An IRDAI order has been issued to Shriram Life Insurance Company Limited following a remote inspection conducted in 2020. The inspection and subsequent investigation revealed multiple violations, including non-compliance with regulations concerning free-look cancellations, policy dispatches, and the protection of policyholders’ interests. The company was found to have accepted free-look cancellations after the stipulated period and delayed refunds. It also canceled a number of policies beyond the three-year statutory limit, citing misrepresentation of age. Additionally, the company was cited for issuing policies where the premium exceeded the policyholder’s annual income, a violation of anti-money laundering and corporate governance guidelines. In response, the insurer cited operational challenges and data issues, stating they had since implemented corrective measures like digital policy dispatch and improved grievance redressal. As a result, IRDAI has cautioned and warned the company, advising it to fix these systemic issues, improve customer service, and ensure compliance with all relevant regulations.
Insurance Regulatory and Development Authority of India(
Ref. IRDAI/E&C/ORD/MISC/105/9/2025
Order in the matter of M/s Shriram Life Insurance Company Limited
1. Based on the
1.1. Show Cause Notice (“SCN”) reference No. IRDA / ENF / 2020 / 503 / SCN / LR / 061 dated 06th November, 2024 issued to M/s Shriram Life Insurance Company Limited (hereafter ‘Insurer’ or ‘Company’) in connection with a remote inspection conducted by the Authority.
1.2. Submissions made by the Insurer vide email and letter dated 04th December, 2024 in response to the aforesaid SCN.
1.3. Submissions made by the insurer during the personal hearing held on 20th March, 2025 at 03.00 PM, by the panel of two Whole Time Members of the Authority – Shri Satyajit Tripathy (Member-Distribution) and Shri P K Arora (Member-Actuary).
1.4. Further submissions made by insurer vide letter dated 2nd April, 2025.
2. Background
2.1. The Authority had conducted a remote inspection of the insurer from 29th June 2020 to 3rd July 2020. The inspection report, inter alia, revealed certain violations of provisions of the Insurance Act, 1938, Regulations, Guidelines and Circulars issued thereunder.
2.2. A copy of the inspection report was forwarded to the insurer on 2nd September, 2020 seeking their response. The response was received vide email dated 3rd October, 2020.
2.3. On examining the submissions made by the insurer, show cause notice (SCN) was issued on 6th November, 2024. The insurer replied to the SCN vide email and letter dated 4th December, 2024.
2.4. As requested for by the Insurer, a personal hearing was granted to the Insurer on 20th March, 2025 by the panel of two whole-time members of the Authority – Shri Satyajit Tripathy (Member-Distribution) and Shri P K Arora (Member-Actuary).
2.5. On behalf of the insurer, Shri Casparus Jacobus Kromhout (Chief Executive Officer), Shri Anand Soni (Chief Financial Officer), Shri Atul Sharma (Chief Operating Officer), Smt. Madhavi Shrine (Head NB & UW) and Shri Bireswar Chatterjee (Chief Compliance Officer) and on behalf of the Authority, Shri R K Sharma (Chief General Manager), Shri T Venkateswara Rao (General Manager), Shri Sanjay Kumar Verma (General Manager), Shri Manoj Kumar Asiwal (Deputy General Manager) and Shri Atul Gupta (Asst. Manager) attended the hearing.
2.6. The submissions made by the insurer in its email dated 3rd October, 2020, submission made after SCN vide email and letter dated 4th December, 2024 and submission during the personal hearing on 20th March, 2025 and those made vide letter dated 2nd April, 2025 have been carefully considered by the Authority and are summarized below:
3. Charge-1
Violation of
a) Regulation 8(1), 10(1)(i) and 10(1)(iii) of IRDAI (Protection of Policyholders’ Interest) Regulation, 2017.
b) Clause 6 of the of the Guidelines on Corporate Governance for Insurers in India issued vide ref. no. IRDA / F&A / GDL / CG / 100 / 05 / 2015 dated 18th May, 2016.
3.1. Inspection Observation 1 and 2
3.1.1. The insurer accepted the Free Look Cancellation (FLC) after 15/30 days of receipt of policy documents by the customer. On the examination of the data furnished by the insurer with regard to free-look cancellations for the years 2017-18, 2018-19 and 2019-20, the following are noticed:
3.1.1.1. There were a total of 6215, 15661 and 7207 cases where FLCs were accepted by the insurer during the financial years 2017-18, 2018-19 and 2019-20 respectively. Out of these cases, in 127, 16 and 35 cases, the date of dispatch was not available in the financial years 2017-18, 2018-19 and 2019-20 respectively. Further, in 1790, 1340 and 4798 cases, the insurer did not maintain the details / acknowledgement of receipt of the documents by the customer in the financial years 2017-18, 2018-19 and 2019-20 respectively.
3.1.1.2. FLC request date is not available with the insurer in 173 and 84 cases in the years 2018-19 and 2019-20 respectively.
3.1.1.3. In the balance cases where the details of acknowledgement available and FLC request date is available, there were 3470, 11709 and 1999 cases where the company accepted the requests after 15 days of the receipt of the documents by the customer in the financial years 2017-18, 2018-19 and 2019-20 respectively. Out of these, there were 1629, 6876 and 1412 cases where the company accepted the requests after 30 days of the receipt of the documents by the customer in the financial years 2017-18, 2018-19 and 2019-20 respectively.
3.1.1.4. In 21, 24 and 12 cases, in the financial years 2017-18, 2018-19 and 2019-20 respectively, the insurer did not deduct any mortality charges. In 92, 33 and 23 cases, in the financial years 2017-18, 2018-19 and 2019-20 respectively, the insurer refunded the premium after 15 days of receipt of the request.
3.1.1.5. In the year 2017-18, it was noticed that out of the 1790 cases where acknowledgement details were not available, there were 766 cases where the request was received after 30 days of risk commencement date. There were 654 cases, where the request was received after 30 days of dispatch of the documents. Similarly, in the year 2018-19, there were 1340 cases where acknowledgement details were not available, there were 570 cases where the request was received after 30 days of risk commencement date. There were 471 cases, where the request was received after 30 days of dispatch of the documents. There were 4798 such cases in the year 2019-20, where acknowledgement details were not available, there were 2018 cases where the request was received after 30 days of risk commencement date. There were 1988 cases, where the request was received after 30 days of dispatch of the documents. Hence, the insurer does not know whether these requests were received after 15 days of receipt of documents or before.
3.1.2. Delay in receipt of documents by the customer was noticed from the grievances sample chosen by the inspecting team. Further, the insurer did not re-dispatch the documents even after the complaint filed by the customer/s. After examining the additional details provided by the insurer relating to policy related issues sample, the following are noticed:
3.1.2.1. Out of 56 cases, in 45 cases, the insurer does not have details of whether the policy documents were received by the insured or not. In 7 cases re-dispatch of policy bonds were carried out by the insurer. In 3 cases, even after the re-dispatch, a complaint of non-receipt of document was received; In 31 cases, the complaint was received after 30 days of dispatch of the documents by the insurer; In 22 cases, the complaint was received after 100 days of dispatch of the documents by the insurer; In 10 cases, the complaint was received after 200 days of dispatch of the documents by the insurer.
3.1.2.2. In none of the above cases, the insurer made any attempt to re-dispatch the documents. Further, in 6 cases, the insurer doesn’t have the dispatch details of the documents.
3.2. Summary of Insurer’s Submissions:
3.2.1. Insurer submitted that on an average close to 45% of their total policies are sold to truck operators who generally have variable income. Therefore, there are cancellations which more often are related to financial considerations.
3.2.2. With regards to dispatch date not available, insurer submitted that there are a few instances where choosing the right and appropriate policy dispatch mechanism / option may lead to some delay in dispatch of policies.
3.2.3. With regards to acknowledgments not available, insurer submitted that they have challenges in obtaining delivery confirmations from service providers.
3.2.4. With regards to FLC request date not available, insurer submitted that there was a specific data extraction issue at the time when FLC request dates were extracted from their system.
3.2.5. With regards to FLC requests accepted after 15/30 days of the receipt of the documents by the customers, insurer submitted that they consider requests for cancellation based on merits of the case and thus accept some cases beyond 15/30 days.
3.2.6. With regards to mortality charges not deducted, insurer submitted that non deduction of proportionate mortality was due to a specific system bug which was identified and fixed later.
3.2.7. With regards to refund of premium done after 15 days of the receipt of the request, insurer submitted that delays are due to documentation & non availability of the bank details of the customer. They have taken necessary steps to reduce such delays.
3.2.8. With regards to the insurer not having details of the receipt of the policy documents by the insured, the insurer submitted that they do face challenges with respect to courier services and in spite of their rigorous efforts, for nearly 30% of the cases, they are not able to get the delivery details of the policy bonds.
3.2.9. With regards to even after the re-dispatch, a complaint of non-receipt of document was received, insurer submitted that the complaints referred to in this observation are part of such situations where they finally hand delivered the Policy bonds.
3.2.10. With regards to receiving of complaint after dispatch of the documents, insurer submitted that they are not able to get the delivery details from couriers or post offices and thus they are not able to establish delivery proof to the customers. The Insurer further submitted that they have started sending Bitly links to customers through SMS whereby the customers can download the PDF version of the key portions of the policy bonds. They have also developed a dedicated Shri Mithra app for all servicing needs of the policy holders.
3.2.11. During personal hearing, insurer stated that they have introduced revised SOP for handling free-look cancellation requests in line with the new master circular on Policyholders’ protection. Overall free-look cancellation ratio has significantly reduced over the years from 5.26% in FY 2018-19 to 0.87% in FY 2023-24. The number of free-look requests accepted beyond free-look period, has significantly come down from 3.93% in FY 2018-19 to 0.10% in FY 2023-24. Free-look cancellation in Shriram Transport Finance Company (now Shriram Finance Limited) segment has progressively reduced to 0.20% in FY 2023-24. Acknowledgement of grievances are being generated immediately after registration of complaints. Grievances are resolved within the period of 14 days from the date of receipt and a resolution letter giving the details including options to approach Ombudsman/Consumer Court, if the customer is not happy with the resolution, is sent to the customer. They have put in place a robust process of handling all customer grievances, including those complaints relating to non-receipt of policies as a result of which the number of grievances on non-receipt of policy documents have significantly reduced.
3.2.12. Post personal hearing, the insurer submitted an undertaking dated 2nd April, 2025 stating that for all free-look cancellation requests, premiums along with interest, as applicable for delayed payments, have been paid to the policyholders. They also confirmed that the free-look cancellation requests are being processed at the request of the customer as per specified timelines.
3.3. Decision on Charge 1:
3.3.1. Notwithstanding the improvements purportedly implemented by the insurer, it is apparent that the insurer continues to encounter several operational-level challenges which have not yet been adequately addressed. These issues are material in nature and have significant implications for the insurer’s overall regulatory compliance, operational effectiveness, and the protection of policyholders interests.
3.3.2. The insurer is hereby cautioned for the lapses and advised to ensure compliance with all applicable regulatory requirements in letter and spirit.
4. Charge-2: Inspection Observation- 3
Violation of
a) Section 45(1), 45(2) and 45(4) of the Insurance Act, 1938;
b) Clause C of the Circular No. IRDA / SDD / MISC / CIR / 009 / 01 / 2013 dated 21st January, 2013;
c) Clauses 6 and 7.3 of the Corporate Governance Guidelines issued vide ref. no. IRDA / F&A / GDL / CG / 100 / 05 / 2015 dated 18th May, 2016.
4.1. Inspection Observation-3
4.1.1. As per the data furnished by the insurer pertaining to foreclosures, it is noticed there were 1792, 8700 and 3238 foreclosure cases during the period 2017-18, 2018-19 and 2019-20 respectively. On examination of the same, it is observed that there were cases where the insurer cancelled policies after 3 years of their issuance and forfeited the premiums. It was found that there were around 38 cases during this period where the insurer cancelled the policies and forfeited the premium.
4.1.2. In these cases, the following was observed:
4.1.2.1. In no case, Insurer issued prior notice seeking explanation from the Life Assured (LA);
4.1.2.2. No proper investigation was conducted in these cases. Wherever, investigation was conducted, no substantive proof was collected to prove that a fraud or misstatement of material facts was committed by LA;
4.1.2.3. In 22 cases, the cancellation was on grounds of wrong declaration of age at the time of proposal by the LAs. In 14 cases, ground for cancellation was life assured died before the issuance of policy. In the remaining 2 cases, insurer did not share the documents;
4.1.2.4. Out of these policies, instances were noticed where the insurer issued multiple policies to individual LAs.
4.2. Summary of Insurer’s Submissions:
4.2.1. Insurer submitted that out of the 38 cases listed in the observation, 2 were cancelled based on the order of the District Consumer Forum and the balance 36 cases are from the southern part of Orissa. Out of 36 such policies, 19 were cancelled for major and deliberate age mis-representation with a clear intention to defraud the company. The balance 17 polices were cancelled as they were “Death before commencement” cases. They have filed 11 police complaints in last few years in the Ganjam region of Odisha to send a clear deterrence message to the fraud cartels active there.
4.2.2. The insurer stated that section 45 (5) of the Insurance Act, 1938 provides that no policy shall be deemed to be called in question merely because the terms of policy are adjusted on subsequent proof that the age of life insured was incorrectly stated in the proposal. Further, if as a result of actual age having been established to be more than the maximum age at entry permissible as per the Product “File & Use” document, the only option available is cancellation of Policy. No other adjustment is possible. If the actual age was more than the age declared in the proposal form and was within the maximum age at entry as per the product “File & Use” document, the company could have continued the policy by appropriately increasing the premium and collecting the differential premium from inception. However, this was not the case in all these 19 Policies which were uninsurable based on the revised age proof obtained.
The insurer during the personal hearing, stated that they have refunded the premium together with interest for the age misrepresentation cases observed during the course of inspection. Further, they have identified another 24 cases on their own accord where there was cancellation on misrepresentation of age and they have refunded the premium together with interest for these cases also.
4.2.3. Post personal hearing, the Insurer submitted
4.2.3.1. a certificate from CA on the “statement of life insurance policies refunded” where the cancellations are done beyond 3 years from the date of issuance/revival;
4.2.3.2. an undertaking signed by CCO that the premium has been refunded along with interest for all relevant cases involving age proof and other cases such as impersonation, etc. The insurer also confirmed that there are no other cases where cancellation of policies has been made beyond three years.
4.2.4. As submitted by the insurer, a sum of Rs. 19,24,974/- has been refunded to 43 policyholders towards refund of premium and interest thereon.
4.3. Decision on Charge 2:
4.3.1. Section 45 (1) of Insurance Act, 1938 makes it incumbent on the insurer to verify all the documents and information furnished with the proposal by the life insured and to question the policy on grounds of fraud, concealment and suppression of material facts “within a period of three years”.
4.3.2. Further, the insurer has also violated Clauses 6 and 7.3 of the Corporate Governance Guidelines issued vide ref. no. IRDA / F&A / GDL / CG / 100 / 05 / 2015 dated 18th May, 2016 as the insurer has failed to institute systems and processes to detect the intended frauds and mis-representation by the life assured / policyholders so that the legislative intent of Section 45 of Insurance Act is upheld.
4.3.3. Insurer acknowledged the cancellation of 43 insurance policies on the grounds of misrepresentation of age and / or impersonation beyond the three-year period.
4.3.4. The Insurer has submitted that most of these policies were sourced in one particular geographical location in Odisha prompting the insurer to file F.I.R. in 11 matters indicating the mala fide.
4.3.5. During the personal hearing, the insurer submitted that they refunded the premium along with interest for 19 cases. Vide letter dated 02nd April 2025, the Insurer submitted an undertaking duly signed by the Chief Compliance Officer along with the details, stating that they have refunded premiums along with interest for all relevant cases as identified in the SCN depicting violation of Section 45 of Insurance Act, 1938 along with 24 more cases they themselves identified where there was cancellation on misrepresentation of age. Section 45(5) of Insurance Act, 1938 allows the insurers to call in question the policies because the terms of the policy are adjusted on subsequent proof that the age of the life insured was incorrectly stated in the proposal. However, in the cases identified, the terms of the policies could not be adjusted and the policies were rather cancelled by the insurer. The reason furnished by the insurer is that “One of the terms of the Policy is the admitted age based on the maximum age of entry as per the Product “File and Use” document approved by the Authority. If as a result of actual age having been established to be more than the maximum age at entry permissible as per the F&U, the only option available is cancellation of the policy.”
4.3.6. Section 45 is sacrosanct provision aimed at policyholder protection and to hold the life insurers accountable to their promise once the period of three years from the date of issuance, commencement of risk, revival of the policy, or the date of any rider to the policy, whichever is later, is over. The actual date of cancellation as observed in these 43 cases is beyond three years. Hence the cancellations made are in violation of Section 45 of Insurance Act, 1938 but since the said cases were limited to a geographical location and the insurer has filed 11 police complaints and the corrective action taken by the Insurer by payment of interests in all the cases is taken on record by the Authority.
4.3.7. In view of the above, the Insurer is hereby warned for the violation of
4.3.7.1. Section 45 of Insurance Act, 1938 and advised to comply with the provisions of Section 45 in letter and spirit;
4.3.7.2. Clause C of the Circular No. IRDA / SDD / MISC / CIR / 009 / 01 / 2013 dated 21st January, 2013;
4.3.7.3. Clauses 6 and 7.3 of the Corporate Governance Guidelines issued vide ref. no. IRDA / F&A / GDL / CG / 100 / 05 / 2015 dated 18th May, 2016.
5. Charge-3: Inspection Observation No. 4,5, and 6
Violation of-
a) Regulation 8(6), Regulations 10 (1) (iii) and 14 (2) (v) of IRDAI (Protection of Policyholders’ Interest) Regulation, 2017.
b) Clause 6 of the of the Guidelines on Corporate Governance for Insurers in India issued vide ref. no. IRDA / F&A / GDL / CG / 100 / 05 / 2015 dated 18th May, 2016.
c) Authority’s circular number IRDA / INSP / CIR / ONS / 157 / 09 / 2018 dated 19th September 2018.
5.1. Inspection Observation 4, 5 and 6
5.1.1. As per the data shared by the insurer, the insurer has received 392, 572 and 525 complaints/grievances during the period 2017-18, 2018-19 and 2019-20 respectively. While going through the same, it is observed that the insurer has delayed in acknowledging the receipt of grievances, delayed in responding to the grievances, delayed in processing of FLC requests, delayed in refund of premium and also indulged in unfair business practices by rejecting the requests received for FLC.
5.1.2. Upon examination of the premium register for FY 2019-20 revealed delays in policy issuance, with 644 out of 13,925 policies (approximately 4.65%) taking over 15 days to communicate decisions.
5.1.3. Upon examination of details submitted in premium register for FY 2019 20, it was examined that around 9502 policies were identified wherein there was delay of more than 15 days in dispatch of policies vis a vis date of issuance of policies.
5.2. Summary of Insurer’s Submissions:
5.2.1. Insurer submitted that they send an auto-mailer in response to the customer mail as an acknowledgment. They assured the Authority that they will enable saving a copy of the auto-mailer in the customer care mail box and in the grievances team mail box, as the case may be. Insurer further submitted that by excluding week end holidays and other national or festival holidays, the cases were processed within the turnaround time of 15 working days. Barring the few cases observed by the inspection team, they have been complying with the process of refunding the premium and meeting the TAT.
5.2.2. In the 4 cases reported by the inspection team, the policyholders indicated reasons which are other than dis-agreement of the terms & conditions of the policy. In these cases, the customers are educated and are doctors, business men and reasonably well-off customers. Hence, they did not consider these requests for Free Look Cancellation. However, in two of the above said cases, the holders of policy numbers NN012002113256 and NN011911004395 had once again requested for cancellation expressing disconnect with the policy terms & conditions and they had accepted their request and cancelled the same under free look cancellation and refunded the amount due.
5.2.3. Insurer submitted that majority of the policies sold by them cater to the rural segment as well as occupation classes which are in the lower strata of society. In rural areas the know-how of insurance is not in the manner as it is in the urban part of the country. In such an environment, they as an insurer are required to seek additional information/ clarifications from the proposer through informal means like, telephone. This continuous engagement, due to multiple follow ups at times may take more time than anticipated.
5.2.4. Insurer submitted that there are a few instances where choosing the right and appropriate policy dispatch mechanism / option may lead to some delay in dispatch of policies. As far as communicating the underwriting decision is concerned, the insurer sends a customized Short Messaging Service (SMS) to all their policyholders within one week of policy issuance. They have started sending Bitly links to customers through SMS whereby the customers can download the pdf version of the crucial parts of the policy bonds.
5.2.5. During personal hearing, the Insurer stated that after underwriting, the decision on the proposal is communicated in 15 days from the date of proposal/submission of last document. In cases where (a) submission of any document or any clarification from customer was pending; or (b) there is a red flag concerning any documents submitted; or (c) clearance of cheque (especially outstation cheques from rural customers), the company continuously follows up for submission of documents for taking decision / waits clearance of cheque/ conducts due diligence on documents before taking a decision and issuing the policy.
5.2.6. The insurer further submitted that the % of cases where policy is despatched within 15 days has improved significantly from 84% in FY 2020-21 to 98% in FY 2023-24. Aadhaar card for residents especially in rural areas do not contain full information such as colony name or street name in some cases. Under such circumstances, they reach out to the customer through distributor or directly to obtain the landmarks and/or verify the address. Post Covid, they have revisited the process and made significant improvements in ensuring TAT for policy dispatch, by sending policy documents digitally through SMS and Whatsapp in addition to physical dispatch. The policyholders can also download the policy documents through “Shri Mithra” app or through its chat bot “ShriA” and through DigiLocker.
5.3. Decision on Charge 3:
5.3.1. The insurer is cautioned for the lapses and is advised to
5.3.1.1. put in place adequate processes and systems to ensure regulatory compliance around free look cancellation facility and all other building blocks like dispatch of policy bonds, grievances relating to non-receipt of policy bonds, etc.
5.3.1.2. ensure prompt and effective redressal of consumer grievances. There shall be no undue delay in the processing of free look cancellation requests and the consequent refund of premiums.
6. Charge-4 : Inspection Observation No. 12 and 15
Violation of-
a) Clause 3.1.13.i (c) and Clause 3.1.VIII of the Master Circular on Anti Money Laundering/ Counter Financing of Terrorism (AML/CFT) dated 28th September 2015.
b) Clause 6 of the Guidelines for the corporate governance for insurers in India issued vide order IRDA/F&A/GDL/CG/100/05/2016 dated 18th May 2016.
6.1. Inspection Observation 12 and 15
6.1.1. Insurer has issued insurance policies to policyholder where the annualized premium has exceeded the annual income of the policyholders. There were 261, 312 and 306 such cases in FYs 2017 18, 2018-19 and 2019-20 respectively.
6.1.2. No due diligence has been carried out by the insurer where the policyholder has submitted the Form 60 in-spite of the fact that the annual income of the policyholders has exceeded the taxable limit. There were 61, 43 and 63 such cases in FY 2017-18, 2018-19 and 2019-20 respectively.
6.2. Summary of Insurer’s Submissions:
6.2.1. Insurer submitted that 72% of the cases are single premium policies which are usually paid by the life assured out of accumulated savings or retirement benefits or bulk proceeds received from the sale of a property or maturity of any financial instrument etc. For the balance 28% of the cases are regular premium cases wherein the underwriters accept the case only after financial evaluation i.e. post considering all the sources of income of proposer disclosed through proposal form, income proofs or declarations.
6.2.2. Insurer submitted that In a few cases listed by the inspection team, there was an error in the selection of document and in cases where Form 60 was initially submitted at the time of receipt entry, the system had captured Form 60. The reports extracted and submitted to the inspection team had reflected the entries made in the initial stage at the branch. However, as part of their follow up mechanism, they had received PAN copy in these cases before issuance of the policy but the same was not reflecting in the data extracted & submitted to the inspection team.
6.2.3. During personal hearing, the insurer stated that in respect of the 879 cases observed:
6.2.3.1. 77% were single premium policies, the insurer had obtained bank statement and verified the source of funds for the one-time single premium received.
6.2.3.2. 7% were regular premium cases, the insurer had sought and obtained the income proofs & annualised premium to annual income ratio was as per their underwriting norms.
6.2.3.3. 16% of the cases, involved data spooling issues and in some cases incorrect data entry on proposer’s income, which were subsequently corrected.
6.3. Decision on Charge 4:
6.3.1. The insurer is cautioned for the lapse and advised to establish and implement the required process and procedure for conducting thorough assessments of a policyholder’s suitability prior to the issuance of insurance policies, particularly in cases where such issuance may pose a potential risk to the policyholder’s financial well-being. The insurer shall carry out due diligence by obtaining standardized and verifiable proof of income for the purpose of accurately determining the policyholder’s actual annual income.
6.3.2. The insurer is further advised to standardize the process by way of an SOP approved by PPGR&CM Committee for financial underwriting.
7. Summary of Decisions:
| Charge. No. | Violation of Provisions | Decision |
| 1 | (i) Regulation 8(1), 10(1)(i) and 10(1)(iii) of IRDAI
(Protection of Policyholders’ Interest) Regulation, (ii) Clause 6 of the of the Guidelines on Corporate Governance for Insurers in India issued vide ref. no. IRDA / F&A / GDL / CG / 100 / 05 / 2015 dated 18th May, 2016. |
Caution and Advisory |
| 2 | (iii) Section 45 of the Insurance Act, 1938;
(iv) Clause C of the Circular No. IRDA / SDD / MISC / CIR / 009 / 01 / 2013 dated 21st January, 2013; (v) Clauses 6 and 7.3 of the Corporate Governance Guidelines issued vide ref. no. IRDA / F&A / GDL / CG / 100 / 05 / 2015 dated 18th May, 2016. |
Warning and Advisory |
| 3 | (vi) Regulation 8(6), 10 (1) (iii) and 14 (2) (v) of IRDAI
(Protection of Policyholders’ Interest) Regulation, (vii) Clause 6 of the of the Guidelines on Corporate Governance for Insurers in India issued vide ref. no. IRDA / F&A / GDL / CG / 100 / 05 / 2015 dated 18th May, 2016. |
Caution and Advisory |
| 4 | (viii) Clause 3.1.13.i (c) and Clause 3.1.VIII of the Master Circular on Anti Money Laundering/ Counter Financing of Terrorism (AML/CFT) dated 28th September 2015.
(ix) Clause 6 of the Guidelines for the corporate |
Caution and Advisory |
8. Further,
a) The Order shall be placed before the Board of the Insurer in the upcoming Board Meeting and the insurer shall provide a copy of the minutes of the discussion.
b) The insurer shall submit an Action Taken Report to the Authority on direction given within 90 days from the date of this Order.
9. If the Insurer feels aggrieved by this Order, an appeal may be preferred to the Securities Appellate Tribunal as per the provisions of Section-110 of the Insurance Act, 1938.
Satyajit Tripathy
Member (Distribution)
P K Arora
Member (Actuary)
Place: Hyderabad
Date: 22nd September, 2025
