GP's corporate fraud investigation practice is instructed by boards, audit committees, independent directors, and institutional investors — not by management. The investigation is structured through legal counsel from the first day to attract legal professional privilege. The forensic accountants who conduct the investigation are GP's in-house team — not an external firm that must be separately briefed. And the legal team that advises on the regulatory disclosure obligations, the criminal complaint, the civil recovery, and the governance remediation is the same team that received the investigation findings — not a new set of lawyers who must read a report and make sense of it.
India's corporate fraud landscape has specific characteristics that distinguish it from most overseas environments. The prevalence of family-controlled businesses — where the dominant promoter family controls both the board and management — creates conflicts of interest that make independent investigation structurally difficult. The regulatory overlap between SEBI (for listed companies), MCA (for all companies), the ED (for PMLA-scheduled offences), and the CBI (for cases involving public officials or public financial institutions) means that the investigation must simultaneously satisfy multiple regulatory frameworks. And the Indian court system's approach to evidentiary standards — particularly for criminal proceedings — requires an investigation methodology that produces findings in a form the courts will accept.
For listed companies, the investigation must also manage the disclosure obligations under SEBI's Listing Obligations and Disclosure Requirements Regulations — which require prompt disclosure of material events, including the discovery of fraud, but which must be balanced against the operational requirements of the investigation and the risk that premature disclosure alerts the perpetrators and triggers evidence destruction. GP advises the audit committee on the disclosure strategy simultaneously with the investigation — ensuring that the regulatory obligation is met at the right moment, with the right information, in the right form.
From the first alert through to the investigation report, regulatory disclosure, criminal complaint, and governance remediation — a complete internal investigation service instructed by and reporting to the board.
Independent fraud investigations instructed by the audit committee or independent directors — structured through legal counsel for privilege, independent of management, and designed to produce findings that the board can stand behind. Initial scoping assessment to define the investigation's boundaries and depth. Document preservation order — ensuring that all potentially relevant records are preserved before any personnel learn that an investigation has commenced. Interview planning and conduct — structured interviews of relevant personnel by forensic investigators, with legal counsel present where appropriate. Financial records analysis — the complete forensic accounting work that establishes the nature, quantum, and perpetrators of the fraud.
Learn More →Investigation of procurement fraud — inflated vendor invoices, fictitious vendor payments, kickback arrangements between company purchasing personnel and vendors, and bid-rigging in competitive tender processes. Vendor background analysis — identifying the beneficial ownership of vendors and the relationship between vendor owners and company personnel. Invoice analysis — identifying statistical patterns in billing that indicate manipulation (Benford's Law analysis, clustering below approval thresholds, vendor concentration). Email and communication analysis — reviewing procurement-related communications for evidence of corrupt arrangements. Quantification of the fraud — calculating the total overpayment from legitimate market rates over the fraud period.
Learn More →Investigation of financial statement manipulation — revenue recognition fraud (premature recognition, channel stuffing, bill-and-hold arrangements), expense capitalisation fraud, inventory manipulation, provision reversal, and related-party transaction structuring to generate fictitious profits or conceal losses. Analysis of the accounting entries used to effect the manipulation, the management overrides of internal controls that enabled it, and the audit failures that allowed it to persist. For listed companies — the SEBI regulatory consequences of financial statement restatement and the disclosure obligations arising from the discovery of accounting fraud.
Learn More →Investigation of undisclosed or improperly approved related-party transactions — identifying the beneficial ownership of counterparties in transactions with the company, assessing whether the transactions were conducted on arm's-length terms, and establishing whether the required shareholder and regulatory approvals were obtained. For promoter-managed companies — the specific RPT patterns that indicate tunnelling of value from minority shareholders to the controlling family: management fees paid to family-controlled entities, property transactions at non-arm's-length prices, loans extended to related parties on concessional terms, and employment of family members at inflated compensation. For listed companies — SEBI LODR RPT disclosure compliance and the potential liability of independent directors who approved transactions without adequate scrutiny.
Learn More →For companies facing regulatory investigation — SEBI market manipulation investigation, MCA Section 206-209 inspection, or SFIO investigation under Section 212 of the Companies Act — preparation of the company's own account of the relevant transactions through internal investigation, enabling the company to respond to regulatory enquiries with a forensically grounded position rather than management's unchecked account. Simultaneous preparation of the company's defence against regulatory findings, drawing on the internal investigation's findings to challenge the regulator's factual basis where it is inaccurate. Coordination between GP's forensic team and the white collar crime legal team for the complete regulatory response.
Learn More →Once the investigation has established what happened, who did it, and how much was taken — the board needs to rebuild the control environment that allowed the fraud to occur. GP's post-investigation remediation service covers: assessment of the control failures that the fraud exploited, recommendations for specific control improvements, redesign of approval hierarchies and financial authority matrices, vendor management process redesign, and the governance changes at board level (audit committee charter, internal audit function scope, whistleblower mechanism) that demonstrate to regulators and investors that the company has addressed the root causes. For listed companies — the SEBI-required disclosures and the investor communication strategy following the investigation's conclusion.
Learn More →The most challenging corporate fraud investigations in India involve the controlling promoter of a listed company — because the promoter controls both the board and management, and the independent directors and institutional investors who need to investigate face a governance structure designed to resist exactly that investigation. GP has conducted investigations at the request of institutional investors and independent directors in promoter-controlled companies — using the Section 241/242 NCLT framework (oppression and mismanagement), the SEBI whistle-blower mechanism, and the MCA inspection framework to create the independent investigation mandate that the governance structure would not otherwise provide. These investigations are the most sensitive and the most consequential — and they require a forensic and legal team that is genuinely independent of the promoter's influence.
When an independent director or audit committee member receives a whistleblower complaint alleging financial fraud, the next 48 hours are the most consequential of the entire investigation. Documents will not be preserved tomorrow that are destroyed today. The perpetrator who learns that a complaint has been made will take steps tonight. The regulators who are notified too soon will begin their own investigation before the company has established its own position. And the board decisions taken in the first 48 hours — who to tell, who to instruct, whether to suspend the relevant personnel immediately — will be scrutinised for years. GP provides immediate counsel to audit committees and independent directors from the moment a whistleblower complaint is received — advising on every decision in the first 48 hours, and managing every subsequent step of the investigation.
A corporate fraud investigation generates multiple simultaneous legal streams: the criminal complaint, the civil recovery action, the SEBI disclosure, the SFIO or MCA engagement, the employee termination and disciplinary proceedings, and the investor communication. In the referral model, each stream goes to a different firm. At GP, every stream is handled by practitioners who share the investigation findings in real time — because the investigation findings belong to the same instruction. The criminal lawyer who files the FIR has read every page of the forensic report. The civil litigator who files the Mareva application built the injunction affidavit alongside the forensic trace. The regulatory lawyer who manages the SEBI disclosure shaped the disclosure language with knowledge of what the investigation found. This is the structural advantage that a unified team provides.
GP's corporate fraud investigations are instructed exclusively by the audit committee, independent directors, or institutional investors — never by management. The investigation scope is set by the instructing party. The investigation findings are reported to the instructing party before management sees them. The decision on what to do with the findings — criminal complaint, civil action, SEBI disclosure, employee termination — is made by the instructing party with GP's advice. Management's role in the investigation is as a subject or a document custodian — not as a principal. This structural independence is not merely a policy preference. It is the foundation on which the investigation's credibility rests.
A forensic investigation report that is not structured for privilege is a document that can be compelled by the regulator or opposing party in subsequent proceedings. It may contain findings that are preliminary, nuanced, or subject to qualification — and which, when read without context in a regulatory hearing, produce an adverse inference against the company. GP structures every corporate fraud investigation through legal counsel from the first engagement — creating the privilege protection that prevents the investigation report from being used against the company by a regulator, by a counterparty in civil litigation, or by a criminal prosecutor who subpoenas the document. The investigation is a tool for the company. Privilege keeps it that way.
Complete confidentiality maintained.
Instructed by the audit committee of a BSE-listed manufacturing company to investigate a whistleblower complaint alleging kickback payments by the head of supply chain. GP's forensic team conducted a Benford's Law analysis of five years of vendor invoices — identifying a statistically anomalous pattern of invoices just below the CFO approval threshold from 23 vendors. Ownership analysis revealed that 17 of the 23 vendors were beneficially owned by family members of the supply chain head. The total overpayment was quantified at Rs.22 crore over five years. GP managed the SEBI LODR disclosure (staged over two announcements), filed an FIR under Sections 406 and 420 IPC, obtained a Mareva injunction, and coordinated the ED PMLA complaint. The supply chain head was arrested within three months of the complaint. Rs.17.6 crore was recovered through a combination of arrested assets and consent settlement.
Conducted forensic financial due diligence for a PE fund acquiring a SaaS company at a revenue multiple valuation. GP's forensic review identified that Rs.14 crore of the company's reported annual recurring revenue (ARR) had been recognised prematurely — contracts with variable renewal clauses had been treated as committed revenue, and multi-year contracts had been fully recognised in the year of signing rather than ratably over the contract term. The misstatement inflated the reported ARR by 34% and — at the acquisition multiple — overstated the enterprise value by approximately Rs.28 crore. GP's findings were used as the basis for a price renegotiation that reduced the acquisition price accordingly. The investigation also identified the specific accounting personnel responsible for the misstatement, enabling the buyer to make informed decisions about the management team post-acquisition.
Instructed by a 12% institutional investor in a listed manufacturing company to investigate suspected promoter tunnelling through related-party transactions. GP's forensic team analysed four years of RPT disclosures in the Annual Reports against the underlying contracts and transaction records — identifying Rs.34 crore of payments to promoter-controlled entities at prices materially above market rates for the services supplied. Management fees paid to the promoter's family office, rental payments for premises at above-market rates, and professional service fees to entities with no apparent professional capability were the primary mechanisms. GP filed an NCLT petition for oppression and mismanagement under Section 241/242 on behalf of the institutional investor, simultaneously filing a SEBI complaint regarding LODR RPT disclosure non-compliance. The promoter settled within eight months, returning Rs.22 crore to the company and agreeing to independent RPT oversight for five years.
The practice combines forensic accountants with specific experience in procurement fraud analysis, accounting manipulation detection, and RPT investigation — working alongside GP's white collar criminal lawyers, commercial litigators for civil recovery, and regulatory lawyers for SEBI, MCA, and SFIO engagement. The SFIO investigation and MCA inspection response capability draws on GP's deep familiarity with the Companies Act investigative framework. The SEBI regulatory response draws on GP's Capital Markets regulatory practice.
For institutional investors who require independent investigation of investee company fraud — without relying on the investee company's own management to conduct the investigation — GP provides the fully independent investigation service, from first whistleblower report to final NCLT settlement.
Document preservation, investigation scope setting, personnel suspension decisions, SEBI disclosure timing, and management communication — the governance decisions that must be made in the first 48 hours of a fraud investigation, and who should be making them.
Read Guide →How statistical analysis of invoice data — Benford's Law digit frequency, clustering below approval thresholds, and vendor concentration patterns — identifies procurement fraud before the investigation has even interviewed its first witness.
Read Alert →Whether you are an audit committee member who has received a whistleblower complaint, an institutional investor who suspects investee fraud, an independent director who needs an independent investigation, or a board that needs to respond to a regulatory enquiry — call us immediately. The first 48 hours matter more than everything that follows.
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