Beyond the Last Petrol Pump

India's Downstream Petroleum Architecture Gap and the Case for Structural Fuel Continuity Reform

Abstract

India's March 2026 LPG and Natural Gas Control Orders — issued under the Essential Commodities Act 1955 in response to disruptions in the Strait of Hormuz — demonstrated both the institutional capacity and the structural limitations of India's downstream petroleum architecture. While the government's crisis response was effective, it was reactive. This paper identifies five structural deficiencies: the absence of an operational neutral wholesale petroleum market; the absence of a comparably clear standalone open-access framework for downstream terminal and rack capacity used for product lifting by independent operators; the absence of a formal industry-wide emergency petroleum stockholding framework specifying obligations, reporting and release conditions; the absence of a pre-established National Essential Petroleum User Registry (NEPUR); and the absence of a pre-crisis framework for triggering domestic supply-protection measures. The paper argues that the March 2026 disruption exposed institutional questions about how available petroleum supply is priced, moved, buffered and prioritised during stress. Five targeted policy steps are proposed, several of which can be pursued within existing statutory authority while others would require subordinate regulatory measures or amendments.