The paper is a significant step towards making the “fit and proper person” criteria more balanced and fairer. However, its triumph depends on how SEBI exercises its discretion.

Market integrity regulation is invariably faced with a dilemma of how far precautionary provisions can be stretched until there exists a possibility of punitive action against a behavior not yet found to have occurred.

The onus of assigning a ‘fit and proper’ status being on the concerned banking company, would act as a hostile takeover defence.