a single agency reporting outage data, combined with the inconsistencies in reporting practices by DISCOMs further complicates the process of data verification.

Conclusion

In July 2024, the National Feeder Monitoring System was inaugurated, which has data on around 2.5 lakh 11kV feeders across the country. Its dashboard provides data on hours of supply in rural and urban areas by state and DISCOM. However, to the best of our knowledge, it does not offer access to historical, granular data on daily hours of supply by feeders, state or DISCOM. The CEA reports annual reliability indices, but it should cover all DISCOMs in its list and augment it by including more granular data. A logical next step, however, is to ensure that the available data is accurate, which requires independent monitoring systems. Prayas Energy Group's ESMI has minute-wise data on supply from November 2014 to December 2018, recording not just outages but voltage fluctuations. Such efforts should be scaled up and maintained on an ongoing basis.

Having accurate and accessible data on hours of supply and areas of outage is crucial not only for consumers to understand and plan their production and consumption but also for a thorough review of DISCOMs' performance. While much of the discussion on DISCOMs centres around their financial health, it is also important to assess their ability to supply reliable power to their customers. Standard of performance indicators should include data on feeder-wise outages, distribution transformer failure rates and SAIDI, SAIFI (Pargal & Banerjee, 2014; Mandal et al., 2019). Reliability indices are valuable for providing consistent, comparable measures of service quality over time, but daily reporting of feeder-wise data that includes time, duration, cause of outage and measures taken to resolve the issue, also has its benefits in allowing for spatial, minute-by-minute analysis to pinpoint weak links in the network. Whichever approach is used, however, it should be standardised across DISCOMs and reported collectively, with a common format agreed upon by all stakeholders. If the sector moves towards reliability indices, their calculation methods should be consistent and published more frequently to ensure meaningful assessments, comparisons and verifications.

References

State of Electricity Access in India: Insights from the India Residential Energy Survey (IRES) by Agrawal, S., Mani, S., Jain, A., & Ganesan, K., October 2020, CEEW Report.

India's electric grid reliability and its importance in the clean energy transition by Athawale, R., May 2021, Regulatory Assistance Project.

Election cycles and electricity provision: Evidence from a quasi-experiment with Indian special elections by Baskaran, T., Min, B., & Uppal, Y, June 2015, Journal of Public Economics.

India's Statistical System: Past, Present, Future by Bhattacharya, P., June 2023, Carnegie Working Paper.

An empirical investigation of the Indian households' willingness to pay to avoid power outages by Bigerna, S., Choudhary, P., Jain, N. K., Micheli, S., & Polinori, P., November 2024, Energy Policy.

Assessing reliability of electricity grid services from space: The case of Uttar Pradesh, India by Dugoua, E., Kennedy, R., Shiran, M., & Urpelainen, J., June 2022, Energy for Sustainable Development.

Blackouts: The Role of India's Wholesale Electricity Market by Jha, A., Preonas, L., & Burlig, F., December 2021, NBER Working Paper.

The long-run value of electricity reliability in India by Khanna, S., & Rowe, K., April 2024, Resource and Energy Economics.

Five Stitches in Time: Regulatory and policy actions to ensure effective electricity service by Mandal, M., Nhalur, S., Pandey, A., & Josey, A., May 2019, Prayas (Energy Group).

Whose Power Gets Cut? Using High-Frequency Satellite Images to Measure Power Supply Irregularity by Min, B., O'Keeffe, Z., & Zhang, F., June 2017, World Bank Research Working Paper 8131.

More Power to India: The Challenge of Electricity Distribution by Pargal, S., & Banerjee, S. G., 2014, World Bank Directions in Development.

Evaluation and Improvement of Reliability Indices of Electrical Power Distribution System by Sekhar, P. C., Deshpande, R. A., & Sankar, V., 2016, IEEE.

The authors are researchers at TrustBridge Rule of Law Foundation. They thank an anonymous referee for useful comments.

Author: Aneesha Chitgupi

Aneesha Chitgupi is a researcher at XKDR Forum.

On this blog:

• Who is "innovative"? Unpacking the process of tax exemption grants to startups, 19 September 2024.
• Who lends to the Indian state?, 24 August 2024.
• Are startups engaging in innovation in India?, 25 April 2023.
• Learning by doing and public procurement in India, 5 November 2022.
• The make vs. buy decision of the union government, 18 September 2022.

Reinforcing the Anchor: The Next Five Years of Inflation Targeting in India

by Rajeswari Sengupta and Ajay Shah.

The adoption of inflation targeting (IT) in 2015 marked a watershed in India's monetary policy. It is a delight to look back to those dramatic weeks. For the first time since its establishment in 1934, the Reserve Bank of India (RBI) graduated from being a `temporary provision', to a clear legal mandate to maintain consumer price index (CPI) inflation at 4 percent. This shift to a rule-based and transparent framework, with price stability as the explicit objective, strengthened the RBI's credibility, and helped anchor household inflation expectations by reducing the importance of extraneous objectives.

After the Monetary Policy Framework Agreement, the statutory basis for IT was provided by the Reserve Bank of India Amendment Act (2016). In this, the government, in consultation with the RBI, must review the inflation target every five years. The precise text of this section is:

45ZA. Inflation target - (1) The Central Government shall, in consultation with the Bank, determine the inflation target in terms of the Consumer Price Index, once in every five years.

The next review is scheduled for March 2026. In preparation for this process that would be led by the government, the RBI has released a discussion paper seeking public feedback on four specific questions:

1. Whether headline inflation or core inflation would best guide the conduct of monetary policy, given evolving relative dynamics of food and core inflation and the continuing high weight of food in the CPI basket?
2. Whether the 4 per cent inflation target continues to remain optimal for balancing growth with stability in a fast growing, large emerging economy like India?
3. Should the tolerance band around the target be revised in any way including whether the tolerance band be narrowed or widened or fully done away with?
4. Should the target inflation level be removed, and only a range be maintained within the overall ambit of maintaining flexibility without undermining credibility?

Targeting headline vs. core inflation

A substantial body of academic research and cross-country evidence informs the debate on whether central banks should target headline or core (excluding food and energy) inflation (Pandey and Patnaik, 2020). Walsh (2011) shows that in low-income economies, food inflation is more persistent than non-food inflation, with shocks to food prices spilling over into non-food prices. In such contexts, an exclusive focus on core inflation risks mis-specification. Empirical studies further document sizeable second-round effects from headline to core inflation, driven by the high share of food in household expenditure and the role of food inflation in shaping expectations and wage-setting (Anand, Ding, and Tulin, 2014).

The core function of monetary policy in this context is not to control the first-round effects of a supply shock (e.g., a poor monsoon), but to prevent them from propagating into generalised inflation through second-round effects on wages and expectations. This would be best achieved by having a credible central bank that fully devotes all the power of monetary policy to the pursuit of one transparent objective, headline inflation.

The Indian case illustrates these dynamics clearly. Food and fuel account for half of the household consumption basket, so excluding these components would eliminate a large share of relevant prices from the inflation measure. The Urjit Patel Committee Report (RBI, 2014) underscored that elevated food and energy inflation typically translates into higher inflation expectations, with lagged effects visible in services and other components. Moreover, shocks to food and fuel prices have larger and more persistent effects on inflation expectations than shocks to non-food, non-fuel items. Since anchoring expectations is central to the success of inflation targeting, a framework that sidelines food and fuel inflation would be incomplete.

The cross-country evidence reinforces this conclusion. As documented by Pandey and Patnaik (2020), most inflation-targeting economies use headline inflation as their target. A few, such as Thailand, initially targeted core inflation but later shifted to headline inflation in recognition of its greater relevance for households and firms.

Headline inflation has further advantages. It reflects the cost of living most relevant to households, shaping both their consumption and investment decisions (including choices between financial assets, gold, and real estate). It also serves as the benchmark for firms' price-setting behavior. Since monetary policy ultimately seeks to anchor public expectations, and central bank accountability operates through the political system, credibility depends on targeting the measure most salient to the public.

For these reasons, despite the argument that much of CPI inflation lies outside the direct influence of monetary policy, excluding food and energy would not yield a meaningful measure of inflation for policy purposes. While monetary policy cannot influence a poor monsoon, it is the only tool capable of preventing the resulting food price shock from de-anchoring inflation expectations and triggering a wage-price spiral. Targeting headline inflation forces the Monetary Policy Committee to remain vigilant against these second-round effects, which is the essence of a credible IT framework. Therefore, headline inflation remains the most feasible and appropriate target for the conduct of monetary policy in India.

The 4 percent inflation target

The inflation target should remain at 4 percent. Raising it would risk eroding public confidence in the RBI's ability to control inflation, un-anchoring expectations and undermining the credibility of the framework. From a public debt management point of view, an unanticipated increase in the inflation target is tantamount to a partial debt default. Indeed, higher targets and wider bands are associated with greater output and inflation volatility (Horvath and Mateju, 2011).

Conversely, a reduction to 2 percent would only be feasible once India's financial system is sufficiently developed to operate with limited policy space near the zero lower bound - a condition still many decades away. The sequencing there lies in first getting up to FSLRC level financial economic policy, having it stabilise for about a decade, and then examining the possibility of going down to a 2% target. This is perhaps 25 years away.

Tolerance band around the 4 percent target

The literature broadly agrees that price stability corresponds to an inflation of 1-3 percent in advanced economies, while for emerging economies the relevant range is 4-5 percent (RBI, 2014). Empirical estimates for India place the growth-impeding threshold of CPI inflation at 6 percent. Accordingly, the 1-3 percent benchmark for advanced economies provides a lower bound, while 6 percent marks an upper bound for India. As explained in the Urjit Patel Committee Report, this rationale underpinned the adoption of a 2-6 percent tolerance band under India's inflation-targeting regime.

The principal merit of a band is that it allows a central bank that possesses a weak monetary policy transmission to have failures on meeting the inflation target without a loss of credibility. Back in the 2013-2015 period, there was a `learn to walk before you can run' reasoning around this: it was a fully new idea, that RBI should target inflation, so it was better to start with an easier objective.

Having operated within this framework for a decade, the RBI has established a minimally viable inflation-targeting regime. The logical next step would now be to narrow the band to 3-5 percent, which would strengthen credibility and inspire greater public confidence than the relatively wide 2-6 percent range. Critics may argue that a narrower band increases the risk of a technical breach, potentially harming the RBI's credibility. However, after nearly a decade of experience, the institution should possess the maturity to manage this tighter constraint and, if a breach occurs, to communicate its causes effectively to the public. The credibility gains from signaling a stronger, more precise commitment to the 4 percent target outweigh the communication challenges of a potential supply-shock-driven breach. It shows progress; it signals a move from a nascent to a mature IT regime; it enhances respect for India's continued progress towards better institutions.

Range vs. Point target

Point targets with tolerance bands provide clarity and precision, while their symmetry conveys that the central bank seeks to avoid both deflation and inflation (Hammond, 2012). By contrast, pure range targets risk signaling weaker control over inflation. Consistent with this, most inflation-targeting countries adopt a point target with a tolerance band (Pandey and Patnaik, 2020). For households, moreover, a single, well-communicated number aids planning and decision-making, reinforcing the value of a widely recognized 4 percent target. When wage raises are being planned, we need for decision makers to not look at current and future inflation, but instead think that a 4% nominal wage hike is a 0% real wage hike.

Conclusion

Since its adoption in 2016, inflation targeting has enhanced the RBI's monetary policy credibility (Garga, Lakdawala and Sengupta, 2024). Since its adoption, the IT framework has been a crucial institutional anchor for India's macroeconomic stability. The forthcoming review is an opportunity not to question its fundamental design, but to reinforce it. Maintaining the 4 percent headline target while narrowing the tolerance band to ±1% would signal a confident evolution towards a more mature and credible monetary policy, safeguarding the hard-won gains in anchoring public expectations.

References

Anand, Rahul, Ding Ding, and Volodymyr Tulin (2014) Food Inflation in India: The Role for Monetary Policy, IMF Working Papers 14/178; International Monetary Fund.

Garga, Vaishali, Aeimit Lakdawala and Rajeswari Sengupta (2024) Assessing Central Bank Commitment to Inflation Targeting in Emerging Economies: Evidence From India,Working Papers 107, Wake Forest University, Economics Department.

Hammond, Gill (2012) State of the art of inflation targeting,Handbooks 29; Centre for Central Banking Studies, Bank of England.

Horvath, Roman and Jakub Mateju (2011) How Are Inflation Targets Set?In: International Finance 14.2, pp. 265-300.

Pandey, Radhika and Ila Patnaik (2020) Moving to Inflation Targeting NIPFP Working paper 316, August 2020.

Walsh, James P (2011) Reconsidering the Role of Food Prices in InflationIMF Working Papers 11/71; International Monetary Fund.

The authors are researchers at IGIDR, Bombay and XKDR Forum, Bombay, respectively.

A Score Card for Pre-Legislative Consultation

by Mallika Dandekar and Antaraa Vasudev.

In 2014, the Ministry of Law and Justice published the 'Pre-Legislative Consultation Policy of 2014', the policy aims to create a framework for effective participation in lawmaking. This policy encouraged Ministries and Departments at the State and Central Levels to proactively publish and seek feedback on draft laws and policies.

Pre-legislative consultation, if implemented to its full potential - is a crucial tool in removing the democratic deficit in law formulation and regulatory functioning. Pre-legislative consultation (or public consultation as is commonly referred to), refers to the process of publishing a draft regulation or legislation for public comment for a period of time to gather feedback from practitioners, academics and the lived experiences of citizens impacted by the law. Consultation leads to further deliberation on the instrument, and re-drafting of certain clauses as needed.

While one may make the case for faster lawmaking, consultation if implemented correctly highlights the practical constraints of a law or policy document, which may not otherwise be visible to an administrator, without adequate input from those impacted by the instrument.

While India's history of consultation (particularly among Parliamentary standing committees and regulators) is long standing - the process continues to be viewed largely as a qualitative or unstructured process to be implemented. This poses challenges as it enables a great amount of discretion in consultation methodologies, and subsequently the input that informs the policy.

The subject of Pre-Legislative Consultation has garnered significant traction in Parliament since 2014. Member of Parliament - Supriya Sule proposed the private member bill the 'Pre-Legislative Consultation Bill, 2019', another private member bill was introduced byMember of Parliament - Jagdambika Pal, titled the 'National Consultation Commission Bill, 2019'. The Finance Minister in budget speeches of 2023-24 and 2025-2026 emphasised on the importance of regulatory consultation and impact assessment. More recently RBI, PFRDA and other regulators have made significant strides in codifying the process of consultation. Borrowing from these examples, as well as international best practices - Civis has aimed to devise a robust methodology to assess and evaluate the procedural integrity of India's pre-legislative consultation methodologies across Central, State Governments and regulatory bodies.

What follows is an exploration of the methodology devised to assess consultations, and an open invitation to assist with contributing to and enhancing the methodology. Annually, these parameters are used to assess consultations culminating in a platform to share recognition with those who excel in implementing the process - an initiative known as CIPCA (Civis' Public Consultation Awards).

The 10-Criteria Matrix of the Methodology:

Building upon a robust theoretical and practical foundation, Civis has codified a methodology. This framework combines academic standards and best practices with Civis' practical experience in fostering public engagement. The core of this methodology is a 10-criteria list, organised under four overarching analysis metrics, designed to provide an assessment of any public consultation.

The methodology to assess public consultations relies heavily on India's 2014 Pre-Legislative Consultation Policy, the United Nations Public Consultation Index, OECD's Practitioners Handbook on Public Consultation, and inputs from our jury of practitioners involved in the awards in 2024 and 2025.

A. Quality of Consultation Document

The first set of matrices assess how effectively the government's document presents the proposed policy for public feedback, focusing on its clarity, comprehensiveness, and accessibility.

1. Justification:This criterion looks at whether the consultation document clearly articulates the rationale behind the proposed policy or legal change. Is the problem it seeks to address defined well, with the context in which it is being proposed, including relevant background, existing issues, and the objectives it aims to achieve? A strong justification helps citizens understand the 'why' behind the proposal, enabling more informed and relevant feedback. Assessing the justification required qualitative assessment of the Consultation document. The jury across the first and second edition has retained this criterion as its original conception.

   This criterion is borrowed from the Pre-Legislative Consultation Policy, particular Section 2 that reads "The Department/Ministry concerned should publish/place in public domain the draft legislation or at least the information that may inter alia include brief justification for such legislation, essential elements of the proposed legislation, its broad financial implications, and an estimated assessment of the impact of such legislation on environment, fundamental rights, lives and livelihoods of the concerned/affected people, etc". This section has also helped shape the next 3 criteria, as detailed below.

2. Essential Elements: This criterion looks at whether the proposed changes, new provisions, or key components of the draft are clearly outlined. Citizens should be able to easily identify and understand what exactly is being proposed, and its key features. These include any proposals being made, key rights and penalties, or any other government intervention or policy decision. The qualitative test is to discern whether these proposals are clear, with no room for ambiguity.

3. Impact Assessment: Has the potential impact of the proposed draft, including financial, social, environmental impact, been analysed and stated within the document? The third criterion looks at this issue in great detail. Transparency about potential impacts, both positive and negative, is crucial for citizens to assess the draft's broader implications and offer feedback after considering these effects. In edition one of the awards, the impact assessment was calculated uniformly across the financial, social and economic impacts flowing from the policy and whether it was articulated. This was an extremely subjective process, validated by each level of deliberation.

   However, as we evolved the criteria for the second edition through fresh deliberations with the jury, it led to a demand for increasing the granularity and detail in how this criterion was evaluated. Hence, we sought support from the Trustbridge Foundation, and the team led by Dr. Renuka Sane, who further refined this criterion to include 25 sub-questions that were answered to arrive at the overall score.

4. Comprehension: This criterion asks the question of whether the draft can be easily understood by an average reader, even if they do not possess specialised domain expertise? This criterion qualitatively evaluates the document's readability, clarity of language, and overall user-friendliness. Is the language unambiguous, avoiding jargon where possible or providing clear explanations for technical terms? Complex technical concepts should be simplified or accompanied by clear explanations, and the document should be free of excessive jargon or overly academic prose.

   In addition to Section 2 of the PLCP, it also follows on the heels of Section 5 of the PLCP - "Every draft legislation or rules, placed in public domain through prelegislative process should be accompanied by an explanatory note explaining key legal provisions in a simple language".

B. Scope of Engagement Opportunities

These matrices evaluate the breadth and effectiveness of the consultation's reach and the opportunities they provided for stakeholders to engage.

1. Duration: Here, we looked at whether a consultation is open for a reasonable period, allowing sufficient time for stakeholders to review the document, understand its implications, and prepare their feedback. An inadequate consultation period can severely limit participation and the quality of feedback. This criterion is derived from Section 2 of the PLCP which reads: "...Such details may be kept in the public domain for a minimum period of thirty days for being proactively shared with the public in such manner as may be specified by the Department/Ministry concerned".

   Across the two editions, the manner of scoring this criterion has evolved through deliberations with the jury. In year one, a more granular approach was adopted, similar to the other criteria, where a range of scores from 1-5 were applicable on a sliding scale based on the number of days a consultation was open for. This looked like:

   • Consultations that gave less than 20 days were marked a 1,
   • Those that allowed between 20 to 29 days were given 2 points,
   • Those that met the PLCP criteria of 30 days exactly received 3 points,
   • Those that allowed for 30 to 59 days received 4 points, and lastly,
   • Those that allowed for 60 days of more for comments received a full 5 points.

   However, the jury in the second edition recommended moving to a binary approach, where only two quantitative scores were possible: 1 for any consultation open for a duration under 30 days, and 5 for any consultation open for 30 days or higher. This was a deviation from our first edition, and it reflects the duration provision contained in the PLCP. In order to have a binary scoring, but not conflict with the scale on the rest of the criteria, 1 and 5 were chosen as the binary scoring indicators.

2. Outreach: Here, we consider if the outreach was comprehensive and diverse through various media and channels to ensure the consultation reached a broad range of relevant stakeholders and the general public. Effective outreach goes beyond merely publishing on a government website; it involves active dissemination through different platforms (e.g., print media, social media, community forums, targeted invitations) to maximise visibility and encourage participation. A compilation of all consultation outreach helped score the efforts undertaken by the relevant department.

   The criterion is derived from Section 3 of the PLCP which reads "Where such legislation affect specific group of people, it may be documented and disclosed through print or electronic media or in such other manner, as may be considered necessary to give wider publicity to reach the affected people".

C. Inclusivity

This set of matrices focuses on ensuring that the consultation facilitated diverse participation and equitable access for all citizens, regardless of their background or location.

1. Feedback Collection: The criterion considers whether multiple, accessible avenues were provided for stakeholders to submit their responses and feedback. This includes online portals, email, postal addresses, and potentially public hearings and interviews. Offering a variety of channels ensures that citizens with differing levels of digital literacy or access can participate effectively.

   This criterion builds on the principle outlined in OECD Practitioner's Guide on Stakeholder Consultations, which recommends evaluating consultations on the "transparency of the process and accessibility of the consultation, e.g., was there an equal opportunity to take part, was the process easily understood by stakeholders".

2. Translations: Here we considered if the consultation document translated into regional languages is relevant to the target audience. In a linguistically diverse nation like India, providing materials in national and local languages is paramount to ensuring true inclusivity, allowing citizens to engage with the content in their mother tongue and participate meaningfully. In addition, braille and sign language transcriptions have also greatly aided the accessibility of some drafts.

   Translation and accessibility of policy documents across languages is emphasised in OECD Practitioner's Guide on Stakeholder Consultations. The Guide recommends that consultation bodies "assure clear and plain language drafting, including in translations".

   Through deliberation, jury members concurred that English and Hindi translations for consultations with a national scope, and English and 1 regional language for a consultation with a regional scope would be scored quantitatively.

D. Open Governance

This final set of matrices examine the transparency and responsiveness of the consulting body throughout and after the consultation process.

Both transparency and responsiveness were created as qualitative criteria on the recommendation of the jury members on our inaugural edition of the awards. These criteria aim to highlight the importance of the completion of feedback loops and providing publicly accessible data, which are higher order asks - but extremely important to determine the responsiveness of policy making.

1. Transparency: Did the consulting body provide a report, a summary, or publish the responses received (in part or in entirety) after the close of the consultation period? Transparency in feedback processing is vital for accountability. It demonstrates that public input was received, analysed, and potentially influenced the final policy, fostering trust between citizens and government. It is also aligned with existing PLCP sections like Section 6 "The summary of feedback/comments received from the public/other stakeholders should also be placed on the website of the Department/Ministry concerned". Additionally, elements of this were also derived from a public consultation index created by UNDP (Page 16 of ASSESSING PUBLIC PARTICIPATION IN POLICY-MAKING PROCESS).

2. Responsiveness: The question to be considered here was if the consulting body is responsive to communications made through letters, RTIs, or other means by citizens or civic organizations.

   Responsiveness demonstrates that the government is open to dialogue and willing to address queries and provide information after the consultation process, reinforcing trust and encouraging future participation. Adding to transparency, responsiveness creates an additional avenue to allow government departments to publish and share information regarding the consultation process, i.e. even if they are not shared on their public websites and notices, they are open to sharing this information when specifically requested.

Application of the Methodology - Draft Kerala IT Policy 2023:

To better understand the methodology, we examine the Draft Kerala IT Policy 2023, ("Draft Policy") and through it explore how the methodology to assess Pre-Legislative consultation in India can be improved upon.

The draft policy in question received an overall score of 37 out of a possible 50 on the scale, translating to a 74% effectiveness rating in the last edition of the awards. In order to contextualise the draft as against other draft documents the mean and the standard deviation for the complete data set of 286 consultations has been calculated. This comparison is only illustrative, as the lawmaking procedures and maturity across State Governments, Regulatory Bodies and Central Legislators differ greatly.

This policy, released in September 2023, aims to be a blueprint for the state's IT sector growth and citizen well-being through digital technologies. We will integrate its performance against each criterion to provide a tangible illustration of Civis' methodology in action.

A. Consultation Quality - Draft Kerala IT Policy 2023

1. Justification: The Draft Policy scored outstandingly well (5/5) on this criterion. Sections 1.1 and 2.1 of the policy thoroughly state the need for an IT policy for Kerala. This is further supplemented by details regarding the state's and India's current IT infrastructure and the opportunities for Kerala to contribute to its betterment.

   The policy provides a clear background, detailing Kerala's historical strengths in IT (e.g., establishing Technopark in 1990) and the need for a new policy framework given global and national shifts in the digital landscape. It explicitly states its two-fold objective: leveraging IT, Electronics, and Space sectors for economic growth and adopting digital technologies for equitable, inclusive societal development.

   Mean Score: 2.74
   Standard Deviation: 1.49

2. Essential Elements: On this, the Draft Policy also received an outstanding score (5/5). Chapter II, titled 'Policy Framework,' meticulously lays down all essential elements, including 'Directions for Growth' (differentiating between economic and social development), 'The Enablers,' 'New Policy Framework,' and 'Policy Objectives.' Notably, section 2.2 explains the anticipated outcomes if the policy is implemented, showcasing forward-thinking and depth of thought. Furthermore, the policy addresses cybersecurity concerns through a dedicated section on 'Information Security' (Section 3.4) and discusses the augmentation of IT industry infrastructure via the development of four IT corridors in section 4.3.

   Mean Score: 3.73
   Standard Deviation: 1.12

3. Impact Assessment: The draft policy exceeded the average score here (4/5). The document effectively identifies the need for an IT policy in Kerala, backed by industry trends and growth potential. Stakeholder engagement and impact articulation are strong, as the Draft Policy incentives and investments for each business category separately. However, cost-benefit analysis and alternative strategies were not present explicitly, which was penalised. While implementation details exist, they lack clear timelines. Additionally, environmental impact, long-term evaluation, and rural integration were minimally addressed.

   Mean Score: 2.54
   Standard Deviation: 1.31

4. Comprehension: The policy also received a 4/5 for comprehension. The draft IT Policy is logically structured and emphasises inclusivity, innovation, and social equity. While it provides detailed objectives, strategies, and frameworks, its technical language may challenge non-expert readers slightly, but not significantly. Visual aids or summaries were absent which could have enhanced accessibility, and hence one point was lost. The document maintains clarity throughout, with no apparent contradictions.

   Mean Score: 3.28
   Standard Deviation: 1.03

B. Scope of Engagement Opportunities - Draft Kerala IT Policy 2023

1. Duration: The Draft Policy scored a 5/5 for its duration. The consultation period was from October 27, 2023, to January 31, 2024, for a total of 96 days. This significantly exceeds the recommended 30-day minimum, providing ample time for review and feedback.

   Mean Score: 2.85
   Standard Deviation: 1.23

2. Outreach: The Draft Policy received a 4/5 for its outreach efforts. The Government of Kerala extensively leveraged social media platforms, with posts found by Infopark, Technopark, and Kerala IT on X. Instagram posts were traced on Cyberpark Kozhikode and Infopark pages, and Facebook was utilized by Kerala IT, Technopark Trivandrum, Infopark, and Cyberpark Kozhikode. Several of these government undertakings also created awareness through their LinkedIn pages. The Draft was also available on the Kerala State Information Technology Infrastructure Limited (KSITIL)'s website. Furthermore, the erstwhile Secretary of the Kerala Electronics and Information Technology department utilized digital media to spread information about this policy.

   Mean Score: 1.49
   Standard Deviation: 0.80

C. Inclusivity - Draft Kerala IT Policy 2023

1. Feedback Collection: Here, the Draft Policy needed improvement (2/5). The Draft Policy did not mention any feedback collection mechanism. However, a webpage was created (https://itpolicy.startupmission.in/) to accept feedback in both English and Malayalam. While a digital portal was available, the lack of explicit mention within the policy document itself and potentially limited other traditional avenues for feedback impacted its score.

   Mean Score: 2.40
   Standard Deviation: 0.69

2. Translations: The Draft policy meets average expectations (3/5) in this category. The Draft is available in both English and Malayalam. This demonstrates a decent effort towards linguistic inclusivity, allowing a wider segment of the population in Kerala to access and understand the policy in their state language.

   Mean Score: 1.50
   Standard Deviation: 0.86

D. Open Governance

1. Transparency: The Draft Policy scored very low (1/5) on transparency. No published reports or public comments were found after the consultation period. Despite the general emphasis on e-Governance and proactive data disclosure within the policy, the lack of specific mechanisms for publishing feedback on this particular draft significantly impacts its score significantly.

   Mean Score: 1.59
   Standard Deviation: 1.20

2. Responsiveness: The Draft Policy exceeds expectations (4/5) in responsiveness. The Government of Kerala responded to Civis' RTI request and answered every question about the process individually. They also provided a list of all comments they received and shared that the final version of the document was not out yet, indicating that the consultation process still has the potential to yield changes to the policy. The criterion of responsiveness was only scored for the final 26 nominees, as data gathering for the full data set would be difficult. With that in mind, the scores for the 26 nominees are:

   Mean Score: 3.84
   Standard Deviation: 0.69

Conclusion

Codifying a methodology for assessment is the first step in building the legitimacy of the process of public consultation. Laying out a pathway for greater efficacy in consultations, and an enhancement of procedural trust in lawmaking as a whole.

The methodology outlined above works towards standardising a growing practice of consultation in India. However, there are unique improvements in consultative practices that we can look to from countries like Taiwan - which has institutionalised the platform vTaiwan, an open-source deliberative platform that brings together policy makers and citizens to deliberate national issues. Another example comes from the European Union's Regulatory Fitness and Improvement (REFIT) program which requires stakeholder consultation at all stages of policy formulation i.e., problem definition, solution identification, drafting, and evaluation.

While the domain of consultation is evolving, the authors invite scrutiny and feedback to enhance the parameters and measures of this methodology. With the aim of creating a practical and evolved framework for consultation evaluation and best practices in the country.

We invite suggestions on:

• Strengthening specific parameters of the evaluation framework.
• Defining the guardrails for what may constitute policy paralysis as opposed to constructive deliberation.
• Highlighting other consultative best practices which don't find mention in the methodology.
• Identifying national/international best practices that can be suggested to policy makers in the country.

Mallika Dandekar and Antaraa Vasudev are researchers at Civis.

Author: Manish Kumar Singh

Manish Kumar Singh is a researcher at IIT Roorkee.

On this blog:

• Who lends to the Indian state?, 24 August 2024.
• Does financial and macro policy explain household investment in gold?, 24 January 2022.
• Stockholm Syndrome in Indian Organizational Culture, 30 May 2020.
• Time to resolve insolvencies in India, 11 March 2019.
• The geography of firms and firm formation in India, 1 March 2019.
• User rights as a novel instrument for infrastructure financing, 19 September 2014.

A narrow path for India and China: de-risking engagement for a cautious peace

by Ajit Ranade, Nitin Pai, Ajay Shah.

The relationship between India and China is at its most difficult point in decades. A foundation of political and military hostility, marked by violent border clashes and a strategic rivalry across Asia, makes any notion of a simple partnership untenable. China’s authoritarian state, its ambition for regional dominance, and its use of economic power as a tool of statecraft present clear and present dangers to India’s national interest. In this environment, a policy of naive engagement is not optimal.

Yet, a policy of complete economic decoupling is equally problematic. China is central to the global economy, an important force in manufacturing, technology, and trade. There is a shared border with India, and with the two countries adding up to 40% of humanity, there are natural opportunities for many kinds of partnerships between Chinese persons and Indian persons. A self-imposed isolation from the world’s second-largest economy carries an opportunity cost for us in India. We need capital to fuel our growth and build infrastructure. The current policy framework reflects this unresolved tension. Measures such as Press Note 3, which mandate government screening for all investment from bordering countries, have hindered new streams of Chinese capital. As of April 2024, 200 of the 526 FDI proposals received under PN3 were awaiting approval. This has its merits, but we do need to find some unfreezing as part of long-term strategy.

The policy question is not whether to engage, but how. How can India interact with a hostile neighbour in a way that captures economic benefits without incurring unacceptable security risks? The debate has been trapped in a false binary between total engagement and total isolation. The intellectual challenge is to design a third way: a policy of "quarantined engagement," where economic inputs like capital can be accepted while the associated strategic risks are neutralized at the point of entry. As Adam Smith said, Trade with barbarous nations requires forts, trade with other nations requires ambassadors.

This article resurrects old ideas that help find this path. We argue in favour of a highly constrained, de-risked channel for Chinese capital into Indian infrastructure. This is not a call for a broad reopening or a return to a more optimistic era. It is a pragmatic, narrow, and carefully controlled mechanism designed for an adversarial relationship. The core proposition is that it is possible to surgically separate Chinese capital from the control, technology, and geopolitical leverage that usually accompany it. Under a strict framework of safeguards, Chinese investment can be transformed from a strategic threat into a simple financial commodity, one that can serve India’s developmental needs while building, over the long term, a small but tangible stake in a stable peace. Such an arrangement would be win-win for both sides: This is good for China also.

Any credible proposal for engagement must begin with a clear-eyed assessment of the risks. The case for a narrow channel of economic contact is not born of optimism, but of a sober understanding of the multifaceted threat China poses. These threats are not discrete; they form an integrated strategy where economic, technological, and military actions are mutually reinforcing. Any Indian counter-policy must therefore be equally integrated.

Strategic and military hostility

The foundation of distrust is geopolitical. The 2020 Galwan Valley clash was the most violent manifestation of a pattern of Chinese military aggression along the Line of Actual Control. This hostility is not confined to the Himalayas. Beijing’s strategic support for Pakistan, its expanding military and economic footprint in nations across South Asia -- from Sri Lanka to Bangladesh and the Maldives -- and its explicit of achieving uni-polarity in Asia are all inimical to Indian interests. This sustained pattern of behaviour demonstrates that China is not a benign competitor but a strategic adversary.

The weaponisation of economic interdependence

China has repeatedly demonstrated its willingness to use economic interdependence as a coercive tool. India’s reliance on Chinese supply chains for critical goods, from active pharmaceutical ingredients (APIs) to electronic components, creates a significant vulnerability. Beijing has the ability to "pull the plug" on these supplies, as it has done with certain restricted exports, weaponizing trade to exert political pressure.

This risk is compounded by China’s internal economic troubles. A structural problem of overproduction, rooted in weak domestic demand and a collapsing real estate sector, has led Beijing to manage its economy by exporting its unemployment. A flood of cheap, often subsidized, Chinese goods—from solar panels to electric vehicles—threatens to overwhelm and destroy nascent Indian industries. This is not merely market competition; it is a strategic economic offensive that requires a defensive response.

The technological trojan horse

The third vector of threat is technological. There are well-documented security hazards associated with Chinese electronics and software. Global security agencies have long held concerns that telecommunications equipment and other hardware contain embedded spyware or backdoors, giving the Chinese state a potential lever for espionage or sabotage. Chinese manufacturers often do not provide full specifications of algorithms, making it nearly impossible to screen for malicious code. This creates an unacceptable risk, particularly in critical infrastructure. The recent weaponisation of social media platforms like TikTok to conduct influence operations in Taiwan serves as a stark reminder of how apparently civilian Chinese technology is deployed to achieve Chinese state objectives.

An old idea for a harsher time

The three problems described above are not separate challenges. A state that exerts military pressure on the border is the same state that will use economic supply chains and technological dependencies as levers of power. A policy that addresses only the trade deficit or only military preparedness is incomplete. A sound strategy must be holistic, designed to neutralize all three threat vectors simultaneously. We think there is a clear possibility in infrastructure financing.

The proposal to channel Chinese capital into Indian infrastructure is not new. Its intellectual foundations were laid over a decade ago, in a very different geopolitical climate. In 2013, one of us (Ajit Ranade) first articulated the synergy that exists between China’s problem of a chronic current account surplus, and India’s infrastructure financing gap. At the time, China’s reserves stood at around \$3 trillion, much of it earning low yields in US treasury bonds. India, meanwhile, needed over \$1 trillion to fund its infrastructure development. A direct investment alliance was proposed, suggesting that even a small fraction of China’s capital -- just 1% annually -- could make a material difference to Indian infrastructure investment.

This economic logic was developed by one of us (Nitin Pai), with the idea that such investments should be directed towards specific, low-risk assets. The insight was that "concrete infrastructure, such as highways and bridges," would be in both countries' interests, providing China with decent long-term returns and India with low-cost financing. Crucially, such assets "do not undermine national security, nor do they lock us into Chinese technology." The key insight was that while India should be open to such investment, it must never be treated as an "ordinary economic relationship".

These ideas were conceived in an era of cautious optimism, a time when some observers still spoke of an "evolving maturity" in the relationship. The reality of the subsequent decade, with enhanced nationalism and militarism in China, with the journey from Doklam to Galwan to Operation Sindoor on the Indian relationship, makes us more cautious. However, the failure of that optimism does not invalidate the underlying economic logic. If anything, the fundamental asymmetry has grown more pronounced. China’s internal economic model has produced an even greater capital surplus in search of stable returns, while India’s infrastructure needs have expanded on its path to becoming a \$5 trillion economy.

The logic of the transaction is stronger than ever. What has changed is the risk assessment. Therefore, the task today is not to discard this old idea but to harden it. It must be adapted for the present moment of hostility by encasing it in a robust framework of security protocols, transforming it from a tool of hopeful engagement into a mechanism for de-risked, pragmatic co-existence.

A framework for safe capital: The three locks

For Chinese capital to be acceptable, it must be rendered strategically inert. This requires a framework of safeguards -- a system of "three locks" -- designed to strip the investment of any potential for geopolitical leverage, espionage, or strategic entrapment. This transforms the nature of the transaction from a potential vector of hostile influence into a simple commodity purchase, where India is procuring capital under tight conditions.

The first and most critical safeguard is the separation of ownership from control. Under this rule, Chinese entities may act as pure financial investors -- either as equity holders or debt providers -- but they should be explicitly and legally denied any role in the management, operation, or maintenance of the infrastructure asset. Their role should be purely passive and financial.

The rationale for this lock is to prevent the weaponization of critical infrastructure. A cautionary tale comes from Europe’s recent experience with Russia. Gazprom, the Russian state-owned energy giant, was not just a supplier of gas to Germany; it also owned and operated critical gas storage facilities on German soil. In the months leading up to the 2022 invasion of Ukraine, Gazprom strategically ensured these storage tanks were left empty, deliberately manufacturing an energy scarcity within Germany that amplified Russia’s blackmail potential and left Germany more exposed. Allowing a strategic adversary operational control over critical infrastructure is an invitation to disaster. The operational lock is designed to prevent such a scenario from occurring in India.

The second safeguard is a ban on Chinese-origin technology within the funded asset. This means no Chinese-made hardware, software, sensors, control systems, or any other networked components. All procurement for technology, from surveillance cameras on a bridge to the software running a water treatment plant, should be sourced from approved, non-hostile jurisdictions.

This lock neutralizes the threat of technological Trojan horses. The global security establishment has consistently raised alarms about the risk of embedded spyware and hidden backdoors in Chinese-made equipment, from telecom networks to military sub-assemblies. Given the opacity of the technology and the near impossibility of conducting foolproof screening, the only truly secure approach is a blanket prohibition. The technology lock ensures that an infrastructure asset funded by Chinese capital cannot become a listening post or a vector for cyber-attacks.

The third safeguard is a risk-based, incremental approach to implementation. Engagement must not begin with a broad opening, but with a carefully phased and probationary process. The initial phase should be strictly limited to what can be termed "dumb infrastructure" -- assets with minimal technological sophistication and low strategic vulnerability. This category includes projects like roads, bridges, irrigation canals, and water and sanitation plants. These are physical assets where compliance with the operational and technology locks is easiest to monitor and enforce.

Only after a decade or two, during which Chinese investors demonstrate consistent and verifiable compliance with the first two locks, could India consider expanding the scope to more complex areas. This phasing creates a crucial probationary period, allowing India to observe behaviour, build confidence in its regulatory capacity, and retain an off-ramp if Chinese entities fail to adhere to the rules. India’s existing FDI screening mechanism, institutionalized in Press Note 3, provides a legal and administrative precedent for managing such a structured, approval-based process. More work is required on the Indian side to achieve institutional quality in such screening.

A better bet for Beijing

A skeptical reader might ask: why would China agree to such restrictive terms? The answer lies in a rational assessment of its own self-interest. From a purely financial perspective, a de-risked, passive investment in Indian infrastructure is a far superior proposition to many of the high-risk ventures China is currently entangled in across the developing world. China has a big and structural current account surplus: the economic system suppresses consumption and lacks good investments at home, so capital must go out. Their choices for destinations for this capital -- from financial assets in the West to infrastructure assets in developing countries -- are all problematic.

China’s flagship Belt and Road Initiative (BRI) has a deeply troubled track record. Beijing is now navigating the uncomfortable role of being the world's largest official debt collector. An astonishing 80% of its overseas lending portfolio in the developing world is supporting countries already in financial distress. Overdue repayments are soaring, and many borrower nations, which have poor credit ratings and unstable political environments, are at high risk of default. The result is that for the next decade, China is set to be more of a debt collector than a banker to the developing world, facing a "tidal wave" of repayments from countries that simply cannot pay.

Investing in India under the proposed framework offers a different risk-return profile. India has maintained its investment-grade credit rating for nearly two decades, has a consistent history of honoring its sovereign and commercial commitments, and possesses a stable political system anchored by some rule of law. While returns might be more modest than the nominal rates on risky BRI loans, they would be predictable, secure, and denominated in a relatively stable currency. For Chinese state-owned banks and funds seeking to diversify their portfolios and secure safe, long-term yields, a passive financial stake in the growth of one of the world's fastest-growing major economies is a rational choice. The proposal is not a concession asked of Beijing; it is a superior financial opportunity offered to it.

Conclusion: Building a stake in stability

This proposal is not a policy of friendship. It is a strategy of pragmatic, self-interested, and de-risked engagement designed for a world of wary rivals. The immediate goal is to build Indian infrastructure with low-cost capital. But the long-term strategic objective is more subtle and more significant. It is to give China a tangible, financial stake in India's economic success and, by extension, in regional stability.

In international relations, particularly between rival powers, the creation of mutual interdependencies -- even highly constrained ones -- can act as a stabilising force. The current India-China relationship is almost entirely a zero-sum game, where a gain for one side is perceived as a loss for the other. This framework introduces a small but meaningful positive-sum element. By creating a channel where Chinese state-owned entities can profit directly from India’s continued economic growth, it adds a new variable to Beijing’s strategic calculus. It introduces a direct financial cost for actions that might destabilize India and the region. Chinese ownership of \$100B of bridges in the Indian Himalayas changes the logic of a next invasion.

This will not resolve the fundamental strategic conflict between the two nations. It will not end the border dispute or erase the deep-seated mistrust. What it can do, however, is build a small constituency within the Chinese state whose interests are aligned with a stable and prosperous India. Over a decade, as such a portfolio could potentially grow, the cost of conflict for Beijing would rise. This is the long-term payoff: not a chimerical peace, but a measure of calculated, self-interested restraint born from a tangible stake in the status quo. It is a modern, economic form of deterrence. To dream of a better peace over a ten-year or twenty-year horizon, we must lay the foundation through safe, feasible, and mutually beneficial steps today. This is one such step.

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