This article explores the critical role of forensic auditing in detecting and addressing corporate financial fraud within the Indian legal framework. It outlines the concept of fraud, distinguishing it from traditional auditing, and emphasizes the investigative nature of forensic audits. It further discusses the regulatory provisions governing forensic auditing in India while examining the evidentiary value of forensic audit reports in legal proceedings and their admissibility in courts. Additionally, it touches upon corporate directors' responsibilities and potential liabilities in cases of fraud while emphasizing the growing importance of forensic auditing in combating increasingly sophisticated financial frauds and improving corporate governance.
Introduction
Corporate frauds pose significant risks to the stability of businesses and economies, with India being no exception. In recent years, we have witnessed high-profile scandals such as the Satyam Computer Services scam, the Punjab National Bank (‘PNB’) fraud, and the IL&FS crisis, which exposed vulnerabilities in corporate governance and financial regulation. As businesses grow more complex and financial operations become opaque, detecting fraud demands more sophisticated methods. Auditing plays a pivotal role in uncovering corporate fraud and safeguarding the interests of stakeholders. Whether embezzlement, bribery, insider trading, money laundering, or Ponzi schemes[i], financial frauds can be perpetrated by anyone engaged in a corporation, an employee, management official, customer, vendor, or even a third party.
Although several checks and measures have been put in place by the law and corporations to prevent fraud, the menace keeps growing. With increasing complexities in detecting fraud, businesses and organizations need new, more efficient tools to uncover and prevent financial misconduct – where forensic auditing is one such tool.
This article is a humble attempt to provide a broad overview of forensic auditing and its application in uncovering corporate fraud within the Indian legal framework.
Fraud ― Deceit and Deprivation
In common parlance, fraud refers to a wrongful and deceptive act that causes wrongful gain to one person at the expense of another’s loss. The Black’s Law Dictionary defines[ii] fraud as encompassing all the various means devised by human ingenuity that one individual uses to gain an advantage over another through false suggestions or the suppression of truth. It includes surprises, tricks, cunning, dissembling, and any other unfair method by which another is cheated. Fraud is an act of deceit that, depending on the nature and severity of the offence, may lead to both civil and criminal actions under the Indian legal framework.
S. 447 of the Companies Act, 2013 (‘CA13’) defines fraud in the context of a company or a body corporate. It includes any act, omission, concealment of fact, or abuse of position committed by any person intending to deceive, gain undue advantage, or injure the interests of the company, shareholders, creditors, or any other person, regardless of wrongful gain or loss[iii]. While no all-encompassing definition of fraud exists, various statutes, including the Indian Contract Act of 1872 and the Indian Penal Code of 1860 (now the Bharatiya Nyaya Sanhita, 2023), shed light on its meaning. Two common ingredients across all definitions of fraud are the intention to deceive and the injury caused by the deceitful act. In Dr Vimla v. Delhi Administration[iv], the Supreme Court explained that the term ‘fraud’ comprises two elements: deceit and injury to the person deceived. It explained that injury refers to something beyond economic loss, such as the deprivation of property – whether movable, immovable, or financial – and includes any harm caused to a person’s body, mind, reputation, or similar interests. In essence, it was held to encompass non-economic or non-pecuniary loss. A benefit or advantage to the deceiver almost inevitably results in loss or detriment to the deceived[v].
The standard of proof for fraud is the same as that applicable to other criminal offences. The Supreme Court in Union of India v. Chaturbai M. Patel and Co.[vi] held that fraud, like any other charge of a criminal offence, whether made in civil or criminal proceedings, must be established beyond a reasonable doubt. Suspicion alone can never override the standard of proof required under the law. Further, in the case of Kisan Sahakari Chini Mills Limited v. Richardson and Cruddas[vii], the Bombay High Court reminded us that the standard of proof beyond all reasonable doubt is the litmus test, and a finding of fraud cannot be based on suspicion and conjecture; the material and evidence must show the same.
Forensic Audits and Investigation – Working and Limitations
Corporate fraud extends beyond private fraud, affecting not only a company but also the society and economy at large. Therefore, auditing becomes essential for identifying financial irregularities within corporate accounts and ensuring that organizations operate transparently and ethically.
In simple terms, an audit is a systematic, independent review of an organization’s books, accounts, statutory records, documents, and vouchers to determine the extent to which the financial statements and non-financial disclosures provide a true and fair view of the entity. It also verifies whether the organization’s accounts are maintained in accordance with legal requirements. Audits can be conducted internally by employees or externally by an independent auditor or firm. However, while useful as a preventive tool, traditional audits are not always sufficient to detect every instance of fraud. They focus on ensuring compliance with accounting standards and statutory regulations and may overlook subtle or hidden fraudulent activities. This is where forensic audits come into play[viii].
Unlike traditional audits, which are compliance-based, forensic audits are investigative in nature. They go beyond the surface-level review of financial documents and aim to gather detailed evidence that can be used in legal proceedings. Forensic auditors are highly specialized professionals with deep knowledge of accounting principles and strong investigative skills. They often work in conjunction with legal teams, regulatory bodies, and law enforcement agencies to build solid cases against fraudulent entities. Forensic auditing involves specific procedures designed to gather concrete evidence, such as examining how fraudulent activities were concealed and how long they persisted within the organization. It also provides answers to issues relevant to in-court purposes, such as how the fraud was perpetrated (modus operandi), who was involved (accused persons), and what the financial impact was (quantification).
Thus, forensic auditing is a critical tool in enforcing laws against corporate fraud and bringing perpetrators to justice. Unlike regular audits, forensic audits are designed to provide corroboration in litigation by producing detailed reports that uncover the full extent of the fraud and offer evidence that has value in courts. This makes forensic audits invaluable for investigating fraud and supporting legal action. After all, financial stability is integral to a robust and inclusive economy. The benefits of a stable corporate world are reflected in the developmental growth of a nation, and forensic auditing ensures the good commercial health of corporations by aiding in the regulation, prevention, and penalization of financial frauds and scams[ix].
With the rise in financial fraud, commonly referred to as white-collar crime, forensic auditing and accounting have become even more valuable in maintaining the financial integrity of companies by helping to prevent, regulate, and penalize financial frauds and scams. To bring out the difference in a single phrase – while financial auditing essentially provides an opinion on whether the financial statements present a ‘true and fair’ view, forensic auditing verifies the accuracy of the accounts and determines if any fraud has occurred.
Further, forensic audits do not have period limitations on transactions being investigated; they can scrutinize historical transactions, even those leading up to a corporation’s operations. Unlike regular auditors who may rely on management certificates or authorizations to confirm the accuracy of current assets and liabilities of a body corporate, forensic auditors act independently of management. Forensic auditors also quantify damages, identify responsible parties, and provide legally viable evidence in cases resulting in adverse findings. In plain words, forensic auditing applies accounting skills for legal purposes.
Forensic auditing has four components: audit, investigation, agreed-upon procedural engagements, and a proactive search for fraud. This proactive approach to discovering fraud makes forensic auditing crucial in uncovering corporate fraud and sustaining legal actions against it. Beyond identification, it is also effective in locating diverted assets or funds of the entity, complementing litigation support.
Regulatory Framework for Forensic Auditing in India
There are various regulatory provisions concerning forensic auditing under the Indian legal system. S. 212 of CA13 empowers the Serious Fraud Investigation Office (‘SFIO’) to investigate corporate fraud, and their investigations often involve forensic audits to detect fraud. The Securities and Exchange Board of India (‘SEBI’), under its Listing Obligations and Disclosure Requirements (‘LODR’) Regulations, 2015, mandates listed entities to disclose the initiation and findings of forensic audits, along with the management’s comments on it.[x] Similarly, the Reserve Bank of India (‘RBI’) requires forensic audits for the restructuring of accounts and large advances under its Master Direction on Frauds, which was released in 2017[xi].
Thus, forensic audits are becoming an essential element of governance, and numerous other obligations under Indian laws concerning economic offences and corporate governance necessitate their use.
Evidentiary Value of Forensic Audit Reports
The evolution of financial crimes has increased the complexities of legal proceedings. There is an urgent and growing need for individuals with refined skills in targeted investigative expertise. To understand the role of forensic auditing in uncovering corporate fraud, we need to appreciate the evidentiary value of the findings and reports of such audits before the Indian courts.
Forensic audit reports are not definitive proof, but they hold significant evidentiary value in Indian courts and, hence, can be termed as corroborative proof. The Indian Evidence Act, 1872 (‘IEA’), now replaced by the Bharatiya Sakshya Adhiniyam, 2023 (‘BSA’), governs the admissibility of expert opinions, including forensic audit reports. S. 45 of the IEA (now s. 39(1) of the BSA) includes expert testimony in matters requiring specialized knowledge, skill, or experience. The definition of an expert has been expanded under s. 39(1) of the BSA by adding the phrase ‘any other field’ to the erstwhile definition under the IEA. As a result, any person possessing specialized knowledge, skill, or experience in any field qualifies as an expert, including forensic auditors.
Notably, the provisions laid under ss. 45 to 51 of the IEA, which primarily deal with expert evidence and third-party witnesses, forensic audit experts or accountants, were not expressly mentioned within the categories listed under s. 45. However, by virtue of the power vested in courts under s. 45, which allows the appointment of an expert with specialized knowledge, was interpreted by the courts to include the opinions of accountants as that of an expert within the scope of ‘science’ and ‘art’[xii] and, therefore, the opinions of forensic experts, particularly in cases involving private investigations, are generally evaluated under this section and are admissible in court. The further legal position remains consistent with the general rules of admissibility of evidence in a court, such as the non-binding effect of an expert opinion and the primacy of evidence by an eyewitness against an expert’s testimony[xiii].
The reliance on forensic audit reports during formal legal proceedings has increased, as these reports help bring structure and focus to complex financial cases. However, such reports are not the ultimate deciding factor in legal cases, particularly criminal matters. The fundamental rule of evidence law is that the best evidence must be presented to the court, meaning that primary evidence is prioritized over secondary evidence. Expert witnesses are an exception to this rule, as they are allowed to give opinions beyond facts to assist the court in reaching a decision. While an expert’s opinion does not bind the court – and such evidence will not necessarily override that of an eyewitness – there is no legal requirement that all expert opinions must be corroborated to be admissible. The Supreme Court has also established that a court cannot form its judgment solely based on expert opinion, as it is not considered conclusive proof[xiv].
Another decision by the High Court of Andhra Pradesh ruled that in cases where a party directly obtains an opinion of a private expert, the findings of such expert will not be admissible in the court[xv]. Therefore, while considering the admissibility of a forensic audit report, it is crucial to know the details of the commissioning of a forensic audit. Another important consideration in this regard is that once a forensic report is commissioned, it becomes part of the company’s official records. If the report identifies an infraction but no action is taken, and the report is later discovered during official investigations, management or others aware of its contents may be held accountable.
Additionally, the evidentiary value of a forensic report can also be examined under s. 126 of the IEA (corresponding to s. 132 of the BSA) governs the admissibility of professional communications and privileges, including attorney-client privilege. If a company hires legal counsel to conduct an internal investigation, the forensic report and related documents may be protected under s. 126. However, these privileges have limitations – they do not apply to disclosures made with client consent, communications made for illegal purposes, or when an attorney uncovers crime or fraud after being engaged. S. 127 of the IEA extends this privilege to interpreters, clerks, and assistants of the legal adviser as well.
To conclude, while forensic audit reports are not considered substantial proof of evidence by themselves, they are relevant and admissible in court as corroborative evidence. Depending on the reliance on such evidence, it may be categorized as primary or secondary evidence and impartial corroboration may be required to establish its credibility. Either way, in cases involving corporate fraud, forensic audit reports are crucial. Once a court adopts an expert’s opinion, it becomes part of its decision and no longer belongs solely to the expert.
Past Scandals ― (Dis)Honorary Mentions
Satyam Scam
This was one of India’s largest corporate frauds, uncovered in 2009. Satyam Computer Services, led by its chairman Ramalinga Raju, falsely inflated its revenue, profits, and assets by manipulating accounts over several years. The scam involved a staggering Rs.7,136 crore, and Mr. Raju confessed to falsifying the company’s financial statements not to ‘attract investors’ but to cover losses and avoid hostile takeovers. The revelation led to a major corporate scandal, causing a sharp fall in Satyam’s stock price and significant repercussions in the Indian IT industry, raising serious concerns about corporate governance and auditing practices in India. This ultimately led to Mr. Raju’s arrest and Satyam’s downfall. The investigation report by the SFIO was voluminous, running up to 12,000 pages. The report concluded that the Chairman and top executives committed the fraud, while the accountants were negligent in performing their statutory duties and complying with reporting standards. The investigation report was crucial in penalizing the accused.[xvi]
Saradha Chit Fund Scam
The Saradha Chit Fund Scam, which became public in 2013, involved the Saradha Group, a consortium of over 200 private companies based in West Bengal. The group operated a Ponzi scheme disguised as a chit fund, collecting over Rs. 2,500 crore from millions of investors, primarily small and rural investors, by promising high returns. When the scheme collapsed, it left these investors in financial ruin. The impact was severe because many investors were from middle- or low-income groups and had banked their entire life savings on this fraudulent scheme. Forensic auditing played a pivotal role in uncovering the scam and tracing the complex network of financial transactions, revealing how funds were misappropriated and siphoned off by Saradha Group executives[xvii]. The detailed investigation helped authorities build a legal case, identify the scale of the scam, and trace the flow of illicit funds. The case is still pending with the CBI, as multiple legal proceedings have taken place, and investigations are ongoing for certain aspects[xviii]. This case also highlights the limitations of forensic audits, which can investigate and uncover fraud, but adjudicating authorities must deliver justice.
Sahara Group Scam
This major financial scandal involved Sahara India Pariwar, a conglomerate led by Subrata Roy[xix]. In 2010, SEBI accused two Sahara companies of illegally raising over Rs. 24,000 crores through Optionally Fully Convertible Debentures (‘OFCDs’) from millions of investors without proper regulatory approval. SEBI ordered Sahara to refund the money with interest. After a prolonged legal battle, the Supreme Court directed Sahara to deposit the funds with SEBI to repay investors. The scam exposed regulatory loopholes in India’s financial markets, leading to Mr. Roy’s arrest in 2014. Forensic auditing played a crucial role in uncovering financial irregularities and tracing Sahara’s illegal fund-raising practices[xx]. It was instrumental in examining the complex financial structures used by the group to raise OFCDs without regulatory compliance. The investigation provided detailed evidence of mismanagement and irregularities, aiding investors in the recovery and refund process. The forensic audit’s litigation support ensured accountability and transparency in the legal proceedings.
Ketan Parekh Scam
This was a major financial scandal in the Indian stock market between 1999 and 2001 involving stockbroker Ketan Parekh. Mr. Parekh manipulated stock prices by colluding with corporate entities, banks, and promoters, inflating the value of stocks known as the ‘K-10’ stocks. Mr. Parekh used illegal means, including misappropriating funds from Madhavpura Mercantile Cooperative Bank and Global Trust Bank. Forensic auditing played a key role in exposing this scam by tracing Mr. Parekh’s financial transactions, identifying fund siphoning, and revealing his use of circular trading to inflate stock prices. The forensic audit provided crucial evidence for regulators and law enforcement to prosecute Mr. Parekh, making this a landmark case in India’s stock market fraud history[xxi].
PNB Fraud
The PNB scam, uncovered in 2018, is one of India’s largest banking frauds, involving over Rs 13,000 crores. The scam was orchestrated by jeweller Mr. Nirav Modi, his uncle Mr. Mehul Choksi, and their companies, in collusion with PNB officials. The fraud revolved around the misuse of Letters of Undertaking (‘LoUs’), bank guarantees used for overseas payments. PNB officials issued fraudulent LoUs without proper documentation or collateral, enabling Mr. Modi’s companies to secure large loans from foreign banks. Forensic auditing played a vital role in exposing the scam by identifying financial irregularities, revealing how the LoUs were issued without proper safeguards, and tracking the trail of funds. The audit provided critical evidence that exposed systemic lapses within PNB’s internal controls, aiding investigations by the Central Bureau of Investigation (‘CBI’) and the Enforcement Directorate (‘ED’). It also helped track misused funds and money laundering activities, leading to legal proceedings against Mr. Modi and others involved.
IL&FS Crisis
The IL&FS crisis refers to the financial collapse of Infrastructure Leasing & Financial Services, a major infrastructure development and finance company in India. In 2018, IL&FS defaulted on debt obligations totalling over Rs. 91,000 crore, causing widespread disruption in India’s financial markets. The company had a complex structure with over 300 subsidiaries, and it misrepresented its financial health by hiding bad loans and inflating assets[xxiii]. The fraud involved poor governance, financial mismanagement, and conflicts of interest at the senior management level. IL&FS borrowed heavily to fund large infrastructure projects, many failing to generate returns. The defaults triggered a liquidity crisis, affecting non-banking financial companies (‘NBFCs’). Forensic auditing was crucial in uncovering the fraud by analysing financial records, exposing accounting irregularities, and identifying the diversion of funds to shell companies. The forensic audit revealed large-scale siphoning of funds and dubious transactions, helping regulators such as the SFIO build a case against IL&FS executives. The audit findings were essential in legal proceedings and efforts to restructure the company’s debt and recover misappropriated funds.
There are several other instances where forensic audits have played an integral role in uncovering and penalizing corporate fraud. In 2014, erstwhile Dena Bank and Oriental Bank of Commerce underwent forensic audits and investigations under the orders of the Ministry of Finance following an alleged misappropriation of Rs. 437 crores[xxiv]. In 2021, SEBI conducted a forensic audit of Suzlon Energy Ltd. to investigate potential violations of securities market regulations[xxv]. Forensic auditing has undoubtedly strengthened corporate fraud investigations and has served as a deterrent to such offences.
Director’s Responsibility and Liability
Given the nature of corporate fraud and its significant impact on the country’s resources and society, the responsibility and liability of corporate directors have become increasingly important. Ordinarily, a company and its directors are separate legal entities, meaning directors are not personally liable for the actions of the company, which is a separate legal person. However, under certain circumstances, liability can shift to the director. One such instance is the fraudulent conduct of business. In these cases, a director can be held personally liable, without limitation, for any or all of the company’s debts or obligations if they were knowingly involved in fraudulent activities. In cases of corporate fraud, the liability placed on directors is primarily of a criminal nature. The legal principle of lifting the corporate veil is often applied to determine such liability, allowing courts to hold directors personally accountable. In addition to this, the identification doctrine is used. This doctrine holds the corporation liable for the actions of individuals considered its ‘directing mind’ (i.e., senior officers or directors), thereby attributing the necessary intent (mens rea) to these individuals when ascertaining criminal liability.
Notably, the Economic Crime and Corporate Transparency Act, 2023 (‘ECCTA’) of the United Kingdom (‘UK’) has expanded the scope of director liability in corporate crimes. The Senior Manager Test introduced by the ECCTA stipulates that if a senior manager commits a relevant crime while ‘acting within the actual or apparent scope of their authority,’ the corporation can be held criminally responsible for the manager’s actions[xxvi].
While the ECCTA is a UK law, comparable developments occur in other jurisdictions, including India, where corporate liability is evolving through statutory and judicial interventions. The increasing responsibilities and potential liabilities of corporate directors, alongside evolving tools like forensic accounting and auditing, will significantly strengthen the enforcement of penal laws against corporate fraud. This evolution simultaneously acts as a strong deterrent against future fraudulent practices and reinforces cleaner corporate governance practices.
Conclusion
Forensic auditing has emerged as a critical tool in detecting and addressing financial fraud, particularly within corporate structures. Unlike traditional audits, forensic audits delve deeper into financial irregularities, enabling the identification of illegal activities such as the misappropriation of funds, embezzlement, and manipulation of financial records. By gathering evidence that can be used in legal proceedings, forensic audits not only uncover fraud but also support enforcement agencies in prosecuting offenders.
In the Indian context, forensic auditing has been instrumental in exposing high-profile corporate frauds, such as the Satyam Scam and the PNB Fraud. The evolving regulatory framework, including provisions in the CA13 and oversight by bodies like the SFIO, further underscores the importance of forensic auditing. However, forensic audits have limitations, as their findings primarily serve as corroborative evidence rather than conclusive proof in court. The effectiveness of forensic audits depends on how well legal and regulatory authorities utilize their insights.
Hence, while forensic audits contribute significantly to investigations, they do not replace the need for corroboration with other forms of evidence. As financial fraud becomes more sophisticated, the demand for forensic auditing will continue to grow. They serve as a strong deterrent against corporate misconduct, contributing to improved corporate governance and fostering a healthier economic environment.
End Notes
[i] A Ponzi scheme is a fraudulent investment scam where returns are paid to earlier investors using the capital from newer investors rather than from profit earned by the operation. This scheme relies on a continuous influx of new investments to sustain itself and eventually collapses when the new investments stop. U.S. Securities and Exchange Commission. Ponzi scheme. Investor.gov. Retrieved October 23, 2024, from https://www.investor.gov/protect-your-investments/fraud/types-fraud/ponzi-scheme
[ii] The Black’s Law Dictionary defines fraud as ‘all multifarious means which human ingenuity can devise, and which are resorted to by one individual to get an advantage over another by false suggestions or suppression of the truth. It includes all surprises, tricks, cunning, or dissembling, and any unfair way in which another is cheated.’
[iii] Section 447, Companies Act, 2013
[iv] Dr Vimla v. Delhi Administration, 1963 AIR 1572
[v] Ibid.
[vi] Union of India v. Chaturbhai M. Patel and Co., (AIR 1976 SC 712)
[vii] Kisan Sahakari Chini Mills Limited v. Richardson & Cruddas, (AIR 1997 BOM 35)
[viii]The Institute of Company Secretaries of India. Forensic audit. Retrieved from https://www.icsi.edu/media/webmodules/FINAL_Forensic_Audit_BOOK.pdf
[ix] Deloitte, India Corporate Fraud Perception Survey Edition IV (December 2020).
[x] SEBI (LODR) Regulations, 2015
[xi] Master Directions on Frauds – Classification & Reporting by commercial banks and select FIs, Master Circular No. RBI/DBS/2016-17/28 DBS.CO.CFMC.BC.No.1/23.04.001/2016-17, dated 01.07.2016. (Updated on 03.07.2017)
[xii] Basudeo Gir v. State, AIR 1959 Pat 534.
[xiii] Forest Range Officer v. P. Mohammad Ali, 1993 SCR (3) 497.
[xiv] Chennadi Jalapathi Reddy v. Baddam Pratapa Reddy, (2019) 14 SCC 220,
[xv] Andhra Pradesh, in Virothi Tirupathi Rao v. Kota Venu, (2016) 4 ALT 478
[xvi] Business Standard. (20.01.2013). SFIO concludes Satyam probe. Business Standard Retrieved from https://www.business-standard.com/article/companies/sfio-concludessatyam-probe-109041500042_1.html
[xvii] Business Standard. What is Saradha scam? Business Standard. Retrieved October 23, 2024, from https://www.business-standard.com/about/what-is-saradha-scam
[xviii] The New Indian Express. (28.05.2024). 11 years on, Bengal’s Saradha chit fund victims await justice amid LS polls corruption discourse. The New Indian Express. https://www.newindianexpress.com/nation/2024/May/28/11-years-on-bengals-saradha-chit-fund-victims-await-justice-amid-ls-polls-corruption-discourse
[xix] Economic Times. (2024). Sahara Group on scam 2010: The Subrata Roy saga—An abusive and grossly condemnable act. The Economic Times. https://economictimes.indiatimes.com/news/india/sahara-group-on-scam-2010-the-subrata-roy-saga-an-abusive-and-grossly-condemnable-act/articleshow/110229691.cms?from=mdr
[xx] The Economic Times. (17.10.2023). SFIO probe into Sahara group companies ongoing, says FM Sitharaman. The Economic Times. https://economictimes.indiatimes.com/news/india/sfio-probe-into-sahara-group-companies-ongoing-says-fm-sitharaman/articleshow/112282048.cms?from=mdr
[xxi] A case study on Ketan Parekh scam. Scribd. Retrieved October 23, 2024, from https://www.scribd.com/document/105986800/A-Case-Study-on-Ketan-Parekh-Scam
[xxii] Business Standard. (n.d.). What is PNB scam? Business Standard. Retrieved October 23, 2024, from https://www.business-standard.com/about/what-is-pnb-scam
[xxiii] Mint. (25.05.2019). Inside the audit lapses that led to IL&FS crisis. Livemint. https://www.livemint.com/companies/news/inside-the-audit-lapses-that-led-to-il-fs-crisis-1558456079750.html
[xxiv] The Hindu Business Line. (28.03.2017). Finance Ministry orders forensic audit on Dena Bank, OBC in Rs 437 cr fraud. The Hindu Business Line. https://www.thehindubusinessline.com/money-and-banking/Finance-Ministry-orders-forensic-audit-on-Dena-Bank-OBC-in-Rs-437-cr-fraud/article20848451.ece
[xxv] Mint. (01.12.2021). SEBI orders forensic audit of Suzlon. Livemint. https://www.livemint.com/companies/news/sebi-orders-forensic-audit-of-suzlon-11616497124637.html
[xxvi] Economic Crime and Corporate Transparency Act 2023(n.d.). https://www.legislation.gov.uk/ukpga/2023/56/enacted
Authored by Shivangi Bhardwaj, Advocate at Metalegal Advocates. The views expressed are personal and do not constitute legal opinions.