The Insurance Regulatory and Development Authority of India cancelled the surveyor licence after finding serious regulatory violations in renewal scrutiny. The Authority observed multiple discrepancies in survey records, including conflicting registers, underreporting of surveys in statutory filings, and submission of inaccurate Form-12 returns. Evidence from insurers showed misattribution of survey work, incorrect locations, and omission of several survey assignments, establishing failure to maintain proper records and lack of integrity. The surveyor also admitted outsourcing core functions such as inspections and re-inspections to unlicensed personnel, violating statutory duties and professional conduct norms. Additionally, significant delays in submission of survey reports beyond prescribed timelines were identified. The Authority concluded that these violations were wilful and substantive, breaching the Insurance Act, 1938 and relevant regulations. Consequently, the licence was cancelled, renewal rejected, and the surveyor made eligible to reapply only after one year, with a right to appeal.
Insurance Regulatory and Development Authority of India
Ref. No. IRDAI/INT/ORD/MISC/59/4/2026 | Date: 30.04.2026
Final Order in the matter of Shri Sharmajeet Singh, Insurance Surveyor and Loss Assessor (SLA) (License No. IRDA/IND/SLA-34645)
1. Background
1.1. The Insurance Regulatory and Development Authority of India (“The Authority”) was in receipt of a surveyor license renewal application no. 500054735 submitted on 23.08.2025 by Mr. Sharmajeet Singh for the renewal of his surveyor and loss assessor licence bearing no. IRDA/IND/SLA-34645. Mr. Sharmajeet Singh is currently acting as a director of DISB Insurance Surveyor and Loss Assessors (DISB). Upon preliminary scrutiny, the License was flagged for disproportionately high volume of surveys conducted in last three financial years. Consequently, the Authority, sought clarifications from Mr. Sharmajeet Singh multiple times with a specific direction to produce his survey registers for last three financial years. Multiple irregularities observed in these survey registers and subsequent submissions raised concerns on regulatory adherence.
1.2. The Authority was in receipt of written complaints alleging engagement of unlicensed personnel for surveys by the DISB and the authenticity of the returns filed under Form 12 along with documentary evidences. The complaints called for a thorough scrutiny of the renewal application and the records submitted along with it, as well as the documentary evidence submitted by the complainants. Subsequently, clarifications/remarks were sought from the surveyor who submitted his response through the BAP portal and various subsequent emails.
2. Show Cause Notice, Reply and Hearing
2.1. Upon examination of the submissions made by the surveyor, the Authority issued the SCN (Show-cause Notice) on 06.02.2026, to which the surveyor submitted his response vide letter dated 11.02.2026. While replying to the SCN, the surveyor also sought a personal hearing in the matter. The hearing was granted by the competent Authority and was held on 18.03.2026. The hearing was chaired by Member (Life) and Member (Non-Life).
On behalf of the Authority, Shri Sudipta Bhattacharya, Chief General Manager – Intermediaries (SLA & IR); Smt. Shiksha Shaha, General Manager – Intermediaries (SLA & IR); Shri Kurapaty Sridhar Rao – Deputy General Manager – Intermediaries (SLA & IR); Shri Chandan Singh, Manager – Intermediaries (SLA & IR); Smt. Priya Yadav – Assistant Manager – Intermediaries (SLA & IR) and Shri Rasure Rajneesh Ravindra – Assistant Manager – Intermediaries (SLA & IR) were present during the said hearing.
3. Based on
The submissions made by surveyor in his written reply to the Show Cause Notice (SCN) dated 11.02.2026, as well as the submissions made during the course of the personal hearing held on 18.03.2026 at 02:30 PM, chaired by Member (Life) and Member (Non-Life) have been duly considered. The findings and decisions on the charges are set out hereunder.
4. Charges
4.1. Charge 1: Failure to maintain survey records, submitting false survey register and filing false returns with the Authority.
– Violation of Reg. 16(1), 16(9), 16(13) of IRDAI (Insurance Surveyors and Loss Assessors) Regulations, 2015.
4.1.1. Observations:
Survey registers were sought owing to the unusually high number of surveys conducted by the surveyor. Surveyor initially requested an exemption from submitting the survey register claiming that his records were lost in a system crash. He later went on to submit three conflicting versions of the same when insisted by the Authority.
Final version of survey register submitted by the surveyor, revealed that the surveyor conducted 2802, 2208, 3012 surveys in financial years 2022-23, 2023-24, 2024-25 respectively as against the 2493, 2099, 2314 surveys reported by him in respective financial years under Form-12 returns, the annual submission of Form-12 with the Authority is mandated in the regulations.
In light of the conflicting submissions of survey registers by the surveyor, Authority sought information from Insurers regarding the surveys conducted by the surveyor in last three financial years. It was observed that surveyor had failed to disclose full extent of these surveys in his submissions. Further, when the survey data was cross-checked with the Insurers additional survey activity was observed in West Bengal and Jharkhand which was not disclosed in the data submitted by the surveyor.
4.1.2. Submissions of the surveyor:
In response to the queries raised against the initial versions, surveyor stated that the details against certain surveys were assigned to him in the survey register by mistake while trying to reconcile the data lost in a system crash which resulted into disparity in the submitted records.
Surveyor reaffirmed in his response that the disparity between Form-12 and survey register was solely due to the aforementioned data loss and submitted that that there has been no wilful manipulation, suppression, falsification, or re-attribution of Survey Registers at any stage. All submissions made to the Hon’ble Authority were in good faith, based on the data available at the relevant point of time, and strictly in response to successive directions issued by the Authority and that there has been no change whatsoever in the total number of surveys conducted/reported in DISB. The differences between versions relate solely to addition of mandatory regulatory columns, improved segregation of data, and reconciliation of legacy system-generated records.
Surveyor submitted that all the surveys conducted in the State of Bihar were attended exclusively by Mr. Pradeep Kumar Singh (former director of DISB) during his tenure (October 2020 to September 2022) who was another director of DISB.
Mr. Sharmajeet Singh reaffirmed that neither him nor his partner Mr. Deependra were involved in any survey activity in West Bengal and Jharkhand as flagged by the Insurer.
4.1.3. Findings:
Post personal hearing, the Authority sought sample reports of the surveys pertaining to DISB from the concerned insurers. As per the copies of 24 sample survey reports submitted by SBI GIC to the Authority, all were found to be countersigned by Mr. Deependra (another director of DISB), details of five of the survey jobs were found to be absent from the survey register provided by the surveyor. Rest of the surveys have been miss-attributed to Mr. Pradeep Kumar Singh in the records submitted by the surveyor.
As per the 30 sample reports submitted by Go Digit GIC, eight were not conducted by DISB as opposed to their earlier submission. However, In rest of the 22 surveys, surveyor has either reported incorrect survey details such as location of the survey or has attributed them to his partners.
Three of these reports have been countersigned by the Mr. Deependra. In the register submitted by the surveyor, one of them has been attributed to the surveyor himself, another survey to Mr. Pradeep Kumar Singh and a wrong location for the third survey has been reported and it has been attributed to Mr. Deependra.
Stamp of DISB was noticed on rest of the 19 reports, details of a survey pertaining to one of these reports is absent from the records submitted by the surveyor, another survey has been attributed to the surveyor himself and a wrong location has been reported for the same. 16 of the other surveys have been attributed to Mr. Pradeep Kumar Singh in the consolidated records shared by Mr. Sharmajeet Singh.
4.1.4. Decision:
Submitting incomplete, incorrect records to the Authority violates Regulation 16(1) of IRDAI (Insurance Surveyors and Loss Assessors) Regulations, 2015 that requires every Surveyor and Loss Assessor to behave ethically and with integrity in the professional pursuits.
Every Surveyor and Loss Assessor must submit annual statement in Form-12 as per the Regulation 20(2) of IRDAI (Insurance Surveyors and Loss Assessors) Regulations, 2015. While the surveyor submitted his Form-12 returns, he provided incorrect details under the same as evident from his own submissions and the information provided by the insurers.
While the surveyor had earlier claimed data loss due to system failure, he went on to provide a survey register riddled with inaccuracies later. Even though he had access to necessary data that would have allowed him to reconcile the register, he only did so when insisted by the Authority. He also failed to maintain a backup of the necessary records.
Regulation 16(9) and 16(13) of IRDAI (Insurance Surveyors and Loss Assessors) Regulations, 2015 mandate that a Surveyor and Loss Assessor must maintain a proper record of the work done by the surveyor and maintain a register of survey work. Surveyor failed to comply with both of these regulations.
The Authority is of the view that the disregard of the regulations, incorrect submissions observed here warrant regulatory action.
4.2. Charge 2: Outsourcing primary responsibilities to un-licensed employees.
– Violation of Regulation 13(1)(d), 16(1), 16(19B) of IRDAI (Insurance Surveyors and Loss Assessors) Regulations, 2015.
4.2.1. Observations:
Questions arise in respect of geographical distance of the locations said to be covered by the surveyor in the final version of his survey register on specific dates. Such as surveys on 21.11.2024 which required covering minimum 709KM within a day; surveys on 28.04.2023 which also required covering minimum 350KM within a day.
The physical impossibility of conducting these surveys on same day, surveys in outlying locations in Bihar and the complaints referred under Para 1.2 inferred that these survey jobs were outsourced to un-licensed employees.
While trying to justify the plausibility of certain surveys, surveyor submitted that those surveys were “only photo snapped by assistant under guidance”, categorically admitting outsourcing his primary duties to un-licensed employees.
4.2.2. Submission of the surveyor:
Surveyor claimed that all the surveys conducted in the State of Bihar were attended exclusively by Mr. Pradeep Kumar Singh during his tenure at DISB (October 2020 to September 2022).
With reference to the phrase “only photo snapped by assistant under guidance”, Surveyor submitted that the same pertains only to photographic documentation collected by support staff under explicit instructions, without any exercise of professional judgment. He also stated that all site inspections, assessments and professional judgments were personally conducted by him in accordance with applicable regulatory norms. Supporting staff assisted only in ancillary and non-technical activities.
4.2.3. Findings:
While surveyor maintains that he conducted on-site inspection of all the other surveys, he also states that his employees only photo snapped some of these surveys when asked to justify their plausibility. His statements contradict his own claim of conducting on-site inspections of these surveys which is a duty of a licensed Surveyor and Loss Assessor as per Regulation 13(1)(d) of IRDAI (Insurance Surveyors and Loss Assessors) Regulations, 2015 and a violation of the Code of Conduct as per Regulation 16(1) of IRDAI (Insurance Surveyors and Loss Assessors) Regulations, 2015 that requires every Surveyor and Loss Assessor to behave ethically and with integrity in the professional pursuits and Regulation 16(19B) of IRDAI (Insurance Surveyors and Loss Assessors) Regulations, 2015 which mandates that a director of a corporate firm shall ensure that interim and final survey assessment is carried out by a licensed Surveyor and Loss Assessor.
4.2.4. Decision:
The surveyor in his submissions admitted that certain primary responsibilities were indeed outsourced to his un-licensed employees which is evidenced by the documents submitted. This constitutes a violation of the “Duties and Responsibilities of Surveyor and Loss Assessor” prescribed under Regulation 13 of IRDAI (Insurance Surveyors and Loss Assessors) Regulations, 2015 and “Code of Conduct” prescribed under Regulation 16 of the regulatory framework. The Authority is of the view that the violations are serious and of substantive nature and warrant a regulatory action.
4.3. Charge 3: TAT Violations.
– Violation of Regulation 13(2) of IRDAI (Insurance Surveyors and Loss Assessors) Regulations, 2015.
4.3.1. Observations:
In perusal of the complaint dated 09.10.2025, it was alleged that DISB had indulged in unethical practices for allocation of survey jobs from IFFCO TOKIO GIC and that the insurer had discontinued allocation of jobs to DISB because of the same. However, IFFCO TOKIO GIC without responding to the clarifications sought on unethical practices, confirmed that the allocation of survey jobs to the firm was discontinued because of consistent delays in handling cases and other complaints of internal conflicts in DISB amounting to violations of Turn-Around-Time (TAT) vide their mail dated 18.12.2025.
4.3.2. Submissions of the surveyor:
Surveyor while denying allegation of unethical practices, attributed special circumstances, complexity, delayed repairs, police custody and external dependencies etc. as factors for TAT violations and claimed that “both the insurer and the insured were fully informed and aware of the delays arising due to the specified circumstances”.
4.3.3. Findings:
Consolidated Survey registers consisting details of the surveys conducted by DISB Insurance Surveyor and Loss Assessors submitted by the surveyor revealed that survey reports were submitted beyond 30-days timeline in 3497 instances out of 13,819 survey jobs. In 206 instances, reports were submitted after 180 days.
4.3.4. Decision:
Regulation 13(2) of IRDAI (Insurance Surveyors and Loss Assessors) Regulations, 2015 mandates that survey report should not be submitted later than 30 days of the assignment of survey job without prior consent of the insurer and in no case shall submit it after six months. Concerns were raised by the surveyor when these issued were pointed out. Certain factors related with the preparation of final report are not entirely in control of the surveyor. The submissions of the Surveyor, in this regard have been noted by the Authority.
4.4. Charge 4: Outsourcing re-inspection of survey jobs to unlicensed personnel.
– Violation of Regulation 13(1)(d) of IRDAI (Insurance Surveyors and Loss Assessors) Regulations, 2015.
4.4.1. Observations:
In his response dated 12.12.2025, Surveyor mentioned “under repair and re-inspection” in the job profile of seven of his employees.
This is a categorical admission of violating regulatory norms by using un-licensed staff on his behalf to meet insurers’ demand and timelines. Surveyor also stated that same was done because insurers do not pay separate fees for re-inspection.
4.4.2. Submission of the surveyor:
Surveyor explained it as “General market practice” and claimed that it was done in low value claims. Surveyor also stated that his employees were engaged only for limited assistance related to survey completions.
4.4.3. Findings:
Surveyor has admitted that re-inspection activities were carried out by his employees.
4.4.4. Decision:
Regulation 13(1)(d) of IRDAI (Insurance Surveyors and Loss Assessors) Regulations, 2015 mandates that it is a duty of Surveyor and Loss Assessor to conduct inspection and re-inspection of property in question suffering a loss. The Surveyor has acknowledged delegating re-inspection duties to unlicensed personnel. His submission that such delegation was necessitated by the absence of supplementary remuneration from insurers is untenable and fails to constitute a valid justification for the regulatory breach.
5. Final Decision
Documentary evidence on record conclusively establishes a gross failure by the surveyor to comply with the regulatory framework across the specified charges. Given the severity and material nature of the infractions observed under Charges 1, 2 and 4, it is the considered view of the Authority that the surveyor has acted in wilful contravention of the Insurance Act, 1938, and its attendant Regulations, rendering him liable for the disqualifications set forth under Section 42D of the Act. Accordingly, pursuant to Regulation 24 of the IRDAI (Insurance Surveyors and Loss Assessors) Regulations, 2015, the license granted to the Surveyor is hereby cancelled.
The Surveyor and Loss Assessor license of Mr. Sharmajeet Singh (License No. IRDA/IND/SLA-34645) is cancelled with immediate effect as per Regulation 24(1) of IRDAI (Insurance Surveyors and Loss Assessors) Regulations, 2015. The renewal application filed vide unique reference number 500054735 also stands rejected.
The Surveyor in accordance with the Regulation 24(3) of IRDAI (Insurance Surveyors and Loss Assessors) Regulations, 2015 may submit an application for issuance of a surveyor license, after expiry of one year from the date of cancellation. Such application shall be treated as an application for grant of fresh licence.
If the surveyor is aggrieved by any portion of this order, he may prefer an appeal before the Securities Appellate Tribunal within a period of 45 days from the date of receipt of this Order as per Section 110 of the Insurance Act, 1938.
Notwithstanding anything in this order, the Authority reserves the right to initiate regulatory proceedings against DISB Insurance Surveyor and Loss Assessor.
