Franklin Templeton winding-up of 2020

The Franklin Templeton winding-up of 2020 is the decision of Franklin Templeton Trustee Services Private Limited, trustee of the SEBI-registered Franklin Templeton Mutual Fund, on 23 April 2020 to wind up six open-ended debt schemes holding Rs 25,648 crore, under Regulation 39(2)(a) of the SEBI (Mutual Funds) Regulations 1996. Subscriptions and redemptions stopped from 24 April 2020, and the 3,15,600 unitholders could not withdraw money until the Supreme Court cleared the first distribution in February 2021.

The six schemes were Franklin India Low Duration Fund , Franklin India Ultra Short Bond Fund, Franklin India Short Term Income Plan, Franklin India Credit Risk Fund , Franklin India Dynamic Accrual Fund and Franklin India Income Opportunities Fund. They ran a credit-heavy strategy, and by April 2020 the AMC had exhausted its bank borrowing and could not sell enough of its lower-rated corporate bonds to meet redemptions in the market dislocation that followed the COVID-19 national lockdown announced on 24 March 2020.

The litigation settled how a mutual fund scheme may be closed. The Karnataka High Court held on 24 October 2020 that the trustee’s decision could not be implemented without unitholder consent. After an e-vote in December 2020 that each scheme passed by about 97 per cent, the Supreme Court held on 12 February 2021 that consent means a simple majority of those voting, and appointed SBI Funds Management to liquidate the portfolios. On 14 July 2021 it confirmed that consent must follow the notice of winding up.

Unitholders were repaid in full in aggregate: Rs 27,508.1 crore had been distributed by September 2023, more than the assets at closure, according to Franklin Resources Inc.’s annual report to the US Securities and Exchange Commission. SEBI separately ordered the AMC on 7 June 2021 to refund Rs 512.51 crore of fees with interest and barred it from new debt schemes for two years; those orders are under appeal at the Securities Appellate Tribunal . The episode produced the 10 per cent liquid-asset rule for debt schemes, the Potential Risk Class matrix, swing pricing and, from 25 January 2022, a written voting rule for trustee-initiated closures that is now Regulation 36 of the SEBI (Mutual Funds) Regulations 2026 .

The six schemes and their assets

The Franklin Templeton winding-up covered six open-ended debt schemes in six different SEBI categories, all managed by Franklin Templeton Asset Management (India) Private Limited . The Supreme Court’s order of 12 February 2021 gives each scheme’s formal name with the number of segregated portfolios it had already created, and Franklin’s wind-up factsheet of 28 February 2023 gives the SEBI category.

Source: Supreme Court of India, Civil Appeal Nos. 498-501 of 2021, order of 12 February 2021, para 1; Franklin Templeton, factsheet for the six schemes under winding up, 28 February 2023, page 3.

Two figures describe the size. The Supreme Court recorded assets of Rs 25,648 crore as on 23 April 2020 (para 4), and the Franklin Resources Form 10-K for fiscal 2025 gives Rs 25,648.3 crore. The Supreme Court’s Observer counted 3,15,600 unitholders in the six schemes as on 3 December 2020, a count made by consolidating folios on PAN , so the number of folios was higher.

Franklin’s own factsheet states every payout as a percentage of “AUM as on April 23, 2020”, and its cumulative figures imply a base of about Rs 25,214 crore (Rs 26,931.27 crore divided by 106.81 per cent, a webnotes.in derivation). The lower base and the court’s Rs 25,648 crore cannot be mixed: a percentage from the factsheet applies to the factsheet’s base only.

The trustee’s reasons for winding up

The Franklin Templeton trustee wound up the six schemes because the AMC had run out of borrowing to pay redemptions and could not sell lower-rated bonds fast enough without loss to the remaining investors. The Karnataka High Court’s judgment of 24 October 2020 (para 254) summarises the trustee board minutes of 23 April 2020, at which Sanjay Sapre, “the President of AMC”, briefed the board.

According to those minutes, the schemes had “fully exhausted a line of credit of Rs.1000 crores received from Bank of Baroda”, and HSBC “had indicated its inability to provide line of credit exceeding 20% of AUM”. The board recorded that “winding up of the Schemes is the only viable mode of preserving the value for investors/unit-holders and an event has occurred which requires the Scheme to be wound up”. That second phrase is the test in Regulation 39(2)(a) of the 1996 Regulations. Bank of Baroda and HSBC were the two named lenders.

The objectors before the Supreme Court alleged that “more than Rs. 15,000 crores were withdrawn from the six schemes two weeks prior to the decision” (order of 12 February 2021, para 3). The court recorded this as an allegation and left the misfeasance and fraud contentions open (para 42).

Credit events before April 2020

The schemes had already isolated two failed credits before the closure. Franklin created segregated portfolios for Vodafone Idea bonds after Crisil downgraded them below investment grade on 24 January 2020, and for a YES Bank Additional Tier 1 bond after ICRA’s downgrade on 6 March 2020 (Franklin wind-up factsheet, 28 February 2023). The mechanism was the side-pocketing framework of SEBI circular SEBI/HO/IMD/DF2/CIR/P/2018/160 dated 28 December 2018, introduced three months after the IL&FS defaults of 2018 .

A side pocket deals with one bad security and leaves the scheme open. It does nothing for a scheme whose whole book of lower-rated paper has stopped trading, which was Franklin’s position in April 2020. The YES Bank AT1 write-down and the Vodafone Idea downgrade were in the segregated portfolios, not in the main portfolios that were wound up for want of liquidity.

The market in March and April 2020

The closure came four weeks after the national lockdown announced on 24 March 2020, when the secondary market for corporate bonds below the top rating had thinned out. The Reserve Bank of India responded four days after the closure. Its press release 2019-2020/2276 of 27 April 2020 opened a Rs 50,000 crore Special Liquidity Facility for Mutual Funds, a 90-day repo at the repo rate open from 27 April to 11 May 2020, citing “redemption pressures related to closure of some debt MFs”.

Banks could draw on the facility only to lend to mutual funds or to buy, or lend against, the investment-grade corporate bonds, commercial paper, debentures and certificates of deposit that mutual funds held. The RBI Bulletin of March 2021 reports that “its utilisation was a meagre” Rs 2,430 crore, under 5 per cent of the window.

The legal basis for closing a scheme in 2020

In April 2020 Regulation 39 of the SEBI (Mutual Funds) Regulations 1996 allowed a scheme to be wound up on three grounds, and Regulation 18(15)(c) separately required trustees to obtain unitholder consent when a majority of trustees decided to wind up a scheme. The dispute was over whether the second provision applied to a decision taken under the first.

The three Regulation 39(2) grounds were an opinion of the trustees that the scheme must be wound up because of an event, a request by 75 per cent of unitholders, and a direction from SEBI in the interests of unitholders. Franklin’s trustee used the first. Regulation 39(3) required a notice disclosing the circumstances, Regulation 40 stopped the scheme from issuing or redeeming units from that notice, and Regulation 41(2)(b) required the proceeds to be paid to unitholders in proportion to their interest in the assets of the scheme on the date of the decision.

Franklin issued the winding-up notices on 23 April 2020 and a further notice on 28 May 2020, both later restrained by the Karnataka High Court. Freezing redemptions was the legal consequence of the Regulation 40 notice, not a separate decision.

Karnataka High Court judgment of 24 October 2020

The Karnataka High Court held on 24 October 2020 that the trustee’s decision to wind up the six Franklin Templeton schemes was valid, but could not be implemented until the unitholders consented by simple majority under Regulation 18(15)(c). The bench of Chief Justice Abhay S. Oka and Justice Ashok S. Kinagi decided three writ petitions, among them Writ Petition Nos. 8644, 8748 and 8545 of 2020, together with SEBI’s Writ Appeal No. 399 of 2020. Franklin Resources’ Form 10-K records that petitions filed in other High Courts were transferred to the Karnataka High Court.

The operative order, at para 290, held that:

1. “no interference is called for in the decision of the Trustees taken on 23rd April 2020 of winding up the said six Schemes”;
2. the decision under Regulation 39(2)(a) “cannot be implemented unless the consent of the unit-holders is obtained in accordance with sub-clause (c) of clause (15) of Regulation 18”, and the trustees were restrained from further steps on the notices of 23 April and 28 May 2020 until consent by simple majority;
3. Regulations 39 to 41 “are legal and valid”;
4. SEBI was to ensure the forensic auditor reported under Regulation 64 and to decide on action under Regulation 65 within six weeks of the report;
5. unitholders were not entitled to a copy of the forensic audit report.

The forensic audit therefore had a court timetable: SEBI had initiated it as an inspection under Regulation 66, and the court tied the report and any action to Regulations 64 and 65. It became the basis of SEBI’s order of 7 June 2021, described in the enforcement section below.

Supreme Court proceedings, 2020 to 2021

The Supreme Court heard the appeals from the Karnataka judgment as Civil Appeal Nos. 498-501 of 2021, Franklin Templeton Trustee Services Pvt Ltd and Another v. Amruta Garg and Others, before Justice S. Abdul Nazeer and Justice Sanjiv Khanna, and decided them in two orders. The order of 12 February 2021 settled the meaning of consent and the vote. The order of 14 July 2021 settled when consent must be taken.

Interim orders and the December 2020 vote

The Supreme Court’s interim orders arranged the vote that the Karnataka judgment required. The order of 12 February 2021 recites them:

• 3 December 2020: the trustees were permitted to convene a meeting of unitholders (para 20).
• 9 December 2020: SEBI was directed to appoint an Observer, with results to be filed in a sealed cover (para 21).
• 18 December 2020: SEBI appointed T.S. Krishnamurthy, former Chief Election Commissioner of India, as Observer (para 22), assisted by a team that included B.N. Sahoo of SEBI and Nayana Ovalekar of CDSL .
• 18 January 2021: the Observer’s report was read in court (para 23).
• 2 February 2021: objectors agreed to the distribution of Rs 9,122 crore, the cash the schemes had accumulated by 15 January 2021 (para 4).

The trustees approved the notices on 5 December 2020 and emailed them to 2,98,704 unitholders on 11 December 2020. Login credentials reached 3,09,052 unitholders, 97.92 per cent of the total. E-voting ran from 9 am on 26 December to 6 pm on 28 December 2020, and the meeting was held by video conference on 29 December 2020. J. Sagar Associates, a law firm, acted as Scrutiniser and reported to the Observer on 9 January 2021.

Order of 12 February 2021

The Supreme Court held on 12 February 2021 that consent under Regulation 18(15)(c) “would mean simple majority of the unitholders present and voting” (para 19), not a majority of all unitholders. On that test it rejected the objections to the poll and held “that the unitholders of the six schemes have given their consent by majority to windup the six schemes” (para 42).

The same order appointed, “with the consent of the parties”, SBI Funds Management Private Limited “to undertake the exercise of winding up, which would include liquidation of the holdings/assets/portfolio and distribution/payment to the unitholders” (para 40). Securities of “more than Rs.17,000 crores” were still to be realised; SBI Funds Management was to follow a “best effort principle” and could pay in tranches (para 41).

The court expressly did not decide, in this order, whether Regulation 18(15)(c) applies to a Regulation 39(2)(a) decision at all, or the allegations of misfeasance and fraud (para 42). Justice Khanna wrote the order.

Order of 14 July 2021

The Supreme Court held on 14 July 2021 that unitholder consent under Regulation 18(15)(c) is required for a trustee-initiated winding-up, but after the notice, not before it. Para 42 reads: “the consent of the unitholders, as envisaged under clause (c) to Regulation 18(15), is not required before publication of the notices under Regulation 39(3). Consent of the unitholders should be sought post publication of the notice and disclosure of the reasons for winding up under Regulation 39(3).”

At para 60 the court “agreed with the High Court that the opinion of the trustees under clause (a) to Regulation 39(2), therefore, must be consented to by the unitholders in terms of the mandate of Regulation 18(15)(c)”. The challenge to the validity of Regulations 39 to 42 then “loses much of its sting”. The court declared its reading of Regulations 18(15)(c) and 39 to 42 “conclusive and binding” (para 68), and left the factual allegations to continue in other proceedings. The order is reported at AIR 2021 SC 3494.

Unitholder vote of December 2020

All six Franklin Templeton schemes approved the winding-up in the e-vote of 26 to 28 December 2020 and the meeting of 29 December 2020, with between 96.78 and 97.97 per cent of the unitholders who voted in favour. The Supreme Court’s order of 12 February 2021 tabulates the result twice, by number of unitholders (para 26) and by units (para 27).

Source: Supreme Court of India, Civil Appeal Nos. 498-501 of 2021, order of 12 February 2021, paras 26 and 27. E-voting 26 to 28 December 2020; meeting 29 December 2020.

Turnout was about 38 per cent of unitholders by number and 54 per cent by value of units, the figures the court accepted at para 31, holding that the Regulations prescribe no minimum quorum. The Observer’s tables counted one vote per unitholder, and the trustees filed a second computation on one vote per unit. The court stated its preference for the second at para 28(i): “Majority consent of the investors/unitholders should depend upon the number of units held by them”. Consent carried on both bases, and the 2022 amendment wrote the units basis into the regulations.

Distribution to unitholders, 2021 to 2023

Franklin Templeton unitholders received their money in 11 tranches between February 2021 and February 2023, a cumulative Rs 26,931.27 crore or 106.81 per cent of the AUM on 23 April 2020 on Franklin’s base, and Rs 27,508.1 crore in all by September 2023. No payment was made between the closure in April 2020 and the Supreme Court’s orders of February 2021.

Source: Franklin Templeton, factsheet for the six schemes under winding up, as on 28 February 2023, page 4. Percentages are Franklin’s, on its own AUM base.

The 7 August 2022 tranche included the “reversal of certain expenses and distribution commission, as directed by the Hon’ble Supreme Court in its order dated August 3, 2022”, according to the same factsheet. On 28 February 2023 Franklin reported that “5 out of 6 schemes have returned over 100%”, with scheme-level returns between 99.32 and 112.46 per cent, and that four of the six had sold all their performing assets. Cash in hand was Rs 10.66 crore.

The final figure comes from Franklin’s parent. Franklin Resources’ Form 10-K for the fiscal year to 30 September 2025, Note 15, states that “by September 2023, all performing securities across the Funds were liquidated and an aggregate of INR 27,508.1 crore … was distributed to Fund unitholders, exceeding the aggregate value of the Funds’ AUM at the date of the wind-up announcement”. On the court’s Rs 25,648.3 crore base that is 107.3 per cent.

Assets still outstanding after the main liquidation

At 28 February 2023 the residual holdings were defaulted or segregated securities, not performing bonds. The factsheet lists a 10.90 per cent Vodafone Idea bond maturing 2 September 2023, rated CARE B+ and valued at Rs 44.25 crore, in the Low Duration Fund’s second segregated portfolio. Debenture trustees had recovered Rs 160.79 crore from Essel Infra across four schemes after a Delhi High Court decision. Bonds of Reliance Big Private Ltd and Reliance Infrastructure Consulting and Engineers Private Ltd, due on 14 and 15 January 2021, were fair valued at zero on 4 November 2020, and the issuers did not pay at maturity.

Unitholders with a segregated-portfolio balance are paid separately as recoveries arrive, and the steps are in claiming a segregated portfolio recovery . A recovery status for 2024 to 2026 could not be confirmed at a primary source, so none is stated here.

SEBI enforcement and the appeals

SEBI’s order WTM/GM/IMD/08/2021-22 of 7 June 2021, passed by whole-time member G. Mahalingam after a forensic audit, barred the Franklin Templeton AMC from launching new debt schemes for two years, ordered a refund of Rs 512.51 crore of fees with interest and imposed a Rs 5 crore penalty. The audit was initiated under Regulation 66 of the 1996 Regulations by the SEBI Investment Management Department , and Chokshi and Chokshi LLP, Chartered Accountants, inspected the fund, the AMC and the trustee.

The directions in para 7.1 of the order were:

• no new debt scheme for two years from the date of the order;
• refund of the investment management and advisory fees collected on the six schemes from 4 June 2018 to 23 April 2020, Rs 451.63 crore, with 12 per cent simple interest of Rs 60.88 crore, a total of Rs 512.51 crore, within 21 days;
• a penalty of Rs 5 crore on Franklin Templeton Asset Management (India) Private Limited, within 45 days.

The findings covered running schemes in a similar manner to one another, the treatment of interest-rate reset securities in Macaulay duration , valuation, portfolio risk management and investment due diligence. The inspection process is covered in SEBI compliance audit of mutual funds .

SEBI passed further orders in June 2021 against the trustee company and individual employees. Franklin Resources’ Form 10-K puts the aggregate monetary penalties across all the June 2021 orders at Rs 20.0 crore, including the AMC’s Rs 5 crore. Press reports of the individual penalties and of an order on redemptions by persons connected to the trustee board could not be confirmed against a SEBI order, so no individual amount is stated here.

Securities Appellate Tribunal

The Franklin Templeton entities and the employees appealed all the June 2021 orders to the Securities Appellate Tribunal, and the appeals were still pending on 10 November 2025. Franklin Resources’ Form 10-K filed that day states that SAT granted stay applications “in June and July 2021, subject to respondents’ deposit in escrow of a portion of the ordered penalties for an aggregate deposit made of INR 257.5 crore”, and that “in the interim, SEBI has approved FTAMI’s launch of certain new fixed income funds”.

The Rs 257.5 crore was an escrow deposit pending appeal, not a penalty. The same filing discloses an Economic Offences Wing FIR in Chennai from about September 2020 and an Enforcement Directorate investigation from about April 2021, both pending.

Regulatory changes after 2020

SEBI’s response to the Franklin Templeton closure ran on two tracks: circulars that made open-ended debt schemes hold more liquidity and disclose risk in a fixed format, and an amendment to the regulations that wrote the courts’ consent rule into law.

Source: the signed SEBI circular PDFs; SEBI (Mutual Funds) Regulations 1996, consolidated text of January 2026, footnotes 181 and 182; SEBI (Mutual Funds) Regulations 2026 as amended to 7 July 2026, Regulations 36 to 38.

The 10 per cent liquid-asset floor in circular 2020/229 addresses the Franklin problem directly. Under para 1(b) the liquid assets are not counted when determining the scheme characteristics set by the 2017 categorisation circulars, so the floor sits on top of the category mandate, and under para 1(c) a scheme below 10 per cent must restore it “before making any further investments”. The 2022 amendment also changed the opening words of Regulation 39(2) from “may be wound up, after repaying the amount due to the unit holders” to “is to be wound up”.

Winding up a scheme under the 2026 Regulations

A trustee who decides today that a mutual fund scheme must be wound up proceeds under Regulations 36 to 38 of the SEBI (Mutual Funds) Regulations 2026, in force since 1 April 2026, and the procedure Franklin’s unitholders obtained through two courts is now the default. The grounds in Regulation 36(2) are unchanged from 1996: the trustees’ opinion (clause a), a request by 75 per cent of unitholders (clause b), or a SEBI direction (clause c).

Source: SEBI (Mutual Funds) Regulations 2026 as amended to 7 July 2026, Regulations 36 to 38; Supreme Court order of 12 February 2021.

The 75 per cent threshold applies only when unitholders themselves ask for a scheme to be wound up under Regulation 36(2)(b). A trustee-initiated closure, the Franklin case, needs a simple majority of units voted. The page on the 75 per cent rule for unitholder approval carries the distinction. A unitholder’s other rights during a closure are set out in mutual fund unitholder rights .

Effect on the Credit Risk Fund category

Assets in the SEBI Credit Risk Fund category fell by half in the two years after the Franklin Templeton closure, from Rs 55,380.52 crore on 31 March 2020 to Rs 27,772.36 crore on 31 March 2022, according to AMFI’s monthly reports. The category was created by the 2017 scheme categorisation circular for schemes investing mainly in lower-rated corporate bonds, and only one of the six Franklin schemes, Franklin India Credit Risk Fund, was in it.

Source: AMFI monthly reports, March 2020, April 2020, March 2021 and March 2022, row “Credit Risk Fund”.

AMFI reported Rs 19,507.05 crore of redemptions from the category in April 2020 alone. The scheme count did not change that month, and AMFI’s report carries no note on how the frozen Franklin India Credit Risk Fund was treated, so the April fall cannot be split between investor exits and the closure itself. Monthly category data is explained in AMFI monthly AUM data .

Figures often misstated about the episode

Several figures circulating about the Franklin Templeton winding-up do not match the court orders, the SEBI order or Franklin’s filings. Each correction below names the document that settles it.

• “Rs 28,000 crore” of assets. The Supreme Court recorded Rs 25,648 crore as on 23 April 2020 (order of 12 February 2021, para 4), and Franklin Resources’ 10-K gives Rs 25,648.3 crore. The Rs 28,000 crore figure appears in no court order or Franklin filing.
• “A. Balasubramanian, Civil Appeal 1997 of 2020, 14 July 2020”. The Supreme Court case is Franklin Templeton Trustee Services Pvt Ltd v. Amruta Garg, Civil Appeal Nos. 498-501 of 2021, with orders of 12 February 2021 and 14 July 2021.
• The Supreme Court “transferred all proceedings to itself in 2020”. The writ petitions were transferred to the Karnataka High Court, which decided them on 24 October 2020; the Supreme Court heard appeals from that judgment.
• A “Rs 250 crore penalty”. Franklin’s aggregate penalties across the June 2021 orders were Rs 20.0 crore. The Rs 257.5 crore in Franklin’s filings is an aggregate escrow deposit made to obtain SAT stays, not a penalty.
• A “six-month bar” on new schemes. SEBI’s order of 7 June 2021 barred new debt schemes for two years.
• Recovery of “89 to 92 per cent”. Distribution reached 106.81 per cent of AUM on Franklin’s base by 28 February 2023, and Rs 27,508.1 crore by September 2023.
• Payouts “from June 2020”. The first tranche was based on the NAV of 12 February 2021.
• The swing pricing circular numbered 2021/576 or 2021/553. SEBI’s extension circular 2022/24 of 25 February 2022 names it as SEBI/HO/IMD/IMD-II DOF3/P/CIR/2021/631 dated 29 September 2021.

Comparison with the UTI US-64 crisis of 2001

The Franklin Templeton winding-up and the UTI US-64 crisis of 2001 are the two scheme failures most often compared in India, and they differ in regulator and remedy. US-64 was a scheme of the Unit Trust of India, a statutory body under the UTI Act 1963 that sat outside the SEBI (Mutual Funds) Regulations 1996, and its liabilities passed to a government-administered undertaking when the UTI Act was repealed in 2002. The Franklin schemes were SEBI-regulated, closed by their own trustee, and repaid from their own assets.

The procedural outcome also differs. US-64 ended with UTI’s other schemes moving into UTI Mutual Fund under SEBI regulation, while the Franklin case fixed the procedure for closing a scheme already inside SEBI’s framework, down to the one-day notice and the 45-day result. The trust structure that gave Franklin’s trustee the power to decide is the same one that now obliges a trustee to put the decision to a vote.

Grievance route for affected unitholders

A Franklin Templeton unitholder with an unpaid or disputed wind-up amount complains first to the AMC and its registrar, and then to SEBI through SCORES , the SEBI complaints system, with escalation to online dispute resolution under SEBI’s SMART ODR circular of 31 July 2023. Amounts left unclaimed by investors are covered in unclaimed mutual fund redemptions , and the filing steps are in filing a SEBI SCORES complaint about a mutual fund .

The distribution method itself was fixed by the Supreme Court’s orders in Civil Appeal Nos. 498-501 of 2021 and by Regulation 41(2)(b) of the 1996 Regulations, which pays the balance “in proportion to their respective interest in the assets of the scheme as on the date when the decision for winding up was taken”. A unitholder’s dispute is therefore usually about execution: payment to an outdated bank account, a missed tranche or a KYC mismatch.

See also

• Franklin Templeton India Mutual Fund
• Franklin Templeton winding-up, detailed timeline
• Franklin Templeton April 2020 wind-up
• Credit Risk mutual fund
• Side-pocketing for debt mutual funds
• Segregated portfolio in a mutual fund
• Claiming a segregated portfolio recovery
• IL&FS default and debt funds, 2018
• DHFL default and credit risk funds
• YES Bank AT1 write-down and mutual funds
• Marquee debt fund credit cases
• SEBI swing pricing framework
• SEBI stress testing for mutual funds, 2024
• Potential Risk Class matrix
• Mutual fund riskometer
• Corporate Debt Market Development Fund
• SEBI (Mutual Funds) Regulations 1996
• SEBI (Mutual Funds) Regulations 2026
• SEBI Master Circular for Mutual Funds 2026
• 75 per cent rule for unitholder approval
• Mutual fund unitholder rights
• Mutual fund trustee
• Trust structure of a mutual fund
• SEBI
• SEBI Investment Management Department
• SEBI compliance audit of mutual funds
• Securities Appellate Tribunal
• Supreme Court of India
• Reserve Bank of India
• SBI Mutual Fund
• Low Duration mutual fund
• Ultra Short Duration mutual fund
• Short Duration mutual fund
• Medium Duration mutual fund
• Dynamic Bond mutual fund
• Open-ended mutual fund
• Macaulay duration of a debt fund
• Credit rating agencies in India
• AMFI monthly AUM data
• UTI US-64 crisis of 2001
• Mutual funds in India
• SEBI SCORES

External references

• Supreme Court of India, Franklin Templeton Trustee Services v. Amruta Garg, order of 12 February 2021 (PDF, hosted by SEBI)
• Supreme Court of India, order of 14 July 2021 (Indian Kanoon)
• SEBI circular SEBI/HO/IMD/DF3/CIR/P/2020/229, 6 November 2020 (PDF)
• SEBI circular SEBI/HO/IMD/IMD-II DOF3/P/CIR/2021/573, 7 June 2021 (PDF)
• SEBI circular SEBI/HO/IMD/IMD-II DOF3/P/CIR/2022/24, 25 February 2022 (PDF)
• SEBI (Mutual Funds) Regulations 2026, as amended to 7 July 2026 (PDF)
• RBI press release 2019-2020/2276, Special Liquidity Facility for Mutual Funds, 27 April 2020
• Franklin Resources Inc., Form 10-K for fiscal 2025, Note 15

References

1. Supreme Court of India, Franklin Templeton Trustee Services Pvt Ltd and Another v. Amruta Garg and Others, Civil Appeal Nos. 498-501 of 2021, order of 12 February 2021 (S. Abdul Nazeer and Sanjiv Khanna JJ.), paras 1, 3, 4, 19 to 27 and 40 to 42.
2. Supreme Court of India, the same appeals, order of 14 July 2021, paras 42, 60 and 68; AIR 2021 SC 3494.
3. High Court of Karnataka, Writ Petition Nos. 8644, 8748 and 8545 of 2020 with Writ Appeal No. 399 of 2020, judgment of 24 October 2020 (Abhay S. Oka CJ and Ashok S. Kinagi J.), paras 254 and 290.
4. SEBI, order WTM/GM/IMD/08/2021-22 in the matter of inspection of six debt schemes of Franklin Templeton Mutual Fund, 7 June 2021, para 7.1.
5. Franklin Templeton Mutual Fund, factsheet for the six schemes under winding up, as on 28 February 2023, pages 3 to 5.
6. Franklin Resources Inc., Annual Report on Form 10-K for the fiscal year ended 30 September 2025, filed 10 November 2025, Note 15, “India Credit Fund Closure Matters”.
7. SEBI circulars SEBI/HO/IMD/DF3/CIR/P/2020/197 (5 October 2020), SEBI/HO/IMD/DF3/CIR/P/2020/229 (6 November 2020), SEBI/HO/IMD/IMD-II DOF3/P/CIR/2021/573 (7 June 2021), SEBI/HO/IMD/IMD-II DOF3/P/CIR/2021/631 (29 September 2021) and SEBI/HO/IMD/IMD-II DOF3/P/CIR/2022/24 (25 February 2022).
8. SEBI (Mutual Funds) Regulations 1996, Regulations 18(15)(c) and 39 to 41, consolidated text of January 2026, footnotes 181 and 182 on the 2022 amendment.
9. AMFI monthly reports, March 2020, April 2020, March 2021 and March 2022.
10. SEBI circular SEBI/HO/OIAE/OIAE_IAD-1/P/CIR/2023/131, 31 July 2023, online dispute resolution in the Indian securities market.
11. SEBI (Mutual Funds) Regulations 2026, as amended to 7 July 2026, Regulations 36 to 38.
12. Reserve Bank of India, press release 2019-2020/2276, 27 April 2020; RBI Bulletin, March 2021, “Unconventional Monetary Policy in Times of COVID-19”, Section IV.