Effectiveness of SCORES system in Investor Protection and Dispute Resolution

I. Abstract

India’s main institutional mechanism for investor’s grievance redressal against listed companies registered intermediaries, and market infrastructure institutions is the SEBI complaints redress mechanism (SCORES) with an aim to ensure swift and transparent resolution under the SEBI Act 1992, and allied laws. SCORES 2.0 has been introduced in April 2024 to provide more better grievance redressal mechanism still the platform’s effectiveness as a tool to protect investors is still compromised by fundamental structural restrictions. Doctrinal legal research supplemented with organized case laws analysis are incorporated to assess SCORES’ efficacy.

The study examines whether SCORES as currently designed and operated constitutes a true investor protection tool, or significant relief turns out to be missing even if SCORES acts as intended. Accountability slips through cracks in SCORES’s system when handling big-time fraud cases, opaque steps, sudden shifts to MI/ODR portals, and no external checks end up leaving key holes in trust.

SAT rulings like Varun beverages case sets a precedent that makes SCORE’s missteps look methodical, not accidental. To boost investors’ trust reforms like AI driven triage and enforcement linkage, required timeframes need to be introduced. For better and strong protection of investors and dispute resolution, any loopholes contradicting the concepts of the Limitation Act should be closed by policymakers.

II. Introduction

Importance of the Securities Market

The securities market’s activities are important for our nation’s economic progress. It is therefore crucial that the securities market activities are fair, open, and effective. In today’s era, individuals are trying to invest, trade, share, and save their excess money into new financial tools, instruments, services such as insurance, bonds, fixed deposits, shares, and mutual funds. All these leads to investor progress but also leads to increase in conflicts as investors venture into new or unfamiliarized financial markets.

SEBI Complaints Redress System (SCORES)

Securities and Exchange Board of India’s (SEBI’s) Complaints Redress System (SCORES) is an online redressal mechanism introduced by SEBI in June 2011(Circular dated 03 June, 2011) to simplify the process of lodging and tracking complaints by investors against market players such as registered intermediaries, listed companies, and others like market infrastructure institutions.[1]

Purpose and Functioning of SCORES

The main aim of SCORES is to ensure that investor grievances are handled swiftly, transparently, and effectively. The recourse to SCORES platform shall be limited to the situation when the corporation in question has been informed of the complaint by the designated individual appointed for handling investor grievance matters. Usually, it is the Listing entity’s Compliance Officer who is the designated person. It is highly advisable that the investor lodging a grievance does so within 1 year from the date of occurrence of cause of action of the grievance to facilitate swift resolution and if any complaint is filed beyond 1 year from the date of occurrence of grievance the SEBI may reject such complaint. Mobile application accessibility is also provided as SEBI SCORES app on google play store.

Complaints Covered Under SEBI Laws

The complaints about issues which can be filed in SEBI are Complaints about issues under the SEBI Act of 1992, Securities Contracts Regulation Act of 1956, Depositories Act of 1996, and their rules, mostly those involving stock trading violations – tend to be filed. It seems many investors report fraud. Probably, these cases aren’t always resolved quickly.[2] The paper examines if SCORES’ association with MI Portal and breach of accountability is stipulated by SAT in large-scale frauds.

Research Gap and Structural Limitations

The study highlights that there is no clear theory of investor protection e.g., accessibility vs. fairness or no qualitative rigor that is thematic analysis of fraud cases, no evaluation of structural limitations (e.g., one-year limit, no hearings) qualitatively using case law synthesis.

III. Issues That Are Not Taken as Complaints in SCORES Include

Complaints that do not concern securities market investments, Unidentified grievances or complaints which are not specific or are inadequate, Allegations without any proof or evidence, seeking help, advice or making recommendations are not considered complaints. In case you are unhappy with the share prices of the companies, you can consider using the MI Portal. Issues related to forged documents, conflicts resulting from private agreements with businesses or intermediaries. Complaints regarding any unregulated or unlicensed activity. [3]

Complaints Pending Before Courts and Online Dispute Resolution Mechanisms

According to SEBI master circular SEBI/HO/OIAE/OIAE_IAD-1/P/CIR/2023/145 dated July 31, 2023, complaints pertaining to cases pending in a court or subject matter of quasi-judicial proceedings, disagreements pending with Online Dispute Resolution mechanisms under the auspices of Market Infrastructure Institutions, etc.[4]

Companies Exempted from Dealing with Complaints on SCORES

Even if complaints are against listed companies or intermediary that is registered with SEBI, it cannot be handled through SCORES:

1. Companies on the Dissemination Board of Stock Exchange get complaints about companies not on the list or removed from trading.
2. Nor can those under the IBC, 2016, filed after a business is liquidated or resolving.
3. Complaints arising when companies name is dropped off from the registrar of companies list or get tagged as Vanishing Companies by the MCA.

Additional Exclusions Under the SEBI Master Circular

4. According to SEBI master circular SEBI/HO/OIAE/OIAE_IAD-1/P/CIR/2023/145 dated July 31, 2023, complaints pertaining to cases pending in a court or subject matter of quasi-judicial proceedings, disputes pending with the Online Dispute Resolution mechanism under the auspices of Market Infrastructure Institutions, etc.[6]
5. Complaints against businesses that fall under the jurisdiction of other regulatory organizations, such as the Reserve Bank of India (RBI), the Competition Commission of India (CCI), the Insurance Regulatory and Development Authority of India (IRDAI), the Pension Funds Regulatory and Development Authority (PFRDA), etc., or other ministries, such as MCA.
6. In accordance with Section 125 of the Companies Act, dividends of shares of which have not been claimed or paid, debentures that are matured, or sale proceeds of fractional shares resulting from bonus shares issuance, preference share redemption amounts that have been unpaid or unclaimed for seven years or more are all transferred directly to the IEPF Ministry of Corporate Affairs’ Complainant Education and Protection Fund and hence it is outside the SEBI’s jurisdiction and cannot be dealt on SCORES. [7]

Other Regulatory Authorities and Complaints Outside SEBI’s Jurisdiction

The list of pertinent regulators and authorities for which SEBI does not entertain the complaints. Complaints from RBI, banking regulators, and the ombudsman cover bank deposits covering grievances related to FDs with NBFCs and other related issues of NFBCs, and principal dealers.

The grievances in respect to the Ministry of Corporate Affairs related to Nidhi businesses, Vanishing Companies, Sick companies etc. The complaints regulatory authorities such as Competition Commission of India, Pension Fund Regulatory and Development Authority (PFRDA), National Housing Bank (NHB), IRDAI.[8]

Summary of Complaints Outside SCORES

IV. SCORES 2.0

Launch of SCORES 2.0

On 1st April 2024, SCORES 2.0 was launched by SEBI to address limitations of SCORES and to enhance investor protection and to make it more user-friendly grievance redressal mechanism.

Key Features of SCORES 2.0

The structural revisions that were added to SCORES 2.0 are as follows:

1. Shortened Resolution Period: Working backward from the date when the complaint was received, the allowed resolution time was reduced from thirty to twenty-one calendar days.
2. Auto-Routing: This feature does away with the manual forwarding delays and automatically sends complaints to the concerned regulatory authority.
3. Automatic Escalation: If the time given has elapsed, the unresolved complaints will be escalated automatically, initially to the Designated Body and then to SEBI.
4. Two-Level Review: If investors are not satisfied with the ATRs, they have the right to ask for a review at the first level with the Designated Body within 15 days, and after another 15 days, they can escalate the matter for a second-level review with SEBI.
5. KYC Integration: The system obtains immediate complaint identification and authentication through integration with the KYC Registration Agency (KRA) database by PAN and mobile OTP.
6. Feedback Mechanism: After closure, investors are allowed to provide feedback on the quality of complaint resolution within 15 days.” [9]

SCORES 2.0 Complaint Resolution Performance

According to data after the launch, SCORES 2.0 was able to resolve 6,539 complaints in March 2024 alone, whereas the old system’s monthly average was between 3,100 and 3,500 The average resolution time in the initial months after the launch of SCORES 2.0 came down from around 45 days (SCORES 1.0) to 35 days.[10]

V. Effectiveness of SCORES in Protection of Investors and Dispute Resolution

Effectiveness of SCORES in protection of investors and dispute resolution influenced by various factors –

A. Connection of SEBI’s Market Intelligence (MI Portal) to Tanzania Bottling S.A. Vs. SEBI

SEBI, NSE, VBL (respondents) Vs. Tanzania Bottling Company S.A. (TBC) (appellant seller through wholly owned subsidiary SBC Tanzania Ltd.^[11]

Respondents (VBL) signed a share purchase agreement to acquire 100% SBC Tanzania Ltd; however, it was later terminated. VBL’s disclosure was camouflaged and in violation of Regulation 30 related to material events, buried the termination in fine print (such as. “Note 15” of financials)^[12].

TBC filed complaints for alleged violations of securities laws like inadequate disclosures under SEBI (LODR) Regulations, 2015 against Varun Beverages Ltd. on MI Portal and SCORES. Complaint was dismissed by SEBI on 02 July 2025 without conducting a substantive review. SCORES bounced all serious law violation cases such as insider trading, or governance failures, non-disclosure to MI Portal. MI Portal lacks tracking, timelines, and transparency.

The SAT bench of 3 judges observed and highlighted this process creates an accountability gap as frequent redirections of complaints were bounced between SCORES and the MI portal. MI Portal lacks transparency as it has no defined timelines and tracking system.

SAT also observed that reliance on Action Taken Reports (ATRs) without assessing or independent verification is a drawback of SCORES platform turning it into a “post office” rather than a regulatory adjudicator^[13]. The SAT ruling mandated to re-examine within 4 weeks by SEBI and NSE and to emphasize transparent disclosures to protect investors and pass fresh orders. SEBI’s dismissal was set aside, and disclosures were found to be insufficient, and LODR regulations standards were not met and stated, “camouflaged disclosure is no disclosure at all”. In this case, portal inefficiencies such as opaque closures without substantive review were also flagged.^[14]

B. SAT Criticized SEBI for Mechanical Handling of SCORES Complaints

SAT criticized SEBI in another incident for treating a complaint through its SCORES in a mechanical manner. On 2 November,2022, an 82-year-old KLA Padmanabhasa, promoter and director of Khoday India Ltd. holding about 20% of the equity in Khoday through HUF structure asked the company’s board for dematerialization of his shareholding and to credit in his beneficiary account. The board refused, citing reason that he would sell to third parties and it would lead to violation of LODR regulations 31(2) that demands 100% promoter demat, and also prohibited under the Companies Act.

Mr. K. L. A. Padmanabhasa, in a SCORES complaint, alleged that Khoday India Limited was misconducting itself with regards to Listing Obligations and Disclosure Requirements (LODR). SEBI promptly informed Khoday India about the complaint. SEBI closed the complaint on April 19, 2023, having had the response of the business that essentially, the business was unlisted or was under the management of the board and as a result, did not require to follow particular listing requirements. SAT overturned this order of SEBI, criticized it as not considering it, and directed a fresh investigation. Khoday’s defenses, such as board discretion and unlisted status, were unsuccessful. This shows an effort by SEBI to delegate complaints to MIIs via one of its circulars of July 31, 2023, even though its effectiveness is in question.

The inefficiency of SCORES as a passive forwarding in this case. Although it was a significant denial by a promoter-shareholder, SEBI did not examine unlawful denial (e.g., LODR violation, Companies Act §58 restrictions on transfer refusals) by Khoday. Simply accepted the company taking its own side of the case and left it at that without doubting the judgment of the board and the inactivity of the RTA. Ignored warning signals like family squabbles and outright wrong actions which required further action to escalate to SAT. Demat was held up several months, and the entity’s goodwill over the enforcement was imperative.^[15]

C. SEBI’s Rejection of Complaints Filed After One Year from the Date of Cause of Action

SEBI’s rejection of complaints filed after 1 year from the date of cause of action occurs. SEBI simply ignores a SCORES complaint. The agency officially states this rule in its FAQs to avoid delays. Late filings lead to skipping of standard steps that is no initial check, no ATR due within 21 days, no forwarding to stock exchanges or designated bodies. Under the SCORES system, it is flagged as expired, and the complaint is shut down without further action.

Even deadlines for SCORES filings are not automatically extended by successive complaints on the same issue as it was ruled in the case of Mridula Bhandari Vs. SEBI SAT (2020), where the Securities Appellate Tribunal considered such techniques as abuse of process.^[16] The Limitation Act, 1963 establishes distinct limitation periods for distinct civil cause of actions and the doctrine of fraudulent concealment and continuous wrongs extend the limitations periods but there is no analysis whether SCORES conflicts with the Limitation Act.

D. Karvy Scam and Its Impact on Investor Protection

Karvy Scam – To fund its real estate business, Karvy Stock Broking Limited (KSBL) had illegally guaranteed the equities of customers held under Power of Attorney (POA), thus robbing them of shares worth over 2300 crore rupees of about 95,000 clients. Even though the transactions did not show up as debits from their demat accounts, investors found that their holdings had been transferred to Karvy’s “pull-in” accounts and mortgaged^[17]. Thereafter, SEBI prohibited Karvy, declared it a defaulter, fined it and imposed market bans, and required recovery processes, but its real reimbursements have been paltry and slow.^[18]

Reasons for Investors Dissatisfaction with SCORES in Karvy Scam

When investors submitted complaints of SCORES against Karvy, they hoped that SEBI would be a proactive regulator, but what they witnessed was a procedure and reactionary. SCORES forwards complaints automatically to the relevant party (in this case, the NSE and subsequently Karvy/intermediaries) who subsequently submits a separate Action Taken Report. SCORES do not conduct an investigation. The case filed against Karvy was basically stalemated as the complaint was not taken up by the Karvy broker until many investors claimed that the broker never acted. The SEBI did not push to have the case investigated or reprieve taken.

Some of the investors complained about being given automated or generic responses which failed to respond to their specific claim or documentation. SCORES has been called by investors and other professionals in the law field as a burial ground of concerns, where concerns are technically closed without real resolution. ^[19]SCORES habitually directed investors to the NICE Plus/IPF (Investor Protection Fund) mechanism of NSE, which cautioned them that their claims could not be compensated, but had a vague hope that they could recover any money through the assets of the defaulter, should the latter have any assets to recover. SCORES did not recover or compel Karvy Realty or other promoters to restitute amounts or assets based on security as many investors had remaining securities or amounts outstanding with Karvy. In the case of Karvy, SCORES was not initiated or run in parallel to SEBI own investigation or expedited client fund or asset recovery since it is not an enforcement vehicle, but an avenue of grievance handling. Due to this, there is a view that SEBI handles SCORES complaints like “post-office” mail, forwarding^[20], acknowledging, and closing them, whereas significant frauds are only dealt with in independent enforcement actions.

SCORES performs well for responses to low value disputes and when intermediaries respond to small grievances like small delays and account level issues. For systemic frauds like Karvy SCORES is unable to verify claims independently, offer adequate compensation or interim relief or operate with enforcement actions.

E. Sequential Process Under the Integrated SCORES and ODR Architecture

A sequential process is followed in an integrated architecture. An investor is required to file a complaint with the organization first and after that investors have the options to file a complaint on SCORES if they are not still satisfied. After this, if SCORES does not offer adequate relief, the investor can use the ODR Portal. Ongoing disputes with SCORES cannot simultaneously be dealt under the ODR portal.^[21] If a complaint is filed by an investor ODR portal when such complaint was still pending under SCORES, then such complaint will be treated as “disposed” on scores. According to SEBI circular dated 31st July 2023 on the online resolution of disputes in the Indian Securities Market specific matters such appeals against decisions passed by the SEBI or its adjudicating authorities under Section 15B of the SEBI the Act, similarly, appeals against rulings by stock exchange or adjudicating authorities under Section 22A and Section 23L of the Securities Contracts (Regulation) Act,1956 and appeal under Section 23A of the Depositories Act of 1996 are excluded from the ODR purview. ODR has become the next step when SCORES is unable to resolve the issue where SCORES is the 2nd step in three stage process where first complaint is given to company then SCORES and then ODR. ^[22]

VI. Findings

Few structural weaknesses make SCORES very ineffective as a method for investor protection and dispute resolution.

1. SCORES Is Not a Court: It has been developed as a medium for facilitation only and thus does not take the decision to run with entities and complainants. Besides, the effectiveness of the ATR measure is limited since that is incapable of producing legal decisions binding on the parties. In SEBI’s own documentation through circulars, notices, etc. provides if complainants or investors and are not fully satisfied they free to approach the court ODR, or the court of law the court of the consumer. When grievance facilitation is equated with investor protection, the system’s remedial potential is over-claimed.
2. One-Year Limitation Constraint: Requiring complaints to be submitted within a year from the date of the cause of action puts inexperienced investors in a difficult position, as they may not be able to identify the cause of action until it is too late, for example in cases of fraudulent investment schemes, delayed share transfers, or mis-selling.
3. Digital Exclusion: Since SCORES is only accessible online, investors who are not digitally literate or who do not have a reliable internet connection will be at a disadvantage, especially in rural and semi-urban locations. Studies indicate that the awareness of SCORES among investors is quite low, and financial literacy shortcomings are quite evident among small investors in rural areas.
4. Enforcement Asymmetry: On the one hand, listed companies face a penalty of INR 1,000 per day from the 61st day of non-compliance.^[23] On the other hand, large companies with a huge number of grievances may not be deterred much by the financial penalty of this amount. Besides, there are no available systematic statistics that indicate what percentage of ATRs actually result in substantive relief, as opposed to pro forma closure.
5. Jurisdictional Gaps for Fraudulent Operators and Unregistered Entities: SCORES’ reach is limited to those companies that are under the regulation of SEBI. This leaves a regulatory gap as investors who are cheated by unregistered entities, which is a very common problem in the shadow investment market of India, have no avenue for seeking help through SCORES.

VII. Reforms

• AI-powered triage and enforcement linkage system which links SCORES system with SEBI’s surveillance and enforcement departments so that the complaints generated on the basis of a pattern (e.g. continuous misselling or frauds using pledges) get regulatory inspection automatically instead of just being forwarded.
• Setting deadlines and review benchmarks by Including deadlines in a subordinate regulation and require SEBI or the Designated Bodies to always resort to the minimum level of evaluation (e.g. evidence-based investigation) before approving ATRs, more so in complicated or high-value cases.
• On a policy level, match the one-year time limit of SCORES with the Limitation Act, 1963, and provide for the time bar exceptions in case of fraudulent concealment and continuing wrongs. This will stop investors from being procedurally locked out solely on the grounds that they get to know of the injury later.
• A “SEBI-refer” function should be created that at the very least would be able to refer complaints against unregulated entities to the appropriate regulator (RBI MCA IRDAI, etc.) and facilitate inter-regulatory solutions, thus eliminating the “no-regulator” situation.
• To be provided with the hybrid human-aided channels which will help to lower the level of digital exclusion, put in place investor service centers, toll-free helplines, and mandatory assisted lodgment especially for post-office and rural users.

VIII. Conclusion

Indeed, SCORES 2.0 is a big step forward in terms of making the process more efficient and transparent, but it still falls short of being a fully-fledged, human rights-based investor protection and dispute resolution system. Besides the fact that at times the platform does not work as expected, the structure of the platform with features such as over-delegation to ATRs, very tight time limits, digital-only functioning, and legal jurisdictional constraints is making it very hard to offer meaningful relief to the aggrieved parties. We need to start seeing SCORES not just as the platform that eventually forwards the complaint to SEBI for enforcement and supervisory actions but rather as a filtered gateway to SEBI’s enforcement and supervisory functions and this will be possible if it is more explicitly linked to the Limitation Act, ODR and the cross-regulatory redressal mechanisms which will also help in building trust.

Therefore, SCORES must evolve from a ‘post office’ into a filtered gateway to SEBI’s enforcement and supervisory functions.

End-Notes

1. Securities and Exchange Board of India, Circular No. SEBI/HO/OIAE/IGRD/CIR/P/2023/156, Redressal of Investor Grievances through the SEBI Complaint Redressal (SCORES) Platform and Linking it to Online Dispute Resolution Platform (Sept. 20, 2023), https://www.sebi.gov.in/legal/circulars/sep-2023/redressal-of-investor-grievances-through-the-sebi-complaint-redressal-scores-platform-and-linking-it-to-online-dispute-resolution-platform_77159.html.
2. Securities and Exchange Board of India, FAQs – SEBI Complaint Redressal System (SCORES), SCORES, https://scores.sebi.gov.in/faqs (last visited Apr. 11, 2026).
3. Supra note 2.
4. Securities and Exchange Board of India, Master Circular No. SEBI/HO/OIAE/OIAE_IAD-1/P/CIR/2023/145, Online Resolution of Disputes in the Indian Securities Market (July 31, 2023), https://www.sebi.gov.in/legal/master-circulars/aug-2023/online-resolution-of-disputes-in-the-indian-securities-market_75220.html.
5. Securities and Exchange Board of India, FAQs – SEBI Complaint Redress System (SCORES), KARUR VYSYA BANK, https://www.kvb.bank.in/docs/faq-complaints-redress-system.pdf (last visited Apr. 11, 2026).
6. Supra note 6.
7. Supra note 2.
8. Id.
9. Securities and Exchange Board of India, Press Release No. 08/2024, SCORES 2.0: New Technology to Strengthen SEBI Complaint Redressal System for Investors (Apr. 1, 2024), https://www.sebi.gov.in/media-and-notifications/press-releases/apr-2024/scores-2-0-new-technology-to-strengthen-sebi-complaint-redressal-system-for-investors_82618.html.
10. Sebi Resolves Twice Number of Complaints After Launching SCORES 2.0, OUTLOOK MONEY (Apr. 2, 2024), https://www.outlookmoney.com/invest/bse-gets-sebi-nod-to-launch-focused-it-index-derivatives.
11. Tanzania Bottling Company S.A. v. SEBI, Appeal No. 519 of 2025 (Sec. App. Trib. Jan. 9, 2026).
12. Ananya Iyer, SAT Slams Varun Beverages for Burying Deal Termination in Fine Print, WHALESBOOK (Jan. 12, 2026), https://www.whalesbook.com/news/English/sebiexchange/SAT-Slams-Varun-Beverages-for-Burying-Deal-Termination-in-Fine-Print/6965000148839f428383651b.
13. Khushboo Tiwari & Samie Modak, Sebi Complaint Portals Face Scrutiny Over Redirections, Opaque Closures, BUS. STANDARD (Jan. 22, 2026), https://www.business-standard.com/markets/news/sebi-complaint-portals-face-scrutiny-over-redirections-opaque-closures-126012201167_1.html.
14. Supra note 14.
15. Sucheta Dalal, SAT Confirms That SEBI’s SCORES Acts Like a Post-office. What Next for Investor Grievance Redress?, MONEYLIFE (Aug. 11, 2023), https://www.moneylife.in/article/sat-confirms-that-sebis-scores-acts-like-a-postoffice-what-next-for-investor-grievance-redress/71615.html.
16. Mridula Bhandari v. SEBI, Appeal Lodging No. 130 of 2020 (Sec. App. Trib. Nov. 2, 2020).
17. Mayuree Tawade, Karvy Stock Broking Scam: Unravelling the Complex Web, 12 INT’L J. CREATIVE RSCH. THOUGHTS 2320 (2024), https://ijcrt.org/papers/IJCRT2401665.pdf.
18. Kaushal Shroff, SEBI Delivers Final Order in Karvy Demat Scam, Cracks Down on MD and Directors, MONEYCONTROL (Apr. 28, 2023), https://www.moneycontrol.com/news/business/markets/sebi-delivers-final-order-in-karvy-demat-scam-cracks-down-on-md-and-directors-10495611.html.
19. Supra note 4.
20. Dalal, supra note 17.
21. Snippet: Online Dispute Resolution, Vinod Kothari & Co. (Aug. 2023), https://vinodkothari.com/wp-content/uploads/2023/08/Snippet-ODR.pdf.
22. Securities and Exchange Board of India Act, 1992, § 15B; Securities Contracts (Regulation) Act, 1956, §§ 22A, 23L; Depositories Act, 1996, § 23A; Securities and Exchange Board of India, Master Circular No. SEBI/HO/OIAE/OIAE_IAD-1/P/CIR/2023/145, Online Resolution of Disputes in the Indian Securities Market (July 31, 2023).
23. Securities and Exchange Board of India, Master Circular No. SEBI/HO/OIAE/IGRD/P/CIR/2022/0150, Master Circular on the Redressal of Investor Grievances through the SEBI Complaints Redress System (SCORES) Platform ¶ 24 (Nov. 7, 2022), https://www.sebi.gov.in/legal/master-circulars/nov-2022/master-circular-on-the-redressal-of-investor-grievances-through-the-sebi-complaints-redress-system-scores-platform_64742.html.

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