Aparna Ravi

Partner, Mumbai
Aparna Ravi
Contact

Tel : +91 22 4302 8000
Fax : +91 22 4302 8001
Email : aravi@snrlaw.in

Practice Areas

Banking and Finance
Private Credit
Restructuring and Insolvency
Private Equity
Mergers and Acquisitions
General Corporate

Prior Work Experience

Samvad Partners in Bengaluru

Credit Suisse in London

Weil, Gotshal & Manges in New York and London

Representative Experience

For a list of select transactions, please contact the individual lawyer

Education

New York University School of Law, NY (J.D., 2003)
Harvard University, Cambridge (A.B. in Government, 2000)

Bar Admissions

India, 2014
New York, 2004

Publications

Regulatory Initiatives on ESG Disclosure Requirements in India

Regulatory initiatives to build the legal frameworks around environmental, social, and governance (“ESG”) disclosures in India, while still nascent, are not of recent origin. Various regulators have gradually introduced requirements aimed at enhancing transparency and fostering corporate responsibility. This note examines these evolving ESG disclosure frameworks as implemented by the Securities and Exchange Board of India, the Reserve Bank of India, and the International Financial Services Centres Authority. It further analyzes the regulatory gaps that these initiatives seek to fill, andproposes solutions to enhance these frameworks.

Recalibrating Compliance: Legal Implications of SEBI’s Revised Listing Regulations for HVDLEs

The Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 (“Listing Regulations”) provide for the various compliance actions and reporting requirements for entities who have listed equity shares or other specified securities and/or non-convertible securities on the stock exchange. The Securities and Exchange Board of India (“SEBI”) recently amended the Listing Regulations by way of the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) (Amendment) Regulations, 2025 which has become effective as of March 28, 2025 (“Listing AmendmentRegulations”).
The changes introduced by the Listing Amendment Regulations primarily provide for additional reporting and compliance requirements for companies that have listed only non-convertible securities and qualify as a “high value debt listed entity” under the Listing Regulations. Previously, all high value debt listed entities needed to comply with Chapter V of the Listing Regulations, regardless of whether they had listed equity shares or other specified securities. Pursuant to the Listing Amendment Regulations, a new Chapter VA has been introduced that prescribes additional requirements for those high value debt listed entities that have only listed non-convertible debt securities. Such entities are now required to comply with the provisions of both Chapter V and Chapter VA of the Listing Regulations.

Updated Master Direction on Foreign Investment in India: Clarifications to the Regulatory Framework

The Reserve Bank of India recently issued an updated Master Direction on Foreign Investment in India (“Master Direction”) on January 20, 2025 to clarify various aspects in the regulatory framework for inbound investments. The Master Direction provides significant regulatory clarifications on foreign investments in India, particularly in relation to downstream investments, cross-border share swaps, share issuances to non-resident shareholders pursuant to a scheme of merger or amalgamation, and the issue of equity-based employee benefits to directors and employees resident outside India. This note highlights the key clarifications and changes to the regulatory framework brought about by the Master Direction that are intended to provide greater certainty and enhance the ease of doing business for overseas investors in India.

CIRP Amendment Regulations 2025: Streamlining Resolution Processes and Protecting Homebuyer Interests

As of December 2024, insolvencies in the real estate sector accounted for approximately 22% of admitted cases under the Insolvency and Bankruptcy Code, 2016 (“IBC”), making it second only to the manufacturing sector that accounted for 37% of admitted cases. The high volume of insolvencies in the real estate sector, the imperative to protect homebuyer interests and specific challenges faced by this sector have resulted in several amendments focused specifically on the insolvency process for real estate projects. Recently, the Insolvency and Bankruptcy Board of India (“IBBI”) notified the Insolvency and Bankruptcy Board of India (Insolvency Resolution Process for Corporate Persons) (Amendment) Regulations, 2025 (“2025 Amendments”) amending certain provisions of the Insolvency and Bankruptcy Board of India (Insolvency Resolution Process for Corporate Persons) Regulations, 2016 (“CIRP Regulations”), which once again have a special focus on the corporate insolvency resolution process (“CIRP”) of real estate developers. This note discusses the 2025 Amendments and their likely impact on streamlining the resolution process and protecting homebuyer interests.

FPI Investments in the Indian Debt Markets: An Overview

Investments in debt securities in India by non-residents require compliance with an array of Indian foreign exchange and securities regulations. Overseas investors intending to invest in debt instruments in India typically do so either under the Reserve Bank of India’s (“RBI”) framework for external commercial borrowings (“ECB”) or through the route available for foreign portfolio investors (“FPI”) registered with the Securities and Exchange Board of India (“SEBI”). In recent years, the FPI route has become a popular option for overseas investors looking to invest in India’s debt markets on a regular basis as it allows for greater flexibility in terms of interest, repayment terms, security cover and end use of funds in comparison to the ECB route. According to data from the National Securities Depository, FPI investments in the Indian debt markets stood at INR 1.1 trillion in 2024. 
In January 2025, the RBI issued Master Direction – Reserve Bank of India (Non-resident Investment in Debt Instruments) Directions, 2025 (“Master Direction”), which, inter alia, consolidates a number of the circulars and directions issued by the RBI on investments in debt instruments by non-resident investors, including FPIs. This note analyzes the key regulatory aspects governing FPI investments in corporate debt securities, particular in light of the Master Direction.

From Rescue to Ruin: The Supreme Court’s Judgment in Jet Airways and the Future of Airline Insolvencies

In a recent judgment, the Supreme Court of India ordered the liquidation of Jet Airways (India) Limited, bringing an end to the five-year-long saga of efforts to revive the distressed airline. Two years after the airline entered the corporate insolvency resolution process, the National Company Law Tribunal, in June 2021, approved the resolution plan submitted by the Jalan Fritsch Consortium, the successful resolution applicant. However, various challenges arose with implementation of the resolution plan, which led the successful resolution applicant to seek multiple extensions and concessions from the adjudicating authority. Finally, the Supreme Court set aside the March 2024 order of the National Company Law Appellate Tribunal and used its inherent powers under Article 142 of the Constitution to order the airline’s liquidation.

The Supreme Court’s judgment is significant as it underscores the importance of implementing resolution plans within agreed upon timelines and identifies certain gaps and shortcomings in the Insolvency and Bankruptcy Code, 2016 as far as implementation of resolution plans are concerned. This note analyzes the judgment to discuss its implications for the implementation of resolution plans as well as specific challenges in the context of insolvencies in the aviation industry.

Karnataka High Court’s Recent Judgement: Are OLA Drivers Employees or Contractors?

The Karnataka High Court (“Court”), in its judgement dated September 30, 2024 in Ms. X v. Internal Complaints Committee, ANI Technologies Private Limited and Ors., held that the relationship between ANI Technologies Private Limited (“OLA”) and its driver subscribers was an employer-employee relationship for purposes of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 (“POSH Act”) and such driver subscribers could not be considered as independent contractors.
The judgement, which closely scrutinizes OLA’s subscription agreements with its driver subscribers and customers, states that OLA cannot, on one hand, exercise complete control over the activities performed by the driver subscribers, while, on the other hand, onboard them as independent contractors to evade its responsibilities under relevant statutes. The judgment also analyzes the intent and objectives of the POSH Act and the wide ambit of the definitions of employer, employee and workplace under the POSH Act in furtherance of these objectives.
OLA has filed an appeal against the judgment before the Division Bench of the Court, which has issued an interim order staying its operation, stating that the issues raised in the judgement require further consideration. While the outcome of the appeal is awaited, the Court’s judgment of September 30, 2024, through its detailed reasoning, assumes significance in contributing to the discourse on the status of gig workers in the current labor economy and the responsibilities and liabilities of companies who engage such workers on a contract basis.