The episode of Rajat Gupta “Insider Trading”
SEC V. Rajat Gupta (Civil Action No. 11-cv-7566 (SDNY))’

[CP Note: Please treat the section below under Article 21 of the Indian Constitution as very important.]

On September 2008, Rajat Gupta disclosed to Rajaratnam material non-public information he learned as a member of Goldman Sachs Board of Director concerning Berkshire’s 5 billion investments in Goldman Sachs. Rajaratnam, in turn, caused certain Galleon hedge fund to trade on the basis of the material non-public information that Gupta disclosed. On September 22, after Goldman Sachs Board meeting, Rajaratnam received a call from Mr. Rajat Gupta’s office, afterward Galleon hedge fund purchased 1,00,000 Goldman Sachs shares.

The very next day Rajaratnam placed a call to Mr. Gupta and after the call Rajaratnam caused Galleon hedge fund purchased additional 50,000 Goldman Sachs shares. Through a Board meeting, Goldman Sachs approved the 5 billion preferred stock investment by Berkshire. As Gupta knew, Berkshire was a respected and influential investors and its decision to make such a large investment in Goldman Sachs would be favourably viewed by investor as a strong vote of confidence in the firm when the information was disclosed to public. Just after a Board meeting, Rajaratnam caused certain Galleon hedge funds to purchase more than 2, 17,200 Goldman Sachs shares. When Goldman Sachs publicly announced the Berkshire investment along with 2.5 billion stock offering its stock prices from $125.05 per share to $133.00. On the next day Rajaratnam liquidated Goldman Sachs shares generating a profit of $8, 00,000.

Mr. Gupta also disclosed the negative list for the fourth quarter of 2008, reporting a $2.1 billion loss, the first quarterly loss that Goldman Sachs had sustained. As a result of Rajaratnam’s trades on the basis of the material non-public information that Mr. Gupta provided, Galleon hedge funds avoided losses of more than $3.6 million.

The financial result for second quarter of 2008 were also disclosed to Rajaratnam, due to which total illicit profits made by the Galleon hedge funds by virtue of their trading on the basis of Gupta’s material non-public information concerning Goldman Sachs second quarter of 2008 results were nearly $18.5 million.

Non-public information of Procter & Gamble’s were disclosed to Rajaratnam who then passed the material non-public information to his Galleon colleagues, who then caused certain Galleon funds to trade on the basis of the information. Through this non-public information, the Galleon funds generated illicit profits of over $5, 70,000.

WIRE TAPPINGS

The Prosecution in this case majorly relied on phone tapping where Mr. Gupta tipped Rajaratnam about information which was not meant to be public at that time. Earlier the United States Court did not allow the wire tapping’s by stating that Government is not authorized to use wire taps to investigate the matters of Insider Trading.

Later U.S District Judge Richard Holwell allowed the tapping’s by stating that “Prior to the Rajaratnam case, you look at insider trading rings, and they are very small. Prosecutors would wind up getting one, two, three people. The Rajaratnam case showed that with wiretaps, you can sweep in rings of tippers, leading to a vast array of prosecution.” The Government asked U.S Senior District Judge for a pre-trial ruling that tapes be admissible because they contains statements that were against Rajaratnam’s interest and were made in furtherance.

In Insider Trading cases the investigating agencies have to establish three basic elements. First of all, one has to have evidence of action in the market, whether a buy or a sell, then one has to prove that the insider had particular information that others did not have and then the investigators have to establish one caused the other. The key frustration for investigators often comes in establishing the cause and effect. Even in the high profile Raj Rajaratnam-Rajat Gupta case in the US, it is not clear if the authorities would have the conversation, taping of which incidentally was permitted to crack the insider trading case. The case of Rajat Gupta challenged the powers of Securities Exchange Board of India where an Insider is prosecuted mainly on the basis of Telephone Tapping and no motive to secure profit.

ARTICLE 21 OF THE INDIAN CONSTITUTION

Privacy, Tapping and Current Laws

[CP Note: Please read this carefully so as to understand the recent issues pertaining to the Jaitley phone tapping recently which has also acquired a lot of significance.]

According to laws in India the main issue would be that can such wiretapping amounts to violation of fundamental right of an individual or not?

In the case of People’s Union for Civil Liberties Vs Union of India and ans “Telephone tapping is a serious invasion of an individual’s privacy. With the growth of highly sophisticated communication technology, the right to hold telephone conversation, in the privacy of one’s home or office without interference, is increasingly susceptible to abuse. It is no doubt correct that every Government, howsoever democratic, exercises some degree of sub rosa operation as a part of its intelligence outfit but at the same time citizen’s right to privacy has to be protected from being abused by the authorities of the day. ”

“No person shall be deprived of his of his life or personal liberty except according to ‘procedure established by law’.” Through the case of A.K Gopalan vs State of Madras the apex court interpreted that the words “procedure established by law” in Article 21 refers to only state made statues, if any statutory law prescribed procedure for depriving a person of his rights or requirement of Article 21. In the subsequent cases such as R.C Cooper v. Union of India it was held that any law that deprives the life and liberty must be fair and just. The apex court widened the scope of article 21 and has provided with the rights article 21 within itself, on of them are of ‘Right to Privacy’.

The right to personal liberty takes in not only a right to be free from restrictions placed on his moment, but also free from encroachment on his private life. It is true that our constitution does not expressly declare a right to privacy as a fundamental right but the said right is an essential ingredient of personal liberty. Before a person is deprived of his life and personal liberty the procedure established by law must be strictly followed and must not be departed from to the disadvantage of the person affected. As the Constitution of India suggests, it is an essential requirement that a statute should be there so that a person’s phone can be tapped. A written statute provides power to a state and the words ‘procedure established by law’ are fulfilled making the act not against Article 21 i.e Right to Privacy.

Stating more in the case of People’s Union of Civil Liberties v. Union of India, The Supreme Court has ruled that telephone conversation is an important facet of a man’s private life. The right to hold a telephone conversation in the privacy of one’s home or office without interference can certainly be claimed as “right to privacy”. Conversations on the telephone are often an intimate and confidential character. Telephone conversation is a part of modern man’s life. Tapping of telephones is a serious invasion of privacy. “Right to privacy” would certainly include telephone conversation in the privacy of one’s home or office. This means that telephone tapping would infract Article 21 unless it is permitted under the procedure established by law. The procedure has to be just fair and reasonable.


INDIAN TELEGRAPH ACT

[CP Note: This is the specific legislation under which the various issues pertaining to tapping are to be considered, therefore very relevant for you guys!]

The powers to tap phone lines are being mentioned under section 5(2) of Indian Telegraph act 1885 which states, “On the occurrence of any public emergency, or in the interest of the public safety, the Central Government or a State Government or any officer specially authorised in this behalf by the Central Government or a State Government may, if satisfied that it is necessary or expedient so to do in the interests of the sovereignty and integrity of India, the security of the State, friendly relations with foreign States or public order or for preventing incitement to the commission of an offence, for reasons to be, recorded in writing, by order, direct that any message’ or class of messages to or from any person or, class of persons, or relating to any particular subject, brought for transmission by or transmitted or received by any telegraph, shall not be transmitted, or shall be intercepted or detained, or shall be disclosed to the Government making the order or an officer thereof mentioned in the order: Provided that press messages intended to be published in India of correspondents accredited Central Government or a State Government shall not be intercepted or detained, unless their transmission has been Prohibited under this sub- section.”

Telephone tapping is permissible in India under section 5(2) of Telegraph Act 1885. The Court has held that this section is constitutionally valid. This section lays down the circumstances and the grounds when an order for tapping of a telephone may be passed. The constitutional validity of this provision has not been questioned, but no procedure for making order is laid down therein. The Indian Telegraph Act 1885 carries few provision under which the Indian Government and its agencies can tap phones in India but these provision are not sufficient an outdated. As on the date there is no constitutionally sound lawful interception and phone tapping law in India. Phone tapping is permitted based on court order only and such permission is granted only if it is required to prevent a major offence involving national security or to gather intelligence on anti national terrorist activities. Though economic offences/ tax evasions were initially covered under the reasons of interception of phones, the same was withdrawn in 1999 by Government based on a Supreme Court order citing protection of the privacy of the individual.

In 1996 Judgment, The Supreme Court of India stated that “wire taps are serious invasion of an individual’s privacy”. The Court also set out guidelines for wire tapping by the government that who can and under what conditions phone lines can be tapped. Only the Union Home Ministry, or his counterpart in the state, can issue an order for a wiretap. The Government is also required to show that the information sought cannot be obtained through any other means. Recordings or transcript of the tapped phone calls are not generally accepted as primary evidence in Indian Court, such evidences are permitted under Prevention of Terrorism Act and the Unlawful Activities Act [CP Note: Please note that this legislation has now been repealed]. After the Judgment of Rajat Gupta’s case, the Indian market regulator i.e. Securities Exchange Board of India has sought approval from the government to use telephone call records as evidence in the insider trading cases.

ARTICLE 19 OF INDIAN CONSTITUTION

When a person is talking on telephone, he is exercising his right to freedom of speech and expression. Telephone tapping, accordingly infracts Article 19(1) (a) unless it falls within the grounds of restrictions falling under Article 19(2).
The grounds mentioned in Article 19(2), that the competent authority under Section 5(2) of Indian Telegraph Act, 1885 is empowered to pass an order of interception after recording its satisfaction that it is necessary or expedient to do in interest of-
1. Sovereignty and integrity of India;
2. The security of the State;
3. Friendly relations with foreign state;
4. Public order;
5. For preventing incitement to commission of an offence

When any of the five situations mentioned above to the satisfaction of the competent authority requires, then the said authority may pass the order for interception of messages by recording reasons in writing for doing so. Thus, so far as the power to intercept conversation is concerned Section 5 clearly laws down the situation under which it can be exercised, but the substantive law as laid down in Section 5(2) must have procedural backing so that the exercise of power is fair and reasonable. The said procedure itself must be fair, just, and reasonable.

In absence of just and fair procedure for regulating the exercise of power under section 5(2) of the Act, it is not possible to safeguard the rights of the citizens guaranteed under Article 19 and 21. Accordingly, the court has itself filled in the gap by issuing procedural directions for exercise of power under S.5 (2) of Telegraph Act 1885.

Through Hukum Chand Shyamlal case the Court has laid down inter alia that an order of telephone tapping under section 5(2) shall not be made except by the Home Secretary, Government of India and Home Secretaries of the State Governments.
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NON PROFIT MOTIVE

In the case of Securities Exchange Commission v. Roger .D. Blackwell , the honourable US District Court for the Southern court of Ohio states that for convicting some person liable for Insider trading it is not necessary that there should be direct profit motive in the mind of Insider. A different judgment in the case of Raymond L. Dirks v. Securities and Exchange Commission , Where Mr. Ray Driks who worked as securities analyst found the insurance company for which he was working was involved in securities fraud. Mr. Driks disclosed this fraud to public. The SEC censured him for “insider trading” because he provided his clients with non-public information. The Supreme Court found Mr. Driks not guilty and stated that “Even though Mr. Driks client had profited from his action, Driks was not guilty because profit had not been his intent in uncovering the fraud.”

Circumstances plays an important role in the cases of Insider trading, on comparing both the above mentioned case Mr. Blackwell disclosed the information to those person with whom he was having fiduciary relations or family or friends, but in the case of Dirks, where the accused just acted as a whistleblower against the insurance company where he worked. Securities laws, whether in India or USA are formed to save the interest of the investors. The act of revealing the unpublished information of the insurance company by Raymond Driks was to save the interest of the investor and to gain any profit out it.

INDIA

In India, according to SEBI (Insider Trading) Regulations there are two conditions need to be fulfilled to hold somebody guilty as an insider.

1.�� �The “insider” must be a connected person with access to unpublished price sensitive information or he is a deemed to be a connected person.
2.�� �He has traded in those securities on the basis of unpublished price sensitive information.

In the case of Rakesh Agarwal v. Securities Exchange Board of India, Mr. Rakesh Agarwal, the Managing Director of ABS Industries Ltd, was involved in negotiations with Bayer A.G, regarding their intention to take over ABS. Being the Managing Director he had access to the price sensitive information. Before announcement of the merger is made public Mr. Rakesh Agarwal through a collusive agreement with his brother-in- law to take over the shares of ABS from market, thereafter he tendered the same shares through the open offer making huge profit. Later Bayer AG acquired ABS and Mr. Agarwal was also considered as an insider.
In defence Mr. Agarwal denied the allegations levelled against him by SEBI stating that he has acted in such a manner for the benefits of the company and he has no intention to have personal gains. He wanted to acquire 51% shares of the company of ABS through Bayer and he wanted to plan to be executed in clinical precision. Taking into consideration of the defence taken Securities Appellate Tribunal held that Mr. Agarwal did that in interest of the ABS.

INSIDER TRADING LAWS IN INDIA

The Patel Committee in 1986 in India defined Insider Trading as “Insider trading generally means trading in the shares of a company by the person who are in the management of the company or are close to them on the basis of undisclosed price sensitive information regarding the working of the company, which they possess but which is not available to others”. The Patel Committee also recommended that the securities contract (Regulation) Act, 1956 may be amended to make exchanges curb insider trading and unfair insider trading and unfair stock deals.

To strengthen the existing Insider Trading Regulations and to create a framework for prevention of insider trading, committee was constituted by SEBI under chairmanship of Mr. Kumar Mangalam Birla. The recommendations of the committee were considered by the SEBI Board and the amended regulations were notified.

The SEBI (Prohibition of Insider Trading) Regulation 1992, comprise of four chapters and three schedules encompassing the various regulations related to insider trading. Chapter I deal mainly with the definitions used in regulation. Chapter II provides for prohibitions on dealing, communicating or counselling by insider. It also contains the defences available to a company in proceeding against it on allegation of Insider trading. Chapter III narrates the investigating powers of SEBI under the regulation and also enumerates the prohibitory orders or directions that it can issue against the guilty in the interest of the capital market regulation. Chapter IV deals with the code of internal procedure and conduct to be followed by listed companies and other entities, disclosure requirements be followed by company. It also contains appeal provisions which an aggrieved person may like to follow against the orders of SEBI.

Hindustan Level Limited- The definition of insider was amended after the famous case of Hindustan Level Limited in 1998 in which the definition included those persons also who “has received or has had access to such unpublished price sensitive information”, and not just a person who is or was connected with the company. A concept of deemed connected person which included all the relatives of that particular connected person.

Complied by Debajyoti Das, CP Mentor

� Anonymous

CRIMES AGAINST WOMEN- An action plan
Former Chief Justice of India J.S. Verma. The committee headed by him says that all organs of the state have failed to fulfil the promise of equality for women.
Women’s groups have generally responded favourably to the report of the three-member committee headed by Justice (retired) J.S. Verma that reviewed the laws dealing with sexual assaults against women. The other two members of the committee, which was set up on December 24 in response to the December 16 gang rape and the public outcry that followed, were Justice (retired) Leila Seth and former Solicitor General Gopal Subramanium. It received over 70,000 responses within a fortnight and came up with its report in a month’s time.
The report, which was submitted on January 23, has drawn praise from political parties and women’s organisations that have been urging successive governments to amend or enact laws for women and implement them.
The report places on the state the onus for ensuring that women are safe. Its authors lament that it is “unfortunate that such a horrific gang rape (and the subsequent death of the victim) was required to trigger the response needed for the preservation of the rule of law—the bedrock of a republic democracy”. They have expressed the hope that “the tragedy would occasion better governance, with the state taking all necessary measures to ensure a safe environment for the women in the country”. The authors have said they hope some follow-up action will be taken within 30 days of the submission of the report, especially before the Parliament session starts. “Unless and until the state pursues a policy of avowed determination to be able to correct a historical imbalance in consciousness against women, it will not be possible for men and indeed women themselves to view women differently through the prism of equality,” the report says. The first part of the report outlines the committee’s approach to the problem, while the second lists its recommendations.
The report draws its moral authority from the Constitution and states in the introductory chapter that the “right to be protected from sexual harassment and sexual assault is, therefore, guaranteed by the Constitution, and is one of the pillars on which the very construct of gender justice stands”. It criticises political leaders and religious heads for reinforcing gender biases through their utterances and some for blaming the victim.
The report equates the importance of political equality with other kinds of equality, such as social, educational and economic, saying that de facto equality guaranteed by the Constitution has not become a reality for women and asking, rhetorically, “Does the Indian state live at two levels?” One level, according to it, comprises the affluent sections that have access to the Constitution and its machinery and the other comprises those who live in the silent domination of the superior will of tradition, customs and practices that are derogatory to women.
The time has come, the report says, to enact laws providing for the disqualification of elected representatives who have expressed a gender bias through their statements. The authors are “distressed to say that all organs of the state have, in varying degrees, failed to fulfil the promise of equality in favour of women”.
The report comes down heavily on extra-constitutional bodies like khap panchayats and the failure of Parliament to denounce these bodies. “We wish to make it clear that acts of extra-constitutional bodies like the khap panchayats, which restrain the right of men and women to select a partner of their choice, do not enjoy the sanction of law in India… we are unable to understand how a set of self-styled bodies and panchayats can outlaw marriages born out of free choice,” the report observes.
ALTAF QADRI/AP
A march against gender discrimination and sexual violence on January 26 in New Delhi. The December 16 gang rape has brought protesters into the streets demanding that the government protect women.
It looks critically at the mindset of the judiciary, at institutional biases, especially towards the economically weaker sections, and at the construct of gender justice in India. It examines the historical neglect of women in planning and public policy, pointing out that it was as early as 1939 that a National Standing Committee appointed a subcommittee to work out a role for women in a planned economy. The lack of empowerment of women, the report says, resides in three factors: one, the inequality perceived and felt by women; two, de facto inequality; and three, poverty and lack of power, or, the inability to access authority in equal terms.
Defining sexual assault
In one of the most important chapters, which deals with rape and sexual assault, the report concurs with the views of women’s organisations that the Criminal Law Amendment Bill, 2012, is far from complete, especially as the new provisions, while expanding the ambit of penetrative forms of rape, has confined itself to penetration alone, with other forms of sexual assault remaining outside the purview of legal sanction. The inclusion of other non-penetrative forms of sexual assault, including redefinition of rape to include all non-consensual penetrative acts of a sexual nature, has been recommended. It has looked at Law Commission reports that have examined issues of consent in rape. With respect to marital rape, it endorses the conclusion of the European Commission on Human Rights, supported by women’s groups here, that a rapist remains a rapist regardless of his relationship to the victim.
Harassment at work
The report has looked critically at the recently introduced Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Bill, 2012, noting that there was no debate on this in the Lok Sabha. It recommends the widest possible application to take within its scope all women in the workforce, including those in the unorganised sector, the armed forces and the police, and women students and staff of all schools and educational institutions. It has noted that the Bill excluded from its ambit students of universities, colleges and schools.
The committee describes as “abusive” Section 14 of the Bill, which seeks to penalise a woman for making a false complaint, and the provision to attempt conciliation between the complainant and the respondent. The report notes that the Bill has no compensatory mechanism for a victim of sexual harassment. While welcoming the definition of sexual harassment in the Bill, the report has suggested that the definition must give due weight to both subjective and objective criteria as far as the explanation of the term “unwelcome” is concerned. The report has suggested the setting up of a tribunal, rather than an internal complaints committee, to receive and adjudicate all complaints.
The committee has also recommended the appointment of retired judges to expeditiously dispose of pending cases. It says that public prosecutors should be appointed on the basis of merit and that cases of rape and sexual assault should be tried by women prosecutors, and, to the extent possible, by women judges.
In the section dealing with other offences against women, the report has recommended the inclusion of acid attacks as a separate offence in the Indian Penal Code. It recommends that sexual violence against women by members of the armed forces or uniformed personnel be brought under the purview of ordinary criminal law and special care be taken to ensure the safety of complainants. It says that the Armed Forces (Special Powers) Act and other similar protocols in situations of internal conflict should be reviewed.
The report also deals with trafficking in women and children and includes detailed testimonies from children that implicate policemen in several acts, including rape. It notes that the term “trafficking in persons” is nowhere defined in Indian law and recommends the usage of the composite definition as in the United Nations Palermo Protocol. The committee members have taken a serious view of the state of homes for children and women and the abuse they face there.
The accused in the Sultanpuri gang-rape case being taken to a court in Rohini, New Delhi, in December 2010. The victim in this case was a teenager who was gang-raped in a moving car.
The committee has not recommended the death penalty for rapists, not even in cases of aggravated sexual assault, including in exceptional conditions where such brutality leads to death or to a vegetative state, because death may not be a deterrent. The committee is also against chemical castration for rapists and the lowering of the juvenile age limit to 16 years. It recommends rigorous imprisonment for the rest of the convict’s natural life.
A new section for gang rape has been recommended where punishment shall not be less than 20 years and may extend to life; the convicted person should also be liable to pay compensation to the victim to the extent that it must at least meet the victim’s medical expenses. New sections covering acts of disrobing, voyeurism and stalking have also been recommended for legislation on sexual assault. Where such offences lead to death, the case could be tried under Section 302 (murder), though many such cases would fall under Section 304 since the intention to kill may not be established.
The report expresses shock at the “incapability of the Government of India and of various State governments to implement even the most basic measures [of safety] with any amount of efficacy”. There have been Supreme Court and High Court directions from time to time banning the use of black film on windscreens, safety glasses and side glasses of all vehicles throughout the country.
Existing laws
The committee says that the existing laws, if faithfully and efficiently implemented, are sufficient to maintain law and order and to protect the dignity and safety of people, including women. Law-enforcement agencies must be insulated from political interference, the report says. It has also dwelt on the “peculiarity of the government of Delhi not having any control over the police force”. This was cited by the Delhi Chief Minister to contend that her government did not have any responsibility in the gang-rape case. The committee recommends the removal of this ambiguity for purposes of accountability so that there is no divided responsibility in Delhi in respect of law and order. One of the primary recommendations relates to the mandatory registration of all marriages in the presence of a magistrate. It says the officer of law should ensure that no dowry has been exchanged and the marriage has the consent of both partners. The report is silent on marriage expenditures, though.
The report suggests that the Criminal Law Amendment Bill, 2012, should be further amended to include sexual assault on men and also transgender and transsexual rape. It has recommended special protocols for medical legal examination of victims of sexual assault, special procedures for protecting persons with disabilities, and the placement of police officers with outstanding ability and character at higher levels of the police force. It has taken strong note of the rising cases of missing children and placed the onus on District Magistrates to carry out a census of missing children in their districts. The Chief Justice of the High Court in every State should have the machinery for the supervision of protection homes, and the immediate and ultimate guardianship of their residents must rest with the court.
A new constitutional authority, akin to the Comptroller and Auditor General, for women and children has also been recommended. The committee has suggested amendments to the Representation of the People Act that will require a candidate to declare pendency of a criminal case and to produce a certificate from the registrar of the High Court to validate his nomination. A candidate who fails to disclose a charge or the commission of an offence ought to be disqualified, recommends the report.
The report needs to be appreciated not only for being sensitive and responsive to the positions of women’s organisations, but also for the approach and understanding it has adopted to lay bare the impediments to ensuring equality for women. There is, however, a degree of cynicism in the report as far as the importance of political representation of women is concerned, a view which is not necessarily shared by women’s organisations.

(Based on the excerpts from ‘an internet source’ and ‘The Hindu’)

Compiled by Sanjay Singh

CP Mentor

Day to Day study Plan for English and Logic for the next 60 Days
So now almost all of you have resigned to your fate as far as your preparation is concerned but dear students please remember THIS IS NOT THE END OF THE ROAD!! And this week’s blog is intended to inform you that with valid ways of progressing in your studies.

To begin with we need to assess YOUR PRESENT STATUS.
1.�� �Take out all the CP mocks that you’ve given and check your scores in English and Logic and maybe all sections. �
2.�� �See if the scores indicate any pattern; such as increasing, decreasing or plane simple haphazard
This pattern will indicate where you need to head in terms of your daily study. An increasing score suggests
1.�� �Progress which may be attributable to your concept clarity.
2.�� �Also shows that with every mock you are drawing learnings which are helping you with your subsequent mock

A decreasing score contrarily shows lack of concept clarity or revision or both.

A haphazard score indicates ad-hoc ‘ism’ in the study pattern itself and even the correct answers are to be seen as suspicious because they may just be pure guesswork.
After the above analysis when you see English and Logic as sections where you need to work on,the following is what needs to be done:

1.�� �Divide these sections into topics and sub topics. some suggested topics are; Reading Comprehension, Grammar, Vocabulary for English and Syllogisms, Consistency, Critical Reasoning ( Assumption, Strong Weak Arguments) for Logic
2.�� �Once the topics are divided rank them in descending order of urgency that means rank 1 should be allotted to the topic you find most difficult. You should take help from your CP mocks to see which topic you’ve got the maximum wrongs
3.�� �Once ranked we start with that topic immediately.
So now is the time to focus on your weak areas one by one. Once you pick your weakest topic we put it to the 3 step prep process
1.�� �Step 1 – redo your basic fundamentals to see if you’ve a gap in understanding. Take assistance from the CP Build Books and/or your CP mentor to go through the basics again.
2.�� �Step 2 – again pick up all the mocks and take out the questions from that topic from each mock. Put them into groups of 10/15/20 and time and solve them. Check your performance and analyse your answers well. Note down any doubts� and immediately seek help from your mentor.
3.�� �Step 3 –now do the same questions from your CP Practice books ( or any other material) and analyse your answers.
4.�� �Finally get ready to solve fresh mocks and papers with a renewed confidence in the topic
This 3 step method will remove any gap in concept and redoing the mocks will ensure revision of the topic with greater clarity in choosing the best answer. Please remember REVISION and REDOING of MOCKS IS THE KEY TO SCORE ENHANCEMENT.
Please repeat this process with the next in your list of topics. Do these topics one by one and get them out of the way. Infact the same can be repeated for the other sections as well.� Combine an English/Logic topic with and AR or Maths to remove monotony.
While you are doing topic-wise revision continue to do your GK and taking tests as and when.

This is exactly how you must prepare for the final days.

Surabhi Modi Chief Mentor, CP