Half a dozen clean and green questions for the Adani Group to clear the air......by KBS Sidhu

A follow-up Op-Ed after LIC’s rebuttal and the Adani Group’s denial

When I published “Dirty Dozen Questions for India’s ‘AngeLIC’ Investor,” my focus was squarely on LIC: a statutory insurer, created by Parliament and entrusted with the savings of ordinary Indians, whose exposure to the Adani Group deserves rigorous, comparable, evidence-based scrutiny.

Since then, two developments have followed. LIC issued a longer clarification describing its exposure and solvency comfort; and the Adani Group issued a categorical denial that any government plan existed to steer LIC funds its way, adding that LIC invests across corporate groups, has earned returns from its Adani exposure, and that any talk of “undue political favour” is unfounded.

This follow-up is therefore addressed to the Adani Group. The object is not to relitigate anyone’s motives or to substitute innuendo for proof. It is to invite documentary clarity that would let policyholders, Adani shareholders and creditors, Parliament and markets examine the facts and move on. The questions below are respectful; they seek verifiable artefacts rather than assurances. If the denials are well-founded, the answers should be straightforward.

Before turning to the six questions, one point of scale. LIC’s own note has, at different points, placed the combined equity and debt exposure to Adani companies in the tens of thousands of crores—roughly the order of ₹33,000 crore or more across time, depending on book value versus market value and the date one chooses. Whether one views that as modest relative to LIC’s total AUM or as systemically significant, it is large enough to merit the same level of disclosure that global insurers routinely provide for concentrated group exposures. That is doubly true when a single May bond was reportedly absorbed by one investor in full, and when legal and regulatory headlines (domestic and foreign) have affected perceived risk.

With that context, here are six questions for the Adani Group—each paired with the specific evidence that would “clear the air”.

1) “No Steering”? Publish the Paper Trail

Your statement “categorically” denies any involvement in a plan to direct LIC funds. The cleanest way to settle this is to disclose the relevant artefacts. Will you publish a dated log of meetings, emails and memos—subject lines, participants and purposes—between Adani entities and (a) the Department of Financial Services/Finance Ministry, (b) NITI Aayog, and (c) LIC, that relate to debt placements or equity raises since January 2024? Where banks or arrangers invited LIC as anchor or sole buyer, please include engagement letters, investor-target lists and post-meeting notes (counterparty names may be redacted). An absence of such communications would vindicate your position; their presence—if purely ordinary course—would still benefit from sunlight.

2) Price Discovery, Not Preferential Access

You argue that “preferential treatment” is a misleading characterisation because LIC invests across many groups. The relevant test is not breadth of counterparties but quality of price discovery. For major 2025 rupee bonds—especially the 30 May Adani Ports issue—will you release anonymised order books and investor distribution lists, along with the pricing memo benchmarking spreads to the sovereign curve, to the issuer’s own curve and to peer infrastructure names? If LIC ultimately received 100% of the allocation, what changed between expressions of interest and allocation? A transparent record of demand and pricing would establish that the terms were market-standard.

3) “LIC Has Earned Returns”: Show the Maths

You state LIC has earned returns on its Adani exposure. With LIC’s consent, will you provide an instrument-wise performance pack—cash flows, coupons/dividends received, and mark-to-market movements—summarised as an IRR since purchase? To make the claim meaningful, please compare those outcomes against realistic alternatives available in the same week (top-tier state-linked or AAA infrastructure credits, or G-secs of similar duration). If your instruments have delivered excess risk-adjusted returns, the data will demonstrate it; if the headline coupon simply compensated for elevated risk, that too will be clear. Either way, numbers trump adjectives.

4) Use of Proceeds and Related-Party Pathways

Markets price not only the borrower’s name, but also where the money goes and how it moves within a group. For each 2024–25 bond, please publish a use-of-proceeds reconciliation: which projects (with IDs), which refinancings (with maturity ladders), and what fees were paid to which entities. Disclose any on-lending, guarantees, pledges or cash-pooling across subsidiaries that could subordinate public bondholders in practice, even if not in form. Confirm whether any rupee proceeds were used, directly or indirectly, to service offshore obligations or shareholder loans. Finally, outline the covenant package (change-of-control, leverage caps, restricted payments, step-ups, puts) designed to protect investors if adverse regulatory findings arise. This is customary in global markets; it should be uncontroversial here.

5) Ratings Gap and Leverage Trajectory

Some Adani assets carry high Indian-scale ratings; select entities have lower marks on international scales. The gap is not a scandal, but it must be reconciled with leverage and cash generation. Please provide a consolidated ratings bridge (agency-by-agency), a transparent debt-maturity schedule through 2030, and the group’s leverage targets—net debt/EBITDA and FFO/net debt—along with milestone dates. Where asset-level ratings are materially higher than holdco or peer international ratings, explain the structural protections that justify the difference. This will help investors understand whether domestic pricing captured cross-market risk appropriately.

6) Risk Disclosures Around U.S. and Domestic Proceedings

Your denial emphasises that allegations abroad involve individuals rather than operating companies, and that “undue political favour” is an unfounded narrative. The legal distinction may be valid, but investors need to know what you actually disclosed when marketing debt or equity. Please publish (with necessary redactions) the risk factors circulated to investors in 2024–25, covering U.S. DOJ/SEC matters, any still-open SEBI lines of inquiry, and potential knock-on effects. Confirm whether any step-up coupons, investor puts or material-adverse-effect clauses are tied to adverse outcomes. If the disclosures were fulsome and the covenants robust, you will be better off showing them.

End of the Beginning

None of these six questions asks you to prove a negative. They ask for ordinary-course documentation: meeting logs, order books, pricing notes, performance summaries, use-of-proceeds schedules, ratings bridges and risk disclosures. In global market practice, sophisticated issuers publish much of this information routinely—particularly when the issuer is systemically important and when a single domestic investor (in this case, India’s largest insurer) is a key holder.

Clarity will also help LIC as well as your group. If its due diligence and price discipline were strong, Adani Group’s documentary evidence will corroborate that. If the issue was simply that other institutions stayed out for mandate or optics reasons, an open order book will demonstrate the difference between reputational caution and credit judgement. Conversely, if concentrated allocations were a function of weak third-party demand at the proposed spreads, that revelation would enable a sober discussion about pricing in future deals.

The point bears repeating: this is not about personalities. It is about stewardship of public savings, comparability across issuers and the market’s right to see how large, complex exposures are priced and protected. In that spirit, I accept the Adani Group’s denial at face value; I simply ask for the evidence that would allow Parliament and policyholders to accept it too.

As for LIC, it remains true that—like Caesar’s wife—it must remain above suspicion. But that principle also benefits the Adani Group. A prompt, documented response to these six questions would be a service to your lenders and shareholders, a relief to policyholders whose money is indirectly at stake, and a contribution to India’s credibility as a capital market where transparency is a norm, not a favour. If the facts are on your side, let them be seen.

October 26, 2025