Tata Sons, the holding company of the Tata group, is undergoing a leadership transition. Its chairman, Natarajan Chandrasekaran, announced on August 12, 2026 that he will not seek re-appointment as chairman. This note focuses on certain corporate law issues arising from such announcement, certain related events and the ensuing transition.
The ‘reasonable person’ standard remains one of the most established and widely applied benchmarks in common law systems, including Indian law. It provides an objective measure of conduct across negligence, contract, criminal law, professional regulation and fiduciary duty. However, the standard rests on certain implicit assumptions related to human cognition – such as finite attention, bounded memory, limited processing capacity and qualified foresight – which the deployment of artificial intelligence (“AI”) materially alters.
AI systems challenge the traditional reasonable-person inquiry because they increasingly (i) operate at a speed and scale that no human actor can match, (ii) act with significant autonomy in the absence of contemporaneous human direction and (iii) involve decision-making processes that are probabilistic and difficult to explain. At the same time, such systems may lack context, common sense and the type of intuitive judgment that the law attributes to reasonable persons. In this regard, a functional analysis sensitive to actual capabilities, control, autonomy and consequence may be necessary.
This note addresses the implications of these developments for corporate governance, fiduciary duties, principal-agent relationships, contractual allocation of responsibility and liability exposure. It reviews emerging regulatory and litigation developments across the European Union, the United Kingdom, the United States and India, and identifies practical governance measures that organizations can consider while legal standards continue to evolve.
SAT’s Decision in Hindustan Foods Limited v. BSE Limited & Anr.
The note analyzes the decision of Securities Appellate Tribunal (“SAT”) in Hindustan Foods Limited v. BSE Limited & Anr., where SAT held that a listed entity’s settlement with Securities and Exchange Board of India does not preclude a recognized stock exchange from subsequently imposing a fine for the same underlying non-compliance where the regulatory framework and the settlement order expressly preserve such action. The note highlights the importance for listed entities of carefully assessing the scope of settlement orders and any express reservations preserving parallel regulatory action.
With effect from July 1, 2026, the Reserve Bank of India has introduced certain amendments to thethe Reserve Bank of India (Non-Banking Financial Companies – Registration, Exemptions and Framework for Scale Based Regulation) Directions, 2025(“Updated Directions”).The Updated Directions,inter alia, bring in a modification to the criteria for determination of Non-Banking Financial Companies (“NBFCs”) in the Upper Layer and replace the erstwhile parametric scoring methodology (based on size, leverage and interconnectedness) with an asset size threshold of INR 1,00,000 crore (Rupees One Lakh crore) (approximately USD 10 billion at an exchange rate of 1 USD to INR 100) and above for identification of an entity as an NBFC in the Upper Layer.
This note discusses the framework for scale-based regulation of NBFCs and the implications of the latest amendments on the NBFCs in the Upper Layer with specific focus on the mandatory listing requirement for such NBFCs.
Final guidelines governing Virtual Power Purchase Agreements (“VPPAs”) in India, issued by the Central Electricity Regulatory Commission (“CERC”) in December 2025 further to stakeholder consultation and hearings on draft guidelines published in May 2025, can now be read in conjunction with a detailed statement of reasons dated April 27, 2026 released by the CERC to address comments and questions.
This note summarizes the background and context surrounding the evolving regime on VPPAs in India, analyzes the core elements of the VPPA guidelines and the CERC’s additional clarifications with regard to the regulatory framework, and locates such discussion in the context of related developments on power market integration, including in respect of regulations on the Indian power market and renewable energy certificates.
The rise of ‘agentic’ AI marks a significant juncture in the evolution of digital technologies. Unlike earlier generations of AI, agentic systems exhibit a degree of operational independence that approximates human behavior, including other defining features – such as the ability to interface with and act upon external ecosystems, as well as to participate in complex environments comprising other such agents.
The primary regulatory concern stemming from widespread deployment arises from the enhanced decision-making authority of such systems while determining how objectives are achieved. As a result of such autonomy, foundational assumptions concerning control, causation, and responsibility may prove inadequate.
The question of liability presents further difficulty. Established doctrines in tort, contract, and criminal law rely on foreseeability, intent, and proximate causation. However, agentic AI may disrupt such foundations, giving rise to a responsibility gap, where no single actor exercises sufficient control to justify full legal attribution.
For companies, risk mitigation may need to be internally driven, especially in the absence of comprehensive regulation. This may begin with use-case classification and risk-tiering, ensuring that high-impact deployments receive enhanced scrutiny. Enterprise-level AI governance frameworks – incorporating legal, technical, and business perspectives – may also be necessary, along with continuous oversight through auditing and monitoring.
Keywords: (feel free to let me know if you have any other suggestions. The keywords given by me are not researched, they are just phrases I think may be relevant.)
Data centers constitute a critical, distinct infrastructure asset class offering stable, long-term returns comparable to regulated utilities. Realizing scalable value requires legal structuring across five interdependent dimensions: reliable, high-capacity power; efficient cooling technologies; complex land-use entitlements; interconnectivity density; and specialized financing frameworks linked to performance and ESG compliance.
Issue 1 of 2026 of our Newsletter on Environmental Law covers key judicial and regulatory developments between the months of July and September 2025. In respect of judicial updates, Issue 1 includes judgements and orders of the Supreme Court, High Courts, and the National Green Tribunal related tointer-aliamandatory requirement of replenishment studies in district survey reports for sand mining projects, minimum green belt requirement for expansion of a coal washery, and periodic environmental audits of common and integrated effluent treatment plants, respectively.
In addition, Issue 1 tracks regulatory updates related tointer-aliacompliance obligations under hazardous waste rules, remediation of contaminated sites under environment protection rules, calculation of green credits in respect of tree plantation activities, and procedures for undertaking environmental audits.
Certain changes to the Indian regulatory framework, as applicable to virtual power purchase agreements (“VPPAs”), have been recently proposed by the Central Electricity Regulatory Commission (“CERC”) pursuant to draft regulatory instruments – including through VPPA-specific guidelines, as well as necessary amendments to existing CERC regulations related to the power market and renewable energy certificates (“RECs”), respectively.
With the broad aim of enabling power consumers and obligated entities to meet their respective renewable consumption obligations (“RCOs”) pursuant to the Indian Government’s decarbonization targets and proposed energy security transition, and given the acknowledged utility of VPPAs to facilitate such mandatory RCO compliance, the draft amendments aim to (i) integrate VPPAs into the Indian power market, including by defining the nature and essential features of such contracts, and establishing their placement within the over-the-counter (“OTC”) market, (ii) provide concrete mechanisms for VPPAs to function as viable market instruments, and (iii) clarify the treatment of RECs under the contractual scheme of VPPAs. Accordingly, OTC platforms now have the additional objective of facilitating transactions between buyers and sellers in respect of contracts related to VPPAs and RECs, among others.
This note analyzes the draft amendments with reference to VPPAs.
Issue 2 of 2025 of our Quarterly Newsletter on Environmental Law covers key judicial and regulatory developments between the months of April and June 2025. In respect of judicial updates, Issue 2 includes judgements and orders of the Supreme Court, High Courts and the National Green Tribunal related tointer-aliatree felling in Telangana’s Kancha Gachibowli Forest, waste collection and segregation in Delhi-NCR, unlawful mining in Aravali and ex-post facto Environmental Clearances.
In addition, Issue 2 also tracks regulatory updates related tointer-aliaconstruction waste management, registration on dust pollution control self-assessment portal, methodology for environmental compensation under hazardous waste rules, greenhouse gas emissions intensity target rules and plastic waste management.