IT is usually very difficult to feel sorry for bankers in the territory, but a little sympathy is in order for the desperate plight that Hongkong Bank finds itself in India. This rare goodwill is not shared among fund managers, who are fretting as they find themselves shut out of what could be one of the biggest investment opportunities of the year. To a certain extent, the hostility is self-inflicted. Yesterday the bank started what is obviously going to be a high-profile programme of explanation. But despite its assurances that its clients had been kept informed, there is a strong feeling among local fund managers that not nearly enough has been done to explain the problems the bank faces. And they are horrendous. India is an emerging market like no other. It has only just opened up to foreign investing institutions, but is already massive. Its current market capitalisation is equal to that of Hong Kong, China, Indonesia and the Philippines combined. It has more stocks quoted than the United States, yet has systems that Hongkong Bank correctly condemns as ''Dickensian and archaic''. Unlike Shanghai, Shenzhen or even Indonesia - which have been built from the ground-up with all mod cons - India is mired in its long stock-dealing history of servicing small retail clients. Board lots in India are so small that hundreds need to be transacted for one reasonably sized institutional investment. What follows is a nightmare of manual manipulation, the licking of millions of stamps every day, and hand-cancelling of certificates. Procedures are being improved, but only slowly. The acceptance of Jumbo certificates, which cut out much of the paperwork by rolling up normal board lots on to one certificate, is a welcome, if small, improvement. Even this has its problems if institutions wish to sell amounts of stock different from those contained on a certificate. The terrible risk of India is that the market will suddenly falter, and big overseas investors will rush for the door. This is always the nightmare that keeps emerging market investors awake, but the potential for mayhem in India is terrifying. Should the market ever go south in a big way, those fund managers who are now complaining at being kept out might suddenly begin to recognise their luck.