Prayas Occasional Report 1/2002, February 2002. Based on the analysis of the data emerging from the regulatory process in states such as Maharashtra, Andhra Pradesh, Haryana, and Karnataka, this paper points out that, even in the HT sector, commercial losses appear to be significant. Based on this revelation, the paper argues that the starting point in our battle against excessive T&D losses should be to institute an effective energy audit at the HT level. Such an approach is desirable for many reasons that include relatively small requirements of investment and of managerial efforts, high cost-benefit ratio due to higher consumption norm, higher tariff, and small number of consumers in the HT sector. It is also a ‘no-regrets’ strategy, - as the HT audit is an essential pre-requisite for effective implementation of "Total Energy Audit" and "100% Metering” approaches. Further the paper also advocates that regulatory commissions need to adopt unyielding stand to ensure timely completion of effective HT level energy audit, which is also crucial for ensuring accountability of utility staff.