The other two Indians in the field -- Neha Tripathi (75) was tied-89 and Amandeep Drall (77) was tied-109th -- and will need solid rounds to make the cut.
At the Real Club de Golf Guadalmina England's Georgia Hall came home with five birdies and an eagle to fire a seven-under-par 65 and take the joint lead with Natalia Escuriola Martinez of Spain and Italian Diana Luna.
Suzann Pettersen, Carlota Ciganda and the 2013 tournament champion Lee-Anne Pace are one back in joint fourth place after rounds of 66.
French duo of Marion Ricordeau and Celine Herbin shared seventh on five-under-par, with joint ninth place occupied by England's Gabriella Cowley, Valentine Derrey of France and Lydia Hall from Wales.
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