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Nobody was running index only porfolio in India even 5 years back. The availability of low cost Nifty Midcap 150, Nifty Smallcap 250, Nifty 500 index funds is only a recent developement. So the question is no longer if the chosen actively managed fund would beat Nifty 50 Index but if it would beat it's benchmark index fund. Indian markets are increasingly getting more efficient. As the efficiency of markets increases, the alpha starts shrinking. The expense ratio of a fund doesn't include brokerage & transaction cost and impact cost. This additional cost is higher for actively managed funds compared to index funds owing to higher turnover. Which tilts the probability in favor of index funds. Besides, fund managers are human beings. The behaviour of no human being is consistent. When your behaviour inconsistent, you become unpredictable. Fund selection therefore is a chance driven exercise. You pick an actively managed fund and hope that it beats the index.