Interesting readings

Strategy for dealing with the banking crisis by Ajay Shah in Business Standard, March 6, 2017.

Mahesh Vyas in the Business Standard about consumer sentiment after demonetisation, March 6, 2017.

Abhijit Banerjee in the Hindustan Times about GDP overestimation, March 6, 2017.

The Politics of Public Interest Litigation in Post-Emergency India by Anuj Bhuwania on NIPFP YouTube Channel, March 6, 2017.

U. K. Sinha speaks with Menaka Doshi, on BloombergQuint, March 5, 2017.

How Uber could end up as Silicon Valley's most spectacular crash, by Kevin Maney in Newsweek, March 4, 2017.

Making sense of algorithmic trading by Nidhi Aggarwal and Susan Thomas in Business Standard, March 3, 2017.

Closing of the University by Pratap Bhanu Mehta in The Indian Express, March 3, 2017.

Govt can do better with Sebi chairman's appointment process by Mobis Philipose in Mint, March 2, 2017.

Speaking Marathi not compulsory for auto permits: Bombay High Court by Ruhi Bhasin in The Indian Express, March 2, 2017.

Fixing the minimum premium price: The insurance cartel may just be back by Shyamal Majumdar in Business Standard, March 2, 2017.

RBI's monetary policy committee must improve its communication by Rajeev Malik in Mint, March 2, 2017.

Organisational hurdles in telecom sector by Shyam Ponappa in Business Standard, March 1, 2017.

India Post Payments Bank will keep operations simple: CEO Ashok Singh by Vivina Vishwanathan in Mint, March 1, 2017.

When debt funds malfunction by Monika Halan in Mint, March 1, 2017.

JPMorgan Software Does in Seconds What Took Lawyers 360,000 Hours by Hugh Son on Bloomberg, February 28, 2017.

Speedbreakers kill over nine a day, half of deaths in UP, TN & Karnataka by Anil Sasi in The Indian Express, February 28, 2017.

In court complex where Kanhaiya Kumar was attacked, police say they can now tackle any situation by Abhishek Dey in Scroll, February 27, 2017.

RBI deputy governor R Gandhi responds to the Watal panel report ; our take by Shashidhar KJ in Medianama, February 27, 2017.

Robert Mercer: the big data billionaire waging war on mainstream media by Carole Cadwalladr in The Guardian, February 26, 2017.

Revealed: how US billionaire helped to back Brexit by Carole Cadwalladr in The Guardian, February 26, 2017.

Who made my cheese? by Aditya Raghavan in The Hindu, February 24, 2017.

What The New SEBI Chairman Must And Must Not Do by Somasekhar Sundaresan on Bloomberg, February 24, 2017.

The Seemingly Immovable Object Standing in the Way of India's Satellite Internet Ambitions by Anuj Srivas in The Wire, February 23, 2017.

Governments must be held to account by Sachin Dhawan and John Sebastian in Business Line, February 23, 2017.

Animals know when they are being treated unfairly (and they don't like it) by Claudia Wascher in The Conversation , February 22, 2017.

Immediate challenges for new Sebi chairman by Somasekhar Sundaresan in Business Standard, February 22, 2017.

In pictures: Seven new species of night frogs discovered in the Western Ghats by Vinita Govindarajan in Scroll, February 21, 2017.

Who's To Blame For HDFC Bank Violating The Foreign Investment Limit? by Menaka Doshi in Bloomberg, February 20, 2017.

The Post-Human World by Derek Thompson in The Atlantic, February 20, 2017.

Why Cut Down Trees When They Can Be Translocated? Meet the Man Who Has Moved 5000 Trees This Way! by Aparna Menon in The Better India, February 20, 2017.

Burner phones are good for democracy. How to Run a Rogue Government Twitter Account With an Anonymous Email Address and a Burner Phone by Micah Lee in The intercept, February 20, 2017.

Why You'll Never Do Your Best Work Alone by Jeff Goins on fastcompany, February 18, 2017.

Public goods for health in India by Jeffrey S Hammer on NIPFP YouTube Channel, February 15, 2017.

4chan: The Skeleton Key to the Rise of Trump by Dale Beran on Medium, February 14, 2017.

Open access to expert reports? by A K Bhattacharya in Business Standard, February 14, 2017.

No Relief without Interim Relief by Somasekhar Sundaresan on Wordpress, February 9, 2017.

The size of personal bank credit in India

by Renuka Sane and Anjali Sharma.

In May, 2016, the Insolvency and Bankruptcy Code, 2016 (IBC) law was passed by Parliament and received Presidential assent. The law consists of provisions for both corporate and personal insolvency. However, only the corporate insolvency provisions of the law have been notified and are being implemented. The rapid implementation of the corporate insolvency provisions is largely a response to the policy discourse on the non-performing asset (NPA) problem of the banking sector.

In this article, we turn our attention to personal credit extended by banks, with a view to informing policy actions on the personal insolvency provisions of the IBC. While banks are just one source of personal credit amidst a variety of institutional and non-institutional sources, they are the largest "formal" source of credit, and therefore, the first likely users of the insolvency provisions. Understanding the nature and composition of personal credit extended by banks has implications for effectively designing the procedural aspects of of insolvency resolution under the Code, as well as the institutions that enable the resolution. The decisions surrounding personal insolvency can help lay the foundations for a healthy market for individual credit.

Bank credit to the HH sector

We use the data from the Quarterly BSR-1: Outstanding Credit of Scheduled Commercial Banks released by the RBI. This is a quarterly data series, from March, 2014 till September, 2016, which provides the composition of bank lending by organisation, occupation, loan size, interest rate bands and regions. RBI classifies household (HH) sector credit into three categories. These are credit to: (1) individual borrowers, (2) proprietary concerns, joint families and unregistered partnerships, and (3) joint liability groups (JLG), NGOs and trusts. The data gives us the following details on the size and composition of lending to this sector:

1. HH sector credit is large, both in terms of value and accounts.

   In September, 2016, credit to the HH sector was Rs. 32.2 trillion, 44.3% of the total credit given by banks. In terms of number of loan accounts, HH sector accounts were 98% of the total accounts of the banking system (Table 1). Within the HH sector, credit to single individual borrowers was the largest component, both in terms of value and in terms of accounts.

Table 1: Household sector credit in India

	Loan accounts	Loan value
Categories	(million)	(Rs. trillion)
Total bank credit	143.7	72.7
O/w credit to HH sector	140.2	32.2
- Individuals	134.3	25.2
- Proprietors/ partnerships	3.0	6.3
- JLGs, NGO, Trusts	2.9	0.7
Source: RBI, Quarterly BSR I, Table 1.6

2. Bank credit to HH sector is growing at a faster rate than credit to the corporate sector.

   In the last six quarters, from Q1 2015 to Q2 2016, bank credit to the HH sector has seen an average quarter-on-quarter (Q-o-Q) growth of 3%. By contrast, in the same period, bank credit to non-HH sectors has only seen an average Q-o-Q growth of 0.3%.

3. Bulk of HH sector credit is given as agri loans and personal loans.

   Personal loans (mostly in the form of secured housing and vehicle loans) and agri loans account for Rs. 22 trillion or 67% of the total bank credit to the HH sector. Average loan sizes are relatively small, Rs. 1.2 lakhs per loan for agriculture and Rs. 2.6 lakhs per loan for personal loans.

   The remaining 33% is spread mainly across three sectors: industries (12%), trade and transport (13%) and professional services (6%). These loans are in the nature of business loans. Within industries, most loans are given to proprietors and partnerships, and at an average of Rs. 9.3 lakhs loan size, are relatively large. In trade, transport and services, average loan size is between Rs. 3.5 to Rs. 5 lakhs per loan.

4. Southern and western regions account for more than 60% of agri and personal loans, by value and by accounts.

   38% of agri and personal loans by value, and 46% of the loan accounts, are in the southern region. 24% of loan value and 19% of loan accounts are in the western region. Two states: Tamil Nadu and Maharashtra account for 40% of the loan accounts and 30% of the loan value.

5. Agri loans are given mainly in rural and semi-urban centers while personal loans are given mainly in urban and metropolitan centers.

   Around 85% of agri loan accounts and 72% of the loans by value are given in rural and semi-urban centers. These are places with population less than 0.1 mn. In case of personal loans, 58% of loan accounts and 51% of loans by value are given in metropolitan areas. These are centers with population of 1 mn or more.

6. Agri credit is largely short tenure whereas personal loans are medium to long tenure.

   70% of agri credit is given in the form of cash credit or as demand loans. In contrast, more than 80% of personal loans are medium to long tenure loans.

7. The interest rate distribution of agri and personal loans suggests that, at an aggregate level, there is limited margin for NPAs

   Table 2 shows the distribution of agri and personal loans by interest rate ranges. A comparison of the lending rates with the marginal cost of lending rate (MCLR) for State Bank of India from September, 2016 shows that the margin available for NPAs is limited. The short term MCLR, relevant for agri loans, is 9.05%. Around 56% of agri loans, are in the 6 - 11% lending rate category, suggesting a less than 2% room for NPAs. Similarly, the MCLR relevant for personal loans is 9.25%. 67% of personal loans are in the 6 - 11% lending rate category, suggesting a less than 1.75% room for NPAs.




Table 2: Agri and personal loan lending rates

Lending rate	% agri-loans	% personal loans
Less than 9%	25%	5%
9% - less than 11%	31%	62%
11% - less than 13%	32%	16%
Above 13%	12%	17%
Source: RBI, Quarterly BSR I, Table 3.3

8. Banks have limited mechanisms for enforcement.

   Currently, banks can avail of SARFAESI for resolving secured loans. However, for individual debtors it is used more as a deterrent than an actual enforcement mechanism. DRTs, with their threshold of Rs. 10 lakhs, are available only to the 6-7% of personal credit loan accounts which meet the threshold. For the remaining segments of personal credit, the only mechanism available is the slow and costly Civil Court system. Some banks use the provisions of the Arbitration and Conciliation Act, 1996 for recovery. However, the enforcement of arbitration awards relies on the Civil Court system. There is no collective resolution process available to deal with an individual with a portfolio of loans. Each lender has to pursue its recovery action separately. This proves to be inefficient and costly.

In summary, the data tells us four important facts about personal credit given by banks. First that it is diverse, in terms of borrower profile, loan profile, and geographical spread. Second, it is growing at a faster rate than overall bank credit, given the slowdown in corporate credit and banks increased focus on extending personal credit. Third, the difference between lending rates and marginal cost of lending for this segment is narrow, leaving a limited margin for NPAs. Any deterioration in credit quality of these loans will spell trouble for the banks. Fourth, the mechanisms for recovery are inadequate.

Implications for IBC implementation

The size, and nature of personal credit extended by banks implications for:

The design of IBC resolution procedures:

Most personal loans are secured loans, and banks might continue to use SARFAESI for recovery action on them. IBC may be used mostly in cases where a debtor has multiple unsecured loans, or where the debtor wishes to file for protection under the Code.

A large proportion of agricultural loans are given to low income households. It is possible that many of them will qualify for the fresh start. As most of these loans are in rural and semi-urban areas, design of access will be important for these households to be able to apply for such a waiver.

For those loans that do come to the IBC, the IRP needs to be aligned with the borrowers' profile. A resolution procedure for an individual borrower with low value loans, needs to be simple, low cost and time effective. A simple form-based resolution mechanism, that requires little or no adjudication, may be desirable here. In contrast, resolution procedure for a large borrower or a proprietor may be closer in design to the process for a small company.

On reach, procedure, cost structure and role of the DRTs:

The size of the loans, their complexity, and their geographical spread will need to shape resourcing decisions of the DRTs. This will, in turn, decide their effectiveness as the adjudicating authority for personal insolvency cases. Today DRTs are designed to deal with bank loans above Rs. 10 lakhs. There are only 65 lakh loan accounts in this size threshold in the entire banking system. In contrast, there are 14 crore HH loan accounts, and their average size is Rs. 2.3 lakhs. To effectively deal with resolution of such loans, the DRT rules of procedure, reach, infrastructure, as well as their use of technology for case management, will require a comprehensive re-think.

On how the market for RPs may develop:

The role of RPs, as well as how the RP profession evolves for personal insolvency cases, will be critical. It is likely that, for high value loans, a market for private RPs, concentrated in urban and metropolitan centers, will develop organically. However, for small sized loans, which are geographically dispersed, the question of who will be the RPs and what role they will perform will require assessment, and perhaps even policy action. Further, even when RPs are identified, the process for their licensing, training and monitoring will need to be carefully formulated.

On design of IUs, their accessibility and cost
structures:

The institution of Information Utilities (IUs) is a core component of IBC design. The IUs are expected to facilitate the digitisation of credit transactions, and give such digital records sanctity as evidence in courts of law. Information in an IU can be used for establishing default, and initiating insolvency resolution processes. The structure of IUs, their mechanisms for accepting personal credit related information, and their standards of service will need to be aligned with the need to digitise a large number of small valued loan accounts given to individuals.

On the role of the Insolvency and Bankruptcy Board of India (IBBI):

For personal insolvency, one of the biggest challenges for the IBBI, will be dealing with consumer protection issues. Individual debtors will be vulnerable to biased advice on whether to file for insolvency, the process guiding the filing, and the process for resolution. The IBBI will have to step up to the challenge of protecting customer interests from misaligned incentives that stem from high powered sales practices that have plagued other sectors of the retail financial market.

Conclusion

The design of personal insolvency systems is a complex problem, with challenges that are completely different from those faced by corporate insolvency systems. This article has discussed only the market for bank credit. There will be a larger category of lenders, including money-lenders and friends and family, that may at some point wish to use the provisions under the IBC. Given the size and complexity of the personal credit market, and the paucity of effective recovery mechanisms, there is need for carefully planning and implementing the personal insolvency law sections of the IBC. This is unlike the approach followed for implementing corporate insolvency provisions where speed of implementation has been prioritised.

 

Renuka Sane is a researcher at the Indian Statistical Institute, Delhi and Anjali Sharma is a researcher at the Finance Research Group at IGIDR, Mumbai.

Announcements

Positions at IGIDR FRG

The Indira Gandhi Institute of Development Research is a PhD and Masters granting research institution set up in Bombay in 1989, and funded by the Reserve Bank of India. The Finance Research Group is a group of researchers working on financial markets, household finance and firm financing. At the Finance Research Group, we are recruiting in a few areas.

Policy research on data management in bankruptcy

The Insolvency and Bankruptcy Code, 2016, envisages a new industry of `information utilities' (IUs). We require a policy researcher who will develop expertise on the working of this industry, have thorough knowledge of the processes, critically evaluate regulations and  critique the developments in the policy space. This work will require mastery of information systems, finance and banking domain knowledge, knowledge of the Indian bankruptcy reforms, the Insolvency and Bankruptcy Code and the IU regulations issued by IBBI.

Policy research in payments

We require a policy researcher who will work on:

1. The legal framework of the payments and settlement systems, India and global.
   
2. Clearing in the area of payments.
   
3. Optimal competition policy in payments.
   
4. Policy issues and market barriers in payment systems, and how to design policy to ensure a vibrant fintech ecosystem.
   

The work profile will include studying contemporary policy developments, developing a point of view on the required reforms, writing policy papers and blog articles, running policy roundtables, etc.

Quantitative research on financial markets

Our research program on financial markets requires staffing in:

1. Measuring and monitoring market quality of exchange traded securities. The measures aim to capture changes in price efficiency, liquidity and volatility over time. This will involve using modern statistical techniques, doing parallel computation with high frequency data in R.
   
2. Impact of changes in regulations on market quality.
   
3. Evaluation of proposed regulations, and development of a cost-benefit analysis of the same.

Contact us

All these are full time positions. Please get in touch with Jyoti Manke at careersatFRG@gmail.com .

Judicial review of the Speaker's certificate on the Aadhar Bill

by Pratik Datta, Shefali Malhotra and Shivangi Tyagi.

Under the Indian Constitution, for a bill to be enacted into a law, it has to be approved by both Houses of the Parliament - the Lower House (Lok Sabha) and the Upper House (Rajya Sabha). There is one exception to this general rule. A bill certified as a 'money bill' by the speaker of the Lower House can be enacted into a law by the Lower House alone, without any approval from the Upper House. The Aadhar Act, 2016 was enacted using this route. After being passed by the Lok Sabha, the Lok Sabha speaker certified the Aadhar Bill as a 'money bill'. Accordingly, amendments suggested by Rajya Sabha were not considered and the bill was enacted into law. This led to a controversy, ultimately leading up to a constitutional challenge by Mr. Jairam Ramesh before the Supreme Court. Mr. Ramesh alleged that the speaker incorrectly certified Aadhar Bill as a 'money bill', allowing Lok Sabha to enact the law completely bypassing Rajya Sabha. This matter is going to come up for hearing before the Court on March 14.

Article 110(3) of the Indian Constitution states that the decision of the speaker, whether a bill is a money bill or not, "shall be final". In Mr. Ramesh's case, the Supreme Court has to first decide if it can question the speaker's "final" decision to certify Aadhar Bill as a 'money bill'. The Supreme Court has in three earlier decisions refrained from questioning the speaker's decision. These judgments are Mangalore Ganesh Beedi Works v. State of Mysore (1962), Mohd. Saeed Siddiqui v. State of UP (2014) and Yogendra Kumar Jaiswal v. State of Bihar (2015). As per these judgments, the speaker can certify each and every bill to be a `money bill' capable of being enacted by Lok Sabha alone, rendering the Rajya Sabha and the bicameral legislative system redundant. And the Supreme Court cannot question the speaker's decision since it is "final".

In a recent paper titled Judicial review and money bills, we argue that this position of law developed by the Supreme Court is incorrect. Many commentators have already argued that the enactment of the Aadhar Act through the money bill route was unconstitutional. For instance, Alok Prasanna Kumar, Amber Sinha and Suhrith Parthasarthy have pointed out that the Supreme Court's decisions denying judicial review are problematic. Vanya Rakesh and Sumandro Chattapadhyay have also made out a case favouring judicial review of the speaker's certificate. Our paper adds to this line of literature by substantiating these arguments in detail. In this post, we highlight five reasons why the Supreme Court could legitimately question the speaker's decision in spite of its "final" status under the Constitution.

Indian Constitution does not explicitly bar judicial review

The Indian Constitution adopted the concept of money bills from the British Parliament Act, 1911, with crucial modifications. The 1911 Act defines `money bill' and lays down a procedure for them. Section 1(2) defines a bill to be a money bill which 'in the opinion of the Speaker of the House of Commons' contains only specific provisions. Article 110(1) of the Indian Constitution defines a bill to be a money bill 'if it contains only' specific provisions. Effectively, in Britain the determination of whether a bill is a money bill is left to the subjective 'opinion' of the British speaker. In contrast, the definition of `money bill' under the Indian constitution is not left to the subjective opinion of the Indian speaker. The Indian speaker's decision has to be based on the definition provided in the Constitution.

The 1911 Act mandates the British speaker to endorse his
opinion on money bills, on a certificate. Section 3 gives absolute legal conclusivity to the certificate of the speaker. It reads:

Any certificate of the Speaker of the House of Commons given under this Act shall be conclusive for all purposes, and shall not be questioned in any court of law.

Article 110(3) of the Indian Constitution also grants 'finality' to the Indian speaker's decision. It reads:

If any question arises whether a bill is a Money Bill or not, the decision of the Speaker of the House of People thereon shall be final.

Unlike the 1911 Act, the Indian Constitution does not mention that the speaker's decision "shall be conclusive for all purposes" and "shall not be questioned in any court of law". Therefore, although the Indian Constitution grants conclusivity to the speaker's decision, it does not explicitly bar judicial review. We find that the Constituent Assembly intended for the "final" status given to the speaker's certificate, to be applicable only inside the Parliament - including the Rajya Sabha and the President. Our paper explains this argument in detail.

"Final" decisions have been questioned by Supreme Court

Decisions of various authorities have been given "final" status under the Indian Constitution. Yet the Supreme Court has on multiple occasions exercised judicial review over such decisions. For instance, in Kihoto Hollohan vs Zachillhu (AIR 1993 SC 412), the "final" decision of the speaker regarding disqualification of members of the House under Tenth Schedule of the Indian Constitution, has been held to be a judicial decision subject to judicial review. This suggests that the "final" status given by the Indian constitution does not automatically immune the Indian speaker's decision or certificate from judicial review. Our paper provides a detailed table where we show that there are 17 types of "final" decisions in the Constitution, out of which there are only 3 instances where the Constitution specifically mentions that the validity of such "final" decision cannot be questioned. The decision of the speaker, whether a bill is a money bill or not, is not one of them. Moreover, the Supreme Court has held 5 types of "final" decisions to be subject to judicial review.

British and Indian Parliamentary systems are different

Much of the differences between the 1911 Act and the Indian
Constitution originate from the inherent differences between the British and Indian parliamentary systems.

Britain follows a system of parliamentary sovereignty where the legislature is supreme. In their model it is possible to give absolute conclusivity to the speaker's certificate and immunise it from judicial review. We feel this was not possible under the Indian Constitution since it is not based on parliamentary sovereignty. Giving absolute conclusivity to the speaker's certificate or decision would have been incompatible with the overall scheme of the Indian Constitution, for two reasons.

First, India has a written constitution. All organs of the state (including the speaker) must abide by the Constitution. Any violation is liable to be struck down by the courts. This separation of powers is a basic feature of the Indian Constitution. Allowing the speaker to violate the constitution without any recourse to judicial review impinges upon this basic feature of the Indian Constitution.

Second, Britain does not have a written constitution. Therefore, it is impossible for the British speaker to violate the constitution. The British Speaker can only violate the rules made by either Houses of the British Parliament or procedural laws enacted by both of them. These being 'internal matters' of the Houses, such violations are immune from judicial review. In contrast, India has a written constitution. Certain law making procedures are prescribed by the Indian Constitution (like the money bill procedure), while some other procedures are prescribed through rules by both the Houses of the Indian Parliament (like voting on bills and resolutions). Similar to Britain, the rules made by the Indian Parliament are treated as 'internal matters' of the Houses, immune from judicial interference. We feel violation of constitutional procedures are not 'internal matters', and hence cannot be immune from judicial review. This explains why the Indian constitution framers did not explicitly bar judicial review of the speaker's decision as is the case in Britain.

Supreme Court's contradictory jurisprudence

Our research highlights the inherent contradiction within the Supreme Court's own jurisprudence on judicial review of legislative proceedings and the Indian speaker's certificate on money bills. Article 122 of the Indian Constitution prohibits the courts from questioning parliamentary proceedings on the ground of 'procedural irregularity'. We argue that 'procedural irregularity' refers to violation of procedures in rules made by each House under Article 118 or in any law made by the Houses under Article 119. Violation of a constitutional procedure is not mere 'procedural irregularity'. This distinction was highlighted by a seven judge bench of the Supreme Court in Special Reference No. 1 of 1964. It held that if the procedure followed by the legislature is illegal and unconstitutional, courts can exercise judicial review. This interpretation of Article 122 has been blatantly disregarded by lesser benches of the Supreme Court in the three decisions mentioned earlier. These three cases erroneously held that violation of the constitutional procedure for money bills is a mere 'procedural irregularity' and hence cannot be questioned by the courts.

Other common law jurisdictions allow judicial review

The position followed by the Indian Supreme Court is at odds with the position adopted across five common law countries with written constitutions and bicameral legislative systems. Our research shows that courts across these jurisdictions broadly support judicial review in this regard. In Australia, if a law imposing taxation deals with any extraneous matter, the Australian High Court can exercise judicial review under section 55 of the Commonwealth of Australia Constitution Act, 1900. The Canadian Supreme Court has observed that the procedural requirement must be complied with to create fiscal legislation. The Constitutional Court of South Africa has exercised judicial review to determine if a Bill was calculated to raise revenue or not. The US Supreme Court has categorically held that a law passed in violation of the Origination Clause (equivalent to money bills under the Indian Constitution) would not be immune from judicial review. Pakistan Supreme Court has in four cases struck down laws enacted as money bills since they did not fall within the definition of money bill under article 73 of their constitution.

Conclusion

Our research suggests that Indian legislative proceedings are immune from judicial review only on the ground of 'irregularity of procedure' and not for constitutional breaches. If a House commits breach of any procedure in any rule made by itself or in any legislation that the Houses themselves had passed, such breach is an internal matter for the House itself to act on. It is not open to judicial review. But if a House commits a breach of any constitutional procedure, such breach is open to judicial review. A contrary interpretation would mean that the Indian speaker can certify each and every bill to be a 'money bill', practically dispensing with the need for the Rajya Sabha. Such an interpretation would effectively render the constitutional design of a bicameral legislative system completely redundant. This is precisely what has been done by the three earlier judgements of the Supreme Court. Jairam Ramesh v. Union of India offers the Supreme Court an opportunity to revisit its interpretation of the Constitution on this issue.

References

Pratik Datta et al., The controversy about Aadhaar as a money bill, Ajay Shah's blog, March 20, 2016.

Vanya Rakesh and Sumandro Chattapadhyay, Aadhaar Act as Money Bill: Why the Lok Sabha isn't Immune from Judicial Review, The Wire, May 9, 2016.

Alok Prasanna Kumar, Why the Centre's dubious use of money bills must not go unchallenged, Scroll.in, May 11, 2016.

Amber Sinha, Can the Judiciary Upturn the Lok Sabha Speaker's Decision on Aadhaar?, The Wire, February 21, 2017.

Suhrith Parthasarthy, What exactly is a money bill?, The Hindu, February 27, 2017.

Pratik Datta et al., Judicial review and money bills, February 28, 2017.

 

The authors are researchers at the National Institute of Public Finance and Policy, New Delhi.

Author: Smriti Sharma

Smriti Sharma is a researcher at the National Institute for Public Finance and Policy.

• Sustainable strategy to eliminate vector-borne diseases, 28 February 2017
• Problems of the Health Management Information System (HMIS): the experience of Haryana, 13 June 2016.
  
• Closing the gap between farmers and warehouses, 13 July 2015.
  
• Improving warehousing in India through a grading mechanism, 25 March 2015.
  
• A dramatic cost reduction for KYC using the e-KYC API of UIDAI, 14 September 2014.
  

Sustainable strategy to eliminate vector-borne diseases

by Shubho Roy and Smriti Sharma.

In his budget speech of 2017, the Finance Minister Arun Jaitley announced that the government has prepared an action plan to eliminate two vector-borne diseases by the end of this year (Paragraph 64):

"Poverty is usually associated with poor health. It is the poor who suffer the maximum from various chronic diseases. Government has therefore prepared an action plan to eliminate Kala-Azar and Filariasis by 2017..."

Kala Azar, also known as Visceral leishmaniasis, is caused by a protozoan parasite of the Leishmania genus. It is carried by an insect vector: Sandfly. If left untreated, Kala Azar can lead to the death of the patient.

Filariasis is a painful disfiguring disease which is caused by roundworms of the Filarioidea superfamily. It is carried by a mosquito vector: Culex quinquefasciatus. The most disturbing symptom is elephantiasis where the patients body parts swell to massive proportions. The infection generally occurs during childhood but manifests itself later in life and can lead to permanent disability.

In this article, we analyse this announcement. We argue that eliminating vector-borne diseases is a good cause for health policy to pursue. However, there is a need to place these actions within a larger strategy on communicable and vector-borne diseases. The critical component of that, which is at present lacking in India, is a sound surveillance system.

Communicable diseases in health policy

A lot of what governments do in the field of health is of dubious value. Tackling communicable diseases, like Kala-Azar and Filariasis, however passes the basic tests of public economics (Hammer, 2015). Communicable diseases involve a market failure, an externality. When one person gets infected, not only does that person suffer, there is the possibility of others getting infected. This is a negative externality. Each person will under-spend on preventing or curing the disease as the individual does not price the adverse impact upon others. This creates a market failure and justifies a role for the State.

In the extreme, when we get to eradication, we get to a public good. When a communicable disease is eliminated, everyone is protected, even if they did not pay for it. It fits both the tests of a public good:

1. non-excludable: it is not possible to prevent consumers who have not paid for it from having access to it. There is no way to ensure that only the people who paid to eliminate Kala Azar don't get Kala Azar and others are still exposed to it.
   
2. non-rivalrous: it may be consumed by one consumer without preventing simultaneous consumption by others. When an infectious disease is eliminated, it cannot come back. Enjoying good health by some persons does not reduce the supply of good health, i.e. absence of the disease.
   

Why Kala Azar and Filariasis?

But we must ask: Why were Kala Azar and Filariasis prioritised for elimination in the Budget speech?

It is not because they are most widespread diseases in the country. Statistics from the Directorate of National Vector Borne Disease Control Programme (NVBDCP) (Table 1) show that here are other vector-borne diseases like Malaria, Dengue and Chikungunya which are more important.

Table 1: Magnitude of vector-borne diseases in India (2014)

Disease	Cases in 2014	Deaths in 2014
Malaria	1,102,205	562
Dengue	40,571	137
Chikungunya	16,049	Unavailable
Encephalitis (Japanese and Acute)	12,528	2,084
Kala Azar	9,241	11
Filariasis	Unavailable	Unavailable

Perhaps it is felt that these diseases are low hanging fruits. Kala Azar is restricted to four states while other vector borne diseases are everywhere. In 2014, a new drug liposomal amphotericin was found to cure Kala Azar with a single dose. Previously, a course of 28 daily doses with hospitalisation was required.In the case of Filariasis, India has reduced the national microfilaria rate (based on sample blood tests) from 1.24% in 2004 to 0.44% in 2014. In Goa, Daman & Diu and Pondicherry, the rates have fallen low enough that mass drug administration (the standard treatment methodology) was stopped in 2012. The government has also achieved good coverage under Mass Drug Administration with 85.6% of the population covered in 2014.

Choosing low hanging fruits has its virtues. It allows for quick results and can potentially help create State capacity. There is a unique charm to eradication. Once a communicable disease is eradicated, you do not have to work on it again (apart from some low-level continued surveillance to check for recurrence). This frees up resources for other purposes.

A story of failure

In the recent past, India has seen many outbreaks of re-emerging infections, which were claimed to be eliminated. Kala Azar itself reemerged after near eradication in the 1960s. DDT was used for controlling malaria between 1953-64. This helped to decimate the sand-flies that cause Kala Azar. But the pathogen continued to reside in humans. In 1977, when the sand-flies resurged, Kala Azar resurfaced. The disease again resurged in 1983 and 2003 (Muniaraj, 2014). The National Health Policy of 2002 had envisaged elimination of Kala Azar and Filariasis by 2010. This was postponed to 2015.The plague in Surat in 1994 was followed by an outbreak of pneumonic plague in Himachal Pradesh in 2002 (Joshi et al., 2009). There was another bout of plague in Uttarkashi in 2004 (Mittal et. al., 2004). The first outbreak of Chikungunya in India was reported in 1963 but it resurged after three decades in 2006.

What does it take to finish the job?

It is important to ensure that an elimination drive is sustained beyond its stated date. Vector-borne diseases will not cease to exist with the administration of mass dosage of drugs alone. We need continued disease surveillance and epidemiological investigation post-2017 too. A Kala Azar patient can relapse after six months after the end of treatment. Similarly, Filariasis does not manifest itself in early stages in any outward symptoms. The infected person can thus continue to host the disease for several years.

India is at the cusp of eliminating Kala Azar and Filariasis. It must ensure that the eliminated diseases do not re-emerge. This requires a surveillance system. Surveillance can provide information on entomological data, which can help in creating clusters of diseases that can be targeted by similar vector management measures. Surveillance for epidemiological data can help in calculating the disease burden attributable to each disease. Lastly, surveillance can provide information on implementation. This can help in monitoring and evaluation of disease control and prevention.

Prevention, control and surveillance: current scenario

NVBDCP's present strategy concentrates on vector management by using indoor residual spraying, nets impregnated with insecticides and anti-larval measures. In addition, early diagnosis and complete treatment is provided to afflicted patients. NVBDCP frames technical guidelines and policies to guide States for implementation. Health departments are responsible for the prevention and control of vector-borne diseases at the State level. But their approach to vector-borne diseases continues to be ancillary and ad hoc in absence of entomological and epidemiological data, and data dissemination:

• Poor entomological surveillance: The government established 72 zonal Malaria offices to conduct entomological surveillance but only 50% of these are functional. State health departments conduct larval surveys but they do not count adult mosquito populations. The field staff uses the outdated ladle and dip method for studying the vector population, despite the availability of new and improved devices like ovitraps. Vector management efforts employ fogging and anti-larval activities to contain mosquito populations. But, this is done without adequate evidence on vector populations.
  
• Poor epidemiological surveillance: IDSP has a laboratory network of 117 district labs in 28 States/UTs to perform tests for epidemic-prone diseases. Out of the 117 laboratories, 44% of the laboratories do not conduct all the tests recommended under IDSP. This means that some diseases cannot be confirmed and therefore they remain unreported. Private healthcare providers do not report diseases and that leads to under-estimation of the disease incidence. The data for dengue, Kala Azar and Chikungunya on NVBDCP's website is outdated enough to render it useful for public health management. Case and death data for filariasis is unavailable.
  
• Poor data collection and dissemination: The reports from the rural reporting units to District Surveillance Units of IDSP are often delayed. While 85% districts communicate surveillance data through emails, 67% report data through the portal. This leads to delays in collating and analysing data. State health departments campaign, educate and inform the public about the diseases. But, none of the measures taken by State health departments are ever evaluated for their impact.
  

The information from NVDCP has three groups of problems:

1. Missing data: The epidemiological data for some diseases is either incomplete or missing. The missing data on deaths cannot be construed as zero deaths.
   
2. Policy decisions without evidence: India hopes to eliminate Filariasis by the end of 2017. But there is no data on the number of cases and deaths resulting from Filariasis.
   
3. Under-estimation of incidence: The burden of disease is likely to be highly under-stated by the official statistics. As an example, Dhingra et. al., 2010 estimate that Malaria kills between 125,000 and 277,000 persons in India every year. This is vastly unlike the official statistics. Similarly, Haanshus et. al., 2016 find that in the class of hospitalised patients with undifferentiated fever in India, malaria prevalence is as high as 19%. Similarly, Shepard et. al., 2014 estimate there were 5.8 million cases of dengue per year.
   

Building a surveillance system

A sustainable strategy should bring down the infectious diseases in the short term and avoid resurgence later on. The US Centers for Disease Control and Prevention (CDC) has developed a framework for preventing infectious diseases which focuses on:

• Continued surveillance of infectious diseases, laboratory detection and epidemiological investigation;
  
• Reducing diseases by developing vaccines, preparing strategies for infection control and treatment;
  
• Using scientific data to inform health policies to prevent and control infectious diseases.
  

India requires the development of similar principles. We need a robust surveillance system that measures all vector-borne and communicable diseases. This system should generate a constant stream of good quality data which can feed back into management decisions in public health.

The policy agenda for vector borne diseases involves the following components:

• Building entomological surveillance capabilities: State health departments should invest in their entomological surveillance capabilities. They should systematically collect and document changes in vector occurrence, abundance and infection rate for the entire country. State health departments should complement larval surveys with adult surveys. In order to estimate and monitor adult mosquito prevalence, health departments should procure mosquito traps like ovitraps and BG-Sentinel traps (Sivagnaname and Gunasekaran, 2012). State health departments should make the entomological surveys public. For example, the Health Department of New York has launched interactive maps. These maps show the progress made on mosquito surveillance and control operations. The City of Chicago publishes maps with a list of locations and mosquito test results. The CDC displays information on vector borne diseases in maps which also give information on the vectors for each disease.
  
• Improving epidemiological surveillance: The government should assess the disease burden for each vector-borne disease. State health departments collect information on disease incidence and mortality. The epidemiological surveillance should also include information on geographical distribution of the disease and sub-populations affected. This information should be compiled and made publicly available. Better laboratories are required that conduct tests for all the vector-borne diseases.
  
• Improving data collection and dissemination: The government should strengthen data management. The health staff responsible for collecting entomological and epidemiological data should be given electronic devices like tablets or mobile phones. The field staff should enter surveillance data through these digital devices. For example, Kenya moved away from manual data reporting to electronic data reporting for its National Tuberculosis, Leprosy and Lung Disease Programme with an Android based application called TIBU. Florida's Department of Health puts out weekly and annual reports on surveillance. State health departments should also conduct impact analysis on vector control measures. NVBDCP and IDSP should make these studies publicly available to all the stake-holders including other State governments, the private sector and consumers.
  

Building a generalised and integrated communicable disease management system is laying infrastructure. It can be used for tackling different problems from year to year. Our objective should be to lay this general infrastructure, and not narrowly run campaigns targeting one disease or another.

For an analogy, consider Aadhar. Aadhar is just an identity platform. However, it has been built on robust technology using sound processes. In itself, Aadhar does not do much. However, Aadhar can act as a backbone for multiple initiatives ranging from financial inclusion, rationalising subsidies, targeting delivery of public services, national security, preventing corruption and leakage, etc. It constitutes a general purpose infrastructure which builds a platform on which many specific public services can run.

In similar fashion, a well designed communicable disease management platform which leverages technology can be used to deal with kala-azar and filariasis this year, but can be used for malaria, chikungunya and dengue the next year. The same surveillance, monitoring and data dissemination systems will work for multiple diseases. So far, the government has integrated the disease surveillance programme, i.e. brought multiple programmes under one umbrella but it has not re-imagined the way it should be carried out.

References

The case for Universal Healthcare is weak by Jeffrey S. Hammer, July 2015, Ajay Shah's blog

The lost hope of elimination of Kala Azar (visceral leishmaniasis) by 2010 and cyclic occurrence of its outbreak in India, blame falls on vector control practices or co-infection with human immunodeficiency virus or therapeutic modalities by Muniaraj Maylisamy, 2014, Tropical Parasitology

Epidemiological features of pneumonic plague outbreak in Himachal Pradesh, India by Joshi K et al., May 2009, Transactions of the Royal Society of Tropical Medicine & Hygiene

Quick control of bubonic plague outbreak in Uttar Kashi, India by Mittal V et al., December 2004, The Journal of Communicable Diseases

Report of the Working Group on Disease Burden for the 12th Five Year Plan by Planning Commission, Govt. of India, May 2011

Adult and child malaria mortality in India: a nationally representative mortality survey by Dhingra Neeraj et al., October 2010, The Lancet

A high malaria prevalence identified by PCR among patients with acute undifferentiated fever in India by Haanshuus CG et al., July 2016, PLOS ONE

Economic and Disease Burden of Dengue Illness in India by Shepard Donald S. et al., December 2014, The American Journal of Tropical Medicine and Hygiene

Need for an efficient adult trap for the surveillance of dengue vectors by Sivagnaname N. and Gunasekaran K., Indian Journal of Medical Research, November 2012

Handbook for integrated vector management by World Health Organization, 2012

Smriti Sharma and Shubho Roy are researchers at the National Institute of Public Finance and Policy, New Delhi.

Protecting retail investors' interest in the bond market

by Ritika Chhabra and Anjali Sharma.

Context

On January 04, 2017, SEBI released a discussion paper titled "Public Issuance of Non-Convertible Debentures having credit rating below Investment Grade" (hereafter, discussion paper) for public comments. The proposals in the discussion paper focus on retail investors' participation in public issuances of sub-investment grade non-convertible debentures (NCDs). Each of these terms is technical and its useful to understand what they mean before analysing SEBIs proposals:

• While protecting retail investors' interest in securities markets is one of SEBIs stated objective, there is no standard definition of a retail investor which is consistent across securities. For example: for equity public issuances, a retail investor is one whose bid does not exceed Rs. 2 lakhs. For issuance of tax free bonds, the IT Act, 1961 defines retail investor as one whose bid does not exceed Rs. 10 lakh.

• A public issuance is defined as per Section 42 of Companies Act, 2013 as one where securities are issued to more than 200 investors. Typically, public issuance of corporate debt securities is in the form of NCDs. The issuance process is laid down by the SEBI Issuance and Listing of Debt Securities (ILDS) Regulation, 2008. As per ILDS Regulation 4(2)(c), for public issuance of debt securities, the issuer has to get at least one credit rating.

• A sub-investment grade rating is one that is below BBB-. Debt securities with this rating are commonly referred to as junk bonds.

In the discussion paper, SEBI makes two proposals with regard to such issuances. First, the introduction of a pictograph, known as the risk-o-meter, to disclose credit rating in the offer document. Currently, credit rating is disclosed on the first page of the offer document in text form. Second, the introduction of a two level restriction on retail investor participation - an investor level restriction: Rs. 2 lakh; and an aggregate restriction on all retail investors: 5% or 10% of the issue size.

In this article, we evaluate SEBIs proposals and offer our analysis of key issues that this discussion paper highlights.

Analysis of SEBIs proposals

1. The proposals are relevant for a very small part of the corporate bond issuance market: The market for public issuance of sub-investment grade NCDs is small, both in absolute terms and relative to the corporate bond market (Table 1). In 2015-16, 2 of the 20 public issuances were sub-investment grade and these accounted for only 1.3% of the public issuance volume. As a proportion of the total corporate bond issuance volume, these were less than 0.1%.

   When we look at the identity of issuers and the rating profile of their issuances, we find that the public issuance market is dominated by highly rated issuers. These include large public sector entities like NTPC, NHAI, NABARD, IRFCL and 3-4 private non-bank finance companies (NBFCs) who are regular issuers. There are only 2-3 NBFCs which issue in the sub-investment grade category and these are repeat issuers.

Table 1: Corporate bond issuance market in India

Year	Issuance value	Private placement	Public issuance	Public issuance - sub-investment grade1
	(Rs. trillion)	(%)	(%)	(%)
2014-15	4.1	97.7	2.3	0.34
2015-16	4.9	93.2	6.8	0.09
2016-172	5.1	94.3	5.7	0.09
Source: SEBI
1 Sub-investment grade represents a credit rating below BBB-
2 Data till December, 2016

2. Retail investors, for whom investment limits are proposed, are the main investors in publicly issued sub-investment grade NCDs: We find that retail investors are the primary investors in these issuances. For example: 16 unique ISINs were generated as part of 2 issuances in 2015-16. An analysis of the ownership pattern of these ISINs, using data from NSDL, shows that in 15 ISINs, retail investors' subscription was more than 90% of the issue size. In the remaining one ISIN, it was more than 70%.

3. SEBIs problem identification is unclear and not supported by data: In the discussion paper, SEBI states:

   Unlike private placement of debt securities, retail investors participate in the public issues. These public issues which are rated below investment grade (i.e. below BBB-) give high coupon rate. The advertisements of such issues also focus mainly on the coupon which lures the retail investors to invest.

   Further, certain issuers with credit rating below investment grade, have issued both secured and another unsecured NCD through same offer document with different credit ratings. Thus, for a retail investor to differentiate between secured and unsecured tranches within the same offer document and with different credit ratings may be a complex task and may affect their investment decision.

   It is felt that there needs to be an additional layer of protection for the retail investors, who get attracted towards such debt securities which though on one side pay higher coupon but on the other side have a below investment grade credit rating.

   From these statements, it appears that SEBI identifies three problems: (1) the manner of disclosure of credit rating in sub-investment grade issue advertisements; (2) issuers offering secured and unsecured tranches within the same offer document, which makes in complex for retail investors to understand credit rating; and (3) retail investors getting attracted to the return and investing in risky securities.

   There are two issues with SEBIs problem identification process. First, it is not supported by any data or analysis. For example in case of problem (1) and (2), there could be two issues: with the visibility of the text based disclosure, or with investors' understanding of the meaning of a credit rating or both of these. It could also be that there are more problems with disclosure quality than just credit rating or that disclosure quality is not a problem at all. Retail investors are attracted by high returns, are aware of the risk, yet invest because of other considerations, such as fact that these are repeat issuers and their past performance is known. Second, the problem identification does not evaluate whether a regulatory intervention is needed. For example: in case of problem (3) if retail investors are attracted to risky securities, it is unclear why the regulator should step in.

4. Cost benefit analysis is missing: Proposal 1 -- introduction of a risk-o-meter, seeks to address problem (1). Credit rating is currently displayed in text form on the first page of the offer document. The table that explains the implications of the rating is placed inside the offer document (Figure 1).

   Figure 1: Current disclosure of credit rating in offer document

   The proposed NCD risk-o-meter makes the credit rating more clearly visible than a text based disclosure (Figure 1 and Figure 2). However, it does not necessarily improve investor understanding of the credit risk. In case of the mutual fund risk-o-meter, from which this proposal is inspired, the risk of the offer can be clearly understood from the risk-o-meter (Figure 3). As mentioned earlier, its possible that investors do not understand credit risk or that there is no problem with the current disclosure format. In both these cases, the inclusion of a risk-o-meter adds no value. The modification of the offer document format may create costs for issuers. However, no cost-benefit evaluation is offered in this regard.

   For problem (2), where an unsecured and secured tranche is issued through the same offer document, SEBI offers no proposals. For example: it does not state whether such offer documents will have two risk-o-meters.

   Figure 2: Proposed NCD risk-o-meter

   Figure 3: Mutual fund risk-o-meter

   In Proposal 2 -- introduction of a investor level and aggregate level investment limit for retail investors, SEBIs approach is contrary to its approach to retail investors in equity markets. An equity security is far riskier than a sub-investment grade bond, yet SEBI actively encourages retail investor participation in equity issuance. Further both the limits proposed: Rs. 200,000 per investor and 5% or 10% aggregate limits are arbitrary. The benefits of this proposal from an investor protection perspective are unclear. Yet the costs are obvious. Given that retail investors are the main investors in these issuances, these limits may cause the sub-investment grade issuance market to dry up completely. Also, regulatory interventions that seek to limit investor choice are a firm step away from SEBIs stated objective of being a disclosure based regulator and a step towards being a merit based regulator.

A small survey: can key disclosures be easily found in offer documents?

Given that SEBI has identified the visibility of credit rating disclosure in offer document as a problem, we conducted a small survey to understand whether other key disclosures can be easily found from an NCD offer document. We gave respondents an offer document for a public NCD issuance, and asked them to find three details about the issue from it: (1) whether the issue is secured or unsecured, (2) what is the rate of return, and (3) what is the tenure. We asked them to measure the time it took them to find this information. 15 personnel from Indira Gandhi Institute of Development Research (IGIDR) and the National Institute of Public Finance and Policy participated in the survey. Table 2 provides a profile of the respondents and Table 3 shows they survey results.

Table 2: Profile of survey respondents

No. of respondents	15
Respondents with demat account	53%
Respondents who invested in equity securities in the last 18 months	40%
Respondents who invested in debt securities in the last 18 months	20%
Average time taken to respond to the survey	15-30 minutes

Table 3: Survey results

	Responses
Questions	Correct (%)	Incorrect (%)	Can't say (%)
Is the issue secured or unsecured?	67%	20%	13%
What is the size of the issue?	47%	40%	13%
What is the minimum tenure of the NCD?	27%	53%	20%
What is the yield for minimum tenure NCD?	40%	40%	20%
What is the maximum tenure of the NCD?	33%	40%	27%
What is the yield for maximum tenure NCD?	20%	53%	27%

The survey results point to a deeper problem in offer document disclosures than just the credit rating. Even locating basic information like yield and tenure is not easy.

As a separate exercise, we reviewed 5 abridged prospectuses from public issuances done in 2015-16 and 2016-17. An abridged prospectus accompanies the application form, and SEBI has mandated that the issue term sheet be disclosed on the first page. Even here, we found that in 1 case the terms of the issue were not on the first page. This was a case where issuance was done as part of a shelf prospectus. A typical abridged prospectus is around 40 to 50 pages in length, and even here it is not easy to locate key disclosures within it.

Conclusion: way forward for SEBI

SEBIs proposals in the discussion paper focus on retail investor protection. Globally, regulators follow a two pronged disclosure based approach to do this. First, reducing information asymmetry between issuers and investors by regulating the quantum and quality of disclosures. Second, enforcing disclosure standards and penalising violations of disclosure norms. Securities regulators, even in Asian countries, have moved away from the merit based approach of imposing investment limits.

Given SEBIs stated objective of being a disclosure based regulator, it needs to focus on improving disclosure quality, not on constraining retail investor participation. However, this requires adopting a systematic and research based approach to addressing the disclosure problem. Our survey findings suggest that SEBI needs to do the hard work of evaluating disclosure effectiveness more comprehensively. In undertaking this exercise, SEBI can take cues from the recommendations of the Sumit Bose Committee (2015) on improving disclosures and curbing mis-selling for financial products. Simply, introducing a risk-o-meter will be insufficient and ineffective.

Other measures, such as stepping up investor education efforts in the debt securities space, may also be relevant. In case of equity securities, SEBIs efforts in this area along with the efforts of a growing industry of equity analysts and proxy advisory firms has contributed to improving investors' understanding of risks and return. A similar effort for the corporate debt market may have greater long term benefits, for both investors and issuers, than introducing any investment constraints.

Finally, sound regulatory governance is critical to building participants' confidence in the financial system and fostering certainty. Regulatory capacity is finite and regulatory interventions not cost-less. Hence, regulation making needs to follow the discipline of a robust process of identifying a problem, proposing an appropriate solution based on research and analysis, evaluating costs and benefits and carrying out a public consultation process. This will ensure that only meaningful interventions, for which benefits exceed the costs, get enacted. SEBI has already started on this path by regularly seeking public feedback on proposed interventions. However, its proposals are not supported by robust problem identification. There is no cost benefit analysis, research or empirical evidence in support of the proposals made. It shows that SEBI has some way to go in meeting global standards of regulatory governance.

The Finance Research Group has submitted its comments on this discussion paper to SEBI.

Ritika Chhabra and Anjali Sharma are researchers at Finance Research Group. We thank all the FRG-IGIDR and NIPFP team members who took time out from their busy schedules to respond to our survey. We also thank Renuka Sane and Bhargavi Zaveri for useful discussions and suggestions.