Unfortunate experiences from the past decades has compelled the
Securities and Exchange Board of India (SEBI) to adopt the
"foot in the game" approach while regulating the Indian
capital markets. This approach requires promoters, persons in
control and comparable persons to hold a minimum number of
securities/ units in an entity for a certain period of time post
listing. For instance, a company proposing an initial public
offering of equity shares is required to lock-in the promoter
holding, of atleast 20% of the equity shares for a period of three
years and the residual holding for a period of one year. Similarly,
the SEBI (Real Estate Investment Trusts) Regulations, 2014 (REIT
Regulations) require the sponsor and sponsor group, collectively,
to hold a minimum 25% of the REIT units, post the initial public
offer for a period of three years, along with other lock-in
requirements. While the sponsor and the sponsor group, as a
concept, are not comparable to promoters of a
