S&R Associates is an Indian law firm with offices in New Delhi and Mumbai providing legal services to Indian and international clients.
Our lawyers are admitted to practice in India and many have previously practiced law in other jurisdictions, including in the United States, the United Kingdom and Singapore. As a result, we offer our clients a unique combination of Indian law expertise coupled with international quality legal services.
We distinguish ourselves based on the quality of our services and legal advice and on the range of our experience. Our lawyers have advised on some of the most significant Indian transactions and matters in recent times. The quality of our legal advice and services has helped us become the law firm of choice for our clients and has also been recognised by various industry publications, surveys and rankings. Lawyers in each of our practice areas have routinely been recognised as leading lawyers in India by Chambers Global, Chambers Asia Pacific, IFLR1000, Legal500 and RSG India Report.
Recent Publications
The Regulatory Framework for Virtual Power Purchase Agreements in India
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.
Compilation of Regulatory Updates in Relation to AIFs
In the recent past, regulatory bodies have issued a series of circulars, notifications and amendments reshaping the structuring, operation, reporting and compliance framework for alternative investments funds in India. To help sponsors, managers, trustees and investors keep pace with these developments, our Investment Funds Practice has prepared this consolidated compilation of key regulatory updates issued from October 1, 2025 to April 30, 2026.
Agentic AI: Opportunities, Risks, and Evolving Legal Frameworks
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.)