Subscribe to UndercurrentS

Message us securely on Signal

_{Originally published in The Wire on August 20, 2025. By Anand Mangnale. https://thewire.in/business/adani-us-indictment-lobbying-campaign}

On November 20, 2024, the US Department of Justice (DOJ) unsealed an indictment against the Adani Group, charging its chairman Gautam Adani, his nephew Sagar Adani and other senior executives with orchestrating a “massive bribery scheme” to win energy contracts in India. This event changed the dynamics of the Adani Group’s newly initiated lobbying efforts in the US. From a modest commercial lobbying exercise, it turned into a targeted lobbying effort with two of most renowned legal and lobbying firms brought on board for what appears to have been a crisis management campaign.

An analysis of federal lobbying disclosures from 2023 to 2025 reveals a distinct three- phase strategy, providing a timeline of Adani’s response to escalating US legal and regulatory pressure. This data has been made available by OpenSecrets, a US-based research group tracking money in US politics and its effect on elections and public policy.

The Adani Group has called the charges in the DOJ indictment “baseless” and denied them. The group said in a press statement on November 21 that it has always upheld and is steadfastly committed to “maintaining the highest standards of governance, transparency and regulatory compliance across all jurisdictions of its operations.”

Phase 1, 2023: The beginning, modest commercial lobbying

Throughout 2023, the Adani Group’s lobbying footprint in Washington D.C. was minimal and focused on business objectives.

The total lobbying expenditure for the year was only $40,000. This effort was run entirely in-house by its subsidiary, Adani Solar USA, with a single registered lobbyist, Anurag Varma.

The group’s stated aim was to engage with a range of government bodies, including the Department of Commerce, Department of State, Export-Import Bank of the US, National Security Council and the Overseas Private Investment Corporation. The focus, then, was on commercial interests related to the company’s solar business and general trade issues.

The main player managing this was Varma, who has extensive experience in lobbying in the US. He has been hired by Indian and Indian-American players – including the Indian government – wanting to advocate for their causes in Washington since the 1990s.

Phase 2, late 2024: The indictment and immediate reaction

The unsealing of the DOJ indictment in November 2024 triggered an immediate strategic shift in Adani’s approach to Washington.

In a rapid response to the indictment, the very next day, on November 21, 2024, Adani hired a major law and lobbying firm, Akin Gump Strauss Hauer & Feld. While the firm’s official registration cited lobbying on “Issues related to the supply chain”, the timing, immediately following the indictment, made it clear that it was likely a response to the legal crisis the company was facing.

With the hiring of Akin Gump Strauss Hauer & Feld, Adani’s lobbying team expanded to five individuals, four of whom were “revolving door” profiles, meaning people with extensive prior government insider experience. Notably, the team included former Member of Congress Ileana Ros-Lehtinen. The group’s total lobbying spending for 2024 nearly doubled, going up to $70,000, with an additional $20,000 paid to Akin Gump. Also, its list of lobbying targets grew to include the White House.

This marked an escalation from commercial advocacy to the quest for high-level political influence.

Phase 3, 2025: The crisis campaign involving high-profile law firms

The first half of 2025, according to the group’s filings, saw Adani’s crisis-response apparatus grow, with a massive surge in spending and the hiring of elite legal defence firms, Kirkland & Ellis LLP and Quinn Emanuel Urquhart & Sullivan, LLP.

Lobbying expenditures exploded to $150,000 in just the first six months of 2025, more than doubling the spending of the entire previous year. The number of lobbyists engaged went up to eight.

Source: Data made available by OpenSecrets

This hints towards a shift to legal defence. The focus of the lobbying effort moved directly to Adani Green Energy, the subsidiary at the heart of the bribery allegations. On January 20, 2025, Adani Green Energy retained two of the US’s most powerful law firms for white- collar defence: Kirkland & Ellis and Quinn Emanuel Urquhart & Sullivan. The registration forms for both firms were direct, stating they were hired to lobby on “Green energy issues and related criminal and civil matters.”

This explicitly connects their work to the DOJ case in the Eastern District of New York, and marks the final shift from commercial promotion to legal defence and high-level lobbying. The new lobbying team included top-tier legal talent such as William Burck, a former deputy counsel to the US president and now a lobbyist at Quinn Emanuel Urquhart & Sullivan.

The main target, with the new legal teams in place, is solely the Department of State. All the other government agencies it had said it was engaging with in previous years’ filings no longer found a place. Given the international nature of the bribery allegations and the

involvement of foreign officials, the State Department is a critical agency for the company to engage with as it navigates its defence in the US criminal case.

Quinn Emanuel Urquhart & Sullivan’s and Kirkland’s lobbying, according to their filings, covers Energy/Nuclear, lobbying related to Law Enforcement/Courts/Judges/Crimes/Prisons and Civil Rights and Civil Liberties with the State Department for the Adani Group. The move from multi-agency efforts to just the State Department suggests that the main target of the efforts is the indictment.

Lobbying activities

_{Source: Data and filings made available by OpenSecrets}

The federal lobbying records illustrate a clear and reactive strategy. The Adani Group’s engagement in Washington transformed from a low-level commercial effort into a high profile legal and lobbying operation in a direct response to the US criminal investigation.

The timeline and expenditure increase, hiring of elite law firms specialising in government connections including one with a former “Deputy Counsel to the President, Special Counsel to the President, Deputy Staff Secretary” as the main lobbyist, along with the explicitly stated purpose of lobbying on “criminal matters” all point to a concerted campaign to manage the legal and reputational fallout from the DOJ indictment.

Subscribe to UndercurrentS

Message us securely on Signal

Share on WhatsApp

Subscribe to UndercurrentS

Message us securely on Signal

_{Coal mining production in Dhanbad, India. (Banner: Hari Mahidhar/Alamy Stock Photo)}

_{Originally published in OCCRP on May 22, 2024. By Anand Mangnale (OCCRP), with additional reporting by the Financial Times, Ravi Nair, Prajwal Bhat and NBR Arcadio. https://www.occrp.org/en/investigation/new-evidence-bolsters-allegations-adani-group-overcharged-for-coal}

On January 9, 2014, the bulk carrier MV Kalliopi L docked at Ennore port in Chennai, the southern Indian city in Tamil Nadu, after a two-week voyage from Indonesia. It carried 69,925 metric tons of coal destined for the state’s power company.

However, the paperwork for the cargo took a more circuitous route, passing though the British Virgin Islands and Singapore.

During this journey, the price of the coal more than tripled to US$91.91 per metric ton. The quality also inexplicably changed from low-grade steam coal to the clean, high-quality version sought by power companies.

MV Kalliopi L’s profitable trip was not an isolated event. Documents obtained by OCCRP and shared with the Financial Times reveal that at least 24 other shipments that landed on the Tamil Nadu coast between January and October 2014 were originally priced as low- quality coal but ultimately sold by India’s Adani Group to the state’s power company for triple the cost.

The evidence comes from multiple sources, including invoices and banking documents from several jurisdictions, details of investigations by India’s Directorate of Revenue Intelligence (DRI), leaked documents from a key Indonesian coal supplier for Adani, and a trove of documents obtained from the Indian state-owned power company TANGEDCO (Tamil Nadu Generation and Distribution Corporation).

While not definitive, the data adds strong new evidence to over-invoicing allegations against the politically powerful Adani Group, which is perceived as close to Prime Minister Narendra Modi and is India’s largest importer and private producer of coal.

The DRI, an agency under the Ministry of Finance, opened an investigation nearly a decade ago into whether Adani Group and other companies had used offshore intermediaries to inflate the price of coal supplied to utilities. But the probe was prevented from progressing in 2019 after Adani won a case in the High Court of Bombay that blocked the DRI from seeking details about shipments, including the types of invoices OCCRP has obtained, from abroad. The DRI then appealed to India’s Supreme Court, where the case has languished without progress.

Last year, opposition politicians called for a new investigation after the Financial Times reported that the Adani Group appeared to have paid over US$5 billion to middlemen for coal imported far in excess of market prices between 2021-2023.

The alleged overpricing would not only burden ordinary Indians with inflated fuel costs. Burning lower quality coal also produces more pollution, a scourge responsible for more than 1.6 million deaths in India in 2019, according to a recent study published in the Lancet.

_{Air pollution in Kolkata, India. (Credit: Indranil Aditya/NurPhoto/Alamy Stock Photo)}

“The implications are that you have overpaid for the fuel, the second implication is that you need to burn more coal for every unit of electricity you produce, which results in more fly ash, and more pollution,” said Tim Buckley, founder and director of Australia-based Climate Energy Finance, who is a leading authority on energy financing and its implications. “More pollution and more energy poverty for the poorest people in India.”

Arappor Iyakkam, a Tamil Nadu-based NGO that has been fighting for accountability in the alleged coal scam, estimates the state’s power company TANGEDCO overpaid Rs 6,000 crore (US$720 million at today’s exchange rate) for coal from all vendors between 2012- 2016, during which nearly half the value of its tenders were given to Adani, according to the organization. The NGO filed a complaint against TANGEDCO in 2018 with the state anti-corruption agency.

When asked about OCCRP’s findings, an Adani spokesperson denied the allegations as “false and baseless.”

“The suggestion that Adani Global Pte Ltd supplied to TANGEDCO inferior coal, as compared to the quality standards laid down in the tender and PO [purchase order], is incorrect,” the spokesperson wrote in an email. “While it is difficult for us to comment on individual cases due to the sheer volume of data and the elapsed time, not to add the contractual and legal obligations, it is important to note that the coal supplied, irrespective of the declaration by the supplier, is tested for quality at the receiving plant.”

The Adani spokesperson rejected Arappor Iyakkam’s analysis and any responsibility for India’s air pollution or losses incurred by state power companies.

“By no stretch of imagination can Adani Global Pte Ltd, with a total supply of less than 2% of the coal burnt by TANGEDCO in the relevant period, be held responsible for either air pollution or the losses of [power distribution companies].”

TANGEDCO did not respond to questions sent by OCCRP.

One Shipment, Multiple Invoices

The documents obtained by reporters track how both the price — and in the case of the MV Kalliopi L — the quality of the coal imported by Adani increased as it moved between companies.

Shortly after the vessel began its journey, the provincial office in the Indonesian port city of Banjarmasin issued a certificate of origin in January 2014 identifying the Indonesia mining group Jhonlin as the consignor and TANGEDCO as the consignee of the coal onboard.

The certificate did not mention the calorific value of the coal — which measures how much energy is produced when the coal is burned and is an indication of its quality. But leaked data from Jhonlin listed the price for this shipment at US$28 per metric ton, which corresponds to the market value of the low-end coal Jhonlin was selling at the time.

Before reaching TANGEDCO, the paperwork for the shipment passed through a middleman: Supreme Union Investors Ltd, a company registered in the tax haven of the British Virgin Islands.

This company issued an invoice for the same shipment to Adani Global PTE Singapore — the group’s regional headquarters — that listed the unit price as US$33.75 per metric ton, and the quality as “below 3500” kilocalories per kilogram (kcal/kg), which is considered low grade.

But when Adani Global issued its invoice to TANGEDCO for the shipment a little over a month later, everything had changed. The unit price shot up dramatically to US$91.91 per metric ton and the coal was listed as having a calorific value of 6,000 kcal/kg, a high quality form relatively free of impurities.

Same coal, different prices

Documents show how the price and quality of the same shipment of coal increased as it changed hands.

A certificate of origin issued in Indonesia shows the coal was supplied by the Indonesia mining group Jhonlin. Leaked data from the miner listed the price as US$28 per metric ton.

A commercial invoice issued by Supreme Union Investors to Adani Global lists the price of the same shipment at US$33.75 per metric ton, and describes the quality as below 3,500 kcal/kg.

A commercial invoice from Adani to TANGEDCO shows Adani supplied the same coal to the state power company for the price of US$91.91 per metric ton, with the quality listed as 6,000 kcal/kg.

Reporters verified two dozen other coal deliveries from 2014 that follow the same pattern, with Adani earning large margins on every shipment.

According to the leaked Jhonlin data, the Indonesia miner initially supplied the shipments to Supreme Union Investors for an average price of US$28 per metric ton, a cost consistent with low-end bulk steam coal.

But records from TANGEDCO show these shipments were ultimately supplied by Adani under the contracted quality of 6,000-kcal/kg and the price of US$91 per metric ton of coal.

Though reporters were unable to obtain all original invoices, they were able to confirm the 24 shipments were the same in the export and import datasets by matching the ship, weight, and shipment dates.

Supreme Union Investors did not respond to requests to comment.

_{Barge loaded with piles of coal on the Mahakam River in East Kalimantan, Indonesia. (Credit: Pacific Imagica/Alamy Stock Photo)}

In a response to reporters, Adani’s spokesperson said the shipments were tested for quality at multiple points in the process.

“With the supplied coal having passed such an elaborate quality check process by multiple agencies at multiple points, clearly the allegation of supply of low-quality coal is not only baseless and unfair but completely absurd,” the spokesperson said.

Jhonlin did not respond to questions from OCCRP, but the miner is primarily known as a supplier of low and medium-grade steam coal, which is also supported by its own data. The dataset from Jhonlin that was leaked to OCCRP includes more than two million documents from between 2012 and 2022, including contracts, supply data, negotiations, emails, and other documents detailing the Indonesian company’s activities. Reporters could not find any example of Jhonlin providing coal with a calorific value above 4,200 kcal/kg — far below the higher quality 6,000-calorie coal which TANGEDCO ordered.

Adani’s spokesperson said that if the coal delivered had been found to be of a lower quality than what was stipulated in the contract, which allowed for a range of between 5,800 and 6,700 kcal/kg, the payment would have been reduced accordingly.

According to commercially available trade data, Financial Times journalists identified 22 of the 24 shipments and found the final payment price varied between US$87 and US$91 per metric ton, indicating that only small adjustments, if any, may have been made.

According to one Indian analyst, power generators in the country have “faced coal quality problems for decades.”

“Given the market power of coal suppliers, they often don’t have a choice but to accept grade slippage,” Rohit Chandra, assistant professor of public policy at IIT Delhi, told the Financial Times. “Third party testing has done very little to address these concerns.”

Justice Delayed

The data obtained by reporters reveals patterns similar to what the DRI described in a 2016 notice about an industry-wide case it had launched against several Adani Group companies and other firms for alleged manipulation of coal prices and calorific value.

_{Protesters took to the streets in Kolkata, India in 2023 following another Adani Group scandal, in which a U.S. short-seller accused the conglomerate of stock manipulation. (Credit: Sayantan Chakraborty/Pacific Press via ZUMA Press Wire/Alamy Stock Photo)}

The agency suspected that the coal was shipped directly from Indonesian ports to India, while the accompanying import invoices took convoluted paths. They were channeled through one or more intermediaries in global hubs such as Singapore, Hong Kong, Dubai, and the British Virgin Islands, before being issued to the buyer by Adani Global.

In the 2016 notice, the DRI wrote that “in a significant number of cases” two sets of test reports were discovered for consignments: “one showing lower gross calorific value (GVC) and the other higher GVC.”

But its effort to seek more information about shipments in other jurisdictions was thwarted by Adani in court.

At the request of the DRI, a Mumbai court had issued formal requests in 2017 to courts in Hong Kong, Switzerland, UAE, and Singapore, seeking help in accessing information held by Adani subsidiaries, including the details of several shipments, their associated invoices, and proof of payments.

However, Adani Group challenged the DRI’s requests to obtain its business records the following year. The Bombay High Court ruled in Adani’s favor, forcing the DRI to rescind the requests.

The DRI appealed the order to India’s Supreme Court and the case has moved at a glacial pace ever since, with Adani reportedly taking three years to file a counter affidavit to the DRI’s appeal. The next hearing is scheduled for August 6.

Additional reporting by the Financial Times, Ravi Nair (OCCRP), Prajwal Bhat (OCCRP), and NBR Arcadio.

Subscribe to UndercurrentS

Message us securely on Signal

Share on WhatsApp

Message us securely on Signal

_{Originally published in OCCRP on August 31, 2023. By Anand Mangnale, Ravi Nair and NBR Arcadio. https://www.occrp.org/en/investigation/documents-provide-fresh-insight-into-allegations-of-stock-manipulation-that-rocked-indias-powerful-adani-group}

Key Findings

Neither India’s stock market regulator nor a high-level expert committee has been able to prove what many suspect: that some foreign owners of publicly listed Adani Group stock are, in fact, fronts for its majority owners. Fresh allegations aired this January by American short sellers rocked the conglomerate, but offshore secrecy has made tracing the transactions difficult. Official investigators “hit a wall,” in the words of one report.

Now, new documents obtained by reporters reveal two men who spent years trading hundreds of millions of dollars’ worth of Adani Group stock: Nasser Ali Shaban Ahli and Chang Chung-Ling. Both have close ties to the Adani family, including appearing as directors and shareholders in affiliated companies. Records show that the investment funds they used to trade in Adani Group stock received instructions from a company controlled by a senior member of the Adani family.

It became one of the largest economic scandals in the history of modern India: The Adani Group, a massive conglomerate with interests in everything from airports to television stations, was accused of brazen stock manipulation.

The allegation, leveled this January by a New York-based short seller, caused Adani stock to plummet, triggered protests, and prompted an investigation by India’s Supreme Court.

But the expert committee convened by the court was unable to get to the bottom of the scandal, which has serious political implications because of the group’s widely perceived closeness to Prime Minister Narendra Modi and its central role in his plan for developing the country.

_{Credit: Enrique Shore/Alamy Live News Indian Prime Minister Narendra Modi speaks at the Bloomberg Global Business Forum 2019 at the Plaza hotel in New York City.}

The essence of the allegations was that some of the Adani Group’s key “public” investors were in fact Adani insiders, a possible violation of Indian securities law. But none of the agencies contacted by the committee were able to identify those investors, since they were hidden behind secretive offshore structures.

Now, exclusive documents obtained by OCCRP and shared with The Guardian and Financial Times — including files from multiple tax havens, bank records, and internal Adani Group emails — shed light on that very matter.

These documents, which have been corroborated by people with direct knowledge of the Adani Group’s business and public records from multiple countries, show how hundreds of millions of dollars were invested in publicly traded Adani stock through opaque investment funds based in the island nation of Mauritius.

In at least two cases — representing Adani stock holdings that at one point reached $430 million — the mysterious investors turn out to have widely reported ties to the group’s majority shareholders, the Adani family.

The two men, Nasser Ali Shaban Ahli and Chang Chung-Ling, have longtime business ties to the family and have also served as directors and shareholders in Adani Group companies and companies associated with one of the family’s senior members, Vinod Adani.

The documents show that, through the Mauritius funds, they spent years buying and selling Adani stock through offshore structures that obscured their involvement — and made considerable profits in the process. They also show that the management company in charge of their investments paid a Vinod Adani company to advise them in their investments.

The question of whether this arrangement is a violation of the law rests on whether Ahli and Chang should be considered to be acting on behalf of Adani “promoters,” a term used in India to refer to the majority owners of a business holding and its affiliated parties. If so, their stake in the Adani Group would mean that insiders altogether owned more than the 75 percent allowed by law.

“When the company buys its own shares above 75 percent … it’s not just illegal, but it’s share price manipulation,” says Arun Agarwal, an Indian market specialist and transparency advocate. “This way the company [creates] artificial scarcity, and thus increases its share value — and thus its own market capitalization.”

“This helps them gain an image that they are doing very well, which helps them get loans, take valuations of companies to a new high, and then float new companies,” he said.

In response to requests for comment for this story, a representative of the Adani Group noted that the Mauritius funds investigated by reporters had already been named in the “Hindenburg report,” referring to the short-seller that sparked this year’s scandal. (The report did name these offshore companies, but did not reveal who was using them to make investments in Adani stock.)

The Adani representative also cited the Supreme Court’s expert committee, which described a financial regulator’s efforts to get to the bottom of the matter as “not proved.”

“In light of these facts,these allegations are not only baseless and unsubstantiated but are rehashed from Hindenburg’s allegations,” the representative wrote. “Further, it is categorically stated that all the Adani Group’s publicly listed entities are in compliance with all applicable laws including the regulation relating to public share holdings.”

_{Credit: Ashish Vaishnav/SOPA Images via ZUMA Press Wire Chhatrapati Shivaji Maharaj International Airport in Mumbai lit up in the Indian tricolor flag to celebrate the country’s 75th year of independence.}

Ahli and Chang did not respond to OCCRP’s requests for comment.

In an interview with a reporter from the Guardian, Chang said he knew nothing about any secret purchases of Adani stock. He did not say whether he had bought any, but asked why journalists were not interested in his other investments. “We are a simple business,” he said, before ending the interview.

Vinod Adani did not respond to requests for comment. Though the Adani Group has denied that he has a role in running the conglomerate, it admitted this March that he was part of its “promoter group” — meaning he had control over the affairs of the company and was meant to be informed of all holdings in Adani Group stock. An Adani Group representative told reporters that Vinod Adani’s involvement had been “duly disclosed,” adding that he is a “foreign national … residing abroad for the last three decades,” and “does not hold any managerial position in any Adani listed entities or their subsidiaries.”

‘Brazen Stock Manipulation’

The Adani Group’s rise has been staggering, growing from under $8 billion in market capitalization in September 2013 — the year before Modi became prime minister — to $260 billion last year.

The conglomerate is active in a dizzying array of fields, including transportation and logistics, natural gas distribution, coal trade and production, power generation and transmission, road construction, data centers, and real estate.

_{Credit: Ashish Vaishnav/SOPA Images via ZUMA Press Wire Women walk past the Adani electricity logo on a wall in Mumbai.}

It has also won many of the state’s largest tenders, including 50-year contracts to operate or redevelop a number of India’s airports. Recently, it even took a controlling stake in one of the country’s last independent television stations.

But Adani’s rise has not been without controversy. Opposition politicians allege that the firm has received preferential treatment from the government to secure its lucrative state contracts. Analysts also describe its chairman, Gautam Adani, as benefiting from a cozy relationship with Modi. Adani has denied that Modi or his policies are responsible for his business empire’s success.

The conglomerate suffered a major setback at the end of January when the New York- based short seller, Hindenburg Research, issued its scathing report, claiming that the group had spent decades engaged in “brazen stock manipulation” and “accounting fraud.”

Gautam Adani, the headline read, was “pulling the largest con in corporate history.”

The central issue, the report claimed, was that the company was in violation of Indian securities law, which requires at least 25 percent of the stock of any publicly traded company to be available to the public for purchase.

Following the report’s publication, shares in the group’s companies plummeted. Gautam Adani lost more than $60 billion in just a few days, dropping from third-richest man in the world to 24th.

_{Credit: ZUMA Press, Inc./Alamy Live News Protestors call for accountability in Kolkata on March 13, 2023 after the Hindenburg report accused the Adani Group of stock manipulation.}

In response, the Adani Group issued denials and wrapped itself in the Indian flag. “This is not merely an unwarranted attack on any specific company,” the Group wrote in a note to stakeholders, “but a calculated attack on India, the independence, integrity, and quality of Indian institutions, and the growth story and ambition of India.”

Many investors appear to have bought this narrative, with shares of major Adani group companies recovering much of their losses.

Hitting a Wall

Meanwhile, in response to the Hindenburg report, India’s Supreme Court convened an expert committee to look into the allegations. The committee’s conclusions, published this May, revealed that the Adani Group had already been investigated by SEBI, the Indian financial regulator.

According to the committee, SEBI had suspected for years that “some of [the Adani Group’s] public shareholders are not truly public shareholders and they could be fronts for [Adani Group] promoters.” In 2020, it launched an investigation into 13 overseas entities holding Adani stock.

But the investigation “hit a wall,” the expert committee’s report reads, because SEBI investigators could not conclusively determine who was behind the money.

Attempting to do so would be a “journey without a destination,” the committee concluded, because multiple layers of opaque corporate ownership could be used to disguise the ultimate owners of the stock.

Documents obtained by reporters do, however, reveal the “destination” in two cases involving two of the 13 offshore entities: A pair of Mauritius-based investment funds.

From the outside these funds, called Emerging India Focus Fund (EIFF) and EM Resurgent Fund (EMRF), appear to be typical offshore investment vehicles, operated on behalf of a number of wealthy investors.

Documents obtained by reporters show that a large percentage of the money was placed into these funds by two foreign investors — Chang from Taiwan and Ahli from the United Arab Emirates — who used them to trade large amounts of shares in four Adani companies between 2013 and 2018.

At one point in March 2017, the value of the investments in Adani Group stock was $430 million.

The money followed a convoluted trail, making it exceedingly difficult to follow. It was channeled through four companies and a Bermuda-based investment fund called the Global Opportunities Fund (GOF).

The Four Companies

The four companies used in the investments were Lingo Investment Ltd (BVI), owned by Chang; Gulf Arij Trading FZE (UAE), owned by Ahli; Mid East Ocean Trade (Mauritius), of which Ahli was the beneficial owner; and Gulf Asia Trade & Investment Ltd (BVI), of which Ahli was the “controlling person.”

According to documents obtained by reporters, these investments resulted in significant profits, netting hundreds of millions over the years as EIFF and EMRF repeatedly bought Adani stock low and sold it high.

Between them, at the peak of their investment in June 2016, the two funds held free- floating shares of four Adani Group companies ranging from 8 to nearly 14 percent: Adani Power, Adani Enterprises, Adani Ports, and Adani Transmissions.

Chang and Ahli’s connections to the Adani family have been widely reported over the years. The men were linked to the family in two separate government investigations into alleged wrongdoing by the Adani Group. Both cases were eventually dismissed.

The first case involved a 2007 investigation into an allegedly illegal diamond trading scheme by the Directorate of Revenue Intelligence (DRI), India’s premier investigative agency under the Ministry of Finance. A DRI report described Chang as the director of three Adani companies involved in the scheme, while Ahli represented a trading firm that was also involved. As part of the case, it was revealed that Chang shared a Singapore residential address with Vinod Adani, the low-profile older brother of the Adani Group’s chairman, Gautam Adani.

The second case was an alleged over-invoicing scam revealed in a separate 2014 DRI investigation. The agency claimed that Adani Group companies were illegally funneling money out of India by overpaying their own foreign subsidiary by as much as $1 billion for imported power generation equipment.

Here, too, Chang and Ahli’s names appeared. At separate times, the two men were directors of two companies later owned by Vinod Adani that handled the proceeds from the scheme, one in the UAE and one in Mauritius.

According to the Hindenburg report, Chang was also either a director or shareholder in a Singapore company that was listed as a “related party” in a disclosure by an Adani company.

Direct Instructions

Aside from these past links to the Adanis, there is evidence that Chang and Ahli’s trading in Adani stock was coordinated with the family.

According to a source familiar with the Adani Group’s business who cannot be named to ensure their safety, the fund managers in charge of Chang and Ahli’s investments in EIFF and EMRF received direct instructions on the investments from an Adani company.

The company that the source named, Excel Investment and Advisory Services Limited, is based in a secretive offshore zone in the United Arab Emirates where corporate records are not available.

However, documents obtained by reporters corroborate the source’s account:

• An agreement for Excel to provide advisory services to EIFF and EMRF was signed for Excel by Vinod Adani himself in 2011.

• As recently as 2015, Excel was owned by a company called Assent Trade & Investment Pvt Ltd., which a 2016 email stated was ultimately owned by Vinod Adani and his wife.

• Though current corporate records from Mauritius, where Assent is registered, do not show who owns the company, they do show that Vinod Adani is on its board of directors.

• Invoices and transaction records show that the management companies of EIFF, EMRF, and the Bermuda-based GOF paid over $1.4 million in “advisory” fees to Excel between June 2012 and August 2014.

• An internal email exchange suggests that, in connection with an upcoming audit, fund managers were concerned that they didn’t have sufficient paperwork to justify following Excel’s investment advice. In one of the emails, a manager instructs several employees to produce records that would justify the reasoning behind the investments. In another, a manager makes a request to obtain a report from Excel which should recommend investing in “more than the number of securities into which the fund has [actually] invested so that it can be demonstrated that the [investment manager] used their discretion to make the selection of investments.”

‘Siphoned-off money’

There is no evidence that Chang and Ahli’s money for their Adani Group investments came from the Adani family. The source of the funds is unknown.

But documents obtained by OCCRP show that Vinod Adani used one of the same Mauritius funds to make his own investments.

Reporters obtained a letter SEBI, the Indian regulator, received from the DRI in 2014, in which the DRI said it had evidence that money from the alleged over-invoicing scheme it were investigating had been sent to Mauritius.

_{Credit: Dinodia Photos RM The Securities and Exchange Board (SEBI) building in Mumbai.}

“There are indications that a part of the siphoned-off money may have found its way to stock markets in India as investment and disinvestment in the Adani Group,” wrote Najib Shah, the DRI’s director general at the time, in the letter.

According to the DRI case, money from the alleged scheme was sent to an Emirati company called Electrogen Infra FZE. This company then forwarded the resulting proceeds of about $1 billion to a Mauritius-based holding company ultimately owned by Vinod Adani that had a similar name, Electrogen Infra Holding Pvt. Ltd.

Reporters were able to trace the onward flow of over $100 million of these funds.

The Mauritius company loaned the money to another Vinod Adani company, Assent Trade & Investment Pvt Ltd, “to invest in [the] Asian equity market.”

As the beneficial owner of both Electrogen Infra Holding and Assent, Vinod Adani signed the loan document as both the lender and as the borrower.

Finally, the money was placed into the GOF, the same intermediary used by Chang and Ahli, and then invested in both EIFF and Asia Vision Fund, another Mauritius-based investment vehicle.

SEBI did not respond to reporters’ requests for comment about the letter it received in 2014.

In the wake of the Hindenburg allegations this year, in addition to appointing its expert committee, India’s Supreme Court directed SEBI to investigate. Its report is due next month.

Subscribe to UndercurrentS

Message us securely on Signal

Share on WhatsApp

Subscribe to UndercurrentS

Message us securely on Signal

Key findings

• In April 2021 Maharashtra’s environment authority ruled the jetty and plant “cannot be treated as independent projects”.

• The environment ministry cleared them through two committees, almost nine months apart, and filed the plant in a state-level category.

• The plant’s papers record no forest land. The jetty takes 0.6497 hectares of mangrove reserved forest.

• The coastal authority told the company to look for another site because of the mangroves, then recommended the same one.

One project, in the state’s words

On 23 April 2021, Maharashtra’s State Environment Impact Assessment Authority sent its answer to Adani Cementation Ltd. The company had brought it a cement grinding unit at Shahbaj, near Alibag in Raigad district, as a standalone plant of the kind the state clears on its own.

The authority refused to see it that way. The plant and the company’s planned jetty on the Amba river “are interdependent activities”, it wrote, and “cannot be treated as independent projects”.

It told the company to take both to the environment ministry in Delhi “as an integrated project”, in Category A. That is the class reserved for projects with the widest impact, which the centre must judge as a whole.

The state authority’s ruling, as the plant’s environmental clearance of 13 September 2024 quotes it.

But Delhi split the file. On 29 December 2023 the ministry cleared the jetty on the advice of its infrastructure committee. On 13 September 2024, almost nine months later, it cleared the plant on the advice of a separate committee for industry.

The summary box on the plant’s clearance records it as Category B1, a state-level class. The state had asked for one file in the top category. It got two letters, and one of them still carries a B.

The category box on page 1 of the plant’s environmental clearance, 13 September 2024.

The split decided what each letter had to look at. Read alone, the plant’s papers say “No involvement of Forest Land” and record no water body within the site.

The jetty, cleared on the same impact study, stands in the Amba estuary and takes 0.6497 hectares of mangrove reserved forest, about 69,933 square feet. Everything that touched the river went into one letter. The plant the jetty exists to serve arrived in the other looking clean.

The company belongs to the Adani Group, whose “widely perceived closeness to Prime Minister Narendra Modi” OCCRP has described. The creek it is building on feeds fishing families from Shahbaj, Shahapur and Dhamanpada. Among the cargo the jetty is cleared to handle is coal.

The site that never moved

The April 2021 ruling was the second warning a Maharashtra authority had given. The first came from the coastal regulator, nine months before it.

In October 2019 the state’s mangrove cell inspected the land the jetty would cross. It found “a dense mangrove dominated by Avicennia marina”, the grey mangrove, on plots listed as reserve forest.

On 7 July 2020 the Maharashtra Coastal Zone Management Authority decided the company “need to explore other site for the project activities”. The reason it gave was “the existence of mangroves at the site”.

The coastal authority records its own July 2020 instruction. Minutes of its 149th meeting, 4 December 2020, page 14.

The company came back with six sites. Every one of them crossed mangrove reserved forest, for 410 to 650 metres, and the company ranked the shortest crossing first.

Five months after its instruction, on 4 December 2020, the same authority recommended the project to the ministry. The application the company filed later lists the very plots the mangrove cell had inspected.

The authority also took the company’s word on fishing. Citing the company’s study, it recorded that “there will not be any impact for fishermen”.

A hearing for each half

On 18 April 2022 villagers gathered in a hall at Poynad, in Alibag taluka, for the public hearing on the jetty. One of them objected that “two public hearings have been kept in a single day”. Project officers said the jetty application dated from 2018 and the cement one from 2021.

A speaker from Pen asked why the coastal authority had approved a site it once said the project should leave. The company’s own project officer confirmed the instruction. The authority had “directed us in its 145th meeting to think about other alternative sites”, he told the panel.

“There are not 150 mangroves, but 1,50,000 mangroves,” a man from Kamalpada said.

By the end of the day the panel held 190 written suggestions and objections. The convener sent them on with the minutes.

The count of written submissions, above the panel’s signatures. Public hearing minutes, 18 April 2022.

The company says it answered them in an annexure to its impact report. The plant’s committee later called its action plan on the hearing “satisfactory”.

Two letters, two sets of gaps

Dr Amardeep Raju, member secretary of the infrastructure committee, signed the jetty clearance. It allows about 158 trees to be affected and 60,000 cubic metres of dredging in the river, with up to 30,000 more if the berths silt up.

The jetty clearance of 29 December 2023 on the mangrove reserved forest and the trees, page 3.

Dinesh Runiwal, a ministry director, signed the plant clearance. It cites a 2010 ministry memo that lets each sector committee appraise its own part of a shared impact report. The split rests on that memo. The state authority had asked for a single appraisal of the whole.

The plant letter went out with large gaps. The project needed 10 hectares, of which the company held 3.24, and the other 6.76 “will be acquired soon”. The committee counted 13 highly protected species nearby and said the wildlife plan should be carried out “post approval”.

Two months later a corrigendum rewrote the letter. The plant’s cost rose from Rs 547.19 crore to Rs 990 crore, and its jobs fell from 900 to 415. The ministry called these “minor typographical errors”.

Cleared by the courts, still two files

To cut the mangroves, the company went to the Bombay High Court. The state and central authorities, the bench recorded, “have not opposed the Project”. The company’s own consultant had warned that cement and fly ash settling on the trees “may result in killing of the existing mangroves”.

The Bombay Environmental Action Group argued that a captive jetty serves one company. The bench was “not at all impressed”. Shipping cement by water, it held, would cut “carbon emission by more than 60%”. On 5 March 2025 it allowed 158 mangrove trees and shrubs to be cut.

The judgment describes the coastal authority’s July 2020 meeting as a request for documents. It does not mention the instruction to look for another site, or the state authority’s ruling that the jetty and plant were one project.

On 21 July 2025 the Supreme Court said it was “not inclined to interfere”, in a short order that gives no reasons. The final central forest approval followed on 24 October 2025, 11 days after the state filed its compliance report. In August 2026 the state forest department issued orders permitting the diversion, the Indian Express reported.

The company now wants its permits moved to a new name, Adani Cement Industries Ltd. On 5 September 2026 the state pollution board refused to move two of the site’s construction consents, because the certificate attached “does not reflect any change of name”.

The environmental clearances are travelling on two separate transfer files, one for the jetty and one for the plant. On 15 July 2026 the ministry’s portal showed both waiting on the company for more information, with no grant date.

The documents this story is based on, the clearances, orders, agendas and filings, are collected in one place.

→ The documents behind this story — add your DocumentCloud link

Subscribe to UndercurrentS

Message us securely on Signal

Share on WhatsApp

Subscribe to UndercurrentS

Message us securely on Signal

Key findings

• Two Mauritius funds held up to 3.90% of four Adani companies from 2013 to 2018, counted as public shares.

• Counted with the promoters, they would have pushed two of the companies below the 25% public floor in March 2017.

• SEBI holds that Vinod Adani was in “de jure control” of the adviser hired for the funds’ main investors, yet finds “no footprint” of him in their investments.

• The companies settled at 6:04 pm on 28 September 2026. At 7:37 pm the same SEBI member ruled the breach “not established”.

Ninety-three minutes

At 6:04 pm on 28 September 2026, Kamlesh Chandra Varshney, a whole-time member of the Securities and Exchange Board of India (SEBI), digitally signed a settlement order. Adani Enterprises, Adani Power, Adani Ports and Adani Transmission had each paid Rs 37,05,000, jointly with their directors, Gautam Adani among them. They paid “without admitting or denying the facts and conclusions of law”.

At 7:37 pm Varshney signed the final order in the same case. The companies’ breach of the public shareholding rule, it ruled, was “not established”. Its second page still reads “settled vide order dated [Insert Order date]”. Nobody had filled it in.

But the order also records what its verdict leaves out. “I hold that the Noticee no. 1 was in de jure control of ARFT,” Varshney wrote. Noticee no. 1 is Vinod Adani, Gautam Adani’s elder brother. ARFT is his family trust in the Cayman Islands. It owned Excel Investment and Advisory Services, the firm hired to advise on the money behind two funds that held Adani shares as members of the public.

The next paragraph begins: “Having concluded that Mr. Vinod Adani effectively controlled Excel.” De jure means by law.

Varshney’s finding that Vinod Adani was in de jure control of the trust that owned Excel. SEBI final order, page 38.

That was the heart of the charge. SEBI’s investigators had alleged that the shares counted as public were bought at Vinod Adani’s direction and controlled by him. These are the companies of a group “widely perceived” as close to Prime Minister Narendra Modi, as a 2023 OCCRP investigation put it.

A line at 25%

Every listed company in India must keep at least a quarter of its shares with the public. Its promoters, meaning the founding family and the companies it controls, may hold no more than 75%. The point, the order says, is “price discovery through market participation”.

From 2013 to 2018, two Mauritius funds, Emerging India Focus Funds (EIFF) and EM Resurgent Fund (EMR), sat on the public side of four Adani companies. At their peak they held 3.90% of Adani Power, 3.77% of Adani Transmission, 3.38% of Adani Enterprises and 2.99% of Adani Ports.

Small stakes, but they sat right on the line. In March 2017 Adani Transmission reported its promoters at 74.92% and the public at 25.08%, with EIFF at 2.47% and EMR at 1.17%. Move the two funds to the promoter side and the public falls to 21.44%. Adani Enterprises, in the same quarter, falls from 25.08% to 22.57%.

Adani Transmission’s public shareholders in March 2017, with the two funds at 1.17% and 2.47% and the public at 25.08%. BSE shareholding pattern.

Below the line, SEBI’s own 2017 rules bite. The stock exchange fines the company Rs 5,000 a day, rising to Rs 10,000 a day after a year, and freezes every share the promoters hold. It “may also consider compulsory delisting”.

The money behind the funds

SEBI opened its investigation on 23 October 2020 and traced the funds’ money back to its start.

It began with Daboul Trading, owned by the Emirati businessman Nasser Ali Shaban Ahli. On 1 September 2010 Daboul lent $350 million to Lingo Investment, which the Taiwanese businessman Chang Chung-Ling had set up eight days earlier. In May 2011 Daboul lent $400 million to a company Ahli had set up six days before. Two more Ahli companies made four investors.

The four put their money into Global Opportunities Fund in Bermuda, which invested through EIFF and EMR. The Bermuda fund had 478 investors. By the investigators’ count, these four supplied 99.49% of EIFF’s Adani money and 99.79% of EMR’s. Together the two funds put about Rs 3,302 crore into the four Adani companies.

From 1 April 2012 the fund’s manager hired Excel to advise on investments for three of the four. The contract also let Excel advise, on written request, “whether and in what manner the rights conferred by the investments shall be exercised”. In plain words, how to vote the shares. Vinod Adani was the settlor, enforcer and beneficiary of the trust that owned Excel, and could remove its trustee.

SEBI’s own chart of the structure, from Daboul’s loans through the Bermuda fund to the four Adani companies, with Excel and Vinod Adani beside the fund manager. SEBI final order, page 34.

What SEBI ruled, and what its order records

SEBI accepted that Vinod Adani controlled Excel. Then it read the contract. Excel’s advice was “non-binding”, and one clause said Excel would not advise on companies “within its Group or to whom it is associated with/to”. The investigators had not discussed these clauses, the order says, so “the alleged chain of control substantially breaks at this stage”. It does not ask whether a firm owned by an Adani brother’s trust was associated with Adani companies.

It went further. “There is also no footprint of him being involved in the decision” of the two funds to invest in Adani companies, the order says. OCCRP had reported in 2023 that Vinod Adani himself signed, for Excel, an agreement to advise EIFF and EMR. The funds’ managers paid Excel over $1.4 million in fees between 2012 and 2014.

SEBI’s finding of “no footprint” of Vinod Adani in the funds’ decision to invest. SEBI final order, page 42.

The funds voted with the promoters on related-party deals and on reappointing promoter directors. That “voting alignment”, the order held, could not “by itself establish control”.

The two men behind the money were fined Rs 20 lakh each. Ahli did not answer SEBI’s summons. Chang told SEBI he had no connection with the Adani promoters, though the investigators alleged he and Vinod Adani had sat together as directors of Adani Global from 1997 to 2008. The order calls his denial, with his failure to say where his money came from, a “deliberate attempt to mislead investigation”. Their ties to Vinod Adani, it says, “would only establish close business and financial relationship”.

The order rests on a legal test. Control means the power to “positively direct” a company’s decisions, and proving it was the investigators’ job. Nobody has shown where the money started. OCCRP found no evidence that it came from the Adani family, but found that Vinod Adani used the same Bermuda fund and EIFF for his own investments.

And SEBI’s charge sheet, the show cause notice, never claimed the money was his. It “does not allege that Mr. Vinod Adani is the beneficial owner” of the funds’ investments, the order says. That “could have been alleged”. “If that had been the allegation and there were evidences to prove the same, the situation could have been different.”

The price of a breach not established

The investigators put the wrongful gains earned through the structure at Rs 1,983.97 crore. The order held those gains not established. SEBI says a “sufficiently higher settlement price” deters wrongdoing. It took Rs 37,05,000 from each company for a breach that, in its own words, “does not stand established”.

The next day Adani Enterprises told the stock exchanges that the settlement had “no material financial impact”.

The order finds that the facts “may legitimately give rise to suspicion warranting further examination.” Its directions order none.

The documents this story is based on, the clearances, orders, agendas and filings, are collected in one place.

→ The documents behind this story — add your DocumentCloud link

Subscribe to UndercurrentS

Message us securely on Signal

Share on WhatsApp

Subscribe to UndercurrentS

Message us securely on Signal

Key findings

• Fourteen forest approvals for Adani-linked projects in five states cover 11,421 hectares of forest land. Nearly 6,900 hectares are for coal mines.

• At Mundra, Kutch’s forest chief wrote there was “no need” for more forest. The ministry approved 1,576.81 hectares in 2018, without the limits its expert committee had set that January.

• At Dhirauli, the ministry called a forest “such pristine area” in February 2024. It gave final approval for a coal mine there in May 2025.

• In Hasdeo in 2011, a minister overruled the expert committee that did “not recommend the diversion”.

On 16 November 2018, the environment ministry in Delhi gave in-principle approval to divert 1,576.81 hectares of reserved forest at Mundra, on the Kutch coast. The land was for an industrial park inside the special economic zone of Adani Ports and Special Economic Zone.

But the forest department in Kutch had already said there was no need. Its chief conservator wrote that the company “has already diverted the reserved forest of 2008.41 ha for the same cause”. So, he concluded, “there is no need for any diversion of forest land for the same cause”.

Those 2,008.41 hectares had gone to the company in a final approval of 30 September 2009. It was then still called Mundra Port and Special Economic Zone.

He also asked that 394.10 hectares at Siracha be left out, as “the unique prominent Acacia nilotica forest in the district”. The state government had asked to keep 100 hectares there for birds and wolves. When ministry officers inspected in 2017, the company said it wanted Siracha to expand its power plant. The officers called it “good forest”, and recommended giving it anyway.

The Kutch forest chief’s recommendation, quoted in the ministry’s 2018 file note on the Mundra proposal: no need for more forest, and keep Siracha’s Acacia forest out.

The two Mundra approvals are the largest of 14 forest approvals for Adani-linked projects, traced through the government’s own letters. Together they cover 11,421 hectares in Gujarat, Chhattisgarh, Madhya Pradesh, Maharashtra and Jharkhand, from 2009 to July 2026, our analysis shows.

Nearly 6,900 of those hectares are for coal mines. About 7,500 were approved after Narendra Modi became prime minister in 2014. OCCRP has reported on the group’s “widely perceived closeness” to him.

The count is permission to clear, not trees already felled. It is also a floor. It leaves out approvals under 90 hectares, and mines where no document shows Adani’s role.

Forest land approved for diversion to Adani-linked projects, by approval. Source: our analysis of the ministry’s approval letters.

“No need for any diversion”

The Mundra file shows how far the ministry moved. In 2016 its inspectors found no plan showing what the forest was for. So they could not establish whether the company had sought the “bare minimum”. The district collector’s certificate on forest dwellers’ rights had not been furnished.

The proposal, from 2004, counted 579,497 trees to be felled. Most of the growth was Prosopis juliflora, an invasive weed from Mexico, the inspectors noted.

In January 2018 the Forest Advisory Committee, the ministry’s expert panel, recommended 1,552.81 hectares, not the full area. It said the diverted land “shall be maintained as green area”, with any other use decided case by case by the ministry. It noted from satellite analysis that an aerodrome “already exists in the zone”. Most of the forest and revenue land was already in non-forest use, it found.

The company then asked the ministry to delete or amend the committee’s conditions. It wanted the green-area condition rewritten, so that the land “shall be utilized for various industrial activities”.

The November 2018 approval gave the full 1,576.81 hectares. The green-area condition was gone. In its place, vegetation could be cleared “as and when a specific project / industry is to come up in the SEZ”. The letter lists Siracha among the villages and sets no area aside there.

Seven years late

The approval had conditions, including compensatory planting on 3,154 hectares, double the forest taken. The state was to report them met before final approval.

In February 2026 the ministry wrote that the compliance report had arrived “nearly seven years after grant of approval”, beyond the approval’s five-year life. It also asked why planting land equal to the forest was offered, instead of double.

After the state replied in April, the ministry granted final approval for 235.46 hectares, and then for another 247.43.

The ministry’s February 2026 letter on Mundra: the compliance report came “nearly seven years after grant of approval”.

“Such pristine area”

The same pattern runs through the coal belt of central India. In February 2024 the ministry wrote to Madhya Pradesh about the Dhirauli coal mine in Singrauli. Its own mapping found 1,601 hectares of forest in the lease, not the 1,397.54 proposed. The state had told it the site lay within a kilometre of an elephant corridor.

It estimated that 570,666 trees would be affected. Most of the land was very dense forest, and the ministry asked the state to justify proposing “such pristine area”.

In-principle approval followed on 24 September 2024. Final approval came on 9 May 2025, four days after the state’s compliance letter. In August 2025 the approval passed to Mahan Energen, whose letterhead gives Adani Corporate House, Ahmedabad.

The ministry’s February 2024 letter on Dhirauli: 1,601 hectares of mapped forest, an elephant corridor, 570,666 trees and “such pristine area”.

In Hasdeo, Chhattisgarh, the ministry’s experts had said no outright. In June 2011 the Forest Advisory Committee recorded sloth bear, leopard and elephants at the Parsa East and Kete Basan block, and forest rights unsettled. It did “not recommend the diversion”.

On 23 June 2011 the minister overruled it, saying he had to keep the “development picture in mind”. Final approval for 1,898.328 hectares came in March 2012. The mine is run by a company 74% owned by Adani Enterprises.

The ministry’s own file note: the Forest Advisory Committee “does not recommend the diversion”, and the minister “has not accepted” that advice.

Next door, Parsa received final approval for 841.538 hectares on 21 October 2021. Two days later the Governor of Chhattisgarh ordered an inquiry into allegedly fake village assembly resolutions for it, petitioners told the Supreme Court.

In Ghatbarra, a village on the edge of the first mine, community forest rights were cancelled in 2016. The reason, the villagers’ petition says, was that they “are interrupting in mining work”.

The approvals have not slowed. Kente Extension, in Surguja, won in-principle approval for 1,742.6 hectares of forest on 9 June 2026. On 23 July 2026 Purunga, an underground coal mine in Raigarh, won it for 621.331 hectares of forest, though surface rights cover only 9.982 hectares. The applicant is Ambuja Cements, whose filings give Adani Corporate House as its registered office.

On the coast, the record shows a safeguard can work. At Hazira, near Surat, mangroves found in the land Adani’s port company sought were left out before the 2022 approvals. From Khavda in Kutch, two Adani transmission lines got 493 hectares of forest land. For the newer line, 261 of its 267 hectares lie in the Banni Grassland forest division.

The ground gets hotter

Forests cool the land around them. Trees pull water from the soil and evaporate it, which carries heat away from the ground.

A 2019 study measured this from satellites across the globe. In the tropics, 5 km squares that lost about half their forest warmed at the surface by 1.08°C on average. That is the heat of ground and canopy as a satellite sees it, an average, not a measurement at any one mine.

Forests also make rain. A 2023 study in Nature looked across the tropics. Over areas of 200 km, each percentage point of forest lost cut rainfall by 0.25 mm a month. India is already hotter: 2024 was its warmest year since national records began in 1901.

There is an innocent reading. Ports, power and coal are lawful projects, and the approvals order compensatory planting, as Mundra’s did. Much of the Mundra forest was invasive weed. In 2023 the Adani Group pledged to grow 100 million trees by 2030.

But the objections in these files came from the government’s own officers and experts, and each time the approval went ahead.

In the ministry’s posted documents, 1,093.92 hectares of the 2018 Mundra approval are still waiting for their final letter.

The documents this story is based on, the clearances, orders, agendas and filings, are collected in one place.

→ The documents behind this story — add your DocumentCloud link

Subscribe to UndercurrentS

Message us securely on Signal

Share on WhatsApp

Subscribe to UndercurrentS

Message us securely on Signal

Key findings

• Five Adani companies paid Rs 1,50,80,000 to settle SEBI charges that grew out of the Hindenburg report.

• They settled “without admitting or denying” the facts, so nobody ruled on whether the charges were true.

• The same officer settled a case against Adani Ports chief executive Karan Adani twelve days earlier.

• Both files cleared SEBI’s committees on the same two days, 29 June and 13 August 2026.

At 3.58 pm on 22 September 2026, Jai Sebastian, an adjudicating officer at the Securities and Exchange Board of India, digitally signed a five-page order. It closed a case against five Adani companies.

Adani Enterprises paid Rs 76,05,000 and Adani Green Energy Rs 45,50,000. Adani Total Gas, AWL Agri Business and Adani Energy Solutions paid Rs 9,75,000 each. The bill came to Rs 1,50,80,000.

What each company paid. Source: SEBI settlement order, 22 September 2026, page 4.

The charges came out of a report the group had called false. When the US short seller Hindenburg Research published it on 24 January 2023, the Adani Group answered with 413 pages. The report, it said, was “nothing but a lie” and “a calculated attack on India, the independence, integrity and quality of Indian institutions”.

The group’s reply to Hindenburg, January 2023. Source: Adani Response filed with the National Stock Exchange, printed page 3.

But when SEBI put those allegations to the companies, they did not fight them. They paid to close the case “without admitting or denying the findings of facts and conclusions of law”.

This was no ordinary defendant. A 2023 OCCRP investigation described “the group’s widely perceived closeness to Prime Minister Narendra Modi”. By late May 2026 the group had added around Rs 5 lakh crore in market value that year, IANS reported. At that pace, the settlement cost it about 38 seconds of the year’s gains.

What SEBI said was wrong

The charges went to whether investors could trust the group’s books. SEBI alleged that Adani Enterprises kept out of its 2012-13 annual report the deals between its subsidiary Adani Estates and Vakoder Investment. Vakoder was a related party, a company tied to the people who control the group.

The second charge was about the auditors. Between 2015 and 2021, group companies filed reports signed by audit firms that held no valid peer-review certificate. That certificate shows the accountants’ own institute has checked an auditor’s work. SEBI’s rules require it.

The charges, and the choice to settle without admitting or denying them. Source: SEBI settlement order, 22 September 2026, page 3.

SEBI had examined Hindenburg’s allegations at seven Adani companies. On 15 February 2024 it sent five of them a show-cause notice. They applied to settle that year. Talks with SEBI’s internal committee ran through August and October 2024 and resumed in May 2026. On 29 May the companies offered revised terms.

Then the file moved. SEBI’s high-powered advisory committee recommended the amounts on 29 June. A panel of whole-time members accepted them on 13 August. On 5 September the companies emailed to say they had paid.

The same officer, the same dates

Those three dates appear in a second Adani file. On 10 September Sebastian settled a case against Karan Adani, Gautam Adani’s son and chief executive of Adani Ports, and B Ravi, its finance chief.

SEBI had alleged that the two men broke the rule on the compliance certificate a chief executive and finance chief give their board. The case concerned bank transactions and deposits between Adani Ports and a company called PMC Projects, under a notice of 22 November 2023. That order does not mention Hindenburg.

Each man paid Rs 13,65,000. Their file reached the advisory committee on 29 June and the panel on 13 August, and their payment was reported by email on 5 September. One officer signed both orders.

Jai Sebastian’s signature on both orders, twelve days apart. Source: SEBI settlement orders of 10 September 2026 (page 4) and 22 September 2026 (page 5).

Six days after the five companies settled, SEBI closed a third Adani case, on public shareholding, the same way.

“Truth has prevailed”

The group has welcomed SEBI’s word when it went its way. In September 2025 SEBI whole-time member Kamlesh Chandra Varshney ruled on Hindenburg’s claim that money was routed through two firms, Milestone Tradelinks and Rehvar Infrastructure. He found the allegations “not established”.

Gautam Adani wrote to shareholders six days later. The Hindenburg report, he said, “was a direct challenge to the audacity of Indian enterprises to dream on a global scale”. “With SEBI’s clear and final word, truth has prevailed.”

Gautam Adani’s letter to shareholders. Source: Adani Enterprises filing, 24 September 2025, page 2.

Varshney’s order weighed the facts and applied the law. Sebastian had been appointed “to inquire into and adjudge” the 2024 charges. His order did neither.

Settling is lawful, and SEBI does it often. In 2025-26 it disposed of 170 settlement applications and collected Rs 109.82 crore. It also turned 199 away that year, rejected, returned or withdrawn. Its rules let it refuse to settle a default that “affected the integrity of the market”.

The group itself had cast the allegations as an attack on the “integrity and quality of Indian institutions”. SEBI settled anyway.

What the order leaves out

The order names the two audit firms, Dharmesh Parikh & Co LLP and Shah Dhandharia & Co LLP. It does not say whether SEBI has acted against either. Nor does it say what the Vakoder deals were worth, or whether the 2012-13 accounts were ever corrected. It does not explain how group companies kept filing reports from uncertified auditors from 2015 to 2021. SEBI can still restore the case if anything the companies told it proves untrue.

Everyone who settles signs an undertaking in a form the rules prescribe. It waives any appeal. It bars the signer from publicly denying SEBI’s findings once the order is passed. And for disclosure defaults it carries the line “I/we do not deny the alleged default.”

The companies that called the charges “nothing but a lie” would have signed that form. SEBI has not published what they signed.

The documents this story is based on, the clearances, orders, agendas and filings, are collected in one place.

→ The documents behind this story — add your DocumentCloud link

Subscribe to UndercurrentS

Message us securely on Signal

Share on WhatsApp

Subscribe to UndercurrentS

Message us securely on Signal

Key findings

• On 18 May 2026, Uzbekistan’s energy minister met Adani’s international energy chief, Amit Singh, in Tashkent.

• The joint statement Modi signed on 30 August repeats that meeting’s readout in the same order, with two changes.

• Adani met Uzbek ministers or state companies six times before Modi arrived, the last on minerals twelve days before a geology pact.

• No visit document names Adani, and no signed Adani deal in Uzbekistan is on the public record.

Two sentences, three months apart

On 30 August 2026, Narendra Modi and Shavkat Mirziyoyev closed a two-day state visit in Tashkent. They signed eleven documents and issued a joint statement.

Under the heading on energy, the two leaders gave one sentence:

“The Leaders welcomed the discussions on advancing cooperation in the fields of renewable energy, modernization of energy infrastructure, and the implementation of prospective investment projects.”

The joint statement’s energy and minerals passages. Source: Ministry of External Affairs, Joint Statement, 30 August 2026.

It welcomes “the discussions” without saying whose. But the same words had been printed three months earlier, about a meeting with the Adani Group.

On 18 May, in Tashkent, energy minister Jurabek Mirzamakhmudov met Amit Singh, who runs international energy for Adani. The next day the state newspaper Yangi O’zbekiston published the official account in English:

“During the talks, the parties discussed the development of renewable energy sources, modernization of energy infrastructure, increasing the efficiency of the industry, as well as the implementation of promising investment projects.”

Renewable energy, then modernization of energy infrastructure, then the implementation of investment projects. The order and the nouns are the same. In three months only two things changed: “the efficiency of the industry” dropped out, and “promising” became “prospective”.

The national news agency’s report of the 18 May meeting, citing the energy ministry, with the minister’s and Singh’s names marked. Source: UzA, 19 May 2026.

A summer of meetings

The energy minister was only the first. The next day, 19 May, investment minister Laziz Kudratov met Singh. The government portal says Adani was “presented with promising project proposals” in hydropower, mining, infrastructure and real estate. Both sides agreed “to jointly advance prospective projects and establish mechanisms for further collaboration”.

Two days later the private outlet UzDaily reported that Deputy Prime Minister Jamshid Khodjaev had met Singh. They went over energy, chemicals, mining and critical minerals, it said, citing Khodjaev.

In June the state hydropower company, Uzbekhydroenergo, took its turn at the Tashkent International Investment Forum. It reported that “an agreement was reached” with Adani “to establish a joint working group and to implement promising projects”.

At the June forum, China Huaneng signed a memorandum; Adani got a working group. Source: UzA, 21 June 2026.

On 10 August the talks moved to Adani’s home city. A delegation led by Kudratov met the Adani Group in Ahmedabad. The national news agency UzA quoted Gautam Adani saying the group was “highly interested” in building hydropower and pumped-storage plants in Uzbekistan.

The metals company

Eight days later came the state metals company. The Uzbekistan Technological Metals Complex, known as TMK, was set up by presidential decree to process metals such as lithium, graphite and tungsten. It belongs to a national plan of 120 critical minerals projects worth $4.2 billion, on which the president was briefed in June.

On 18 August TMK met the Adani Group. Its statement, quoted by the Azerbaijani agency Trend, said the two sides discussed TMK’s mining projects, “studying the available geological and technical data” and more exploration. TMK also laid out “a pipeline of potential investment projects”.

Trend’s report of TMK’s statement on the Adani meeting. Source: Trend News Agency, 18 August 2026.

Modi landed eleven days later. Among the eleven documents signed on 30 August was a memorandum on geology and mineral resources between India’s Ministry of Mines and Uzbekistan’s Ministry of Mining Industry and Geology.

The joint statement then went over the ground TMK had covered. The leaders “expressed interest in encouraging Indian companies to participate in the development of prospective mineral deposits in Uzbekistan”. They agreed on joint projects in “geological exploration, mining, mineral processing, and the development of integrated value chains”.

Another of the eleven documents paired the Indian state of Gujarat with the Samarkand region. Ahmedabad, where Kudratov’s delegation met Adani, is in Gujarat.

India’s list of outcomes from the visit, items 5 and 11 marked. Source: Ministry of External Affairs, 30 August 2026.

What the record leaves out

Adani’s name appears in none of it. None of the eleven documents on India’s list mentions the group, and the joint statement speaks of Indian companies in the plural.

Uzbekistan courts many investors at once. At the June forum Uzbekhydroenergo met nine parties, among them China Huaneng, MUFG and the World Bank. China Huaneng signed a memorandum there, while Adani got a working group. In the same round Khodjaev also saw AD Ports Group and a German cable maker.

Nor is there a deal. A search of Uzbek and Indian official sources found talks, project proposals, a working group and stated interest. It found no signed Adani contract, licence or joint venture in Uzbekistan.

What the record does hold is the order of events and the wording. A group widely seen as close to the Prime Minister sat with Uzbekistan’s energy, investment and metals officials through the summer. Then the two leaders signed off on cooperation in the same fields, in nearly the same words.

After Ahmedabad, UzA reported, both sides agreed to keep going “by establishing strong project partnership mechanisms”. The leaders set up a mechanism of their own, led by their foreign ministers, to oversee “priority bilateral initiatives and projects”.

As of 23 October 2026, the text of the geology memorandum has not been published. Neither government has said whether any other Indian company was shown TMK’s geological data.

The documents this story is based on, the clearances, orders, agendas and filings, are collected in one place.

→ The documents behind this story — add your DocumentCloud link

Subscribe to UndercurrentS

Message us securely on Signal

Share on WhatsApp

Subscribe to UndercurrentS

Message us securely on Signal

Key findings

• Two Adani data centre parks for Google’s AI hub were cleared nine days after the companies applied.

• The forest officer’s no-objection for the Tarluvada site is dated 8 April, the day before the application.

• The state’s expert committee recorded about 90% of that site as reserve forest, and recommended clearance at the same meeting.

• Both parks were filed as buildings, each just under the size ceiling of a class that needs no impact report and no public hearing.

On 18 April 2026, S Sri Saravanan put his digital signature on two environmental clearances. He is member secretary of Andhra Pradesh’s State Environment Impact Assessment Authority. The clearances went to two Adani companies building the data centres of Google’s AI hub outside Visakhapatnam, each park described as 1,000 MW. The companies had applied nine days earlier, on 9 April.

But one paper in the Tarluvada file is older than the application. The minutes of the state’s expert committee, copied into the clearance, record a forest no-objection certificate from the Divisional Forest Officer, Visakhapatnam, for 266.60 acres of the site. It is dated 8 April.

Just above it, the same minutes record what the committee saw when it checked PARIVESH, the Union environment ministry’s clearance portal. “Approximately 90% of the proposed site falls within the Pedda Chukka Konda Reserve Forest,” they say. The next sentence says the Survey of India map shows no forest on the land. The minutes never say which record the committee believed. It recommended clearance at that meeting, one day after the applications came in.

Page 4 of the Tarluvada clearance: the committee’s reserve forest finding, and the forest officer’s certificate dated 8 April 2026.

The applicants were not ordinary. Adani Enterprises and Google announced the hub in October 2025, about $15 billion, to be built with AdaniConneX, Adani’s data centre venture. The group’s chairman, Gautam Adani, was an early supporter of Narendra Modi’s political aspirations, CNBC reported. Chandrababu Naidu’s government in Andhra Pradesh is allied with Modi’s party.

The state is paying for the hub too. Its package for Google, tax breaks and cheap land, power and water, is estimated at Rs 22,000 crore over 20 years, the Guardian reported. At Tarluvada, 520 families have lost plots the government allotted them about 20 years ago. By September bulldozers had stripped the hillside near the village of its trees, and the paper put the forest to be cleared for the project at more than 100 acres.

Nine days

The land moved first. APIIC, the state’s industrial corporation, provisionally allotted 266.60 acres at Tarluvada to the Adani subsidiary on 20 February, and the full price had been paid by 27 February. The forest officer’s certificate followed on 8 April.

On 9 April both companies applied online. The same day, the committee drew up an “additional agenda” that put both projects before it the next morning. On 10 April Pridhvi Envirotech, a Hyderabad consultant, presented both, and the committee recommended both.

On 15 April the authority accepted the recommendations, and on 18 April Saravanan signed. Ten days later Google broke ground, and Naidu laid the foundation stone with Union IT minister Ashwini Vaishnaw.

The committee’s additional agenda, created on 9 April 2026, the day the companies applied, for a meeting on 10 April.

The rules give the committee up to 60 days to appraise a project like this, and the authority up to 45 more to decide. Andhra Pradesh used one day and five.

Other files waited their turn. Of the 26 items on the authority’s 15 April agenda, 23 had been filed in earlier months, one of them in 2022. Only three dated from April 2026: the two Adani parks and a solar factory. The hub’s third site, at Adavivaram, applied on 24 April and was cleared on 10 June, after 47 days.

S Sri Saravanan’s digital signature on the Tarluvada clearance, dated 18 April 2026 (page 17).

Filed as buildings

Both parks went in as “building and construction” projects, a class for built-up areas between 20,000 and 150,000 square metres. Tarluvada declared 148,922 square metres and Rambilli 148,476, each within about 1,500 square metres of the ceiling. Projects in this class need no environmental impact report and no public hearing.

Data centres have no category of their own, and the state later told the High Court that was why it used this one, LawChakra reported. So two parks drawing 1,626 MW from the state grid between them were appraised as buildings. Tarluvada lists 200 diesel generators as backup, Rambilli another 150.

The committee wrote down the limits of its own review. It “appraised the application from the Environmental point of view only with respect to liquid, solid and air pollution management.”

The water budget was drawn to the same scale. Tarluvada declared 267 kilolitres a day, and the consultant’s slides show it was built from drinking and flushing water for 785 staff, guards and visitors, plus equipment cleaning and gardens. Google says the hub will be cooled by air. Permission to draw groundwater was left for later, to be “obtained” before construction or operation.

What the committee wrote about the forest

The consultant’s slides describe the Tarluvada land as “undulated terrain with trees, herbs, shrubs, and grass”, with a hill, Chukka Konda, on its western side. A photograph in the same deck, stamped 27 February, shows scrub and trees below the hills.

The consultant’s photograph of the Tarluvada site, stamped 27 February 2026, from its presentation to the state committee.

The slides name three forests near the site: Kambalakonda reserve forest, 1.7 km to the south, and two farther off. Pedda Chukka Konda is not among them. The reserve forest entered the record when the committee checked the federal portal at its 10 April meeting.

The minutes also place Kambalakonda Wildlife Sanctuary about 1.53 km from the first phase. The clearance answers the forest and the sanctuary with general instructions: obey the forest and wildlife laws, and “scrupulously comply” with the conditions of the forest officer’s certificate.

The Adani group says all legal approvals were given. Google told the Guardian it had “engaged deeply” with local communities and that the project would have “no expected impact” on them. Neither statement addresses the reserve forest the committee recorded at Tarluvada.

Before the tribunal

The order names two ways it can be undone. An appeal lies with the National Green Tribunal, within 30 days. The authority itself may cancel the clearance at any time if it was obtained “through suppression of any information or furnishing false information”.

Human Rights Forum has gone to the tribunal, calling the state’s risk assessment “grossly inadequate, scientifically unrealistic, and misleading”, the Guardian reported. The Andhra Pradesh High Court has declined to stay construction, LawChakra reported.

A separate appeal against the Adavivaram clearance says that site lies about 750 metres from the Kambalakonda sanctuary. The tribunal has asked the Union government to respond, and listed the appeal for hearing on 26 October 2026.

On the forest, the Tarluvada clearance leans on the officer’s certificate of 8 April. It does not reproduce the certificate or list its conditions, only its acreage and its date, the day before the companies applied.

The documents this story is based on, the clearances, orders, agendas and filings, are collected in one place.

→ The documents behind this story — add your DocumentCloud link

Subscribe to UndercurrentS

Message us securely on Signal

Share on WhatsApp

Subscribe to UndercurrentS

Message us securely on Signal

Key findings

• The Supreme Court ordered customs to refund the tax Adani Power paid on Mundra electricity from September 2010 to February 2016.

• Its reason: a rule already makes Adani pay the duty on its coal, so taxing the power too “is to double count”.

• A government order had switched that rule off from 6 September 2010. The judgment never mentions it.

• A Rs 963.94 crore coal duty demand for 2009-10 to 2014-15 is still open, with nothing paid under protest.

“Is to double count”

On 5 January 2026, Justices Aravind Kumar and N.V. Anjaria of the Supreme Court signed a 33-page judgment in favour of Adani Power. Customs was to hand back the tax the company had paid on electricity sent from its Mundra plant into the rest of India. The refund covers 16 September 2010 to 15 February 2016, and was due within eight weeks.

The government had defended that tax as a way to recover the benefit of duty-free inputs “such as imported coal”. The judges disagreed. A rule of the special economic zone, they wrote, “already obliges” the plant to pay back the duty on its inputs when its power leaves the zone. To tax the electricity on top “is to double count”.

Supreme Court judgment of 5 January 2026, para 64: the rule “already obliges” Adani Power, so taxing the power “is to double count”.

But for the years the court was refunding, that rule had been switched off. On 28 October 2010 the Department of Commerce issued an order one sentence long. It reads: “Operation of Rule 47(3) of SEZ Rules, 2006 is kept abeyance w.e.f. 6.9.2010 till further orders.” Rule 47(3) is the rule the judges relied on. It stopped running on 6 September 2010, ten days before the refund period begins.

The one-sentence order that suspended the coal duty rule from 6 September 2010. Department of Commerce, 28 October 2010.

The judgment reproduces Rule 47(3) in full, with no word that it had been suspended. The words “instruction” and “abeyance” appear nowhere in its 33 pages, and neither does the Commerce Department.

So the court refunded one tax on the strength of another that the government had stopped collecting. Adani Power belongs to the Adani Group, which OCCRP reported in 2023 is widely perceived as close to Prime Minister Narendra Modi. Its counsel in the Supreme Court was P Chidambaram, the former finance minister.

How much was paid back is not stated in the judgment or in Adani Power’s latest annual report. In 2014-15 alone, the company booked Rs 86.94 crore of customs duty on its electricity.

Two taxes, one switched off

The Mundra plant sits inside a special economic zone on the Gujarat coast, so its imported coal arrives free of customs duty. Power used inside the zone keeps that benefit. For power sold to the rest of India, the rules required the plant to pay the duty “on consumables and raw materials used for generation of power”. For a coal plant, that is the duty on its coal.

In February 2010 the government added a second charge: 16% on the power itself, backdated to June 2009. Adani Power went to the Gujarat High Court and called it double taxation.

Then the government changed course. From 16 September 2010 the 16% gave way to ten paise a unit, later cut to three paise. Ten days before that, the coal duty rule had been switched off. A second order in February 2011 narrowed the suspension, but the clause on duty for power sold into India stayed off.

For five and a half years the coal duty was off and a small power tax was on. In February 2016 the power tax went to nil for plants like Adani’s.

The order that dropped out

In July 2015 Adani Power won its first case. The High Court struck down the 16%, but only for June 2009 to September 2010, when both taxes had run together.

The company then went after the small power tax as well, every paisa from September 2010 to February 2016. On 28 June 2019 the High Court refused. The government’s lawyer had put the 2010 order before the judges. With the coal duty off since 2010, he argued, a refund would hand Adani a “double benefit”. Counsel for another respondent said the rule had “been kept in abeyance for a period of five years”.

In the Supreme Court the order fell out of view. The judgment’s account of the government’s arguments does not mention it. Its summary of the 2019 ruling leaves out the double benefit.

Chidambaram told the judges there had been “no change in the law or in the underlying facts” between September 2010 and February 2016. The court agreed, finding “no change either in the law or in the relevant facts”.

That finding carried weight. The court held that the 2015 ruling covered the later years only in the “absence” of a change in the legal setting. The 2010 order was such a change, and it suspended the very rule the double count rests on.

Liable, paid, not required

Did Adani Power pay the coal duty? Its answer has moved with the case.

In 2010, fighting the 16%, it told the High Court it would “continue to be liable” for duty on its coal. By 2015 the same court recorded its case as having “already paid duty on raw materials, namely, coal”. The government’s lawyer described a letter the company sent in September 2015. In it, Adani Power put the duty benefit it had taken at Rs 963.94 crore and the duty it had paid at Rs 458.50 crore.

In June 2017 the group gave another answer. Asked by the Economic and Political Weekly about its tax benefits, the Adani Group’s chief legal officer wrote: “we are not required to pay any duty/levy on the goods imported/procured in SEZ”.

The Adani Group’s chief legal officer to the Economic and Political Weekly, June 2017, as republished by The Wire.

The bill still open

Since 2017-18, Adani Power’s annual reports have disclosed a demand from the Development Commissioner of the Mundra zone. It is for duty on raw materials used for power sold outside the zone, covering 2009-10 to 2014-15. The amount is Rs 963.94 crore, and the company is contesting it. That is the same figure as the duty benefit in its 2015 letter. The 2018-19 report called it “custom duty on coal”.

So the government suspended the coal duty from September 2010, then demanded it for years that include the suspension. The Supreme Court refunded the power tax as though the duty had applied throughout.

The company has also said who would carry the cost if it lost. Its reports describe such duties as “eligible to be made good” under its power purchase agreements with distribution companies. Every report from 2017-18 to 2025-26 repeats the line. Since 2022-23 the reports add that the company has “not considered this as contingent liabilities”, meaning it does not list the demand even as a possible bill.

Adani Power annual report 2025-26, note 45: the Rs 963.94 crore coal duty demand, and the view that it can be made good under power contracts.

On 31 March 2026, three months after the Supreme Court ordered the power tax refunded, the auditor’s list of disputed dues still showed the Rs 963.94 crore coal duty pending before the Development Commissioner. Nothing had been paid against it under protest.

The documents this story is based on, the clearances, orders, agendas and filings, are collected in one place.

→ The documents behind this story — add your DocumentCloud link

Subscribe to UndercurrentS

Message us securely on Signal

Share on WhatsApp