By Bhavin Patel
Welcome to The Bridge! India's regulators affect markets, govern disputes, and test the rule of law through their orders, regulations, and policy implementation actions. Yet the quality of this work rarely gets the scrutiny it deserves. The Bridge is TrustBridge's window into India's regulatory state: how it decides, how it regulates, and how it could do both better.
The demands of quasi-judicial order writing
Quasi-judicial order writing is a tough job. Adjudicators have to navigate intricate technicalities, wade through seas of submissions, and arrive at an answer that satisfies the combined requirements of law, policy, and sectoral technicalities.
In addition to addressing all the issues that are presented in the matter at hand, adjudicators must also simultaneously keep an eye on both the future and the past:
The future, because they must take into account what impact their decision might have on the sector, as well as on the possibility of appellate and writ challenge. They must therefore take care to ensure that their orders are written in a manner that is well-reasoned, in line with the law, and capable of withstanding appellate and writ scrutiny.
The past, because the rule of law requires that quasi-judicial orders be consistent - while some changes may be necessary to accommodate the requirements of changing times, the principles of certainty and predictability of law mean that adjudicators should not take dramatically different positions on similar matters without offering good reasons for doing so.
These requirements place great demands on the regulatory quasi-judicial order-writing process. Do adjudicators have the resources they need to fulfil these requirements?
The lack of resources
Indian regulators have capability, capacity, and technological resource shortfalls that make quasi-judicial order writing even harder than it has to be.
All regulators do not require the presence of a ‘Legal Member’, or someone with legal training and expertise in the adjudication process. This means that an officer who may have sectoral expertise but no legal experience is required to untangle the complexities of Indian administrative law, evidentiary standards, and the principles of natural justice, along with the law applicable to their sector. Take, for example, the Securities and Exchange Board of India (the “SEBI”): the SEBI Act does not mandate the appointment of legally-trained persons as adjudicators; nonetheless, such adjudicators must not only discern the fine technical aspects of the case they are dealing with, they must also understand Indian securities law - no mean task in itself - as well as all of the other legal requirements we have already mentioned. This points to the capability limitations endemic to quasi-judicial processes at Indian regulators.
Where regulators have a requirement for a ‘Legal Member’, the post remains unoccupied for long durations, adding to delays and backlogs. As one example, the Supreme Court has emphasised the need for a Legal Member in Electricity Regulatory Commissions (“ERCs”),1 but has had to step in when this position remains unoccupied, even having to go to the extent of passing contempt orders against the Central ERC, where a Legal Member vacancy persisted despite the Court’s directions.2 These vacancies create backlogs and build pressure on adjudicatory officials when a Legal Member is finally appointed and proceedings resume, posing tremendous capacity problems.
Finally, there are limited technological tools customised to suit the requirements of quasi-judicial processes. Commercial legal databases may include regulatory orders, but these records are often incomplete, or out-dated. Advanced features, such as Shepardisation or precedent checks, are unavailable for regulatory orders. This means that a quasi-judicial officer does not, for example, have a convenient means of determining what prior orders apply to the case they are dealing with, or what the regulator’s position on a particular issue has been. Record-keeping is archaic, and structured databases of regulatory orders are not maintained in-house at all regulators. All this poses technological challenges to the regulatory quasi-judicial function.
Introducing the TrustBridge Order Review Tool
TrustBridge has studied regulatory quasi-judicial processes and functioning for over three years now.3 We have used Large Language Models (LLMs) extensively in the course of this work, and have also studied the limitations and potential problems associated with the use of this technology, as well as means to address these drawbacks.4
We have leveraged our expertise to develop a proof-of-concept version of an ‘Order Review Tool’ that we believe holds tremendous potential for assisting order-writers in regulatory quasi-judicial processes. The tool provides an overview of the material facts involved in an order, evaluates the order against a set of ‘Good Order Writing’ metrics,5 and provides lists of previous regulatory and appellate orders that may hold precedential value for the matter under consideration. We suggest that this tool can augment human capability at regulators; it can take large amounts of research and routine workloads off adjudicators, helping with the capacity problem; and is a good example of how technological limitations can be addressed.
The video below provides a demo of the tool and how it functions:
Use cases for the Order Review Tool
We suggest that the Order Review Tool could serve several useful purposes:
It could augment regulatory capacity in the quasi-judicial process by offering adjudicators a detailed analysis of draft orders, feedback on what could be done to improve the draft, and applicable precedent for consideration.
Litigants and market participants could use the tool to evaluate published orders, so that they may better understand whether the order can withstand appellate scrutiny, and what precedent they might rely upon to challenge the order.
Appellate fora may scrutinise impugned orders to check their completeness, and adherence to settled law.
The tool can also serve as a useful research resource for the study of regulatory quasi-judicial processes at scale.
- The author is a researcher at TrustBridge.
CITATION
Bhavin Patel, 2026. “The TrustBridge Order Review Tool”, The Bridge, TrustBridge Rule of Law Foundation
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References
Aggarwal, Natasha; Desikan, Amrutha; Patel, Bhavin; Bondre, Satyavrat; and Sanyal, Dipyaman (2026) “Can Technology Augment Order Writing Capacity at Regulators?,” Indian Journal of Law and Technology: Vol. 22: Iss. 1, Article 2.
Natasha Aggarwal and Bhavin Patel, 2026. “Evaluating regulators’ orders: The good order writing indicators explained”, The Bridge, TrustBridge Rule of Law Foundation.
State Of Gujarat v Utility Users Welfare Association, 2018 (6) SCC 21
‘SC Slams Centre for Not Appointing Mandatory Legal Member in CERC’ (Hindustan Times, 12 December 2020) https://www.hindustantimes.com/india-news/sc-slams-centre-for-not-appointing-mandatory-legal-member-in-cerc/story-6IEuDNVJExOEXBJaOOf3hJ.html accessed 15 July 2026.
State Of Gujarat v Utility Users Welfare Association, 2018 (6) SCC 21
‘SC Slams Centre for Not Appointing Mandatory Legal Member in CERC’ (Hindustan Times, 12 December 2020) https://www.hindustantimes.com/india-news/sc-slams-centre-for-not-appointing-mandatory-legal-member-in-cerc/story-6IEuDNVJExOEXBJaOOf3hJ.html accessed 15 July 2026.
A number of papers that emerged from this work are available at: https://trustbridge.in/publications/. The Bridge has a number of shorter pieces on this topic as well.
Aggarwal, Natasha; Desikan, Amrutha; Patel, Bhavin; Bondre, Satyavrat; and Sanyal, Dipyaman (2026) “Can Technology Augment Order Writing Capacity at Regulators?,” Indian Journal of Law and Technology: Vol. 22: Iss. 1, Article 2.
See: Natasha Aggarwal and Bhavin Patel, 2026. “Evaluating regulators’ orders: The good order writing indicators explained”, The Bridge, TrustBridge Rule of Law Foundation.