Capital Markets

Author: | Published: 12 Jul 2001
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A noticeable development in the Indian securities markets has been the emerging trend towards integration of the stock market with other financial markets. The behaviour of stock prices is being influenced by a variety of factors, including exchange rate movements arising out of foreign portfolio flows into the market. Much of the growth in India's market has been driven by the economic reforms in the wider economy, which freed industry from controls on investment and expansion. These have been amply supplemented by regulatory reforms and infrastructure development in the securities markets.

Several international financial institutions participate in India's capital markets in various capacities. Such financial institutions have also been active in underwriting offshore securities issues by Indian companies, and in managing and marketing mutual funds.

The Securities and Exchange Board of India (SEBI) is responsible for the development and regulation of India's securities, investor protection, and collaboration with the government and the Reserve Bank of India on securities market development.

DESCRIPTION OF THE MARKET

Capital market growth

The present process of economic reform, which began in 1991, has focused on increasing output. Improved efficiency is hoped to contribute to the greater competitiveness of Indian industry at home and abroad: efforts include pulling down artificial entry barriers for industry, removing restrictions on firm growth, and eliminating licensing requirements. The aim of the current regulatory move has been to increase the role of the private sector in the economy and to allocate capital more efficiently through market mechanisms. This has led to the development of a well-capitalized and professionally run securities market in India.

In addition to conventional equity/preference shares and debentures, Indian securities firms are now able to offer a wide variety of instruments.

The stock market scams of 1992 and 2001 have not dampened the enthusiastic reaction of the Indian securities markets to global market events. Although suffering from a combination of what is perceived by some as over-regulation and differing global pressures, the markets now tend to be less volatile. However, the markets in India are sturdy and have bounced back from many such meltdowns with resounding ferocity, making the Indian securities markets a viable international investment alternative.

Many regulators regulate India's capital markets, including the Department of Company Affairs of the Central Government, the Securities and Exchange Board of India (SEBI), and the Reserve Bank of India. Their roles are defined in terms of the Acts that each of these bodies is required to enforce. In any event, the primary law governing corporate securities is the Companies Act 1956. The secondary markets have been governed by the Securities Contracts (Regulation) Act 1956 (SC(R)A).

The Securities and Exchange Board of India, effective since 1992, is the primary regulatory body in respect of India's securities markets. The SC(R)A lays down the powers of SEBI over the governance of the secondary markets by regulating the establishment and running of the stock exchanges. Further, the SEBI Act 1992 lays down the structure of the SEBI, and the powers and limitations vested in SEBI for it to function as the primary securities market regulator in the country. Section 11 of the SEBI Act lays down the various aspects of the securities markets over which SEBI may regulate by drafting and enforcing rules and regulations. Almost all intermediaries in the securities markets (except investment advisers and special purpose vehicles for securitization transactions) are required to register themselves before they begin to function as intermediaries, and are required to abide by a specified code of conduct. Penalties and consequences in the event of default, enacted with a view to reducing white collar economic offences, have been laid down and are expected to function as deterrents.

Although the efficacy of SEBI has been questioned in the wake of current market occurances, SEBI is treated by some as having performed all in it power to prevent and mitigate the losses suffered by small investors. The basic flaw in the functioning of SEBI, as far as the development of a level playing field in the securities markets is concerned, has been the lack of focus, caused primarily because the "small investor" remains a mythical creature – undefined!

The term "securities" as defined in the Securities Contracts (Regulation) Act 1956, includes:

(i) shares, scrips, stocks, bonds, debentures, debenture stock or other marketable securities of a like nature in or of any incorporated company or other body corporate;
(ia) derivative;
(ib) units or any other instrument issued by any collective investment scheme to the investors in such schemes;
(ii) government securities;
(iia) such other instruments as may be declared by the central government to be securities; and
(iii) rights or interests in securities.

These are the instruments that can be traded by market players in the securities markets in India. Any other instrument may at best be traded over the counter unless specifically prohibited.

In terms of the SC(R)A 1956, all transactions in securities are illegal unless traded through the members of a recognized stock exchange. The only exception to this is a spot delivery contract – this is a contract that provides for the actual delivery of securities and the payment of a price for the securities either on the same day as the date of the contract or on the next day.

All stock exchanges in India provide online, screen-based trading and are linked to two depositories. The depositories are set up under the Depositories Act 1994. The depository participants involved are governed by the SEBI (Depositories and Participants) Regulations. Trading on the secondary market is in account period settlement mode. However, from July 2 2001, T+5 rolling settlement will begin in the most liquid stocks – also termed as A Group stocks in the Indian markets. Until recently, there were two deferral products available in the Indian market – Badla and the Automated Lending & Borrowing Mechanism (ALBM). In the wake of the recent crisis, these products have been banned with effect from July 2 2001 and it is proposed to introduce in their place options on individual stocks.

With effect from July 2001 many changes are being made to the trading structures of the Indian securities markets. What remains to be seen is whether the markets and its players react positively to the far-reaching changes, so as to develop the markets to truly global standards.

DERIVATIVES

Derivatives were introduced by the inclusion of the term "derivatives" within the definition of "securities" in the SC(R)A 1956. The term "derivatives" has been defined in the SCRA, to include:

"(a) a security derived from a debt instrument, share, loan whether secured or unsecured, risk instrument or contract for differences or any other form of securities;
(b) a contract which derives its value from the prices, or index or prices, of underlying securities."

The regulatory framework for derivatives trading in India was first laid down by the Dr L C Gupta Committee constituted by SEBI. SEBI also promulgated the suggested bylaws for derivative exchanges/segments and their clearing corporation/house, which set out the provisions for trading, and settlement of derivative contracts.

SEBI has also laid down the eligibility conditions for derivative exchanges/segments and their clearing corporation/house. The eligibility conditions have been framed to ensure that derivative exchanges/segments and their clearing corporation/house provide a transparent trading environment, ensure safety and integrity, and offer facilities for redress in the case of investor grievances. In India, the derivatives segments of the Stock Exchange, Mumbai and the National Stock Exchange are now in operation, following approval by SEBI.

Derivatives trading in India takes place through the online, screen-based trading system. The derivatives trading system is order-driven. The derivatives segments have online surveillance capability to monitor positions, prices and volumes on a real-time basis to deter market manipulation. The derivatives segments disseminate information about trades, quantities and quotes on a real-time basis through information vending networks, which are easily accessible to investors across the country. The derivatives segments have arbitration and investor grievance redressal mechanisms, which operate from all four regions in India. The derivatives segments have a system of monitoring investor complaints and preventing irregularities in trading, and a separate investor protection fund.

SEBI has approved the clearing house/corporation of the derivatives segments of the Stock Exchange, Mumbai and the National Stock Exchange. The clearing corporation/house performs full novation, ie it interposes itself between both legs of every trade, becoming the legal counterparty to both or alternatively providing an unconditional guarantee for settlement of all trades. The clearing corporation/house of the derivatives segments performs client-level exposure monitoring and all margins paid by clients are kept in trust by the clearing corporation/house.

For the purpose of guaranteeing trades, the clearing corporation/house has a separate trade guarantee fund for the trades executed on derivatives segments.

The derivatives segments and the clearing houses/corporations function in terms of the bylaws, rules and regulations that have been framed by the stock exchanges and approved by SEBI, under the SC(R)A.

In the derivatives market there are two levels of intermediaries, the trading member and the clearing member. The trading members provide trading facilities and are members of the derivatives segment. The clearing members provide only clearing facilities and are members of the clearing corporation/house. The clearing member is approved to carry on functions, subject to satisfying SEBI of certain criteria, including:

  1. the necessary net worth requirement, which at present is Rs30, 000, 000 ($XX);
  2. the certification requirement for dealers, sales personnel of member firms etc; and
  3. submitting the deposit of Rs5000, 000 with the clearing house/corporation.

The derivatives segments of the exchanges have also specified certain required net worth criteria for trading members.

The risk containment framework of the derivatives market has as its first line of defence the margins, which include initial, up-front and marked-to-market margins. The concept of value-at-risk is used for calculating the required level of initial margins. The initial margins are large enough to cover the one-day loss that can be encountered on 99% of the days. The exchanges are using standard portfolio analysis of a risk system developed by the Chicago Mercantile Exchange to calculate the worst-case loss over a one-day horizon, and charge the same as initial margins. As a second line of defence, trading and clearing members are required to restrict their exposure to 331/3 times the value of their deposits with the exchanges. The net worth of the trading and clearing members acts as a third line of defence in the risk management framework of the derivatives market in India.

Products

Any derivatives contract in India must have a minimum contract value size of Rs200, 000. This is enforced on all derivative contracts are traded on the stock exchanges. Notification 184(E), dated March 1 2000, passed by SEBI under section 16 of the SC(R)A permits trading only in derivative instruments that are listed on stock exchanges. Consequently, over-the-counter derivative products are not permissible in India. Further, all derivative products have to be approved by SEBI prior to listing and consequent trading.

The Indian scenario at present includes index-based futures and options, which are being traded on the derivatives segments of the stock exchanges. Stock options will be introduced by July 2001 and both SEBI and the exchanges are gearing up to promulgate the adequate risk management framework for the introduction of equity options on individual stocks. The equity options are proposed to be American-style cash settled options. SEBI has announced the indicators for choosing stocks for the introduction of such equity options. These include daily turnover, free float, market capitalization, volatility and continuous trading requirements.

Indian mutual funds have been permitted by SEBI to deal in derivatives for the purpose of portfolio balancing and hedging market risk on their portfolio. SEBI has also permitted, after suitable amendments to the regulations governing them, foreign institutional investors to trade in the derivatives markets. However, in the Indian markets, foreign institutional investors are also governed by the circulars issued by the Reserve Bank of India, which, at present permit trading only in index futures contracts, and restrict their transactions in such contracts to the amount of their portfolio in the cash markets. Therefore, foreign institutions and funds, like commodity trading advisers and hedge funds, which deal only in derivatives worldwide, are not permitted to trade in derivatives in the Indian markets. These provisions of the Reserve Bank of India are being reconsidered and may, in the near future, be amended to permit foreign institutional investors to trade in all SEBI-approved derivatives contracts.

Debt market developments

Regulatory structure and laws

Trading in the debt markets in India is at low volumes and the regulatory structure is unclear. The regulators for different kinds of debt instruments differ. The largest players in the debt market are the Indian government and the various local governments. They are the largest issuers and, traditionally, institutions are the largest investors and traders in the debt markets in India.

Laws relating to the instruments

The Indian capital markets recognize the existence of the following instruments:

  1. government dated securities and treasury bills;
  2. commercial paper, term bonds and certificates of deposit;
  3. repos, forward rate agreements and interest rate swaps;
  4. call/notice/term money; and
  5. corporate bonds, debentures and other corporate debts.

The term "debt instrument" has been defined in the SEBI (disclosure and investor Protection Guidelines) 2000 "an instrument which creates or acknowledges indebtedness, and includes debenture, stock, bonds and such other securities of a body corporate, whether constituting a charge on the assets of the body corporate or not".

The terms "bonds, debentures, debenture stock or other marketable securities of a like nature in or of any incorporated company or other body corporate, government securities" have been included within the definition of "securities" under the Securities Contract (Regulation) Act, and include within their ambit the entire gamut of debt instruments recognized, issued and traded in the Indian markets today.

Further the term "dividend" has been defined in the Companies Act 1956 to include "debenture stock, bonds and any other securities of a company, whether constituting a charge on the assets or not".

The Companies Act 1956 lays down special provisions in respect of debentures. These provisions refer to the appointment of debenture trustees prior to the issuance of a prospectus or letter of offer to the public for subscription to such debentures. In this respect and generally, the provisions of the Companies Act in respect of debenture trustees is consistent. However, the provisions differ as regards technical requirements including those provisions that relate to when a debenture trustee is to be appointed, and when a debenture redemption reserve needs to be created. In most such issues, however, controversies arise in respect of the interpretations thereof. For practical application purposes, however, the more conservative view is generally taken. In most cases, since the Companies Act 1956 is superior to the guidelines of SEBI, the provisions of the Companies Act 1956 are generally deemed applicable. However, when the instruments are to be listed, compliance with the SEBI requirements is also ensured.

The Guidelines deal in Chapter X with the issue of debt instruments and the relevant prerequisites. The guidelines apply to all public issues by listed and unlisted companies; all offers for sale and rights issues by listed companies whose equity share capital is listed, except in the case of rights issues where the aggregate value of securities offered does not exceed Rs50 lacs; and to public issues by unlisted companies and offers for sale to the public by unlisted companies.

In respect of the issue of convertible/non-convertible debt instruments by a company through an offer document, the company is required to comply with the following requirements mentioned:

  1. The offer document should contain all the necessary particulars mentioned in the guidelines and should be filed with SEBI, by a merchant banker appointed for the purpose by the company issuing the debt instruments.
  2. A credit rating from a credit rating agency has to be obtained and disclosed in the offer document. In respect of a public/rights issue of debt security of issue size greater than or equal to Rs100 crores, two ratings from two different credit rating agencies need to be obtained and disclosed in the offer document. Further, the offer document has to disclose the credit rating obtained for three years prior to the proposed public issue.
  3. The issue of FCDs having a conversion period of more than 36 months is prohibited by the guidelines, unless conversion is made optional with a put and call option. If the conversion takes place at or after 18 months from the date of allotment, but before 36 months, any conversion in part or whole of the debenture shall be optional on the part of the debenture holder. The issue of debentures by an issuer company for the acquisition of shares or providing a loan to any company belonging to the same group is prohibited by the guidelines.
  4. In the case of the issue of a debenture with a maturity of more than 18 months, the company is required to appoint a debenture trustee whose name is in the offer document. A trust deed is required to be executed by the company in favour of the debenture trustees within six months of the closure of the issue.
  5. In the event that there are assets on which charges arise, SEBI requires the company to provide certificates from the company's bankers that the assets on which security is to be created are free from any encumbrances, and that the necessary permissions to mortgage the assets have been obtained, or a no objection certificate from the financial institutions or banks for a second or pari passu charge in cases where assets are encumbered, have been obtained.
  6. The company has to maintain a debenture redemption reserve (DRR) in the case of the issue of debentures with a maturity of more than 18 months. If the debentures are being issued for project finance, a DRR can be created for a period until the date of commencement of commercial production. The DRR in respect of debentures issued for project finance may be created either in equal installments or higher amounts if profits so permit. In the event that partly convertible debentures are being issued, the DRR needs to be created in respect of the non-convertible portion of the debenture issue along the same lines as applicable for a fully non-convertible debenture issue. In respect of convertible issues by new companies, the creation of DRR would start from the year the company earns profits for the remaining life of debentures. The company can draw from the DRR only after the company has actually redeemed 10% of the debenture liability. The only exception in respect of the creation of a DRR is in respect of the issue of debt instruments by infrastructure companies.
  7. In the case of new companies, a distribution of dividends will require the approval of the trustees to the issue and the lead institution, if any. In the case of existing companies, the prior permission of the lead institution for declaring dividends exceeding 20% or as set out under the loan covenants is necessary, if the company does not comply with institutional conditions regarding the interest and debt service coverage ratio.
  8. The company may decide on redemption of the debentures. However, this cannot differ from the terms disclosed in the offer document at the time of the issue of such debentures. The premium amounts payable and the time of conversion must be determined by the company and disclosed. The company can freely determine the interest rate for debentures.
  9. SEBI has placed a time limit on the creation of security in respect of debenture issues that cannot exceed six months from the date of issue of the debentures. However, if for any reason the company fails to create the security as required, and continues such a default for a further period of six months from the date of issue of the debentures, the company will be liable to pay 2% penal interest to debenture holders. If this period of default extends to 18 months from the date of the issue of the debentures, a meeting of the debenture holders needs to be called, according to the guidelines, within 21 days of the expiry of 18 months, to explain the reasons for the default, and the date by which the security shall be created.
  10. If the issuing company proposes to create a charge for debentures of less than 18 months' maturity, it is required by the guidelines to file with the registrar of companies particulars of the charge in terms of the applicable provisions of the Companies Act. In the event that the Companies Act 1956 does not require the charge to be created on such debentures, the company is required by the guidelines to ensure compliance with the provisions of the Companies (Acceptance Of Deposits) Rules 1975. These rules treat unsecured debentures/bonds as "deposits".
  11. A letter of option containing disclosures with regard to credit rating, debenture holder resolution, option for conversion, justification for conversion price and such other terms which the board may prescribe from time to time, must be filed with the board through an eligible merchant banker, in the following cases:
    1. for the issue of rollover of non-convertible portions of partly convertible debentures (PCDs)/non-convertible debentures (NCDs);
    2. in the case of conversion of instruments (PCDs/FCDs, etc) into equity capital; and
    3. in the case of conversion of debentures issued under the consent of the controller of capital issues (CCI).

The Dhanuka Committee set up to review the regulatory issues in the capital markets have stated in their report, on the matter of the necessary development of the debt markets in India, that the revival of the debt market may involve permitting repo or ready forward transactions in debt securities, including government securities, along with proper safeguards and systems to prevent the recurrence of manipulations.

The Dhanuka Committee report stated "doubts as to the validity of the repo transactions surfaced under certain court decisions, as a result of which parties entering into such transactions do not have the necessary confidence that such arrangements would eventually be enforceable, should the need arise. A market as important as the debt market cannot meaningfully be developed in the backdrop of such fundamental ambiguities, and, the committee, therefore, is of the view that these doubts be removed by appropriate changes, which have now been suggested". Repos are regulated and governed by the Reserve Bank of India.

Private placements and disclosures

The SEBI vide circular, reference no SMD/Policy/CIR- /97 dated September 26 1997, regarding the listing of debt instruments without listing of equity, permitted the listing of debt security without satisfying the requirement of a prior listing of securities to be a public issue, in respect of debt instruments fully or partly convertible into equity, issued by infrastructure companies and municipal corporations. However, the above exemption would be available only if the following conditions are fulfilled:

  1. the issue of debt instruments is made through a public offer and in compliance with the rules, regulations and guidelines issued by SEBI from time to time;
  2. the instruments, irrespective of their maturity, carry an investment grade credit rating and are disclosed in the prospectus;
  3. the instruments are fully secured by creating appropriate security in favour of the trustees, irrespective of the maturity of the instruments;
  4. in the case of issue of pure debt instruments by infrastructure companies, equity issued prior to the public issue of debt shall not be permitted to be listed unless the provisions of rule 19(2)(b) of the SCR Rules 1957 are complied with, ie a public offer of equity has been made; and
  5. in the case of an issue of debt instruments fully or partly convertible into equity by infrastructure companies, while the PCD/FCD must be listed directly, the equity held prior to the public issue of the PCD/FCD must be listed only at the time when the equity arising on conversion of the PCD/FCD is listed.

Laws relating to trading in the instruments

To develop, the debt markets need an increase in the progressive deregulation of interest rates. Further, there is a greater for reliance on borrowing at market rates by the government and other quasi-statutory issuers, and greater use of open market operations as a tool for monetary policy. This in itself will vastly improve procedures for the trading, clearing and settlement of debt securities.

On September 1 1999, a circular bearing ref no PR 202/99, issued by the secondary market, and research and publication department of the SEBI, following the meeting of the committee on negotiated deals, observed: "trading in the debt market takes place largely over the telephone and through the mechanism of negotiated deals. The world over the trend is to move away from a telephone based debt market to a screen based trading system of the exchanges. This allows greater transparency, better price discovery, reduction in transaction cost and benefits the investors. Accordingly, it was also decided today that negotiated deals in respect of listed corporate debt securities will not be permitted and all such trades will have to be executed on the price and order matching mechanism of the stock exchanges as in the case of equities. As government debt securities and money market instruments are under the regulatory jurisdiction of RBI and do not fall within the purview of SEBI, this decision does not apply to such securities."

Consequently, through a letter bearing ref no SMDRP/POLICY/CIR-32/99, dated September 14 1999, to the executive directors/managing directors of all the stock exchanges, SEBI stated in respect of "negotiated deals" that "negotiated deals in listed corporate debt securities shall not be permitted and all such trades will have to be executed on the price and order matching mechanism of the stock exchanges as in the case of equities". Further, SEBI noted that since "government debt securities and money market instruments are under the regulatory jurisdiction of RBI and do not fall within the purview of SEBI, the aforesaid decision will not apply to such securities".

Dealing and settlement

In the absence of systems regulating trading in debt instruments, the existing practice for negotiating and dealing in debt instruments is characterized by a number of inefficiencies. The system includes a combination of the following kinds of markets:

  • online negotiation platforms and regulatory reporting requirements;
  • wholesale debt market segments on the National Stock Exchange; and
  • telephonic negotiation and dealing between primary dealers and regulatory reporting requirements.

The online negotiation platforms are mainly provided by private debt market participants and other information technology service providers, leaving the entire gamut of negotiation in debt market securities free from regulatory overview. The legality of the services provided, though recognized by the regulators, has not been ratified by inclusion in the applicable laws. Consequently, the legal system permits the increase in the availability of negotiation and deal conclusion platforms whose roles remain undefined.

The wholesale debt market segment of the National Stock Exchange, although in existence only for a short period, is at best an effort to establish a system for making existing practices uniform in the market. Unable to generate or attract trades to its floors, the National Stock Exchange is not necessarily a needed or favourable arena for debt market participants. Trading on the national stock exchange's wholesale debt market system is governed by the rules applicable to trading through the telephonic mode and regulated by the Reserve Bank of India.

In view of the fact that the trend in the debt markets is away from the traditional telephone-based system to the more user-friendly online trading systems, the Reserve Bank of India intends to permit the issue and trading of certain debt instruments through the negotiated dealing system (NDS). The proposed NDS is likely to act as an electronic dealing platform in government securities and money market instruments. It is proposed that this system would connect to the settlement and clearing mechanisms to allow straight-through processing of deals. However, the activities of settlement and clearing of deals occurs in a vacuous space where the reporting and requisite enforcement mechanisms to ensure timely reporting or monitoring of trades is lacking. The NDS is intended to fill the void by introducing a new mechanism for reporting and dealing in debt instruments in real time, and to ensure a degree of enforceability of transactions and accountability of the players. The introduction of the NDS is proposed to be made in phases, so that the transition to the system from the more irregular current scenario is seamless and, consequently, effective.

Emerging practices

The debt markets in India are only now, coming of age. Liberalization and the merging of global markets have brought in new practices to the pure loan transactions that used to typify the markets. Consequently, the markets are seeing a growth in the nature of instruments and in the regulatory requirements to ensure the safety of investors and issuers. The securitization bill pending before the Indian parliament is a move in this direction. The increase in asset-backed securitization is a development that the regulator is straining to catch up with. Relevant issues include the structure of the transaction, the vehicle to carry out the transaction and its structure, the issue of trading in pass-through certificates, and the risk management measures required to contain the issue and trading risks in pass-through certificates. The laws, although drafted, are awaiting bureaucratic intervention and will probably kick off a revolution in debt market trading volumes, once introduced.

The securitization bill has been drafted with the objective of enacting a law to facilitate the securitization of financial assets, and for the regulation of entities carrying on or undertaking securitization transactions. The securitization bill governs the securitization of financial assets by recording the vesting of the assets by a deed through a special purpose vehicle established for the purpose or otherwise. The securitization bill envisages SEBI acting as the regulator of securitization transactions, including the instruments (pass-through certificates) as well as the structure (special purpose vehicles).

The securitization bill has not yet been passed in parliament.

The securitization bill envisages that a special purpose vehicle can perform the following activities:

  • launch or establish and operate or administer one or more schemes, and to engage in the collection, recovery or such other activities as may be necessary, in respect of securitized financial asset;
  • subject to the terms of the offer document or to the information memorandum, invest the monies raised under any scheme in any kinds of financial assets; and
  • subject to the terms of the offer document or to the information memorandum, issue one or more class of transferable receipts with or without differential rights pursuant to any scheme.

The securitization bill empowers SEBI to make regulations and rules to carry out the Securitization Act, which may provide, among other things:

  • the eligibility criteria to be fulfilled for the granting of a certificate of registration to any special purpose vehicle;
  • the conditions subject to which the certificate of registration is granted to any special purpose vehicle and the fees payable in respect of such registration;
  • the conditions of the licence of a licensed registrar, and the functions, duties and responsibilities of the licensed registrars;
  • the procedure and manner for the establishment and winding-up of schemes for subscription;
  • the manner of and the frequency for providing information to the board;
  • the transfer of schemes from a special purpose vehicle whose registration may have been cancelled or withdrawn by the board, or which is required to be wound up under any law for the time being;
  • action in respect of consequences in the case of a breach of the act, rules or regulations thereunder; and
  • the matters relating to the issue of transferable receipts to the public and other matters incidental thereto, and the manner in which such matters will be disclosed to the public.

SEBI is in the process of drafting the regulations that are required for the Securitization Bill.


Capital Markets

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