Thursday, May 19, 2016

Designing taxi regulations for the 21st century

App-based aggregators are disrupting the transportation business world-wide. Existing regulatory and policy frameworks were not designed for this new reality. This has resulted in some knee-jerk reactions globally to do something. 

Nearer home, this is exemplified by Delhi Government. On May 1, the State Chief Minister had tweeted a fresh warning after Uber resumed surge pricing: “…Surge not allowed under law. They are warned that strong action will be taken against them”. This was a replay of April 18; when the CM had threatened permit cancellation and impounding of taxis that charged fares beyond the government rates. US based Uber and homegrown Ola had then suspended surge pricing.

The tweet led ban is an example of rule of law being compromised. The State implicitly allows a gap between policies and accepted market practice. The government has let the aggregator market take shape under this incompatible legal regime instead of acknowledging the new technology by issuing new rules. This displeased neither the entrenched incumbents (fixed fare auto and taxis) nor the disruptors (Ola and Uber) – a stable equilibrium.

Depending on the political situation, the regulatory muddle allows the governments to either stay mum or wash its hands off and claim that this new market was always illegal. This attitude increases the cost of doing business and the State gets stuck in a stable low-level equilibrium.

Politicians and bureaucrats tend to miss the fundamental reason for regulation: Government should intervene to address market failures - when the competitive market outcomes are not satisfactory for the society as a whole.

Realising the policy gaps, the Indian central government has now constituted a Committee to prepare a policy framework for taxi and other transport operators.

Pratik Dutta & I have an article in Business Standard (May 18, 2016) discussing how should policy makers think about taxi regulation? What are the market failures? 

Wednesday, May 11, 2016

Case Summary: NCDRC order against Jaypee Group

The National Consumer Dispute Redressal Commission (NCDRC) has in record five months ordered Jaypee Group to compensate home buyers for delay in construction. The case summary is discussed below.

The gist of the order dated May 2, 2016 is:

1. Give possession within 3 months. After that pay penalty @ Rs 5000 per day.
2. Pay delayed interest @ 12% on total amount paid by the consumer (from the original proposed allotment date to actual handover).
3. Taking money separately for parking was illegal. Refund any such amount with 12% interest.
4. Pay litigation cost @ Rs. 50,000 per complainant.

Read  the complete order: Consumer Case NO. 1479 of 2015

In the above case, the buyers of Kalypso Court apartments were promised delivery of homes in less than four years but only the structure was completed after eight years.

It is interesting to read Jaypee's defence at the NCDRC:

1. Delay has been beyond the control of the Company: (a) There was shortage of labor, scarcity of water, restrictions in excavations etc., which continued to exist for a period of 3-4 years, (b) In view of the environment order by the National Green Tribunal (NGT), the relevant authorities have been restrained granting Completion Certificates to the OP herein, since 28.10.2013.

2. Increase in saleable area at a later date was justified: After construction, upon measurement, it was realised that the area of the subject matter apartment had increased due to functional engineering necessities.

3. Fair terms: There is a provision for damages in case of delay @ Rs.10/- per sq.ft., per super area of said premises. The allottee had option to cancel the allotment.

4. The home buyers might be investors and not consumers so they should not be heard at NCDRC. This they did by asking buyers to prove that they did not purchase any other home.

On the question of delay, NCDRC noted: "This is an indisputable fact that no stay was granted by the National Green Tribunal at any time.  The complainant has raised much ado about nothing.  There was no rub in constructing the houses/flats. The OP (Jaypee) has failed to bolster its case with any kind of evidence.  It should have produced solid and unflappable evidence to show that there was shortage of labour, scarcity of water, restrictions in excavations, etc." OP refers to Opposing Party i.e. Jaypee Group in the order.

NCDRC did find some force in Jaypee's plea on increase in the area. However, this contention was rejected when it noted: "Although,  the internal area has not  been changed, even by an inch, yet, the OP (Jaypee) is claiming that the super area of the apartments has increased on account of increase in common areas,  a consequence of which, would be a financial  burden on Home Buyers...If there is any increase in the internal area, the OP (Jaypee) is entitled to get the additional amount, that too, at the rate fixed at the time of booking.  However, no such proof has been produced on record.   Consequently, we hereby hold that the OP is not entitled to any additional amount."

On the issue of parking charges, NCDRC relied on the Supreme Court judgement in Nahalchand Laloochand Private Limited Vs. Panchali Co-operative Housing Society Ltd (Civil Appeal No. 2544 of 2010) and reiterated that the promoter has no right to sell `stilt parking spaces' as these are neither `flat' nor appurtenant or attachment to a `flat'. Therefore, it rejected its claim to charge separate cost for parking.

As regards fairness of terms, the NCDRC noted that while the builder was charging interest @ 18% for any delay from the buyer, it provided for a token payment if the delay was from its side.

One the last point above, NCDRC noted:"...The OP (Jaypee Group) has made a vain attempt to make bricks without straw..."

NCDRC rejected all the allegations of Jaypee Group. It noted that the story advanced by Jaypee Group did not stack up.

NCDRC had passed an order on similar lines (Consumer Case NO. 427 of 2014) against Unitech, another defaulting builder, in 2015.

It is not at all expensive to approach the NCDRC. You don't even need to hire a lawyer though it might be a good idea to have one on your side. With the above judgement already in place, getting a similar order might not even take five months.

One can approach the NCDRC if the claim is over Rs. 1 crore. NCDRC's above order reiterates that consumers can combine and file cases together and each individual consumer need not have a claim of this limit.

It noted: "as per Section 2(1) (c) of the C.P. Act, 1986, which lays down that “one or more
consumers, where there are numerous consumers, having the same interest, with
the permission of the District Forum, on behalf of, or for the benefit of, all consumers, so

There are thousands of buyers who are stuck with Jaypee for 5-10 years.  Many other face similar predicament with their builders. Only 10 buyers came together to file the above case. It is high time more buyers rolled up their sleeves and took the first real step to a fair deal. Lack of regulatory oversight and enforcement has resulted in this situation.

Builders are betting that they can get away with huge delays and non-delivery of homes after taking bulk of the money from buyers. This needs to change.

Thursday, March 17, 2016

Why are we stuck with India Post?

People in large cities no longer need to depend on India Post except for sending occasional package/ letter to some small town, official work (Speed Post) or where official proof of delivery is needed (Registered Post). 

City folks would get stuck occasionally, like me, when they order something from US using USPS, or any other shipping where India Post is expect to bring the package home. Here is a quick guide I wrote on what a consumer should expect and do in the above case. This perhaps helps highlight one example of the postal mess. It is possible to avoid getting stuck in such cases by opting for Fedex or DHL, which though expensive, handle the customs efficiently and deliver faster.

Most city folks might therefore, generally, not feel stuck with or without India Post.

However,  larger India depends on it

India Post is an important institution. It helps connect India with its 155,000 branches. It has rolled out core banking solution in 20,000 branches. It is India's largest core banking network. In comparison, State Bank of India has about 13,000 branches. India Post disbursed Rs 11,400 crore through 6.4 crore MGNREGA accounts in 2013-14.

The fact that the concept of customer service is still largely alien outside of big cities also helps. We are elated if we are not asked for a bribe. It is expected for government run agencies to not pick up the phone or disconnect while the consumer is still explaining the problem.

Peek into the puzzling problem

In 2012-13 and 2013-14, the annual report shows the deficit to be around Rs 5,500 crore for each of these years. City folks too should bother as their taxes fund these massive losses.

These losses are more than the budget of India's space program for the corresponding years. We could potentially double ISRO's budget if this loss did not exist. While the space budget now stands increased to Rs 6000, the information on the revenue deficit of India Post for 2014-15 is not yet available. There is an annual report for 2014-15 on the website. This appears to be misleading as the data provided is one year old. It should actually be labelled as the annual report of 2013-14.

It is not just international shipping that is run in a sloppy manner. Out of 18 product lines listed as sources of revenue - the data for 2013-14 shows that India Posts makes losses on 15 of them. Of the remaining three, Book Post - Other Periodicals marginally exceeds the cost. Letter has a profit margin of 12 per cent. Only Competition Post Card shines with a profit margin of 35 per cent. Maybe, the simple Post Card needs to be subsidised and suffer losses but why nearly everything makes losses? Why does Speed Post make a loss of 41 per cent?

It is not to say that it is impossible for government agencies to do a decent job. ISRO too is government but it is generally regarded as cost efficient and high performing. Why is India Post not a patch on this?

New opportunities or worries?

Online retail is growing rapidly. This presents an opportunity for India Post in the larger India. India Post is now launching a Payments Bank which is expected to be operational by March 2017. What might give confidence that these opportunities would not turn loss making? Will India Post confine itself to delivery of government schemes to the poor?

India Post occupies large resources when it owns nearly 4500 buildings across the country and rents many others. It has a staff of 460,000 (March 2014), including 260,000 Gramin Dak Sevaks. It is inefficient and makes huge losses, year on year.

I am sure there must be ways to turn it around and a lot of things must have already been tried. Obviously, the results have not been as expected.

Should we not ask, why are we still stuck with India Post?

Ordered something using USPS - India Post? You should:

India Post's FPO near ITO, Delhi

1. Not expect timely delivery even though the package might reach India within three days.

2.  Not expect to find the helpline easily. The India Post website has reams on whom one can complain to -- but no details of customer care to get answers. For Delhi one may try 011-23233325. It took me 15-25 minutes just to connect. Their internet might be slow. If they say that there is no update on your package beyond a certain date -- request them to check if the page on their computer has loaded fully!

3. Most likely, expect delay at Customs. Do not try and contact them. No one will pick the phone. The India Post helpline will share their contact numbers, if asked. I got this email id from India Post for Customs in Delhi: fpocustoms[attherate] Did not get any response.

4. Track shipment on India Post site also. This might give some more details. My package was stuck at Customs and released after quite a delay. The reason posted on the website was "Others".

5. Know that, once the package is cleared from Customs, it will be sent to local post office corresponding to the pin code. If the package is bigger than what can be accommodated on the Postman's bicycle -- do not wait for them to deliver it. Just go and collect. Remember to carry the item tracking id, and sufficient money to pay the applicable customs duty. It might be useful to also carry a copy of invoice. I was not asked for this but then who knows. Here is one link you can use to estimate the customs duty.

6. Be able to locate the phone number of local post office. This will most likely be the number where they take bookings and not handle delivery. So one may skip this step and save time.

7. At the first point when one realises that things are getting delayed, ask the seller to initiate an inquiry from the international shipping agency like the USPS. Later, one could use the same process to initiate insurance claim process, if needed.  No point in being irritated with the seller as (in most cases) the problem is Indian Customs and India Post.

Thursday, March 10, 2016

Progress on Financial Sector Legislative Reforms

The FSLRC submitted its recommendations for structural reform of the Indian financial regulatory architecture in 2013. Subsequent budgets have promised implementation of parts of these recommendations. The Union Budget 2016 has proposed to implement a few more of these. This post takes a stock-check of the FSLRC-related promises made in the Budget Speech of 2015-16 and summarises the developments on the recommendations of the FSLRC made in this year's Budget.

FSLRC reforms promised in 2015:

The Budget Speech of 2015-16 had promised to implement the following recommendations made by the FSLRC: (i) Constitution of a monetary policy committee; (ii) Establishment of the Public Debt Management Agency (PDMA) (which was subsequently withdrawn); (iii) Constitution of a task force for setting up a Financial Redress Agency, which is intended to be an adjudicatory body for consumer protection in the financial services sector.
  1. Monetary Policy Committee: The Finance Bill, 2016 provides for a monetary policy committee by amending the RBI Act. However, the composition of the monetary policy committee is not in line with the recommendations of the FSLRC or the instructions subsequently issued by the Central Government on this subject as reflected in the Indian Financial Code1.1.
  2. A snapshot of the differences in the constitution of the MPC is summarised in the chart below:

    Differences in the constitution of the MPC
    Particulars Members appointed by RBI External members appointed by Central Government Members appointed by Central Government, in consultation with RBIGovernor veto
    IFC 1.0232Yes
    IFC 1.1340No
    Finance Bill 2016330No

    The Finance Bill, 2016 requires the Central Government to appoint the external members as per the recommendations of a Search and Selection Committee which will comprise of the Cabinet Secretary, Secretary (DEA), the RBI Governor and three experts in the field of economics, banking, monetary policy or finance, to be nominated by the Central Government.

  3. PDMA: The last year budget had proposed setting up a PDMA which will bring both India's external borrowings and domestic debt under one roof. However, the proposal was later withdrawn. The implementation document merely states that while the Government is committed to setting up the PDMA, it is in the process of preparing a detailed roadmap separating the debt management functions from the RBI in consultation with RBI.

    Accordingly, the Government and corporate bond market continues to be bifurcated between the exchange and NDS-OM platforms. In the absence of an integrated market infrastructure for Government and corporate bonds, the agenda for development of a corporate bond market in India will remain incomplete.
  4. Financial Redress Agency: The budget had proposed to create a Task Force to establish a sector-neutral Financial Redressal Agency that will address grievances against all financial service providers. The budget-implementation document merely states that the Task Force was set up on June 5, 2015.
  5. Capital Account Controls: Last year budget had proposed to amend, through the Finance Bill, Section-6 of FEMA to clearly provide that control on capital flows as equity will be exercised by the Government, in consultation with the RBI. The FSLRC had recommended placing the formulation and implementation of capital controls on a sound footing in terms of public administration and law.

    The implementation document merely notes that the process of consulting Reserve Bank on Debt and Non-debt instruments classifications is on.

Promises in Budget 2016:

  1. Specialised Resolution Regime: The Budget Speech proposes the tabling of a comprehensive law establishing a specialised resolution regime for banks and financial institutions during 2016-17. This Code will provide a specialised resolution mechanism to deal with bankruptcy situations in banks, insurance companies and financial sector entities. This Code, together with the Insolvency and Bankruptcy Code 2015 (now referred to a JPC in December 2015), will provide a comprehensive resolution mechanism.

    This is a welcome move. However, the Government must hit the road running in building the Resolution Corporation so that when the law gets enacted, the resolution machinery actually works as it is intended to.

  2. Financial Data Management Centre (FDMC): The Budget Speech proposes setting up a FDMC under the aegis of the Financial Stability Development Council (FSDC) to facilitate integrated data aggregation and analysis in the financial sector. The speech is, however, conspicuously silent on whether the Data Centre will be supported by a statute.

  3. The FSLRC's vision for this Data Centre was to provide for a nation-wide integrated repository of information relating to the financial sector, which can be used to study systemic indicators in the economy and further research in this field. As a nerve-centre for regulatory data cutting across various segments of the financial sector, the importance of this centre cannot be underestimated. This, and the obligation on regulators to share the information with the Data Centre, underscore the importance of a statutory instrument to make the Data Centre work.

Further developments on FSLRC proposals

  • Merger of SEBI-FMC: One of the fundamental proposals made by the FSLRC was to constitute a unified regulator for financial products and financial services, except for the purposes of banking. As a step towards integration, the FMC was merged into SEBI under the Finance Act, 2015. The merger was effected in September 2015 and SEBI now regulates the commodities and the securities markets.
  • Building other agencies envisaged by FSLRC: In 2014-15, the Government had constituted four task forces for building the institutions envisaged under the Indian Financial Code. This could easily be classified as a first attempt of its kind by the Central Government to build institutional capacity of this scale in India.

    The Task Forces submitted their recommendations in June 2015. The budget-implementation document states that the Central Government is in the process of considering the recommendations made by the Task Forces.
  • Indian Financial Code: In June 2015, the Ministry of Finance released for public comments a version of the Indian Financial Code (IFC1.1) which was refined and revised on the basis of public feedback received from March 2013 onwards. The implementation document states that the Government has consolidated the comments received during Public Consultation in July-August 2015 and the government is in process of responding to public comments, and is assessing the preparatory work involved to gauge a realistic target for introducing IFC1.1 in Parliament.


The FSLRC envisaged creation of a new financial regulatory architecture with each element complementing the other. The recommendations are in danger of being taken up on a piecemeal basis. This should be avoided as it would result in less than optimum outcomes.

It is going to be one year since the four task forces have submitted their recommendations and over six months since public comments were received on IFC 1.1. The Task Force on FRA should submit its recommendations by June, based on its tenure. It would be useful for the government to provide a plan to implement the IFC 1.1 and simultaneously operationalise the agencies recommended.

Wednesday, March 09, 2016

Full text of NGT order: Rs 5 crore pass for Art of Living Foundation to run its WCF!

Read the full text of the NGT order passed today. The gist is:

  1. The Applicant (complainant) approached the NGT at a late stage (wrote to the Lt. Governor on 11.12.2015 but approached NGT only on 08.02.2016) and by then the damage was already done -- NGT now cannot stop the event and ask for removal of the construction material and restoration of the area at this stage.
  2. Applicant did not do full homework (did not challenge DDA's permission dated 30.06.2015) but still the case could not be rejected outright.
  3. Delhi Pollution Control Committee (DPCC) did not apply its mind when it said it was not required to give any permission in this case.  DPCC failed to discharge its statutory obligation despite the fact that the Foundation had submitted an application for obtaining its consent. The Board failed to exercise due diligence and  exercised its authority improperly. For all the trouble, DPCC got away with a cost of Rs. 1 lakh imposed on it.
  4. Art of Living Foundation submitted its application to all the agencies:
    • Police Department, Fire Department did nothing (not give permission or stop any action): NGT said they failed to exercise due diligence in fulfilment of their public duties.
    • Ministry of Water Resources, River Development and Ganga Rejuvenation did nothing (did not give permission or stop any action): NGT said, in terms of the Notification dated 31st July, 2014, this Ministry is the Authority responsible for conservation, development, management and control of water pollution of River Yamuna -- it failed to exercise due diligence in fulfilment of their public duties.
    • Ministry of Environment, Forest and Climate Change: NGT did not accept the contention of the ministry that it was not required for the Foundation to seek Environmental Clearance for the project relating to all matters of construction etc. as afore-referred. It noted that the stand of MoEF&CC is contrary to the Notification, particularly with respect to development of an area of more than 50 ha. as contained in the EIA Notification, 2006.
    • Government of NCT of Delhi: NGT noted that the permission granted by the Delhi Government was of no consequence as it was permission only for flood situation (flood in March -- I wish!).
    • DDA: Permission granted dated 30.06.2015: NGT noted that this was a vague permission. It said in its order,"the permission is not in consonance with the orders of the NGT and in fact is in excess of the powers vested in DDA which runs contrary to the spirit of the judgment of the Tribunal. This cannot be termed as a recreational activity simplicitor. Cultural activity could be recreational but the entire construction of ramps, roads, accumulation of debris, alteration of the natural topography and removal of natural vegetation from the flood plains, cannot be said to be recreational. It is a complete project in itself and the DDA ought to have applied its mind. Strangely, it has neither conducted inspection of the site prior to the grant of permission nor during operation or subsequent thereto. " For all this failure, DDA got a ticket of Rs 5 lakhs for failure to perform its statutory duties.
  5. The NGT ordered that the DDA shall not, in future, issue such permission and any permission issued by the DDA or any State/Authority in relation to flood plain of River Yamuna, shall be subject to the orders of the Tribunal.
  6. For the damage done, Art of Living is to deposit Rs 5 crore initially.
  7. The Principal Committee formed under the judgement to report on the steps needed for restoration and estimated cost within 4 weeks.
  8. The entire area in question shall be developed as a biodiversity park in terms of our judgment in the case of Manoj Mishra (supra).
  9. The cost thereof shall be paid by the Foundation and DDA in the proportion as would be directed by the Tribunal finally.  
The above is a good example of poor laws and terrible enforcement.

Yamuna floodplains destruction: photos today - March 9, 2016

Main stage

Back side of stage

From  Mayur Vihar leaf of the DND flyway

Pontoon bridge

Tuesday, March 08, 2016

Yamuna: The river is dead. Grab the land.

If it was possible to kill a river which was already dead -- the Art of Living's World Culture Festival planned for 11-13 March 2016 has managed to do it by ruining about 1000 acres of Yamuna's floodplains.

The National Green Tribunal (NGT) appointed expert committee which visited the site on 20.2.2016 had observed in its report:
  1. Entire flood plain between river and DND flyway has been levelled, all natural vegetation removed.
  2. Construction debris are dumped/ used on the roads that are constructed.
  3. Two ramps have been constructed joining DND flyway with the stage using construction debris and earth.
  4. One pontoon bridge has been constructed and other is in process.
  5. Most trees have been chopped/ removed.
  6. Parking sites are proposed on eastern and western side of floodplain and approach roads to the same will be constructed and 650 portable toilets will be placed.
  7. Several large portable enclosures have been erected for different functions, offices and facilities for performers.
  8. An enormous stage (1200 feet long, 200 feet wide and 40 feet high) is being erected with the help of scaffolding of steel pipes. This is expected to support 10's of thousands of musicians, performers and dancers during the function.
  9. Entire site is littered with construction material. A network of access roads to the parking lots will be constructed from Noida link road and NH-24.
  10. On the western side, 50-60 hectares has been completely destroyed and all vegetation, trees, birds etc have vanished.
  11. The permission given by DDA is in complete violation of NGT order dated 13.01.2015.

Says, don't stop the crime

Having said all this, the committee meekly reports there is an urgent need to restore the area damaged by the organisers soon after the festival is over. Since extensive and severe damage is already done, simply stoppage of activity and removal of all that has been done at this juncture may not serve much purpose!!

The committee in its report places confidence in its interaction with one Mr. Gautam Vig (director, Art of Living) that only 2-3 lakh people are expected though the preparation are on to accommodate 35 lakh people. It recommends that in light of the revised plan, the area used should be minimised.

The committee recommends a penalty of Rs 100-120 crore on the organisers and restoration plan be implemented in one year. It recommends that a strong message must go to DDA. Pray, what that might be? It does not suggest.

Rule of law

I am not sure whether to laugh or throw up in disgust.
  • The run up to Commonwealth games in 2010, led to permanent (in the garb of temporary structure) construction of an entire housing colony (Games Village), stadium (sports club) spread over 157 acres.
  • The massive 60 acre permanent (again in the garb of being a temporary structure) DTC Millennium Park Bus Depot came up on the other side of the river where DTC runs its depots and repairs -- causing incalculable damage. This, as per Wikipedia, is supposed to the largest bus depot in the world.
  • The Delhi Metro too has abused the river, constructing Delhi Metro Depot called as Yamuna Depot, the Metro Mall and station (Akshardham station), Yamuna Bank Station and apartment blocks for its staff on the floodplains of the river.
  • When the huge Akshardham temple was constructed during 2000-2005 on over 60 acres of flood plain, I used to sit during some weekends at the construction site and watch the floodplains getting concretised.
  • Earlier, around 1994-95, about 20 years back, I had seen the construction of pontoon bridge on the river to connect Mayur Vihar - 1 to Sarai Kale Khan Bus Terminal. Later, this was disbanded and permanent slums came up on either side as encroachment.

All this has happened in the last 20 years -- in front of my eyes and within a few kilometre from my home. There is much more to be be said about the destruction/encroachment of river floodplain across the city. It is not that people have not complained and that cases have not been filed in courts. Just like the present example of Art of Living -- cases were filed earlier too. Nothing came of them.

When a poor person observes all this and he also sees his hut getting pulled down or his small shop demolished because of encroachment -- it must be hard for him to reconcile that he is being fairly punished for his wrong.

My dad says that the law is not same for the powerful and the ordinary. I want to disagree. I believe we need to strengthen our enforcement and strengthen our laws.


1. Art of Living

Why did the expert committee say that it was no use stopping the Art of Living Festival? If the function is stopped -- it will really send a strong message to everyone, right? Stop them and fine them. Do we let a murder continue just because it is already in process?

2. DDA

Why should all the top brass of DDA be not sent to jail for contempt of court? Why should they not be fired from their jobs and individually penalised?

3. Central Government

Why is the Prime Minister silent? Should he not have said that he will not attend such an event? After all, he won the election from Varanasi and one of his promise was to clean river Ganga! How could he let this happen to Yamuna then? What was the irrigation department, ministry of environment etc doing? Why is Indian Army constructing the pontoon bridges for the Art of Living event?

4. State Government

It is reported that Delhi water minister is supporting the event. What is the Chief Minister Kejriwal doing? Why is he not sitting on dharna along with Manish Sisodia and his Aam Aadmi on the construction site?

5. Opposition

Why is Rahul Gandhi not agitating about this?

I don't know. Maybe river Yamuna does not vote. Makes it even easier to rob than voters.

6. Media

There is some news in Media about all this. But surprisingly, not enough. The nation wants to know. Why?

Where is hope?

Yesterday night when I was going back home from work -- the flood plains were flood lit and construction was in full swing. It was a sight to see. People were stopping to click pictures. I did not see many on Facebook, lamenting the crime that is taking place. Why? The radio jockey on my morning office drive too wondered - what if birds get killed? After all, they are birds.

I will pack up in a few minutes and head back home -- see the Art of Living construction stand like a huge monster on fire in the darkness near the DND flyway. Somewhere, I am almost hoping, there is heavy rain during 11-13th. What if we have massive floods this monsoon and the river reclaims its space?