International Journal For Multidisciplinary Research

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Comparative Study of Whistleblower Protection Laws: India vs USA (Sarbanes-Oxley Act & Dodd-Frank Act)

Author(s) Ms. Seema Choudhary, Ms. Megha Chandok, Mr. Shivam Gupta
Country India
Abstract This paper undertakes a comparative analysis of whistleblower protection frameworks in India and the United States, focusing on the Indian Whistle Blowers Protection Act 2014 (WBPA), Section 806 of the Sarbanes-Oxley Act 2002 (SOX), and Section 922 of the Dodd-Frank Wall Street Reform and Consumer Protection Act 2010 (Dodd-Frank). The study examines the scope of protected disclosures, institutional mechanisms, remedial architecture, incentives and jurisprudential evolution in each jurisdiction. It finds that while India largely adopts a public-law, anti-corruption centric model oriented towards disclosures against public officials, the U.S. regime embeds whistleblowing within securities regulation, coupling robust anti-retaliation protections with powerful monetary incentives.
The central argument advanced is that the Indian framework, despite representing a significant normative commitment to transparency, remains under-inclusive in institutional coverage, weak in terms of private-sector reach, and underdeveloped in implementation when measured against the more mature and enforcement-driven U.S. model under SOX and Dodd-Frank. The paper concludes with reform-oriented suggestions for the Indian regime including extension to the corporate private sector, clearer retaliation remedies, creation of an independent whistleblower authority, and calibrated adoption of incentive mechanisms, while also highlighting emerging criticisms and limitations within the U.S. approach.
Keywords Sarbanes-Oxley Act, Dodd-Frank, Whistle Blowers Protection, Consumer Protection, anti-retaliation protections
Field Sociology > Administration / Law / Management
Published In Volume 8, Issue 3, May-June 2026
Published On 2026-06-02
DOI https://doi.org/10.36948/ijfmr.2026.v08i03.80212
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