Towards better enforcement by regulatory agencies in India

by Trishee Goyal and Renuka Sane.

India is on the verge of establishing yet another regulator, the Data Protection Authority (DPA), to implement the provisions under the Personal Data Protection Bill, 2019. As per the Bill, the DPA will regulate anyone who collects data for commercial use with a turnover of more than INR 20 lakh annually. This would cover entities from small time telemarketers to social media behemoths. The scope of its regulated entities will thus be more extensive than any of the regulators previously established in India. The DPA has the power to either suo motu or on a complaint take action against a data fiduciary or a data processor who may be violating the law. It can, inter alia, issue directions, call for information, conduct inquiries, issue orders for injunctive relief, suspend or cancel the registration of businesses.

With such an expansive responsibility, it is important to get the design of the enforcement processes of the DPA right. Failure to follow due process in enforcement would be damaging to the ease of doing business, to the digital and start-up ecosystem and damage India's chances of dominance in these spheres. More importantly, such failures will have adverse consequences on the justice and dignity of the regulated entities.

In a new working paper, Towards better enforcement by regulatory agencies, we study the gaps in enforcement at the Securities Exchange Board of India (SEBI) and the Competition Commission of India (CCI). The gaps pertain to whether processes of natural justice have been adhered to during the conduct of enforcement activities. We reflect on the lessons this might have for the DPA.

In India, there exists a small literature on the problems with the legislative functions (some examples include Burman and Zaveri, 2018; Bhandari and Sane, 2019), and the judicial functions (see Datta et. al., 2019). In this paper we focus on the executive, or the enforcement, functions of a regulator. Our paper also connects to a larger literature across the world on the dilution of accountability at the 'new administrative state'. Administrative agencies are increasingly built with legislative, executive and judicial mandates. Such agencies are expected to draft subordinate legislation, be responsible for licensing and enforcement actions, and also adjudicate on investigations usually carried out by itself. Questions on checks and balances and due process that were reasonably settled in liberal democracies when it came to government functioning are now being debated once again w.r.t regulators.

Why SEBI and CCI?

Before we discuss questions on natural justice, a word on why we chose to study SEBI and CCI. The Justice Srikrishna Committee Report on data protection suggests that the DPA will be modeled along the lines of other Indian regulators such as TRAI, SEBI, CCI etc. Among the regulators discussed in the report, we found that SEBI has been considered the most effective, as far as its enforcement actions are concerned. CCI is relevant as it is a more recently established regulator. A study of CCI comes at an interesting checkpoint in the development of regulatory governance. As the DPA will be modeled on these regulators, it is important to understand how enforcement is currently taking place and whether there is an inherent problem in the structure of enforcement. For example, Roy, Shah, Srikrishna, and Sundaresan (2019) argue that Indian regulators have too often veered into controlling as opposed to regulating, and that enforcement has been selective and weak, and failed to adequately follow the rule of law, especially on due process. State capacity is known to be weak in India, suggesting the need to move beyond existing models of regulatory design.

Three elements of natural justice

Natural justice is a vast area. We focus on the three most basic elements of natural justice - how are notices served, whether parties are allowed to examine material and cross-examine witnesses, and whether there is separation of powers, especially between the investigation and adjudication functions.

Procedural failures at SEBI and CCI

In the case of SEBI, we studied orders of the Securities Appellate Tribunal (SAT) for a six month period (October, 2019 to March, 2020) where we found that 33% of SEBI orders were over-ruled on failure to adhere to principles of natural justice. Of the cases over-ruled, 86% were related to issues of notice and 14% to issues of examination of materials. SEBI fares poorly on separation of powers. With respect to CCI, a survey of appellate orders passed by the Competition Appellate Tribunal and the Supreme Court, pointed to the lack of due process being ingrained in enforcement procedures. However, CCI maintains separation of powers with a far greater degree as compared to SEBI. The design of the enforcement structure also allows for application of mind by the Commission at multiple stages - at the time of formation of prima facie opinion, at the time of issuance of direction for investigation and lastly, at the time of penalty proceedings.

Importance of codification

Why is it that there are such procedural failures? Legislation in India confers certain powers of a civil court to a regulatory agency, and expects that the regulator will comply with the principles of natural justice. There is, however, no guidance on how regulators should comply with these principles (Burman & Krishnan, 2019; Sundaresan, 2018). Common law in India has held the view that principles of natural justice are not considered embodied rules -their application has been made dependent on a variety of factors such as the nature of the tribunal in question, the controversy in question and the facts and circumstances at hand. As a result, the development around principles of natural justice in administrative law has been in an ad hoc manner. There is very little by way of standardised procedures that an administrative body can source from common law.

What would improve these processes? We look at the structure of regulators in other countries - namely the US and the UK. We find that the processes that Indian law just assumes will be followed, are actually codified in laws, regulations and process manuals in these countries. Codification is important as a study of CCI also shows - while the CCI does better in terms of structural separation, issues of due process continue to remain due to scanty guidance available in the Competition Commission of India (General) Regulations, 2009 on other aspects. Codification of processes on legislative powers, such as having more prescriptive rules on the requirements of consultation, have led to better regulation making processes (Burman & Zaveri, 2018).

Lessons for the DPA

We have the following recommendations for the DPA. The objective is to provide adequate guidance to the regulator as it discharges the enforcement function, as well as to the broader community as it continuously evaluates the performance of the regulator on these counts.

1. There should be an inclusion of the procedural rights in the statute itself. These provisions would specify a detailed outline of the show cause notice, the scope of the right of examination of materials, the procedure to be followed in case of ex-parte orders and the timelines of providing representation against each of the processes where such representation can be made.

2. Further, regulations should include the manner in which notice is to be served, the manner of providing opportunity of hearing (written submissions), the form in which materials are to be submitted to the regulated entity under its right of examination of materials etc.

3. The law, regulations, as well as detailed manuals should be available in the public domain.

4. At the very least, there should be a cadre of administrative law officers who would not be engaged in any functions of the regulator except performing the quasi judicial functions. There should be an Administrative Law Member in the Board of the agency whose specific task would be to manage the cadre of administrative law officers. This would lead to the insulation of quasi judicial functions of the regulator from executive, investigation and inspection functions.

Conclusion

The concerns raised by us have begun to get recognised in India. For example, in 2011, the Financial Sector Legislative Reforms Commission (FSLRC) Report laid out a regulatory framework imbibing the principles of natural justice. More recently, in 2019, the Report of the Competition Law Review Committee, reviewed the enforcement processes in the CCI. Similarly, the Sahoo Committee Report set up to examine development and regulation of valuation professionals, while laying out the regulatory design for the said purpose, emphasised the need of principles of separation of powers, reasoned orders, independence and accountability. The follow through on the recommendations, however, has been scarce. We think that a statutory formulation of the administrative law requirements would strengthen the rule of law in enforcement actions.

References

Bhandari, V., and Sane, R. (2019) A Critique of the Aadhaar Legal Framework. 31 NSLIR Rev 1-23.

Burman, A., & Krishnan, K. (2019). Statutory regulatory authorities: Evolution and impact.

Burman, A., & Zaveri, B. (2018). Regulatory responsiveness in India: A normative and empirical framework for assessment William & Mary Policy Review , 9 (2), 1-26.

Datta et. al. (2019), How to Modernise the Working of Courts and Tribunals in India. NIPFP Working paper 258.

Roy, S., Shah, A., Srikrishna, B. N., & Sundaresan, S. (2019). Building state capacity for regulation in India. Devesh Kapur and Madhav Khosla (eds.), Regulation in India: Design, Capacity, Performance, Oxford: Hart Publishing.

Sundaresan, S. (2018). Capacity building is imperative. Column titled Without Contempt in the editions of Business Standard dated August 2, 2018.

The authors are researchers at NIPFP. This paper was produced as part of the Data Governance Network. We thank Somasekhar Sundaresan for useful discussions.

Strategic patience and flexible policies: How India can rise to the China challenge

 by Gautam Bambawale, Vijay Kelkar, Raghunath Mashelkar, Ganesh Natarajan, Ajit Ranade, Ajay Shah.

A paper, Strategic patience and flexible policies: How India can rise to the China challenge, has been released by the Pune International Centre. Key ideas of this paper are presented here.

After the war in 1962, the India-China relationship was frozen till 1988. After that, both sides agreed on a framework of holding border disputes in abeyance and pursuing increasing economic engagement. Procedures and protocols were established for handling situations on the border, if they should arise.

In recent years, China has dismantled this arrangement and established a more hostile stance towards India with simmering military conflict. This raises important questions for policy in India. How should India navigate this landscape? When the conflict became kinetic in Doklam and then Ladakh, the immediate impulse was of course about mobilising troops. There was an outcry in the press, nationalistic fervour, and emotional boycotts of Chinese goods.


It is important to see these problems on a larger scale, in terms of space, time and force. It is not just about a few weeks in Ladakh involving a few thousand troops. There is much more at play. If India merely responds with troop movements and winter gear, this may set the stage for future reverses. Indian thinkers need to address deeper questions. What are the forces shaping Chinese behaviour? What is the best path for India in the short term and the long term? How can diplomacy and economic policy work in an intertwined fashion, to best further India's interests?


At present, India is in a weak position when compared with China. Whether we look at raw GDP, state capacity, the capabilities of the best firms, the extent of internationalisation, the mastery of science and technology or the quality of the top intellectuals: at present, China is significantly ahead of India. This superiority can be used by China to put pressure on India in many ways. Some examples of this include a sheer display of military strength to grab land at the border, the use of a variety of levers to foster friction for India with neighbouring countries, and nudging decision making at international organisations in ways that hinder India's interests.

Looking into the future, if the gap between Chinese and Indian economic growth rates continues, these problems will be amplified. As an example, we must visualise a future scenario where Chinese carrier groups prowl the Indian ocean, and the Indian navy is out-matched.

In this scenario, how best should India proceed? There is a useful distinction between the short run and the long run.


In the short run, Indian diplomacy faces a new situation. Never before has India faced a hostile nation with significantly superior strength. China in 1962 was at roughly Indian levels of GDP; Pakistan is a smaller country. This is the first time that India has   hostilities with a substantially stronger nation. Confronting China alone would be unwise. It is essential to build coalitions.

There are three groups of natural allies for India: the great democracies of the world, who worry about the global prominence of an authoritarian China; the countries on China's borders, who are all facing difficulties just as India is; and the countries in India's region who can potentially have positive exposure to Indian success given that proximity matters greatly in cross-border economic and cultural activities.

India needs to embark on a process of building deep ties with about 20 countries. The genuine depth of these relationships requires linkages in trade, finance, investment, education, travel, migration and shared values. India will need to modify domestic policy positions in ways that suit the interests and values of these partners. Diplomacy needs to play a much bigger role in domestic policy making, than has ever been the case in Indian history. The coming decades need to become a golden age of diplomacy.

In the short run, there is debate about protectionist measures that will harm Chinese exports or investment in India. A significant proportion of those moves are self-defeating in that they harm India more than they harm China. There is a case for three groups of restrictions : Limit companies controlled by the Chinese state from a controlling stake in a hotlist of sensitive infrastructure assets; steering clear of Chinese-controlled technological standards; and blocking surveillance of Indian persons.

Strategic thinkers in Indian firms need to rethink business plans in the light of these complexities. In some areas, China-centric sourcing and technological dependance can elevate business risk. For these, a selective retreat from economic engagement with China, and increased emphasis upon the global market, is optimal. In other areas, India can become the dominant alternative to the China-centric supply chains of the past, addressing the desire of global firms to reduce their exposure to China.


In one scenario, India remains smaller than China for an indefinite future, and the strategy of coalition-building will remain central. There is, however, the possibility that India can roughly match Chinese strength in about 20 years. This is not just wishful thinking, and this is not predicated upon Chinese stumbles. It requires reversing the growth malaise of the post-2011 period. This requires foundational change in public policy frameworks around three main ideas: the increasing scale of government micro-management of the economy, the expanding administrative state and the growing erosion of the rule of law. A critical element of this 20-year journey lies in innovation policy. India needs to match and improve upon China's achievements in fostering research institutions and the intellectuals that inhabit them.

Becoming an advanced economy has always been the objective in India, right from the freedom movement and the creation of the Republic. What has changed in recent years is Chinese hostility, which has given a fresh dimension of urgency on solving the growth malaise, on learning how to be a mature market economy located in a liberal democracy. The judicious use of self reliance ("atmanirbhar") grounded in self confidence ("atmavishwas"), where a confident India engages with the world without insecurity, forms alliances with like minded countries, and leverages democracy and a skilled workforce to good effect, is the path through which the China challenge can be addressed.

Gautam Bambawale is former Ambassador of India to China, Pakistan and Bhutan. Vijay Kelkar is Vice-President, Pune International Centre. Raghunath Mashelkar is President, Pune International Centre. Ganesh Natarajan is Chairman of 5F World and of Lighthouse Communities. Ajit Ranade is Chief Economist, Aditya Birla Group. Ajay Shah is Research Professor of Business, Jindal Global University.

Grievance Redress by Courts in Consumer Finance Disputes

by Karan Gulati and Renuka Sane.

India has made progress on financial inclusion through the use of digital payments and fintech. As more and more consumers interact with the consumer finance industry, there will invariably be greater frictions and an increasing number of grievances. In an environment with a good consumer complaints system, these should get resolved by the financial service provider (FSP), and if not the FSP, then the regulator. However, this is not so in India. Courts are often the preferred recourse for retail consumers. For example, in the ongoing dispute regarding Yes Bank's written off AT-1 bonds, consumer courts seem like the last remaining alternative for retail investors. Unless grievances are satisfactorily resolved, we may hurt the progress made on financial inclusion. While India needs to set up good regulator-based grievance redress mechanisms such as a Financial Redress Agency, it also needs to improve the functioning of courts to provide effective relief in consumer finance (and other)disputes. In a recent paper, Grievance Redress by Courts in Consumer Finance Disputes, we review 60 judgments on consumer finance to study the position that courts have taken on these disputes. We also describe the challenges in court functioning that have a bearing on the efficiency of courts in dealing with issues of grievance redress.

The structure of courts

In 2020, India enacted a new Consumer Protection Act (CPA). The Act aims to protect consumers' interests and provide timely and effective settlement of disputes. It entrusts courts to redress consumer grievances. A complainant can approach specialised courts i.e. consumer commissions established by the CPA. However, these are additional remedies. Cases may also be decided by the High Court of various States and the Supreme Court of India.

The powers to grant relief depend on which court the complainant approaches. Consumer commissions are bound by the CPA. They may order a party to: (i) remove defects, (ii) return the price of the goods or the charges for the services along with interest, (iii) pay compensation or punitive damages, and (iv) withdraw the goods or services from the market. High Courts are bound to decide cases either within the confines of a statute under which they are approached or the constitution. Going one step further, the Supreme Court has held itself not restricted in any way to grant adequate relief.

Banking and insurance disputes

Litigation is disproportionately costly and troublesome for small consumers. Very rarely can an ordinary consumer go through the prolonged ordeal of fighting with a bank. For this reason, courts have granted relief to individual consumers, given that they come with clean hands.

This has not been the case when interpreting insurance contracts. If consumers knew about the terms, courts have enforced the terms of the contract, regardless of whether the terms themselves were unfair, one-sided, or opaque. On the other hand, if the terms were kept hidden from the consumer, courts have granted relief to consumers. This is true both while entering the contract and settling claims.

Several consumers have been introduced to complex products and contracts, but these consumers have insufficient know-how. They are vulnerable to mis-selling. The strategy in Indian finance has historically focused on the caveat emptor doctrine -- let the buyer beware. Though the new CPA gives consumer commissions the power to declare certain unfair terms as void, it does not address the ability to understand the terms. Thus, consumers have been left to their own devices, and unaware consumers are unlikely to get their desired remedy if they approach a court.

Challenges to court functioning

We find the following challenges in court functioning as they deal with consumer finance disputes.

1. Low Compensation: Courts tend to award low compensation that does not adequately compensate the complainant. For example, in Dr Virendra Pal Kapoor v. Union of India and Ors, a senior citizen had invested INR 50,000 in a unit-linked product in 2007. Upon payout in 2012, he had lost the entire sum except INR 248 on account of hidden charges. Though the insurer was directed to repay the original Rs. 50,000, no interest was awarded. The reason for low compensation seems to be that there are no guidelines for courts to follow. There is no expert analysis of the loss. In the absence of financially prudent legislation, courts often tend to award compensation that only makes sense when the legislation is enacted.

2. Delay: Low compensation becomes more severe when it takes too long to settle disputes. The CPA provides that cases should be decided in no more than five months. However, as per the case management system of the National Commission, it takes 1.99 and 2.38 years to settle banking and insurance disputes, respectively, i.e. more than five times the statutory guideline. In fact, in February 2020, the National Commission adjourned a matter till January 2021 - almost a year after the hearing.

3. No Class Action: If consumers cannot understand complex financial agreements, they may benefit from pooling their knowledge and approaching courts as a class. Plaintiffs can share evidence, expert witnesses, and litigation costs. However, unlike other countries, such suits are few and far between in India. This may be because of unclear substantive law and strict rules on financing litigation. This makes it difficult for class members to come together. Courts have left it to their discretion to evaluate whether the class is adequately represented and whether financing agreements are fair. Moreover, the legislature had prohibited contingency fees. This creates a system that either prohibits or disincentives class actions.

4. Specialisation: Consumer courts in India resolve all consumer disputes. Though the members are highly qualified individuals, they lack specialization in finance. This is unlike other common law countries where sectoral experts adjudicate finance disputes. They have adopted extensive adjudicatory legislation regarding financial products and services. On the other hand, laws in India regarding finance have been restricted, leaving courts to start from a clean slate. If timeliness and predictability can make India's finance regime more appealing, specialization by adjudicators could prove valuable.

Way forward

One obvious way to improve the system is by general improvements in the judiciary's capacity and knowledge on matters related to finance. This will, however, take a long time. Policymakers should also consider adopting certain targeted interventions.

There are two types of interventions that are required. The first is on the legislative front. Like the targeted legislation in other countries, the legislature could enact separate rules for financial transactions mandating clear and understandable disclosures. Policymakers may also consider prescribing adequacy requirements in class action suits and transitioning towards contingency fees for lawyers and third-party investors. Any such changes in legislation would also benefit from an advisory council on consumer finance. The council may be responsible for making representations about policies; reviewing, monitoring, and reporting their effectiveness; and highlighting its views on new rules and regulations.

The second is on the judicial front. One problem we identify is low compensation. This may be addressed by updating and consolidating the rules governing compensation considering modern market understanding. Other jurisdictions often order disgorgement (surrender of profits earned through illegal means) or grant a remedy of restitution. This seeks to measure actual damages. On the question of delays, courts may also separate their judicial and administrative functions. This will likely reduce the time it takes to conclude hearings since members of the commission would have more time to focus on their judicial tasks. The National Commission can also exercise its power to call for statistics from State Commissions and conduct systematic reviews.

These solutions can have significant consequences, especially in India, where financial literacy is low and regulatory enforcement appears weak. Though they were developed after studying consumer finance disputes, they may have consequences outside this domain and yield better functioning courts. Market-oriented compensation, without delay, when parties can come together as a class would be beneficial in any dispute. In a growing financial landscape such as India, redress bodies such as the judiciary become increasingly important. A specialized consumer protection law is a step in the right direction, but it can benefit from targeted interventions.

References

Department of Economic Affairs, Report of the Financial Sector Legislative Reforms Commission: Volume 1, March 2013.

Dhirendra Swarup, Establishing the Financial Redress Agency, January 27 2017, The Leap Blog.

Dr Virendra Pal Kapoor v. Union of India and Ors, May 29 2014, Allahabad High Court.

Karan Gulati and Renuka Sane, Why do we not see class-action suits in India? The case of consumer finance, May 03 2020, The Leap Blog.

Karan Gulati and Shubho Roy, India's low interest rate regime in litigation, March 11 2020, The Leap Blog.

Murali Krishnan, Supreme Court urges consumer forum to look into grievance of year-long adjournments, August 16 2020, Hindustan Times.

National Informatics Centre, Computerization and Computer Networking of Consumer Forum in the Country.

Neil Borate, Those mis-sold Yes Bank AT1 bonds face long haul, May 11 2020, LiveMint.

Pratik Datta, Mehtab Hans, Mayank Mishra, and others, How to Modernise the Working of Courts and Tribunals in India, March 25 2019, NIPFP Working Paper No 258.

Reserve Bank of India, National Strategy for Financial Inclusion, January 10 2020.

Supreme Court Bar Association v. Union of India, April 17 1998, Supreme Court of India.

Tinesh Bhasin, RBI sees 387% rise in complaints against NBFCs, 58% rise against banks, February 08 2021, LiveMint.

The authors are researchers at NIPFP.

How large is the payment delays problem in Indian public procurement?

by Pavithra Manivannan and Bhargavi Zaveri.

Payment delays are endemic in government contracts in India. Businesses generally factor payment delays into the price of public sector contracts. Measuring the size and extent of overall payment delays from the government to vendors and contractors has, however, been a challenge. In this article, we use a novel data-set put together from public sources to ascertain the size of the payment delays problem in Indian public procurement.

When a private entity delays contractual payments, the delay is factored into the price of the next vendor contract or the debt contracted by the private entity. This feedback loop naturally instills payment discipline by aligning the payer's incentives with maintaining payment discipline. This is harder to achieve for government contracts, as information about payment delays in public procurement is often sparse, difficult to discern from budgetary statements or missing altogether. The problem is compounded as the state procures goods, services and works at various levels and through various entities owned by it. Payment delays affect the working capital cycle of vendors of all sizes. However, payment delays have a particularly deleterious impact on Micro Small and Medium Enterprises (MSMEs), which often have limited access to formal financial systems to bridge their working capital requirements. Timely payments, therefore, are of crucial importance to MSMEs as they rely on their cash-flow cycle to fund their working capital requirements.

Payment delays in contracts with CPSEs

A significant proportion of overall central government procurement is undertaken by centrally owned public sector enterprises (CPSEs). Most CPSEs are incorporated as companies and many of them are listed. We use the information in the annual results of CPSEs as a proxy to ascertain the scale of payment delays in the public procurement undertaken by the central government. We study the balance sheet and annual reports of listed CPSEs for the last three financial years, 2017-18, 2018-19 and 2019-20 ("study period").

We find that CPSEs had annual average outstanding trade payables of Rs.1.3 trillion as against an annual average procurement value of Rs.1.1 trillion, during our study period. This suggests that the annual average outstanding trade payables of CPSEs were about 18% higher than the annual average procurement undertaken by the CPSEs. We also find that when taken as a percentage of the value procured, CPSEs under some ministries, such as the Railway and Defence Ministries and Ministry of Housing and Urban Affairs, fare significantly worse than others. Further, we find that on an average, payments worth 8% of the total value procured from MSMEs are delayed for more than 45 days from their due date. Finally, we find that CPSEs demonstrate weak payment discipline towards all their vendors, and that the MSME vendors are not worse-off than the other vendors. This suggests that in the case of government contracts, the imbalance of the relative negotiating power of MSME vendors and non-MSME vendors has limited impact on the behaviour of the payer.

Our work demonstrates the potential to develop an ongoing system to measure payment discipline in public procurement, which could then act as a feedback loop for pricing vendor contracts when dealing with CPSEs and the government departments to which they are aligned.

Data and methodology

Our analysis is based on a hand collected data-set put together from the following two public sources of data:

1. the MSME Sambandh portal set up by the the Ministry of Micro, Small and Medium Enterprise in 2017, to monitor the implementation of the Public Procurement Policy, 2012;
2. Annual reports and annual balance sheets published by CPSEs.

Our data-set consists of firm level information about CPSEs, such as the year of their incorporation, listing date, industry classification, variables indicative of their financial health and the procurement undertaken by them. We augment the data-set with information on payments delayed by CPSEs to MSME suppliers beyond 45 days from the date on which such payments became due (hereafter, "delayed payments"). The Micro, Small and Medium Enterprises Act, 2006 (MSME Act)requires all companies that procure goods, services and works from micro, small and medium enterprises to disclose such payments in their annual report in the prescribed format.

Our data-set covers this information for 57 listed CPSEs. We collect the data for these CPSEs for three financial years beginning with the year in which the MSME Sambandh Portal was set up. This gives us data for the financial years, 2017-18, 2018-19 and 2019-20, which is our study period.

These 57 CPSEs are spread across 17 departments or ministries of the Central Government, with the largest number concentrated under the Ministry of Petroleum and Natural Gas (19.3%), followed by the Ministry of Power (10.53%) and the Ministry of Steel (8.77%). The CPSEs in our data-set are spread across 34 industries, as per the National Industrial Classification (NIC) scheme prescribed by the Ministry of Statistics and Programme Implementation (MoSPI). CPSEs in the business of 'electricity, gas, stem and hot water supply' account for the largest group (12.28%) followed by CPSEs engaged in the business of manufacturing coke, refined petroleum products and nuclear fuel (8.77%).

Each CPSE reports a target procurement value at the beginning of the financial year and the actual procurement value at the end of the financial year, on the MSME Sambandh portal. Table 1 shows the aggregate value of goods, services and works targeted and actually procured by the CPSEs in our data-set across different government departments.

Table 1: Procurement by CPSEs

	No. of CPSEs	Target (Rs. crore)	Actual (Rs. crore)
Department of Chemicals and Petrochemicals	2	371.66	308.38
Department of Commerce	2	17.28	18.3
Department of Defense Production	3	1963.33	2880.47
Department of Fertilisers	4	2547.34	2641.74
Department of Heavy Industry	4	16392.1	15209.25
Department of Telecommunications	2	0	0
Ministry of Coal	2	5977.39	1774.82
Ministry of Defense	3	5838.79	7066.05
Ministry of Housing and Urban Affairs	2	12.61	12.67
Ministry of Mines	2	2573	7132.09
Ministry of Petroleum and Natural Gas	11	52175.63	63849.08
Ministry of Power	6	6142.97	6608.55
Ministry of Railways	4	395.07	429.31
Ministry of Science and Technology	1	38	17.49
Ministry of Shipping	3	1725.67	1321.45
Ministry of Steel	5	4556.4	5356.22
Ministry of Tourism	1	125.07	34.85

The Ministry of Petroleum and Natural Gas is the largest procurer in our data-set, both in terms of the number of CPSEs and the value of goods, services and works procured by them. Table 1 also shows that a majority of the CPSEs have procured more than their annual targeted value. We observe this to be true across all the three financial years comprised in our study period.

Findings: CPSEs' outstanding dues

Trade payable are a rough proxy of the amounts due from a firm to vendors and service providers. We use the data on outstanding trade payable from the balance sheets of CPSEs as an estimate of payment delays in public procurement. Table 2 shows the three-year annual average outstanding trade payable due from the CPSEs in our data-set. The second column indicates the corresponding annual average value of procurement undertaken by these CPSEs, and the last column indicates the average outstanding trade payable as a percentage of the average annual procurement undertaken by the CPSEs.

Table 2: Average outstanding trade payable and procurement value

	Procurement value (Rs. crore)	Outstanding payable (Rs. crore)	Payable/ procurement (percent)
Department of Chemicals and Petrochemicals	308.38	106.11	34.41
Department of Commerce	18.3	1119.66	6118.36
Department of Defense Production	2880.47	3449.92	119.77
Department of Fertilizers	2641.74	1971.93	74.65
Department of Heavy Industry	15209.25	10297.54	67.71
Department of Telecommunications	0.00	2313.67	0.00
Ministry of Coal	1774.82	1898.59	106.97
Ministry of Defense	7066.05	3031.90	42.91
Ministry of Housing and Urban Affairs	12.67	2709.40	21384.37
Ministry of Mines	7132.09	1227.54	17.21
Ministry of Petroleum and Natural Gas	63849.08	82830.09	129.73
Ministry of Power	6608.55	7907.65	119.66
Ministry of Railways	429.31	1243.77	289.71
Ministry of Science and Technology	17.49	29.38	167.98
Ministry of Shipping	1321.45	1562.02	118.21
Ministry of Steel	5356.22	8739.99	163.17
Ministry of Tourism	34.85	58.94	169.12
Total	114660.72	130498.11	113.81

While the procurement value of a given financial year does not necessarily mean that the entire value of the contract becomes payable in the same financial year as the procurement contract may span across multiple years, the three year average numbers in Table 3, however, show a systemic break-down in the payment discipline of CPSEs. We speculate that these trade payable would have aggregated over time, and do not necessarily pertain entirely to the study period.

We then look at three departments/ ministries that account for the largest procurement by value in our data-set, to investigate the differences in the payment behaviour of CPSEs towards MSMEs and non-MSME vendors (Table 3). The CPSEs in these three departments also account for nearly 75% of the total outstanding trade payable of all the CPSEs in our data-set.

Table 3: Outstanding trade payable of CPSEs (as percent of value procured)

	2017-18		2018-19		2019-20		Total
	Non-MSME	MSME	Non-MSME	MSME	Non-MSME	MSME	Non-MSME	MSME
Department of Heavy Industry	84.02	7.87	80.87	15.82	110.63	11.81	88.89	12.22
Ministry of Petroleum and Natural Gas	182.65	7.60	187.97	3.56	143.05	4.13	171.49	4.32
Ministry of Power	116.44	14.90	161.54	15.35	292.02	21.73	175.63	17.46

In each of the three cases, the proportion of total outstanding trade payable to the value procured by the CPSEs during the study period is much higher for non-MSMEs than MSMEs. In the case of the Ministry of Petroleum and Natural Gas and the Ministry of Steel, the proportion of outstanding trade payable to non-MSME vendors exceeds 100% of the value procured, on an aggregate basis across the three years. Compared to non-MSME vendors, this proportion is significantly lower for MSME vendors (the highest being 21%).

Findings: Delayed payments by CPSEs to MSME suppliers

The final leg of our measurement involves estimating the 'delayed payments' by CPSEs to MSMEs, that is, payments delayed beyond 45 days from their due date. We aggregate the delayed payments outstanding as at year-end, by CPSEs to MSMEs, government department wise. Table 4 shows the delayed payments as a percentage of their annual procurement value from MSMEs.

Table 4: Delayed payments as percentage of procurement

	2017-18	2018-19	2019-20	Average
Department of Chemicals and Petrochemicals	6.22	11.73	11.84	10.46
Department of Commerce	0.86	47.38	1.08	17.47
Department of Defense Production	5.82	3.35	5.44	4.78
Department of Fertilizers	7.58	5.25	4.82	5.38
Department of Heavy Industry	7.91	15.92	12.11	12.37
Department of Telecommunications	0	0	0	0
Ministry of Coal	9.11	5.42	8.47	7.19
Ministry of Defense	3.55	3.20	3.98	3.56
Ministry of Housing and Urban Affairs	6.72	4.86	5.49	5.70
Ministry of Mines	2.79	1.51	2.85	2.37
Ministry of Petroleum and Natural Gas	4.12	4.80	6.18	5.25
Ministry of Power	24.95	25.33	31.87	27.51
Ministry of Railways	11.03	20.58	11.02	13.62
Ministry of Science and Technology	0	0	0	0
Ministry of Shipping	14.36	3.47	2.94	5.62
Ministry of Steel	4.84	10.18	4.81	6.18
Ministry of Tourism	0	0	21.13	21.13
Total	7.36	8.06	8.70	8.16

We find that the delayed payments by CPSEs to MSMEs average at about 8% of the actual value of goods, services and works procured by them from MSMEs during the study period. This percentage has marginally increased from 2017-2018, and is higher than the average in 2019-20.

Conclusion

In this article, we take a sector-agnostic approach to measure the scale of the payment delays problem in public procurement in India. An analysis of the annual returns and balance sheets of CPSEs gives us new insights on the scale of the problem at three levels, namely, at the level of the CPSE, the industry and the government department to which the CPSE is aligned.

Our analysis provides evidence of the popular perception of CPSEs' weak payment discipline to vendors. Taken as a percentage of the average procurement undertaken by CPSEs, the payment delays by CPSEs to their vendors far exceeds their procurement values. Second, while CPSEs demonstrate weak payment discipline to both MSME and non-MSME vendors, the delay seems to be much larger towards large vendors than the small ones. Third, the delayed payments reporting requirements mandated under the MSME Act provides us an illustrative picture on the payment discipline of the CPSEs. For two out of three years of our study period, we notice that the total delayed payments to MSMEs is higher than the three-years average (Rs. 2323.42 crores).

Our approach of understanding payment delays in public procurement in India, through balance sheets of CPSEs demonstrates the possibility of setting up ongoing systems for the measurement of payment discipline of government departments through CPSEs aligned to them. Further, these delays may be indicative of either of liquidity mismatches or solvency issues, at the CPSE, or a mix of both. By approaching this problem from a balance sheet perspective, our study lays the foundation for conducting future work on the possible relationship between the financial health of the procurers and their payment discipline.

The authors are researchers at the CMI-Finance Research Group and thank Susan Thomas for valuable discussions.

Grievance Redress in the Financial Sector in India: Lessons from the field

by Renuka Sane, Srishti Sharma and Karthik Suresh.

The Reserve Bank of India (RBI) recently announced measures to strengthen its grievance redress (or consumer complaints) system. This is a timely announcement as banks have not been performing well on customer service. There has also been an increase in the number of complaints on digital transactions. The National Strategy for Financial inclusion has also said that improved grievance redress would enable wider access to finance.

While research on financial inclusion and consumer protection in India has evolved in the last decade, studies specific to consumer complaints are more recent (Siddique and Tripathi, 2010; Balasubramaniam, Biswas, Sane and Sarah, 2020; Raghavan, 2020; Dvara Research and Khabar Lahariya, 2020). An understanding of the nature and extent of the problems in accessing existing systems is an important input to policy.

In this article, we present our findings from the group interviews we conducted with diverse customers in rural and urban Maharashtra. We present our learnings on the products customers use, the problems they have when using the products, and how they deal with the problems. We also study experiences in accessing formal grievance redress mechanisms (GRMs). These interviews have important lessons on the differences in the approach between rural and urban customers. This can be a useful input in making the GRMs more inclusive.

Sample

We conducted 12 group interviews in the months of January and February 2020 with a total of 120 participants in Nagpur and Wardha districts, and Mumbai. Participants in the groups varied in economic conditions and usage of financial products. The groups were as follows:

1. Nagpur and Wardha: The respondents belonged to eight villages in Nagpur and Wardha districts. These were women who were customers of Microfinance Institutions (MFI). Their occupations ranged from agriculture, dairy, animal husbandry and wage labour.

2. Mumbai: We interviewed four groups in Mumbai: members of a self-help group of women who live in slums, media professionals, post-graduate students from a premier educational institution, and retired men who were members of the committee for their co-operative housing society.

Details regarding the groups we interviewed are provided in Table 1.

Table 1: Description of group interviews

Location	Number of interviews	Group description	No. of participants	Gender	Age group	Smart Phone Usage
Nagpur	8	Microfinance customers	80	All women	30-50	5
Mumbai	1	Self Help Group	14	All women	30-50	All
Mumbai	1	Post-grad students	10	80% men	20-25	All
Mumbai	1	Committee members of a cooperative housing society	5	All men	55-65	All
Mumbai	1	Media professionals	6	All men	30-40	All

Group Interviews

A typical session lasted about 20-25 minutes. After general introductions, our conversation revolved around the following questions:

1. What kind of financial products did they use? Did they use banking services, credit, insurance, pensions, equity products, payment wallets etc.
2. Had they heard of regulators such as the RBI, or the Insurance Regulatory and Development Authority of India (IRDAI)? Had they heard of formal mechanisms of grievance redress such as the system of Ombudsman set up by the regulators?
3. Did they face any problems when using these products? If yes, what kind of problems did they face?
4. What did they do when faced with such problems? Did they complain? If yes, to whom? What happened after they lodged their complaints?
5. If they did not complain, why did they not complain?
6. What kind of improvements would they like to see in the complaints mechanism?

Sometimes, it is possible that consumers do not remember incidents that may have happened, or do not see certain incidents as "problems". We therefore used hypothetical scenarios of aggrieved customers. For each financial product, we designed 3-4 scenarios each of which showed a different type of grievance. Each scenario was also placed at a different level of escalation within the system. Table 2 shows the set of scenarios for banking services. For instance, in the first case the problem had just happened and no action had been taken. In the second instance, the customer had complained to the provider, but had not received a reply. In the third, the customer had complained to the regulator who ruled against the customer. After presenting the scenarios, we first asked participants whether they have faced similar situations in the past. We also asked them what they would have done if they would have been in the situation as described in the scenarios. This helps us explore how consumers would react to different situations.

Table 2: Examples of hypothetical case studies: Banking

Scenario 1	Raj found that an ATM withdrawal transaction has been debited twice in his passbook.
Scenario 2	The cashier at a bank talked rudely to Seema, who had politely requested him to work faster as he was gossiping and functioning slowly. The manager refused to intervene even after Seema had complained.
Scenario 3	The bank increased the interest rate by 3% on a home loan taken by Rahul, saying it has the right to change interest rates whenever it wishes. He complained to the Ombudsman, which agreed with the bank.

Findings

1. Access to financial instruments : We asked all the participants whether they used the following financial services: banking, insurance, payment apps, pensions and securities. Figure 1 shows the variation in access to these instruments among the rural and urban samples. The rural sample had access only to banking services, microfinance loans and micro-insurance products. Very few among the rural sample used an ATM card, and even fewer had heard of payment apps. Considering that most of the women did not own a smart phone, there was no usage of mobile phones for financial transactions. They met their MFI representative and visited their bank branch about once a month. The urban sample had access to all the products. Everyone had a bank account. In the overall pool of 120 participants, only 4 participants used pension products. Hence this article does not include information on the usage of pensions.


Figure 1: Access to financial instruments

2. Awareness of GRMs: We listed the the names of various regulators and redress mechanisms and enquired if participants had heard of them. Among rural participants, no one had heard about the regulators or knew about the existence of GRMs and ombudsman. When we presented the hypothetical scenarios, their response was to go to the service provider from whom they had purchased the product. If this failed, they would approach the police or a government official like district magistrate or tehsildar. There was no awareness about existing formal grievance redress mechanisms among the rural sample. Most of the urban participants had heard about the regulators but only a few knew about the grievance redress mechanisms.

3. Nature of grievances: The rural and urban sample differed in their perception of what constitutes a problem. The rural sample, for example, had internalised the rudeness of the staff. Misbehaviour, inconvenience (e.g. going to the bank branch to withdraw cash because the ATM card doesn't work) etc. were not seen as major problems. Everyone in the rural sample first reported they had never faced a problem with their bank or MFI. But when we shared the scenarios described earlier, two women said that they had faced such problems in the past. The grievances were mostly related to difficulty in opening bank accounts, ATM card getting stuck in the machine and an increase in interest rates. In the urban sample, the nature of grievances ranged from wrong debit transactions, mis-selling of insurance products, rude behaviour, delays in service delivery and concerns for data privacy (See Table 3).

4. Response to the grievances: In the rural groups, women had not taken any action to seek redress. In one instance, a woman in Wardha district shared that her ATM card got stuck in the machine while she was withdrawing cash. Instead of approaching the officer at the branch, she stopped using the ATM card altogether and now visits the bank branch every time she wishes to withdraw cash. Some of the participants in the urban groups who had a grievance had approached the bank/insurance company and the regulator. In some cases, the threat of going to the regulator drives the service provider to resolve the complaint immediately. For example, a respondent in Mumbai told us that he had informed the branch manager that he has written to the RBI Ombudsman since a complaint had not been resolved within a reasonable time-frame. The branch manager ensured that his complaint was addressed on priority basis. Table 3 provides a description of the nature of grievance, as well as the response of the participant.

Table 3: Nature, responses and outcomes of grievances

Grievance	Response	Outcome
Rural
Banking
ATM card got stuck	Stopped using ATM card	Goes to branch
Rude behaviour, refusal to entertain the complaint	No action
Microfinance
Threat to increase interest rates	No action
Charge higher rate of interest than what was informed	No action
Painful recovery process	No action
Urban
Banking
Opening bank account	Approached Tehsildar after six months	Changed the provider
Sharing data with third party vendors	Online complaint to bank	Stopped getting unsolicited communication calls
Refusal to make cheque/DD	Letter to Ombudsman	Manager apologised and issued cheque
Lack of cooperation by bank staff	Met the branch manager	Issue resolved
Delays in EPF payment	Letter to Ombudsman	Matter out of jurisdiction
Insurance
Mis-selling of policy	Contacted branch office	No satisfactory response

5. Reasons for not complaining: Fear of retribution was one of the major reasons for not complaining about grievances, especially among the rural sample. These participants were afraid that if they try to take any action, they might face an adverse action from the service provider e.g. difficulties in getting a loan. One of the respondents from Nagpur district told us, "when the bank staff speak to us rudely, we just let it go. We did not want to create an issue with the bank manager." Further, they felt that even if they complain, nobody will listen to them. Among urban professionals, the most common reasons for not complaining were lack of trust in the system, complexity of procedures and the time consumed by these procedures. For instance, one student shared that his parents were mis-sold an insurance policy, however they did not file any complaint citing that their problem was unlikely to be resolved. Some participants also reported that they did not consider their problem to be big enough to undertake the effort to complain.

Implications for the design of GRMs

The Indian Customer Satisfaction Index (ICSI) study showed that Indian banks have customer loyalty score of 65 compared to Singapore (74), US (72), South Africa (71) and UK (67). Yet, only a small fraction of consumers file complaints with the regulators in banking, insurance and pensions sectors. Indians operate 574 million basic savings bank accounts however for FY2019, the RBI Ombudsmen across 21 offices in India received only 1,95,901 complaints in FY2019 i.e. 0.34 complaints per thousand accounts. With life insurance products, this figure for FY19 stands at 0.59 complaints per thousand policies sold. For comparison, the corresponding figure for the Financial Ombudsman Service (FOS) in the United Kingdom (UK) is 2.3 complaints per thousand accounts during the same period. Our study sheds light on some of the reasons for the low rates of complaints despite the high level of dissatisfaction.

1. Perceived cost of inconvenience: We found that the perceived cost of inconvenience or bad behaviour is very low for the rural and urban poor samples. Those who faced such problems either took no action or stopped using the product. Only when there was some kind of monetary loss, consumers took some action. The cost of inconvenience is compounded for women who have recently become a part of the formal financial sector and gotten access to microfinance loans. For instance, one woman who took a microfinance loan shared that a recovery agent stayed at her home for 12 hours and refused to leave without the money. She did not file a complaint because she perceived her inconvenience to be lower than the threat of losing access to the product.

2. Low levels of awareness: Awareness about the grievance redress mechanisms in both rural and urban samples is low. Lack of awareness increases the cost of complaining. The problem is further exacerbated by the fact that spreading awareness of existing processes to seek redress is not high on the agenda of financial service providers.

3. Fear of retribution and perceived right to redress : The low levels of engagement with GRM in the rural sample is driven by the fear of retribution. We also saw that the propensity to complain within this group depended on their perceived right to redress. They felt that redress is a luxury for them and not a right.

4. Costs of complaining: Among the group that has an awareness of GRMs, and an awareness of their rights with limited fear of retribution, the costs of the process were seen to be very high. For instance, due to delays in processing cheques by the bank, one respondent, a middle aged professional from Mumbai, could not obtain a favourable rate of interest for his provident fund payment. He approached the ombudsman to complain regarding the loss he incurred due to the lower interest rate. However the ombudsman responded by stating that the matter was outside their jurisdiction. Confused with which provider to approach, he did not pursue the matter further.

Our results suggest that there are deficiencies in the existing GRM process, and consumers are responding to their dissatisfaction either by bearing with the problem, changing their behaviour to avoid confrontation with the system, or stopping the use of the financial product entirely. These seem to be the preferred modes of adjustment relative to formally complaining.

Spreading awareness about the rights of consumers, and the formal grievance redress mechanisms should be a vital element of any good GRM design. Information should be imparted on types of legitimate grievances for which a customer can seek redress. Such an effort would help mitigate consumers' fear of retribution associated with the task of complaining. The onus of spreading awareness on rights to redress and redress mechanisms should be put on financial service providers. The providers should not only impart knowledge on existence of such mechanisms but also explain the methods to access these systems and to escalate their complaint in case of unsatisfactory resolution. Moreover, there is a need for simplification of grievance redress process, especially in the cases where two or more financial products are involved and jurisdictions of various regulators are unclear. Such measures would reduce the cost of complaining and improve trust among the consumers about the system.

Conclusion

Financial inclusion is one of the major policy goals for the Indian government. Aided by various government schemes like the Pradhan Mantri Jan Dhan Yojana, 357 million new savings bank accounts with insurance coverage have been opened since March 2014. The number of National Pension Trust subscribers has doubled from 6.5 million in FY2014 to 13.9 million in FY2020 and the number of demat accounts of Indian residents registered with the National Securities Depositories Ltd. (NSDL) has increased from 13.4 million in FY2014 to 19.1 million in FY2020. However, to sustain financial inclusion, an effective customer grievance redress mechanism (GRM) is important. The group interviews helped us understand the nature and extent of complaints, the reasons that consumers chose to complaint or not and the experiences consumers had while engaging with the GRM. We hope that the lessons from such studies can provide valuable insights to regulators as they take steps towards improving existing grievance redress mechanisms.

References

Balasubramaniam, Biswas, Sane and Sarah (2020), Estimating customer complaints using Twitter feeds, The Leap Blog, 14 May 2020.

Dvara Research and Khabar Lahariya (2020), Video series on access, redressal and finance in Uttar Pradesh.

Raghavan (2020), Transaction Failure Rates in the Aadhaar Enabled Payment System: Urgent Issues for Consideration and Proposed Solutions, 21 May 2020.

Siddiqui and Tripathi (2010), An analytical study of complaining attitudes: With reference to the banking sector, Journal of Targeting, Measurement and Analysis for Marketing, Vol. 18, p. 119-137.

The authors are researchers at NIPFP. We thank Sudipto Banerjee and Sarang Moharir for participating in the Mumbai interviews. We thank Vimal Balasubramaniam for useful comments.

Inflation got back into the target zone

by Ajay Shah.

On 20 February 2015, MOF and RBI signed the `Monetary Policy Framework Agreement', and the power of monetary policy (i.e. setting the short term rate) got connected to an objective (get y-o-y CPI inflation to 4%, with a permissible range from 2 to 6 per cent). For some time thereafter, it worked rather well.

From late 2019, we have had problems with inflation. In December 2019, the bound was breached, when inflation reached 7.36 per cent. In the 12 months from December 2019 to November 2020, there was only 1 month (March 2020) where the value at 5.84 was within the 2-to-6 range.

There was considerable angst about this. For many people, aggregate demand was clearly adversely affected by social distancing, and the task of monetary policy was to stimulate demand. In this period, headline inflation being above 6 per cent was an irritant. It even proved, to some, that the very concept of inflation targeting was flawed. There was the angst that is often heard in India, about supply constraints that shape inflation.

RBI eased monetary policy using the many instruments that it possesses, including the repo / reverse repo rates where the votes of 3 external members of the MPC also count.

In my research network, we felt comfortable about this stance of monetary policy:

• Our models, which work with seasonally adjusted data, suggested that headline inflation would drop in December. 
• We expected that the easing of supply restrictions that comes with post-pandemic normalisation would help address glitches in the price system.
• Our macroeconomic common sense suggested that at a time of weak aggregate demand, inflationary pressure was going to be low. 
•  In any case, monetary policy acts with a long delay. Headline inflation (a moving average of the point-on-point inflation of the latest 12 months) is a poor guide for anticipating headline inflation about one to two years out.
  

These arguments fed into our writings of this period: 7 Apr, 24 Jul, 24 Aug, 4 Dec, 11 Jan (the day before the December CPI release). 

We now have a data release for December 2020 and headline inflation was reported at 4.59 per cent, which is close to the target of 4 per cent, and well below the upper bound of the target range, of 6 per cent:

Headline inflation, in the inflation targeting period

I am reminded of Ken Rogoff who once said "Those who think inflation is caused by too little pork rather than too much money are wrong" (in the Financial Times, 4 February 2008). It speaks well for the Indian economic policy process, that the Ministry of Finance and RBI stayed the course through this period, and protected the inflation targeting system.

Announcements

Roundtable on public procurement and its impact on firms in India

The Finance Research Group and the Chennai Mathematical Institute are organising a web-roundtable on 'Public procurement and its impact on firms in India' on 22nd January, 2021 from 9:00 am to 12:30 pm. The roundtable will focus on identifying key issues in public procurement in India, distinguishing the symptoms from the causes and the pathways to building greater capacity in commercial contracting by the state.

Context

The Indian state is a large procurement body. Beginning with the central government and its agencies, CPSEs, state governments, SPSEs, municipal bodies, the state has a large presence in commercial contracting. Estimates suggest that the size of public procurement in India ranges from anywhere between 15-20% of GDP.

The discourse on public procurement in India has conventionally focused on issues of red tape, corruption and payment delays. Dues of the government to private enterprises are reported to have reached a magnitude large enough to be a drag on the economy. However, much of this discourse has been largely anecdotal. Over the last few years, digitisation of large parts of the Indian economy has created new sources of data that could support research-based analyses of the problems of public procurement and its impact on the financial health of firms.

This roundtable brings together academic researchers, practitioners and policymakers, to present and discuss their research to an interested group of peers and experts to elicit views and comments on their work.

Agenda

08:55 - 09:00	Welcome address Susan Thomas, Economist
09:00 - 09:35	A cross-country comparison of procurement laws Diya Uday, FRG-CMI and Anjali Sharma, S.P.Jain Institute of Management and Research         Discussant: Sudha Krishnan, Department of Atomic Energy, Government of India (Retired)
09:35 - 10:10	Inefficiencies in government procurement processes: a demonstration Anjali Sharma, S.P. Jain Institute of Management and Research and Shubho Roy, University of Chicago         Discussant: Santhosh Mathew, BMGF
10:20 - 10:55	Break
10:10 - 10:20	Dispute resolution in public contracts: evidence from courts Devendra Damle and Karan Gulati, NIPFP, Anjali Sharma, S.P. Jain Institute of Management and Research & Bhargavi Zaveri, FRG-CMI         Discussant: Surya Prakash B.S, Daksh
10:55 – 11:55 Presentation: Moderator: Panelists:	Panel: Payment delays in public procurement contracts Susan Thomas, Economist Ajay Shah, Economist Junaid Ahmad,World Bank Rajiv Mehrishi, Former Comptroller and Auditor General of India K.P. Krishnan, NCAER Pradnya Saravade, Maharashtra State Police Housing Corporation
11:55 - 12:10	Summing up Devesh Sharma,, BMGF
12:10 - 12:15	Closing remarks Susan Thomas, Economist

For those interested in attending the roundtable, please get in touch with Shyna Adhia on shyna.adhiya@gmail.com.