RTI Judgement Series
RTI Judgement Series: How MCD officers kept pushing papers for three years

In one representative case it was revealed how officers from the MCD kept pushing papers from one desk to another for over three years without any productive work. This is the 53rd in a series of important judgements given by former Central Information Commissioner Shailesh Gandhi that can be used or quoted in an RTI application

The Central Information Commission (CIC), while disposing off an appeal, stated that this was a representative case of how officers from the Municipal Corporation of Delhi (MCD) kept pushing papers from one desk to another without any productive work.
While giving this important judgement on 30 September 2009, Shailesh Gandhi, the then Central Information Commissioner said, “The deemed Public Information Officer (PIO) showed that a number of man-hours in the MCD are being wasted by moving the files from one table to another."
Bahadurgarh (Haryana) resident Vipin Gupta, on 20 April 2009 sought information related to payment of bills from the Municipal Corporation of Delhi. Gupta was also a contractor of the MCD. Here is the information he sought and the reply given by the PIO...
1. Face-lifting of maternity centre & child welfare centre Dr. staff Qtrs. in Old Rajinder Nagar in C-127/KBZ/Div. now EEM-I/KBZ H/A XVI.J. VII.I W.O. No.-10/EEI/TC/KBZ/05-06 dt.1/04/05.  What is the Status of above said H/A.
PIO's reply- Non Plan demands under all heads of accounts received in this office up to October 2008 have already been released. Status of Head of Account pertains to DHA.
2. The above said work was completed in 2005 & bill was passed on 28/03/2006.  How long you will take to release the payment.
PIO's reply-Non Plan demands under all heads of accounts received in this office up to October 2008 have already been released. However, details regarding passing of bill, whether send in demand etc. can be given by EE-M-I/KBZ.
Due to non-receipt of information from the PIO, Gupta filed his first appeal. The First Appellate Authority (FAA) in his order directed the Executive Engineer-I to ensure that the pending payments of Gupta are released at the earliest, under his intimation.
Not satisfied with the reply, Gupta then approached the CIC with his second appeal.
During the hearing, Gupta said he was contracted with the MCD and raised a bill of Rs1.39 lakh in March 2006 which was not paid. The PIO and FAA, both admitted that the amount was due to Gupta.
However, Gupta contended that since the budget of the particular head had been exhausted in 2006, the MCD was unable to make the payment even three years later.
During the hearing, the PIO also showed Mr Gandhi, the then CIC, the number of man hours wasted in MCD by moving the files from one table to another.  
“This is a representative case of how MCD officers keep pushing papers from one to another without any productive work. The respondent states that the payment will be made soon but he is unwilling to define how much time ‘soon’ means," the CIC said while disposing the appeal.
Decision No. CIC/SG/A/2009/001933/4973
Appeal No. CIC/SG/A/2009/001933
Appellant                                                         : Vipin Gupta
                                                                               Bahadurgarh, Haryana
Respondent                                                     : Suresh Chandra
                                                                               Municipal Corporation of Delhi
                                                                               Office of the CA cum FA
                                                                               Town Hall, Delhi-110006


Fat tails have a tale to tell

Between 1998-2013, out of a total of 3,785 days, movement in the CNX 500 was outside 3 sigma on 60 occasions, that is 1.59% of the total. By normal distribution, less than 0.03% observations should fall outside the 3 sigma

In the world of investments, returns are measured by the first moment of prices (mean) and the risks are measured by the second moment (standard deviation or sigma). Most of the classical theories of finance are based on the assumption that the returns are normally distributed. In the probability theory, the normal distribution is a bell shaped curve of probability values for various natural events—hence the word ‘normal’. This distribution assumes that the tails or the ends are flatter and extreme events are rare. For example, this means that the probability of returns moving more than three standard deviations beyond the mean is 0.03%, or virtually nil. But what is ‘normal’ in markets?

In the Indian context, taking daily CNX 500 data from 1 January 1998 to 28 February 2013 (more than 15 years), 99.73% of the daily returns should ideally fall within -4.97% and 5.09%. Or less than 0.03% observations should fall outside the 3 sigma.

Out of a total of 3,785 daily observations during the period of analysis, 60 times the returns were outside 3 sigma in the case of CNX 500, that is 1.59% of the total observations. Clearly much more than we bargain for. The rule book says that if we are looking at daily events, a 5 sigma event would occur once in 4,776 years. A 6 sigma event would occur once in 1.388 million years and after that, the numbers are, let's just say too big to bother.

On 17 May 2004, the financial market experienced a more than 7 standard deviation fall, when markets crashed due to political uncertainty. Markets fell more than 5 to 6 standard deviations many times in 2007 and 2008, owing to global melt down. Similarly, the market posted a more than 9 standard deviation gain, once again due to the political scenario in the country at that time.

In reality, we have experienced 5, 6, 7 or even more than that, sigma events more frequently than what the normal distribution suggests and we dare to accept.

This is true globally, not just in India. For instance, Goldman Sachs, Citigroup, UBS, Merrill Lynch, all experienced large (as large as 25) sigma events on multiple days in 2007 and 2008. There was the South East Asian crisis, the 11 September 2001 attacks on the World Trade Centre, the Euro crisis, all in the past two decades.

It is not just that these events occur more frequently, these events have greater impact, as well. The impact is, in fact, higher due to the surprise element attached to them. It hits one at the place where it hurts the most and makes it very difficult to recover.

Our observations suggest that the distribution is more leptokurtic in nature, with fatter tails. This means that more observations are concentrated around the mean and tails are fatter, or have greater number of observations than suggested by the normal distribution.

So what we must do is first, acknowledge the limitation of our knowledge that we cannot explain everything and second, we must believe that such events occur more frequently than we had thought. This must call for better risk management systems. Perhaps these events indicate that we must prepare for more incorrigible things that will happen.

What this also points to is that the assumption of normal distribution does not hold. Hence, financial mathematicians must look at distributions with fatter tails for building their theories and models.

Additionally, Daniel Kahneman’s prospect theory says that humans are more likely to act to avoid loss than to achieve a gain, articulated very well in his book “Thinking fast and slow”. If we accept this to be true, then it becomes all the more important for the theorists and professional money managers to rethink the way they build models or the appropriateness of the models which they use.

As for the investors, it would be wise to question their financial advisor on the soundness of their advice during a large sigma event!

(Nupur Pavan Bang is a senior researcher at the Centre for Investment, Indian School of Business, Hyderabad. Khemchand H Sakaldeepi is a researcher at the Centre for Investment, Indian School of Business, Hyderabad.)


Naïve brokers: Espirito Santo too gets “seduced and dumped” by hopes raised by the FM. Put GDP growth at 6.6% as the best-case for FY14

ESS has come out up with its monthly report and realised that its expectations were too high and needs toning down. But it still remains optimistic and expects the economy to recover and RBI to slash interest rates

The latest brokerage to get “seduced and dumped” is Espirito Santo Securities (ESS). Like BNP Paribas, it had kept its expectations rather high and was let down by P Chidambaram’s budget. ESS said, in its latest “Blackbook” titled Waiting for Dawn: “FII flows and market movements since August 2012 show that (high expectations). And the budget, with media hype around a ‘dream budget’ in the run up, was expected to provide the next leg up to reforms, but the FM disappointed." Despite the disappointment, ESS is optimistic that the Reserve Bank of India (RBI) would do its bit to stimulate the economy by cutting interest rates by as much as 50 basis percentage points (bps) within the next two months. ESS said, “On balance we’re slightly more bullish on rate cuts than consensus, and expect the RBI to cut the repo rate by another 50 bps by its May 2013 policy meeting, with a likely 25 bps cut in the March policy meeting." This is a big expectation indeed, given that inflation risks continue to persist.

Earlier we had written how other brokers like BNP Paribas fell for FM’s hardsell and were left high and dry. Check here for more information. Of course, it finally dawned to ESS that there was no basis for such hopes. In the report, it cautioned investors of the finance minister's so called ‘tricks’. It was stated: “And investors should be careful of expecting too many more reform rabbits up Chidambaram’s sleeve to offset disappointment in the actual fundamentals.” Oh well, the reality is dawning on analysts.

ESS expects populist measures to take the centre-stage as the election nears. This is something it should have thought of much before the budget and before the finance minister sold the idea of ‘reforms’ and India being the premier investment destination. The report said, “as elections draw closer in H2 pro-growth and pro-investment reforms are likely to take a back seat, and the shift will be towards more inclusive and populist measures.”

Given that the finance minister has all but dashed ESS’s hopes for a ‘reform’ budget, the brokerage has moderated India's GDP forecast to 6.6%. The report said: “Overall our analysis still suggests a recovery, just a slow and difficult one, with 6.6% GDP growth for 2014 probably a best case scenario now”.

It is also optimistic on inflation and expects 'core' inflation to “tread below 4.5%”, even though the government is going into full blown expenditure mode. It is hard to see how inflation go down can given how much headwinds is there in the economy, especially one reliant on imports and breaks in domestic competition and distribution.

With the markets in a ‘correction’ mode post-budget, ESS thinks there is value in select stocks and it has come up with a “silver bullet” list of stocks to buy and sell. They are ING Vysya Bank, Wipro, Gujarat Pipavav, Cipla, Jindal Steel & Power and Motherson Sumi. ESS has put a sell on L&T and Marico.

Apart from the “silver bullet” list, it has also come up with conviction ideas, a list of stocks which are primed to do well, according to its sales desk and analyst. One of its picks caught our eye—Dewan Housing Finance (DHFL). This is one of the companies which had been in the news for all the wrong reasons. According to the report, DHFL was accused of rigging of its share price at the time of the QIP offer. However, SEBI had reportedly investigated the company and given it a clean chit. This isn't surprising given how ineffectual SEBI has been in apprehending and punishing corporate wrong-doers.

The reason ESS has given this company a buy based on ‘facts’ is that its valuation is really low (according to the report, the stock is trading at 1x FY14 estimated price/book ratio).

Other “conviction ideas” includes Oriental Bank of Commerce and Shriram Transport Finance.

Another section of ESS report caught our attention was the IPO snapshot. A lot of investors are interested in raking in big bucks by investing in the primary market. But not all companies do well either because their pricing is totally out of whack with reality and works against investors. We noticed that in the ESS list, all the companies that were listed last year have given negative returns so far. Moreover, out of the 34 companies that were listed since 2010, according to the report, as many as 22 companies have given negative returns. Poor post-IPO returns shows how greedy the promoters have been egged on by investment bankers.


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