International Gypsy

Monday, September 01, 2014

First 3 weeks of Premier League: Arsenal and Chelsea - two extremes of squad planning

After the first three weeks of the Premier League, it is clear Chelsea are the team to beat. Man City and Liverpool have both dropped points. In the second tier, Spurs and Everton have shown a lot of promise and Swansea look all set to challenge them in a big way. Teams like Stoke, Southampton continue to perform strongly while newly promoted Leicester are the reason why EPL is the most competitive league in the world.  
That brings me to my team, The Gunners. I can bring out all the excuses in the world on how we had two really physical and demanding games against Besiktas, our key players are injured, our major players have not had enough practice etc. etc. but the fact remains we have not looked or played like title contenders in first five competitive games of the season.
This transfer window was going to be an opportunity for the Club to build on last season’s equity.  Yes we finished fourth yet again but we had the momentum after winning the FA cup. Champions League football, a storied history and London location should have been enough to lure quality players to build a squad that can compete for all the titles. We have clear gaps in the squad – a world class striker, a top defensive mid fielder and reinforcements at the center back position.
We bought well in Chambers and Debuchy – they are emerging stars and add to the depth of the squad.  Alexis is an expensive buy but promising – he however does not fill the gap at striker position and we have enough wingers who could be the false number nine. Alexis costing more than Diego Costa however still beats all the sense that’s left in the football world. Of course, one can justify that by pointing me to David Luiz transfer price but then that was plain and pure insanity.
I am writing this with a few hours still to go and if rumors are to be believed, we have Danny Welbeck coming to the Emirates – quite a revenge on United after they took away RVP and won the league!
While I still fully subscribe to Wenger’s philosophy of keeping the transfer market sane and keeping players inflated wages and egos in check but that does not take away the fact we have a problem in how the squad is being built every year. It just does not seem like we are building the squad to be serious contenders. We start every year with gaps in the squad, be it for the top 11 on the pitch or for maintaining the depth. Giroud and Sonogo are not the strikers who, even if they remain fully fit throughout the season, can win you the league. Similarly, you cannot go into a season where you are competing in Champions League with defensive midfield pair of Arteta and Flamini. They are both past their primes and at best make good squad players to add depth and rotation.
Chelsea on the other hand provide a perfect template of planning for a title contenders’ squad. You don’t have a goal scorer – buy Diego Costa early in the transfer window. You need to revamp your game and make it more fluid and creative – buy Fabregas. Need a quality back up to Costa – loan out Torres and buy Remy. You need to manage financial restrictions imposed by governing authority – sell luxury players like Luiz and Mata. In a year’s time, Mourinho has not only built a serious title contender squad but also revamped the playing style to make it more fluid, creative and attractive. A squad that can not only win but also get the love of fans all over the world for the playing style and philosophy.
We on the other hand seem to be either stuck in the past or owned by a management that is looking to squeeze out as much dividends as possible until the fans run out of patience. It is too early to call the season though - there are still four hours to go and of course the promise of Alexis and Ozil that combined with the grit of Ramsey and work ethic of Carzola can reignite hopes. 


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Friday, December 20, 2013

India's Reaction to Kobhragade Arrest - Excessive, Unbecoming of an Aspiring Superpower

If you belong to a party that just lost assembly elections in four out of five States and are increasingly poised to loose the General Elections in 2014 in a humiliating fashion, all you wish for is an episode such as Devyani Kobhragade's arrest. It presents to you an enticing opportunity of appearing tough, shifts the discussion from corruption and governance to that of hurt pride and seek revenge even if such a reaction may not be the ideal thing to do for an aspiring superpower.

Similarly, if you happen to be a leader of the BJP that just won all of the four elections and is expected to win the 2014 General Elections, you are left with no choice but to search for a tougher line than your opponent, howsoever ludicrous, even if it may undermine the foreign policy your previous government and leaders worked tirelessly for.

And of course, if you happen to represent the most despicable face of India's identity based politics, you make it a Dalit issue and hope enough of your followers remain dumb enough to keep voting for you. Mayawati, obviously did not know that Devyani Khobragade achieved a rank of 168 in her civil service examination which does not get you into the IFS unless you happen to enjoy the special privileges of belonging to the SC/ST category.

The above largely sums up why India (The Government, Media, Social Media and the Chattering Class) reacted the way we did on the arrest and strip search of a diplomat by the US. Cheap domestic political interests overpowered the larger foreign policy interests of the Nation.

It goes without saying that the treatment handed out to our diplomat was heavy handed and we needed to express outrage and take it up strongly through the official channels. But by stripping down the security barriers, taking away diplomatic privileges of the American consulate members, imposing a ban on import of food and liquor for the embassy staff, raising calls for arrest of homosexual partners of the embassy staff and our leaders refusing to meet the visiting American delegation, we have ended up far exceeding American Arrogance with our stupidity. The way American police reacted is of course not how you treat the diplomat of any country, at least not that of a country you project as a strategic ally but you also don't act the way we did when you keep staking your claim to be the next superpower and a permanent member of the UN Security Council.

Devyani Kobhragade is a seasoned bureaucrat having been in the IFS since 1999. She is the daughter of a retired IAS officer. She, of all people, must know not to violate the law of the country in which you are posted. When you declare 11 immovable properties on your profile including an apartment in the Adarsh Society and happen to be the 2nd highest ranking official at India's Embassy in the US, the least you should be able to afford is to pay minimum wage to your baby-sitter. You decide not to do it because at some level you believe yourself to be above the law and consider a domestic help helpless. Or perhaps because you could use all your political connections and might in evading prosecution in the Adarsh Society scam, you tend to assume immunity for acts of corruption.

Devyani moreover is not the first Indian diplomat to have exploited their domestic help in the US. We have had two of our high ranking diplomats in US accused of the same in the recent past, one having been ordered to pay as much as US$1.5 million in penalties.

Washington Post (Link) , New York Times (NYT Link) and Financial Times (FT Link) have published their opinion pieces on the events largely holding India at fault. Their editorials are read by global audience which helps shape the perception of our country overseas. The image that emerges of India from this episode is of a country that does not care or respect the laws and is willing to throw its weight behind the dignity of a dishonest diplomat while showing no concern to the plight of the domestic help who may be the real victim here. Salman KHurshied in his interviews on the television dealt another blow to our reputation by saying our diplomats underpay the domestic helps all the time and that is not really bad. His interview paints the image of us as a country where as long as violation of a law happens all the time, it is OK and while law may be same for everyone in letter, its implementation is different for different people.

Germany didn't react the way we did at the news of US spying on Merkel. Even we didn't react the way we have done now when Snowden's leaks showed NSA spied on Indian Embassy. The reaction this time is purely an outcome of political posturing for garnering momentum at the cost of jeopardizing foreign policy. Our leaders do that all the time - we have lost an ally in Sri Lanka due to Tamil Politics at home and we are increasingly loosing allies in our neighborhood for lack of vision and tactical oversight in our foreign policy setup.

Once again, I am not saying what US did was right - they could have asked India to remove Devyani or accorded her more courtesies before putting her through an arrest. A strip search could have clearly been avoided. But our reaction has clearly absolved the US from its misconduct. The US government can express regret for the cause of larger relationship while their legal system keeps its head high for passionately defending the law of the land. We on the other hand emerge as a country that claims to be a superpower in the making but plays the victim card at the slightest of opportunity. Perhaps our government, politicians and media would do well to realize, it pays to be tactical and strategic in foreign relations rather than oscillate between being a lap-dog or a wild cat.

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Friday, December 21, 2012

Another Rape in Delhi and Gun Violence in US conclude an 'Outright Depressing' 2012

2012 has been an outright disappointing year. A latest event each in the two countries I am physically and emotionally affiliated with sum up the disappointment and outrage I have felt many times during the course of the year.

A young woman got raped, beaten and thrown out of a moving bus to die on the sidewalks with her boyfriend who too was physically crushed in the city I call home, Delhi. This was not an isolated incident. This was the 10th such instance of rape in a moving vehicle and one of 550 rape cases that are reported in Delhi each year. We have seen a medical school student raped in broad day light and we have seen several working women raped on their way back home from work. Response of police and politicians remains the same - the victim must have done something to invite the brutality upon herself.

Our three term Chief Minister (CM), most likely to be fourth term, has made outrageous comments every time a case is reported. This time, her reaction was to proudly report cancellation of the bus license and direct further queries to police. Public outrage forced her to dispassionately suggest several policy actions and constitution of a committee to recommend action. In past, she blamed the murder of a female journalist upon the murdered victim  herself as she was being too adventurous to be out at 3 in the morning. Her idea of instilling a sense of security among women in Delhi – women should not work; if they necessarily need to, to make ends meet then they must be home before dark; they should preferably have a male escort and not use public transport. 

I would however be naive to suggest better enforcement can eradicate Delhi’s rape problem. Rot runs much deeper into Delhi's society. Lack of empathy, widespread incivility, pompous mindset, an undeserved sense of superiority and omnipresent political and bureaucratic corruption that has driven people to stop fearing the law, are as much to blame for the rape problem.

Unlike Mumbai where a hard working lower middle class incumbent is content in the surrounding of mega rich, his Delhi counterpart harbors a feeling of contempt and envy towards the affluent. While working harder is key to success for this Mumbai man, his Delhi counterpart sees it as a zero sum game, trying to push someone down to rise up. While people in Mumbai appear cold and indifferent on the outside, they have a genuine sense of compassion. People in Delhi appear warm and friendly on the outside but are often found lacking genuineness. One thinks before committing a crime in Mumbai for the fear of the parallel justice system that I believe runs stronger than police. In Delhi no system exists except the system of corrupt connections everyone happily flaunts. This is a very broad generalization but having lived in both the cities, the differences stand out and reflect in each city's status as the safest and most unsafe city for women in India.  

Delhi is my home, a city I so much love for the history, food, diversity, open spaces and several top universities. It hurts me that Delhi is firmly acknowledged as the rape capital of India. The disturbing lack of empathy from the executive class and police coupled with the deep societal flaws hurt me even more as there does not appear to be a near term fix to this most inhumane of all crimes.

Second event took place a week back in the country I currently live in. A mentally ill young man with easy access to guns rampaged his way through an elementary school killing 20 innocent children and 6 adults. This again was not an isolated incidence. 
A few weeks back, a pro football player shot his girlfriend and then shot himself. Before that, there was the Colorado shooting in a movie theater killing 12 and injuring 58. There was the 2011 Tucson shooting where congresswoman Giffords was shot. 

There are over 32,000 deaths each year due to gun violence in the US. 40% of the gun sales take place without background checks. There is easy access to those denied legitimate sale in the second hand and black market. Web sites and blogs promoted by the gun industry provide assembling manuals for those ineligible to buy guns so that they can rather by spare parts and assemble one themselves. Gun markets are organized just like Christmas and Halloween costume markets. Civilians have access to automatic weapons. 

Everyone knows what needs to be done but a small minority of gun fanatics (aprx 4 million members pay monthly membership to the NRA) and their collective lobbying power outweighs the collective conscience and will of the rest of America and her politicians.

NRA brazenly held a press conference today to make a pitch for even more guns in the street, recommending the country be transformed into a curfew-ed war zone to protect children and innocent civilians. President Obama arrogantly responded to a reporter who asked, ‘where you have been on this issue’ as I have been the President of the United States overseeing the worse economic recession since the Great depression. Quite clearly human lives matter less than economy.  He conveniently forgot to mention he was busy campaigning for more than a year to get reelected and is still campaigning rather than get his hands dirty and try solving many issues this great country faces.

Republicans quite shamelessly continue to beat their trumpet of protecting the constitutional right to bear firearms no matter what. Their key argument being guns don't kill people but people kill people. That way, even weapons of mass destruction (WMD) don’t kill people but people who operate those WMDs kill people.  Sounds ridiculous enough I know but tune into fox news or read gun right blogs for the most outrageously ridiculous arguments in favor of guns.

I can only hope with my sincerest of wishes that 2013 be a better year.

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Friday, October 12, 2012

Repository of my articles published on HuffPost, Technocrati and Niti Central

I have been making efforts to write for a wider audience in newspapers and magazines. My articles published so far are listed below:

Published on Niti Central:

Institutionalisation of Corruption under Congress - 10/10/12

Depiction of women in Indian television needs a rethink - 09/26/12

BJP is justified in disrupting Parliament over Coalgate - 09/16/12

Published on Huffington Post:

Why I Lost My Fascination for the Republican Party - 08/29/12

Common Sense Rebuttal of FHFA's 'Mortgage Principal Waiver' Denial - 08/08/12

Published on Technocrati:

Arsenal and Van Persie Transfer Saga - Why European Soccer Needs Payroll Caps - 07/13/12

Break-up of EU and Euro Inevitable - 01/11/12

'Collective Identity' and the EU Failure - 12/02/11


Tuesday, September 25, 2012

Meaningless Reforms that Distract, bring out yet again the Ineptitude of UPA Govt.

We are probably the most innocently naive subjects of a contemporary democracy. Last week Prime Minister Singh announced a few policy actions disguised as major reforms. These reforms were widely hailed by the media as the second inning of Prime Minister Singh. Commentators across the media networks and intellectual community decided to forget the ineptitude and corrupt governance choosing instead to re-brand him as a courageous leader who is not afraid to fight with the firebrand and errant Mamata and put his government to risk. Media narrative and discussions shifted to whether Congress would be able to retain majority, if these reforms were good or bad and if this meant UPA was back in action after years of slumber. We conveniently chose to shrug aside a report from the UN that India is home to the highest number of infant deaths in the world due to lack of healthcare and nutrition. We forgot Coalgate which had made us forget 2G which in turn had made us forget CWG which in its own very recent era made us forget cash for votes and the list can go on.

Let us examine the much praised reforms for their practical utility:

Petroleum pricing - I discussed this particular issue in details in earlier post (Read here). Rationing of LPG is an intellectually bankrupt decision and would create a black market for corrupt politicians and dealers. Diesel price hike and excise cut on petrol were good steps that had to be taken out of necessity. No action on Kerosene was yet again a clear signal this government has no intent to reform petroleum pricing and it wont let go of its legitimate black money machine.

FDI in Retail - I am a supporter of FDI in retail. BJP is both wrong and hypocritical in opposing FDI in retail when the party itself proposed this when in power.

40% of fresh produce goes waste in India due to supply chain bottlenecks. Farmers get a fraction of retail price while middlemen pocket all the profits. Retail labor productivity in India is 6% that of the US. In food retailing, it is 14% that of Brazil. Modern trade and an integrated supply chain is the solution to both lower prices at retail end and better incomes to the farmers and producers. As far as fears of jobs is concerned; firstly Big Bazaar, Spencers, Pentaloons, Shoppers Stop and otters are now present in all major cities and I have not seen any report that quantifies job losses or destruction of local communities as is widely propagated by the critics, secondly every change naturally leads to a disruption to the status quo and therefore there is no argument to protect the status quo that promotes inefficient subsistence retailing and illegal hawkers.

In all the developed and majoremerging nations, big box hypermarkets, supermarkets, specialty retailers and mom and pop stores have learned to coexist and I see no reason why it wont be the case in India.

So I should be all praise for this reform except that it comes with a caveat that renders it meaningless. UPA government has conveniently left final approval of opening a store owned by a foreign investor to concerned states!. This condition makes this reform meaningless. No retailer would invest in India knowing very well that it may very well end up with a holding company approved by the central government but no scale as State Government hold on to approvals. Congress led Kerala has already rejected FDI in retail in addition to opposition ruled states. There are a number of other ludicrous restrictions and conditions that raise more questions on the policy than answers (Read here). I need not mention this same government had launched this reform in Nov 11 and took it back under protest from its allies and that Congress had dubbed FDI in retail as 'Anti National' when BJP proposed FDI in retail. So this particular reform is not only half hearted aimed to fool people but also hypocritical.

FDI in aviation - A welcome step indeed. Who would invest is a question we all know the answer of - no one!. Aviation industry globally is in a turmoil. Japan Airlines just came out of recession. Most of American airlines are either coming out of bankruptcy or going through bankruptcy. Qantas is struggling. If one needs to invest in the Aviation sector, there are many lucrative destinations. Air India is a mess that cant be cleaned up. Jet, Spicejet and Indigo are fighting the battle to make money and be sustainable. Kingfisher is bankrupt and I doubt if anyone would invest there. A real reform in aviation would have been the decision to shut down Air India, auction its assets and save taxpayers the promised $ 5 bn bailout over next few years. Second reform would have been to mandate state government standardize sales tax on aviation fuel and reduce taxes that treat air travel as a luxury.

In conclusion, policy announcement of last week mean practically nothing. When someone with an average level of intelligence knows that, I am sure our technocrat economist PM knows it. But the reforms serve a great deal of political purpose. It has taken the focus away from corruption, once again given people who view Prime Minister Singh as a person of integrity a reason to believe in him and positioned the UPA as taking a step to reform in challenging times while BJP keeps whining as aggrieved opposition.

In truth, it has once again brought to the forefront the ugly face of out parliamentary democracy where majorities can be cobbled together by promising special favors to opportunistic regional leaders. Regional leaders whose only interest lies in keeping power in their respective states, who do not even remotely share ideology or style of governance with the government they choose to support and are often the worse of the lot up for grabs either for money or concessions.

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Friday, September 14, 2012

Need for a Transformational Change in Fuel Policy not Random Pricing, Rationing, Inefficiencies and Corruption

As always the news of fuel price hike was met with much criticism across the political aisle including those of the ruling government's alies while social media was abuzz with creativity in showing the effects of such a hike. My favorite was a marketing pitch for petrol sachets.

Keeping the criticism of the masses and my personal belief that government must get out of industry keeping no role to play in setting fuel prices aside, increasing diesel prices and reducing excise on petrol was for once a sensible decision taken by the government.

I broke down the cost of petrol in my earlier blog (Read Here) - c. 40% of the retail price of petrol is made up of Cental and State taxes. These high taxes on petrol have long been put justified in the disguise of cross subsidizing diesel, kerosene and LPG. This cross subsidization however serves no purpose. Cheaper diesel has led to proliferation of diesel run passenger cars and SUVs cuasing unreasonably high consumption of diesel. Diesel as we know is an extremely high polluting fuel compared to petrol. Kerosene on the other hand has been rampantly adulterated with petrol causing engine and environmental damage while creating another avenue for black money in the system. Reduction of central excise on Petrol by 5.3 a litre is therefore a step in the right direction. Increasing the price of diesel is certainly going to lead to a slight jump in inflation across the board but we cannot always escape the hard reality of global markets where crude prices have jumped more than 30% in last 3 months due to speculation and middle east uncertainties. 

Only way to manage price stability is for the oil companies to effectively and opportunistically use hedging instruments which would never happen as long as they are government owned and dont have any incentive to improve efficiencies and compete in an free market environment.  

Turning to no price hike in kerosene - in a fractured coalition and messy democracy like ours, it is more or less blasphemous to expect an increase or rather rationalization of kerosene prices. Black marketing of kerosene has become so intertwined with the corrupt political system and bloated bureaucracy that no one would ever dare plug the spigot that feeds politicians' and middlemen's Swiss accounts. Narasimha D Rao of 'International Institute for Applied Systems Analysis' concludes in 'Energy For Sustainable Development' March 2012 issue, 'kerosene subsidies are regressive and of minimal financial value to poor rural households. This is in part because household quotas are based on cooking needs, but kerosene is used predominantly for lighting. In urban areas, subsidies are progressive, and provide benefits of up to 5 to 10% of household expenditure among poorer households which lack affordable access to LPG and biomass. Overall, only 26% of the total subsidy value directly reaches households'. Another study was more liberal to the government and mentioned c. 40% of kerosene is stolen and never reaches intended beneficiaries.

Based on this, kerosene subsidies are the biggest and longest running scam India has ever seen still going strong. Based on mid point of this 74% and 40% loss estimated by the two studies mentioned earlier and last years subsidy of $4 Bn, here is $2.3 Bn in corrupt money warming politicians/middlemen pockets annually.

I dont want to sound an environmental activist here but common sense thinking would suggest a better policy would be to give intended beneficiaries access to cleaner cooking and lighting options than subsidize what is quite clearly the most inefficient, environmentally disastrous and unhealthy option.

The decision to limit LPG cylinders at subsidized rates to 6 per family however was an antiquated and intellectually bereft decision that one has compromised to expect from this government headed by a renowned technocrat. A two tier pricing structure often leads to a black market. Indian scam-artists' and local politicians' ingenuity would right away lead to a flood of bogus gas connections and quota on those bogus connections would make it to genuine middle class families at 600 a piece compared to the full priced 750 cylinder. Families would be waiting for a long time to get their subsidized cylinders while the 600 a pop would be available instantly. So wait and watch as this latest experiments makes many millionaires while housewives tackle yet another complication in their already stretched tiger mom inspired life.

I would prefer a policy that eliminates all the subsidies on LPG, petrol, diesel and kerosene in return for elimination of import duty on crude, reduction in all central government taxes to the minimum bracket and incentive to private sector to invest in building pipelines and efficient refineries. Inefficient refining adds c. 1.5 a litre to price while inefficient trucks based transport and vested interests in dealer network and marketing adds another 4 bucks of inefficiencies. I would have added investment in public transport to this wish list as well but that would make me an eternal but naive optimist. The wish list above makes me more or less an enemy of socialists but keeps me among sane eternal optimists nonetheless.

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Wednesday, September 05, 2012

India's Competitiveness - A fall of 10 places from 2009-2012

If the news of GDP growth slowing to 5.5 pct last quarter was not bad enough, India's competitiveness in 2012 dropped 3 places to 59.

Quoting from the report:
  • Since reaching its peak at 49th in 2009, India has lost 10 places. Once ahead of Brazil and South Africa, India now trails them by some 10 places and lags behind China by a margin of 30 positions.
  • The country’s supply of transport, ICT, and energy infrastructure remains largely insufficient and ill-adapted to the needs of the economy (84th).
  • The picture is even bleaker in the health and basic education pillar (101st). Despite improvements across the board over the past few years, poor public health and education standards remain a prime cause of India’s low productivity.
  • Once ranked a satisfactory 37th in 'Trust in Institutions' dimension, India now ranks 70th driven largely by lack of trust in politicians (106th).
  • The macroeconomic environment (99th) continues to be characterized by large and repeated public deficits and the highest debt-to-GDP ratio among the BRICS.
Despite the above, report does point out a couple of strengths:
  • Fairly well developed and sophisticated financial market (21st) that can channel financial resources to good use.
  • Reasonably sophisticated (40th) and innovative (41th) businesses.
The decline in competitiveness should come as no surprise to anyone given that the current government has been focused in carrying out and then managing the fallout of scandals failing to push through any meaningful reforms, especially in the last 3 years during which we lost 10 places in competitiveness.

In the recent past, we have seen corruption at an unprecedented scale (Commonwealth games, Defense procurement, 2G, Coalgate, Thorium etc), widespread failure in the running and maintenance of existing infrastructure (grid failures, T&D losses, coal mining below potential, railway accidents etc), repeated delays and cost overruns in infrastructure projects (Bangalore Metro, JNPT upgrade, Delhi Mumbai Industrial corridor, numerous power plants and the list can go on) and policy and regulatory gridlock leading to delays and uncertainty in private sector and FDI ($12 Bn Posco steel plant, $9 Bn Mittal Steel plant, multi-billion dollar Himalayan Ski Village project near Manali, Vodafone tax dispute, renegotiation of Mauritius tax treaty. FDI in retail etc). 

Incompetence of this government is so widespread that finding adjectives to describe the tragic state of affairs is difficult. Times Magazine's portrayal of Manmohan Singh (MMS) as an 'Underachiever' and Washington Post's description of him as a 'Tragic Figure' can be characterized as a mild judgement at best. It does not come as surprise that the day India dropped 3 places in competitiveness, this Government was demanding an apology from Washington Post for labeling MMS as 'Tragic Figure' and trying to push through a bill that would kill little remaining meritocracy among government employees.

Reports highlight of the two areas of strength also do not come as a surprise. Reserve Bank of India (RBI) is the only institutions that has managed to remain independent and take tough and independent decisions regarding bank supervision and conduct of monetary policy. While one could argue RBI has been painfully slow in opening up the banking sector to foreign competition and launch reforms that would create a corporate bond market and foster efficiency, it could not be denied that RBI has managed the monetary policy impeccably despite governments push to keep rates low, supervised banks diligently to limit credit risk and been pragmatic in helping them manage cyclical risks in a downturn.

Similarly the vibrancy of our private sector is a hallmark of our culture that places a lot of emphasis on hard work (talking about work life balance is more or less still taboo), education, mobility and most importantly to learn to succeed despite the government.

I am eager to see how long the party continues on these two fronts given that private sector is beginning to feel more and more disenchanted with lack of infrastructure and an extremely inefficient judiciary coupled with an uncertain regulatory environment while government is eager to get RBI into its fold to pander to minorities (islamic banking), direct lending to its cronies and manage an ever growing deficit at low rates.

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