In a major development likely to trigger regulatory and legal scrutiny, the Legal Rights Protection Forum (LRPF), a Hyderabad-based NGO has submitted a detailed and explosive complaint to the Ministry of Home Affairs (MHA), Foreigners Division, calling for an urgent investigation into a web of FCRA violations, alleged benami operations, and financial misappropriations involving four high-profile NGOs based in Anantapur, Andhra Pradesh. The complaint, addressed to the Joint Secretary, Foreigners Division (FCRA Wing), urges an urgent and comprehensive investigation into the activities of Rural Development Trust (RDT), Rayalaseema Development Trust (RyDT), Accion Fraterna Trust (AFT), and Women’s Development Trust (WDT).
The LRPF’s complaint stems from the MHA’s recent decision on April 21, 2025, to decline the FCRA license renewal for Rural Development Trust (RDT), Anantapur, due to “egregious financial irregularities,” including the diversion of over INR 26 Crore collected from patients at foreign-donated hospitals into non-FCRA domestic bank accounts. The audit also revealed unlawful transfers of foreign contributions to entities without valid FCRA registration.
Interconnected NGOs Alleged to Be Shell Fronts
The Legal Rights Protection Forum’s (LRPF) complaint asserts that the Rural Development Trust (RDT) operates in a deeply intertwined manner with the Rayalaseema Development Trust, Women’s Development Trust, and Accion Fraterna Trust, suggesting a complex web of shared addresses, personnel, donors, financial operations, and even project details. LRPF alleges these organizations function as “shell fronts” or “benami” entities, acting under a unified command while presenting themselves as distinct to sidestep financial oversight and FCRA regulations, pointing to profound interlinkages such as shared office bearers, identical or proximate registered addresses, overlapping operational jurisdictions, convergent declared objectives, and common foreign donor networks.
A key concern raised is the dual role of Mr. Moncho Ferrer, who serves as Board Member for Indian trusts while also functioning as Chief Functionaries of their primary foreign donor organizations, Vicente Ferrer Foundation (USA) and Fundación Vicente Ferrer (Spain). The LRPF contends this “dual role raises serious concerns under the FCRA framework, as it potentially indicates a conflict of interest and warrants scrutiny regarding control, direction, and utilization of foreign contributions.”
The LRPF suspects that this structural and functional convergence points to these entities operating as “shell entities” or “Benami” fronts designed to “circumvent the stringent provisions of the FCRA.”
Pattern of Internal Fund Routing and Financial Obfuscation
The complaint highlights numerous “frequent and substantial inter-NGO transfers of foreign contributions” between these entities, as revealed by their FCRA filings. The LRPF asserts these transfers indicate “a discernible pattern of internal fund routing” rather than legitimate, need-based expenditures for beneficiaries, pointing to “deliberate financial obfuscation and concealment.” For example, significant transfers include INR 23,00,00,000 from the Women’s Development Trust to the Rural Development Trust in 2015–16 for “Social Purpose,” and INR 9,63,720 from the Rural Development Trust to the Women’s Development Trust in 2014–15 for “Establishment of Corpus.”
Deceitful Declarations and Overlapping Projects
A critical accusation in the complaint is the alleged “fraudulent pattern of overlapping addresses, shared field offices, identical or deceptively similar project descriptions, and common personnel” in the FCRA returns filed by RDT, RyDT, and WDT. The LRPF asserts this is a “deceitful and collusive network clearly designed to present the illusion of distinct legal entities while engaging in coordinated activities to bypass FCRA regulations.”
The complaint lists 16 specific “Door Numbers” and addresses that have been “fraudulently represented across multiple FCRA filings by these entities,” often declared as separate projects for “construction of field offices” and “purchase of fixed assets.” This “duplicative and misleading declarations” are seen as a “systematic effort to misrepresent facts, conceal true control structures, and illegally circulate foreign funds among affiliated bodies.”
Suspicions of Fraudulent Fundraising and Asset Misappropriation
The LRPF also highlights “strong suspicions of fraudulent fundraising and asset misappropriation” particularly concerning Women’s Development Trust (WDT). WDT reportedly received substantial foreign funding for “Hospital Program Expenditure” and “Construction of Buildings” for “WDT Hospitals” in Kalyandurgam and Kanekal areas. However, the LRPF claims a “striking absence of transparency and credible, verifiable documentation” that WDT independently owns or operates such hospitals.
Further compounding this suspicion, both WDT and RDT have allegedly used “identical images of hospital infrastructure in their respective Annual Activity Reports and official websites, yet displayed different name boards—one as WDT Hospital, the other as RDT Hospital.” This “highly suspicious duplication” indicates “misuse of WDT’s foreign contributions for a facility that is not under its control, raising the likelihood of fund diversion to RDT operations.”
Undisclosed Foreign Contributions to Women’s Development Trust
The complaint also points to “critical non-compliance” by WDT regarding undisclosed foreign contributions. Between 2011-12 and 2014-15, WDT allegedly received a total of INR 36,04,42,175 from “Unknown” donors, with the purpose “Not Declared.” This, according to LRPF, constitutes a “grave violation of statutory mandates” under Sections 18 and 19 of the FCRA, 2010.
Call for Comprehensive Investigation
The LRPF concludes that the observed patterns of “circular fund flows, asset layering, and obfuscated financial reporting” could potentially fall under the purview of the Prevention of Money Laundering Act (PMLA), 2002, in addition to the FCRA. Given this compelling evidence, the LRPF has urgently called upon the MHA to initiate a comprehensive forensic audit and financial inspection of all four trusts, rigorously scrutinize their FCRA-designated bank accounts, donor communications, and project implementation, verify the independent existence and operational legitimacy of “WDT Hospital,” and thoroughly examine whether the intricate organizational structure constitutes a “Benami” network designed to illicitly route and misuse foreign funds.
The complaint underscores the necessity of prompt action to uphold the integrity of foreign contribution regulations in India. The MHA is expected to respond to these serious allegations, which could have significant ramifications for the concerned NGOs and the broader non-profit sector.
(Published with inputs from the Legal Rights Protection Forum)
Arise Bharat 
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