Debt Funds Face Seismic Shift as Supreme Court Upholds SEBI's Total Return Index Mandate

Manasvi Sharma

BDS School of Law

Editor : Harsh Kashyap

New Delhi, November 10, 2025: For the first time in India's mutual fund industry, which has issues worth almost ₹50 lakh crore, the Supreme Court affirmed today what should be regarded as a landmark pronouncement: the controversial mandate of the Securities and Exchange Board of India (SEBI) for showing debt mutual funds as benchmarked against their performance on the Total Return Index (TRI). On Monday, the judgement vindicated the values espoused by the market regulator in favour of an increased level of transparency but sends the houses of funds scrambling to shore up their communication and investment tactics.

The constitutional bench from which this case finally got its final verdict included Lord Justice Aniruddha Bose. There ended the meeting of the AMFI and the regulator. In an ex parte application, the court said: SEBI's directive was a "pro-investor measure instituted within the legal domain of its regulatory authority" and was a must-have for delivering a "true and comparable picture of fund performance."

From Price Return to Total Return: Total Transformation

What had caused all the misunderstanding was how benchmark returns were determined for a fund. Historically, debt funds were using a Price Return Index (PRI) which only recorded changes in the market price of the bonds. Hence, SEBI's definition, which states that from now on, benchmarks will have to be established in relation to the Total Return Index (TRI), which will account for all price increases and the income coupon from the bonds reinvesting back into the index.

It's probably quite nuanced on the surface, but it bears severe consequences. Finding the end to a fund manager's strategy would hinge on whether or not he managed to outrun a benchmark. With the PRI method, a fund could seem to outperform merely by holding bonds and collecting the coupon with no active management. The TRI sets a higher bar by including the coupon, making real outperformance-through a savvy interest rate calls or credit selection- harder to attain.

"It's not a complete report card," said the anonymous SEBI official, "A fund could be trailing in actual returns for the investor but still look good against a price-only benchmark. The TRI gives the complete picture, so the excess, the alpha returned claimed by funds is really there, not imaginary when posturing the coupon along separate accounting lines.

Industry Grapples with Operational Overhaul and Margin Pressure:

The immediate response from the fund industry has generally accepted and worried about the costs of implementation. "This is a paradigm shift," said Vishal Kapoor, CEO of a leading asset management company. "Our entire communication machinery - factsheets, marketing presentations, performance reports - is based on the old benchmark. Transitioning this is, while educating our vast distributor network and millions of investors, a mammoth operational and financial undertaking."

The ruling will also squeeze the already-thin margins of passive funds, including target maturity funds or index funds, whose raison deter is not to outperform but simply replicate their benchmark. Its tracking error-the deviation between the fund return and the index return-will now be measured against a higher TRI, thereby increasing the risk of making them less attractive if they consistently fall short of this new and more comprehensive gauge.

Furthermore, the TRI mandate will further deepen fee pressure on active debt fund managers. By and large, many funds that had appeared outperformers under the PRI would now be classified as underperformer, which further makes it difficult for them to justify the higher management fees. This is likely accelerating the trend towards passive investing in the debt space," said an analyst from CLSA in its report this week.

The apex level of clarity for the investors in the growing market:

Consumer activist groups proclaimed that the Supreme Court decision was a landmark moment in the protection of retail investors. "For too long, the average investor comparing a fund's returns to its benchmark was not getting a like-to-like comparison. The TRI removes this opacity. An investor can now clearly see if the fund manager's expertise is truly adding value over and above the basic interest income from the bond market," noted Dhirendra Kumar of Value Research.

Such a step would therefore be significant for the next level at which the mutual fund industry in India would grow, whose Assets Under Management (AUM) nearly doubled in an increasingly retail market entering Tier-2 and Tier-3 cities. Indian standards are being aligned with international best practices and TRIs are really commonplace more so making such a market attractive for foreign institutional investors who are already sophisticated.

The Road Ahead

SEBI is most likely to roll out a fresh implementation circular in the coming weeks to clear the heavens for firms to phase in the changes and get technical guidance. Fund houses now have no option but to adapt. Firms will rapidly modify their internal systems, retrain their sales teams, and commence investor awareness campaigns explaining why their performance charts now look different.

This very judgment has done much more; it has actually made stronger push towards new accountability in the vast financial saving market of India-a reality that exposes to every investor the real cost and value of active fund management.