An Unspoken Reality of Corporate Greenwashing in India’s ESG Sphere

Paper Details 

Paper Code: RP-VBCL-27-2025

Category: Research Paper

Date of Publication: April 20, 2025

Citation: Dr. Priya A Jagadish & Ryle James Ammagol, “An Unspoken Reality of Corporate Greenwashing in India’s ESG Sphere", 2, AIJVBCL, 381, 381-393 (2025).

Author Details: Dr. Priya A Jagadish, Assistant Professor, Jss Law College (Autonomous), Mysuru

Ryle James Ammagol, 1st year LL.M, JSS Law College (Autonomous), Mysuru.

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 ABSTRACT

The growing environmental consciousness and global call for sustainability have led to increased regulatory oversight by national and international authorities, with companies now coming under the microscope regarding their sustainability claims. Greenwashing is astrategy often used by companies to attract consumers and investors who seek to support environmentally sustainable products and services. It refers to the practice of making bold, unsubstantiated, or misleading claims regarding the sustainability or environment- friendliness of their business practices and products or services, thus deceiving investors and consumers to increase their market share and gaining an edge over their competitors. It may even take the form of ‘cherry-picking’ certaineco-friendly- aspects of the product while suppressing data regarding the other aspects of the product which are not eco-friendly. This practice of greenwashinghas impacted CSR and ESG reporting bymisrepresenting the truth of the environmental initiatives of the company, making false disclosures or withholding unfavourable data while making the relevant disclosures under the ESG framework. In India, corporate greenwashing is not regulated by any single piece of legislation, rather it is indirectlyaddressed by a regime of many laws including the Consumer Protection Act,2019, the CCPA Guidelines, the Advertising Standards Council of India (ASCI) Guidelines, the BIS Certifications,SEBI’s Business Responsibility and Sustainability Reporting (BRSR) and Business Sustainability Responsibility (BSR) Core framework, apart from the provisions for CSR in the Companies Act,2013. Greenwashing results in the deception of bonafide investors and consumers, adversely affects the reputation and goodwill of the company, and also impedes genuine conservation and sustainability efforts, thus eroding the pillars of transparency, accountability, and good governance, which are the basic foundations of the ESG and CSRinitiatives.The authors attempt to analyse the extent and the loopholes of the laws that regulate corporate greenwashing in India.

Keywords: Sustainability, Environment Social Governance (ESG), CSR, Greenwashing, SEBI

INTRODUCTION

In an era marked by major environmental protection and sustainability concerns, the UN’s 2030 Agenda for Sustainable Developmenthas placed the onus on various stakeholders, explicitly calling on businesses “to apply their creativity and innovation to solving sustainable development challenges and meet societies’ most pressing problems”.[1]

Over the past years, there has been a growing trend of ‘green business’, wherein traditional business practices are being substituted for more sustainable practices, driven by increasing awareness of environmental issues, social inequalities, and corporate governance failures at the global level.[2]Green – marketing evolved as a strategic business policy of organisations to market their products as ‘eco-friendly’ and environment safe.

Green marketing, also alternatively known as environmental marketing and sustainable marketing, refers to an organization's efforts at designing, promoting, pricing and distributing products that will not harm the environment.[3]

According to Peattie (2001), the evolution of green marketing has three phases, firstly beginning with the ‘ecological’ green marketing, and wherein all marketing activities were concerned with alleviating environmental problems, secondly, with "Environmental" green marketing, the focus shifted to clean technology addressing pollution and waste issues by  designing innovative new products, and lastly, the third phase saw "Sustainable" green marketing, emerging in the late 1990s to the early 2000s.[4]

With the rise of CSR Reporting and increasing environmental disasters like the Chernobyl nuclear power-plant disaster (1986) and the Bhopal Gas Tragedy (1984), companies worldwide began adopting such green- marketing strategies to regain their reputation and attract consumers who began to grow more environmentally conscious.

While certain genuine green-marketing initiatives may be lauded, such as the lead-free paints from Kansai Nerolac[5]there is a tendency for companies to adopt misleading or false practices under the pretense of attracting more consumers, and this leads to the phenomenon of ‘greenwashing.’

In the evolving Indian CSR and ESG regulatory sphere, many companies have resorted to greenwashing practices, to the adverse effect of the investors, consumers, regulatoryauthorities and the other stakeholders. This Article attempts to analyse the meaning of corporate greenwashing and its impact on the ESG framework in India.

UNDERSTANDING CORPORATE GREENWASHING

The term ‘greenwashing’ was coined by environmentalist Jay Westerveld (1986), and it refers to a scenario, where companies create a misleading impression of their environmental efforts,typically by exaggerating or misrepresenting the company’s commitment to sustainability, thus threatening consumer trust and the global push for sustainability.[6]

As defined by the Advertising Standards Council of India (ASCI)’s Guidelines for Advertisements Making Environmental/Green Claims 2024, greenwashing, inspired by the term ‘whitewashing’, is the practice of engaging in “unsubstantiated, false, deceptive, misleading environmental claims about products, services, processes, brands or operations as a whole, or claims that omit or hide information, to give the impression that they are less harmful or more beneficial to the environment than they actually are”.

McDonald’s paper straws that turned out to be non-recyclable[7], Coca-Cola Life’s Green label claiming it has lower calories but had 6.6% sugar[8], Starbucks’ straw-less lid (2018),[9]that had more plastic than the previous lid and straw combination, and Windex’s claim of that its bottles were made from 100%ocean plastic are a few examples of greenwashing.

In India, HUL falsely claimed in its advertisement that its Surf Excel Easy Wash detergentwas ‘100% natural’ and ‘environment-friendly’, but in reality, it contained synthetic ingredients. Similarly, Voltas Limited, was accused of making false claims that its ACs were eco-friendly and had a ‘5-star energy rating’, but in reality, they had a lower energy rating. Voltas was fined Rs. 50,000 by the ASCI. Even Godrej Consumer Products Limited was accused of making false claims that its soap was ‘100% natural’, ‘biodegradable’, and ‘eco-friendly’, but in reality, it contained synthetic ingredients and they fined Rs. 15 lakhs by the ASCI.

Such greenwashing practices undoubtedly undermine conservation efforts in the business sphere by providing false disclosures in the CSR and ESG initiatives, thus misleading stakeholders.

IMPACT OF CORPORATE GREENWASHING IN THE CONTEXT OF ESG AND CSR REPORTING

ESG, short for Environmental, Social, and Governance, is a comprehensive framework for evaluating corporate performance across environmental, social, and governance factors and can help measure the impact of the company’s sustainability objectives.

While S.135 of the Companies Act 2013and the Companies (Corporate Social Responsibility Policy) Rules, 2014, require compliance with corporate social responsibility provisions, ESG reporting can be said to provide a more holistic view of a company’s non-financial performance to investors and other stakeholders.

Corporate Social Responsibility mandates companies meeting specified thresholds of turnover of ₹1,000 crore or more, or net worth of ₹500 crore, or net profit of ₹5 crore, to spend at least 2% of their average net profits on CSR activities, as per Section 135 of the Act, including environmental sustainability projects.

CSR and ESG are thus closely interlinkedand these mandates have led companies to consider their social and governance responsibilities more seriously. Particularly since internationalstakeholders expect companies to orient themselves to social and environmentally sustainable goals apart from regular profit-oriented plans and policies.[10]

In this regard, there are many success stories in how ESG reporting has addressed various sustainability issues, for example, Infosys has achieved certified true zero waste for some of its campuses in 2024[11]

On the other hand, greenwashing fits the logic of opportunistic business by taking advantage of a short- term business opportunity for a focus on quick financial gain rather than making strategic long-term investments[12] , and thus many companies engage in this practice.

While greenwashing offers advantages such as a competitive edge, and brand reputation, it also has disadvantages, such as misleading consumers, harm to the environment, missed opportunity for sustainable development, and legal repercussions[13], although any gains made are fraudulent and short-lived.

Further, greenwashing also harms stakeholder perceptions[14] , negatively influenceconsumers and investors who are misled into investing in the company, and thus can ultimately result in brand dilution, loss of goodwill, reputation, and financial losses. For instance, the Volkswagen controversy in 2015[15] revealed that the corporation had inserted a software in its cars to evade emission tests, adversely affecting its business’s reputation.

Genuine CSR efforts require transparency, accountability, and a commitment to continuous improvement[16]  and thus, it can be seen that greenwashing undermines not just the CSR initiatives, but all three dimensions of ESG- the Environment, the Society through the consumers and investors, and affects the pillar of good governance as well.

INDIAN LEGAL FRAMEWORK TO REGULATE CORPORATE GREENWASHING 

India’s regulatory landscape to address corporate greenwashing lacked any specific provisions until the CCPA Guidelines for Greenwashing and the ASCI Guidelines for Advertisements Making Environmental/Green Claims. Before these guidelines, it was broadly regulated under the false and misleading advertisement provisions of the Consumer Protection Act, 2019, The Bureau of Indian Standards (BIS)’ Certifications for standards of environmentally safe products, the Magic Remedies (Objectionable Advertisement) 1954 Act, the Food Safety and Standards Act, 2006 and the Drugs and Cosmetics Rules 1945.

The Companies are also regulated by the Corporate Social Responsibility (CSR) reporting provisions under the Companies Act, 2019, and the Business Responsibility and Sustainability Reporting (BRSR) for reporting ESG as mandated by SEBI for the top 1000 listed entities.

a.       Regulation of Misleading Advertisements that Lead toGreenwashing: Role of the CCPA and ASCI

The Consumer Protection Act, 2019 prohibits the making of misleading advertisements by a manufacturer or service provider. It is defined in S.2(28) to mean those advertisements that misrepresent or omit important facts, leading consumers to make decisions based on incorrect or incomplete information, and can also constitute unfair trade practice[17]making it a punishable offence.[18] However, it lacked any specific provision for false environmental claims or greenwashing.

Consequently, the Central Consumer Protection Authority (CCPA) issued the‘Guidelines for Prevention and Regulation of Greenwashing or Misleading Environmental Claims’ (“Guidelines”),on October 15, seeking to foster practices whereenvironmental claims are truthful and meaningful, thus enhancing consumer trust and encouraging sustainable business practices.[19]

It has defined greenwashing in section 2(f) as a deceptive or misleading practice whichincludes concealing, omitting, or hiding relevant information, by exaggerating, making vague, false, or unsubstantiated environmental claims. It also includes the use of misleading words, imagery, and symbols that emphasises the positive environmental impacts but downplays or conceals the harmful attributes.

It applies to manufacturers, service providers, advertisers, and endorsers who make all ‘environmental claims’ which means representationsof the environmentally friendly attributes of their products or services, including manufacturing process and disposal methods.[20] Section 4 of the Guidelines strictly prohibits greenwashing and engaging in misleading environmental claims.

The other provisions of the CCPA’s Guidelines are also similarly reflected and reinforced by the Advertising Standards Council of India (ASCI)’s Guidelines for Advertisements Making Environmental/Green Claims (“ASCI Guidelines” effective February 2024), to prevent greenwashing in advertising, as it violates Chapter I of the ASCI Code on misleading advertisements.

Role of ASCI

As per ASCI’s Guidelines for Advertisements Making Environmental/Green Claims, merely using terms like ‘environment friendly’, ‘eco-friendly’, ‘sustainable’, etc is not allowed, and rather, absolute and specific claims limited to the actual part of the product or service that has the environmental benefit should be made.

The actual limits of the claim are to be specified if the benefit is not for the entire life cycle of the product or service.Any future promises of being green cannot be made unless there are some specific plans to achieve those claims.

It also provides guidelines for claims of compostable, biodegradable, and recyclable products, guidelines for carbon offset claims, and also, guidelines for the use of visual elements like

recyclable logos and colour schemes on the packaging, etc., so as to not mislead the consumers.

Further, it also requires that all seals and certifications must be from accredited organizations, for example the BIS Certifications. Any such grant of certificationfrom a third-party must specify the aspects of the product/service evaluated.

In India, the Ecomark certification is used to label products that meet the prescribed environmental standards and help consumers identify genuine eco-friendly products.In pursuit of these guidelines, the ASCI has issued a notice against Ekam Eco Solutions Pvt. Ltd– for the Zerodar CARE Natural Hand Wash Liquid, which is claimed to be eco- friendly[21].

Another instance of greenwashing was by Godrej Industries’ who claimed that its Good Knight Fast Card mosquito repellent was “100% natural” and “chemical-free (2012). They were fined Rs. 5 lakh by the Advertising Standards Council of India (ASCI) for making false and misleading claims.

b.      Regulation of Corporate Greenwashing: Role of SEBI, RBI and MCA

The Security Exchange Board of India (SEBI) has taken steps to avoid corporate greenwashing by issuing a Circular [22]for green debt securities, which are issued to raise funds that are to be used for projects or assets falling under categories such as renewable and sustainable energy, clean transportation, sustainable water management, climate change adaptation, energy efficiency, sustainable waste management, sustainable land use, biodiversity conservation, or other categories notified by SEBI[23].It has also released another circular[24]to regulate the issue of green debt securities.

Para 4 (i) of the SEBI Guidelines Circular[25] provides that issuers of such green debt securities are to monitor and assess the measures taken for sustainable operations and reduction of adverse impact on the environment as envisaged in the offer document issued at the time of raising funds.

Similar to the ASCI Guidelines and the CCPA Guidelines, the issuers are also not allowed to omit any unfavourable data while highlighting other green practices, use any misleading labels,[26] or give a false impression of certification by a third-party entity.[27]

SEBI has also issued the Revised Disclosure Requirements for Issuance and Listing of Green Debt Securities[28] which provides for independent third-party reviewer to evaluate and certify the project, process and issue.

Similarly, even the RBI has issued a circular[29] for acceptance of green deposits from customers to finance projects with certain environmental objectives, to protect the interest of the depositors, address greenwashing concerns, and help augment the flow of credit to green activities and projects.[30]

Further, if any company violates the provisions of the Environmental Protection Act 1986, it can be penalised.[31]

Apart from the advertisement of Green Debt Securities, SEBI has given major impetus to reporting disclosures of the Environmental initiatives taken by certain companies in the form of ESG Reporting.

Initially for FY 2022-23, the top 1000 listed companies were required to file the Business Responsibility and Sustainability Report (BRSR), as a part of their annual reports, disclosing their performance across all three factors - Environment, Social, and Governance (ESG)on 9 Key Performance Indicators, which included Greenhouse Gas (GHG) Footprint, Water Footprint, Energy Footprint and waste management details, focusing on both quantitative data and qualitative disclosures.

The MCA has also issued National Guidelines on Responsible Business Conduct (NGRBC) to encourage companies to align their strategies with sustainable development goals and incorporate ESG considerations into decision-making.[32]

In 2024, SEBI has also issued the BRSR Core[33]which is a sub-set of the BRSR, calling for more detailed disclosures in its updated format, such as the level of treatment of wastewater, energy consumption from renewable sources, etc in the Annexure to the Circular.

It is applicable to thetop 250 listed companies by market capitalization in FY 2024–25 and to the top 1,000 listed companies by market capitalization by FY 2026–27.

The Corporate Governance codes such as SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, issued by the MCA also indirectly influence ESG adoption by emphasizing Board composition, transparency, and ethical conduct. These aspects are closely linked to governance and vital to ESG.

By mandating disclosure under the above regulatory frameworks, it ushers in the age of  transparency and accountability in corporate behaviour in India, thus curtailing the practice of corporate greenwashing to a certain extent.However, the various gaps in the existing ESGand other legal regulations prove to be inadequate in addressing this issue completely.

Analysing the Gaps: Is the Current legal frameworksufficient to curb corporate greenwashing?

The efforts in India have resulted largely due to the global push for increased and standardized disclosures in the form of the existing CSR initiatives and now ESG reporting, along the international principles of the Sustainable Development Goals (SDGs) and the UN Principles for Responsible Investment (PRI), the growing demand for transparency and accountability of corporate performance and governance practices, and is also largely brought about by the necessity to live up to the expectations of international investors.[34]

While India has introduced several regulatory measures to promote transparency and curb greenwashing, there are still significant gaps in enforcement.

The Consumer Protection Actprovides an avenue for affected consumers to seek redress in cases of misleading and deceptive advertisements,and the CCPA Guidelines have taken the right step in defining and prohibiting greenwashing, its strict enforcement is yet to be seen. The ASCI Guidelines focus purely on the advertising and marketing aspect of greenwashing, but these frameworks do not fully address greenwashing in corporate reporting, investor communication or other areas of business.In other words, the former is limited in operation to the protection of consumers while the latter is limited to the scope of advertisements only.

Further, while the BIS certifications are helpful, they are not compulsorily followed by allmanufacturers and many companies can get away with greenwashing their products and services.

The SEBI (2021) circular on Business Responsibility Reporting (BRSR) was initially made voluntary in FY 21-22, however seeing the very low response, it had made it mandatory from FY 22-23. While its updated BSR Core framework for ESG reportingis a positive stepmandating comprehensive and detailed disclosures,it still lacks the necessary teeth to prohibit greenwashing altogether, as the reporting framework only covers company-specific data, and as such, companies operating in several different sectors may have the opportunity to green-wash by hiding their polluting activities through the activities of their non-polluting sectors.

The BRSR framework does not require third party verification of ESG disclosures so as to ensure their completeness and enhance their credibility[35], and so far, SEBI has only made it compulsory in regard to the issuance of Green Debt Securities. This can lead to selective disclosures, and even the collection of accurate, updated and timely data remains a problem.

Moreover, it only applies to the top 1000 listed entities, and the greenwashing practices of smaller or non-listed entities are left out of scrutiny of the ESG requirements. They are only regulated by other laws that are not comprehensive enough to address the issue.

FINDINGS

Prohibition of Greenwashing by companies is not directly regulated by any law except for the new CCPA Guidelines which is more consumer protection–oriented.  The ASCI guidelines regulate the misleading advertisements and SEBI regulated issue of green debt securities. The ESG disclosure under the new BSR core framework has made positive steps in calling for highly detailed disclosures, yet there is no specific prohibition to avoid greenwashing in the existing ESG reporting regime. There is absence of clear established guidelines for ‘environmental claims’ and mandatory third party verification for ESG reported disclosures, although SEBI has made it compulsory for issuers of green debt security with regard to their process and operations.

SUGGESTIONS

SEBIcan introduce ESG reporting for all publicly traded companiesand encourage smaller companies to embrace ESG practices. Introducing mandatory third-party certification for all disclosures under the BSRS framework along with adducing proper evidencecan also enhance transparency and accountability. Thus, there is an immediate need for a robust legal framework to ensure that companies do not engage in greenwashing tactics and that they are held accountable with proper enforcement and penalties. Public, investor, and consumer awareness is the need of the hour, as they can influence companies to be more accountable until efficient and stringent laws regulating greenwashing come into place.

CONCLUSION

The ESG and CSR framework have made significant contributions in making companies more sustainable and ‘green’, yet India is still in its nascent stage when it comes to regulating greenwashing, as such many smaller listed and unlisted companies evade the law and practice greenwashing to the detriment of their stakeholders, going against the philosophy of the ESG and CSR framework. The pillars of transparency, integrity and accountability are eroded, and companies in the name of sustainability and ethical green-marketing end up eventually causing more harm than good to the environment. Hence, India must move beyond such fake practices and must genuinely commit to national and global efforts for corporate and business sustainability.

*Assistant Professor, Jss Law College (Autonomous), Mysuru.

**1st year LL.M, JSS Law College (Autonomous), Mysuru.

[1] Chantal Line Carpentier and Hannah Braun,‘Agenda 2030 for Sustainable Development: A Powerful Global Framework’ (2020) 1(1) Journal of the International Council for Small Business 14 https://doi.org/10.1080/26437015.2020.1714356 accessed 08 February 2024

[2]Martina Linnenluecke,‘Environmental, Social and Governance (ESG) Performance in

the Context of Multinational Business Research’(2022) Multinational Business Review

https://www.researchgate.net/publication/357698081_Environmental_Social_and_Governance_ESG_Performance_in_the_Context_of_Multinational_Business_Research accessed 08 February 2024

[3]Shubha Ranjan Dutta,‘Green Marketing in India: Emerging Opportunities and Challenges’(2024) 6(2) International Journal for Multidisciplinary Research

[4]Ibid

[5]Mayank Bhatia and Amit Jain,‘Green Marketing: A Study of Consumer Perception and Preferences in India’(2013)https://ssrn.com/abstract=5064069 accessed 08 February 2024

[6]Shilpa Ajay, H. Lakshmi, and HK. Keerthi, ‘From Greenwashing to Green Branding: Navigating the Thin Line’ (2024) 11(3) Shanlax International Journal of Arts, Science and Humanities 121https://doi.org/10.34293/sijash.v11iS3-Feb.7253 accessed 07 February 2024

[7]Sarah Arnold, ‘Of course McDonald's paper straws can't be recycled – it's yet another corporate green wash’ (independent.co.uk 6 August 2019) https://www.independent.co.uk/voices/mcdonalds-plastic-straws-recycling-carbon-footprint-green-washing-waste-starbucks-a9041871.htmlaccessed 07 February 2024

[8]Rachel Arthur, ‘Coca-Cola Life axed in the UK’ (beveragedaily.com, 06 April 2017)https://www.beveragedaily.com/Article/2017/04/07/Coca-Cola-Life-axed-in-the-UKaccessed 07 February 2024

[9]Disha Jain,Macherla Bhagyalakshmi, and Narasimha Murthy ‘The Art of Camouflaging: Unravelling the Motives and Consequences of Greenwashing’(2024) 11(3) Shanlax International Journal of Arts, Science and Humanities https://doi.org/10.34293/sijash.v11iS3-Feb.7260 accessed 07February 2024.

[10] Vidhi Agrawal, “From Tradition to Transformation: ESG Initiatives in Indian Corporate Landscape’(2023) ICSI Chartered Secretary Journal 81 https://www.icsi.edu/media/webmodules/CSJ/October/12.pdf accessed 06 February 2024

[11]Infosys,‘ESG Report 23-24’https://www.infosys.com/sustainability/documents/esg-2023-24/environment.pdfaccessed 09 February 2024

[12]Priyanka Aggarwal and Aditi Kadyan,‘Greenwashing: The Darker Side of CSR’ (2011)4(3)Indian Journal of Applied Research  61

[13]Jain (n 10).

[14]UdayKirankommuriand Thangaraja Arumugam, ‘Greenwashing Unveiled: How it Impacts Stakeholder Perception as Well as Sustainability Realities’ (2024) 11(3) Shanlax International Journal of Arts, Science and Humanities https://api.semanticscholar.org/CorpusID:268433125accessed 8 February 2024

[15]Russell Hotten, ‘Volkswagen: The Scandal Explained’(bbc.com, 10 December 2015)https://www.bbc.com/news/business-34324772accessed 09 February 2024

[16]HK. Keerthi, H. Lakshmi, Shilpa Ajay, and Sendhil Kumar Manoharan,‘Greenwashing’s Influence on Corporate Performance and Strategies for Regulation and Oversight’ (2024) 11(3) Shanlax International Journal of Arts, Science and Humanities https://doi.org/10.34293/sijash.v11iS3-Feb.7249

[17] Section 2(47) of The Consumer Protection Act, 2019

[18] Section 89 ofThe Consumer Protection Act, 2019

[19] Ministry of Consumer Affairs, Food & Public Distribution, ‘Central Consumer Protection Authority Issues Guidelines for ‘Prevention and Regulation of Greenwashing and Misleading Environmental Claims’ (2024)https://pib.gov.in/PressReleasePage.aspx?PRID=2064963#:~:text=%E2%80%9CGreenwashing%E2%80%9D%20is%20a%20term%20that,%2C%E2%80%9D%20or%20%E2%80%9Cgreen.%E2%80%9Daccessed 07 February 2024

[20] Section 2(e) of the Guidelines for Prevention and Regulation of Greenwashing or Misleading Environmental Claims

[21]https://www.ascionline.in/complaint-outcomes-details/?case_id=2024-3-28-6-C.29006accessed 07 February 2024

[22]Issue of Green Debt Securities by an issuer under Securities and Exchange Board of India (Issue and Listing of Municipal Debt Securities) Regulations, 2015 (Circular No.: SEBI/HO/DDHS/DDHS_Div1/P/CIR/2022/158 dated November 24 2022)

https://www.sebi.gov.in/legal/circulars/nov-2022/issue-of-green-debt-securities-by-an-issuer-under-securities-and-exchange-board-of-india-issue-and-listing-of-municipal-debt-securities-regulations-2015_65404.htmlaccessed 09 February 2024

[23] Regulation 2(1)(q) of the SEBI (Issue and Listing of Non-Convertible Securities) Regulations, 2021

[24]Dos And Don’ts Relating to Green Debt Securities to Avoid Occurrences Of Greenwashing (Circular No.: SEBI/HO/DDHS/DDHS-RACPOD1/P/CIR/2023/020 dated 3 February 2023)https://www.sebi.gov.in/legal/circulars/feb-2023/dos-and-don-ts-relating-to-green-debt-securities-to-avoid-occurrences-of-greenwashing_67828.htmlaccessed 09 February 2024

[25] ibid

[26] Para 4(iv) of the SEBI Guidelines.

[27] Para 4(vii)

[28]Revised Disclosure Requirements for Issuance and Listing of Green Debt Securities

https://www.sebi.gov.in/legal/circulars/feb-2023/revised-disclosure-requirements-for-issuance-and-listing-of-green-debt-securities_67837.htmlaccessed on 06 February 2024

[29]RBI Framework for Acceptance of Green Deposits(April 11 2023)https://rbi.org.in/Scripts/NotificationUser.aspx?Id=12487&Mode=0accessed on 08 February 2024

[30] Para A of the RBI Guidance.

[31] Section 15 and16 Environmental Protection Act 1986

[32]Ministry of Corporate Affairs, ‘National Guidelines on Responsible Business Conduct’ https://www.mca.gov.in/Ministry/pdf/NationalGuildeline_15032019.pdf

[33] Circular No. SEBI/HO/CFD/CFD-SEC-2/P/CIR/2023/122 dated July 12, 2023. https://www.sebi.gov.in/web/?file=https://www.sebi.gov.in/sebi_data/attachdocs/jul-2023/1689166456465.pdf#page=1&zoom=page-width,-35,259

[34] Agrawal (n 14).

[35]V Rishi Kumar, ‘ESG: A pragmatic recipe for India Inc.’ (hindubusinessline.com, 18 September 2022) https://www.thehindubusinessline.com/specials/clean-tech/esg-a-pragmatic-recipe-for-india-inc/article65840750.eceaccessed 09 February 2024