NAME OF THE CASEAnuradha Bhasin v. Union Of India
CITATION AIR 2020 SC 1308[1]s
DATE OF THE CASEJanuary 10, 2020
APPELANTAnuradha Bhasin and others.
RESPONDENTUnion Of India and others.
BENCH /JUDGEJustice N. V. Ramana, R. Subhash Reddy and B.R. Gavai.
STATUTES/ CONSTITUION INVOLVEDThe Constitution of India, Code of Criminal Procedure 1973, Information Technology Act 2000, The Telegraph Act 1885, The Temporary Suspension of Telecom Services (Public Emergency or Public Safety) Rules, 2017.
IMPORTANT SECTIONS/ ARTICLES The Constitution of India—Article 19, CRPC Section-144


Modernity is something that society needs, to become modern means, in the sense of technology, in the field of education and to become modern through the mind. The basic need in today’s world that we saw during the pandemic was that the Internet, which was the only medium at that time, became useful for many of us. It is very useful in digital technologies, as the COVID-19 pandemic has increased the use of digital tools. This case focused on the right to internet access, technical judicial standards to interpret the issues relating to Article 19 (1) (a) and (g), and the impact of such standards on the scope of restriction under clauses (2) and (6), respectively. Further, the case discussed political, social, and technological developments at the same time, which necessarily affect the judicial endeavor. The main points to be discussed here are the medium of the internet and the exercise of rights by individuals.


Once a government is committed to the principle of silencing the voice of opposition, it has only one way to go, and that is down the path of increasingly repressive measures, until it becomes a source of terror to all its citizens and creates a country where”–Harry S. Truman[2]

A society can develop or grow when an individual present in it has the liberty to express one’s opinion or thought without any restriction, especially without penalties. Only then can the concept of a free society emerge. Freedom of speech and expression is an integral part of an individual’s life; it is a basic part of human rights. Under Article 19(1)(a) of the Constitution of India, freedom of speech and expression are enshrined. The Indian Judiciary played an operating role in interpreting the fundamental rights, and with time, the ambit of the fundamental rights has increased. This freedom of speech and expression has been categorized or mentioned as one of the golden threats along with Article 14 and Article 21 of the Constitution of India, which run across the fabric of the Constitution of India. It is the bedrock of any democracy because this right is recognized not only by Constitutions but also internationally, i.e., in Article 19 of the Universal Declaration of Human Rights, as a basic right of an individual. And a democracy becomes a democracy only by virtue of the freedom of speech and expression of its citizens.


This case challenged the legality of internet shutdown and movement restriction in the state of Jammu and Kashmir. The state of Jammu and Kashmir has seen a lot of political disturbance or instability since a very long time, especially since the enforcement of the Constitution when its status was not fully decided by constituent assembly and it was given a legal status. hardly there was political stability in Jammu and Kashmir, after the removal of Article 370 from Jammu and Kashmir there was an apprehension that the people of Kashmir would come out to create havoc in the state and so based upon this constructive and presumed apprehension, the government while anticipating such danger shut down the internet and also restricted the movement. This case is not the first case over the internet access there are also other cases where court held that right to access internet is a fundamental right.


Freedom of speech and expression does not  means to sing along with the tunes of government , this type of freedom is also available under monarchy or dictatorship , it is not that if one has ability to speak  he is allowed to speak . The actual meaning of freedom of speech and expression is when one have right to dissent with the government democratically but there is a thin line difference between freedom of speech and expression and sedition that should be maintained. The ambit of freedom of speech and expression with time has been increased, there are lot of cases with molded the freedom of speech and expression. In Romesh Thappar Vs State of Madras it was held that freedom of press is a part of freedom of speech and expression. In Sakal Papers Ltd. VS Union of India and in Bennett Coleman Vs Union of India the validity of the newspaper control order, which has fixed the number of pages was struck down by Apex court of India declaring it as a violation of Article 19 (1) (a) and does not fall into reasonable restrictions under Article 19(2).

Give me the liberty to know, to utter, and to argue freely according to conscience, above all liberties”.John Milton[3]

John argued that without human freedom there can be no progress in science, law or politics, which according to him required free discussion of opinion. Mill’s on Liberty, published in 1859 became a classic defense of the right to freedom of expression. Democracy is based essentially on free debate and open discussion, for that is the only corrective of government action in a democratic setup. If democracy means government of the people by the people and for the people, it is obvious that every citizen must be entitled to participate in the democratic process and in order to enable him to intelligently exercise his right of making a choice, free and general discussion of public matters is absolutely essential.[4] Freedom of speech and expression can be understood with instrumentalist and non instrumentalist side, in the case Indian Express Newspapers (Bombay) (P) Ltd. & Ors. V. Union of India & Ors. The honorable Supreme Court held that “Freedom of expression, as learned writers have observed, has four broad social purposes to serve: (i) it helps an individual to attain self-fulfillment (ii) it assists in the discovery of truth, (iii)it strengthens the capacity of an individual in participating in decision-making and (iv) it provides a mechanism by which it would be possible to establish a reasonable balance between stability and social change. All members of society should be able to form their own beliefs and communicate them freely to others.”[5]

In this case right to know was brought into the ambit of Article 19(1) (a) which shows the instrumentalist side.


Internet access is not a new concept it has been a part of debate for a long time but now it is recognized as a fundamental right but there was brief history of internet access to become as a part of fundamental right .It was all started on  4August 2018 when in Jammu and Kashmir there was an internet shutdown due to security concern and it was remained for 213 days then in September a case named Faheema Shirin R.K .Vs State Of Kerala where the girls of hostel were not allowed to use phone after 10 pm in the hostel which was challenged and here Court held that right to internet access is fundamental right as right to privacy and right to education is a fundamental right. Freedom of speech and expression includes right to express opinion with variety of medium. UN report outlined with Internet Access already mentioned “Right to Communication” and “Right to seek, receive and impart information”.

  1. Right to communicate: The idea of right to communicate was first articulated by late UN Official Jean d’Arcy in 1969. This right was later given much importance by the United Nation Educational, Scientific and Cultural Organization (“UNESCO”), which brought the idea to right to communicate in 1980 in the general conference in Belgrade. It was recognized as “right of the public, of ethnic and social groups and of individuals to have access to information sources and to participate actively in the communication process” 17and this was further recognized in 1981 and 1983. But this right couldn’t succeed in getting a better support for recognition from other international organization thus the movement to codify it as a right internationally failed. One of the reasons for this to become a failure was the needs for a positive recognition for this right and also the implementation of this right require obligation on state to provide a means for communication which was not supported by many states due to lack of resources. However, the failure of this movement provided a stepping stone for internet access right as given importance in the UN Rapporteur.[6]
  2. Right to seek , receive and impart information: The central idea for the UN Report 2011 was the right to seek, receive and impart information which was drawn from Article19(2) of the ICCPR which is: “Everyone shall have the right to hold opinions without interference and everyone shall have the right to freedom of speech and expression; the right shall include freedom to seek, receive, and impart information and ideas of all kinds, regardless of frontiers either orally or the form of writing or print, in the form of art, or through any other media of their choice”.[7]


Internet plays an important role in communicating and expressing their ideas and opinion through the medium of freedom of speech and expression. People are connected even though there is presence of physical barrier through internet access. The United Nation human commission also recognized free speech though internet as a medium of communication. Also, Article 19 of UDHR and Article 19(1) of ICCPR also provides for freedom of speech and expression even in case of internet. However, internet is not only regarded as just a medium for communication but it is also considered as a source of information, global business and social platform.

 • Internet has been regarded as a vital source of information which provides people with wide range of resources thus helps in promoting education.

• Internet plays a crucial role in promoting one global economy as it eliminates the hindrances caused due to physical boundaries.

 Need for internet access as a separate right has also been recognized by international institutions. United nation has always been upfront in supporting internet access.[8]


Jammu and Kashmir is the Indian state which occupies Indian territorial bordering with Pakistan which has been remained the subject of debate for long term between two countries. Under Article 370 of Constitution of India, the territory acknowledges special status of the state in matter of its autonomy and its power to frame laws for its permanent residents. This Article 370 stated that the State had its own Constitution and Indian citizens were not allowed to settle there. i.e. they were not allowed to buy land or property there.

On August 5, 2019, an order was passed by the Indian government Constitution (Application to Jammu and Kashmir) Order, 2019, which deprived Jammu and Kashmir from its special status which had been enjoyed since 1954 by it and all provisions of the Constitution of India were made applicable to Jammu and Kashmir by amending Article 367 of the Indian Constitution. The order dissected the state of Jammu and Kashmir into two Union territories which are Jammu and Kashmir, and Ladakh.

On 4 August, 2019 in the view of danger or threat to public order and security to the state, the state imposed restrictions on internet shutdown. All mobile connective, telecom were shutdown. Further the government was so frightened that not even two people should be allowed to gather or to stand together in any place of market. Every single person, every single individual in the state must be confine to their homes, no person should go to office, no children or youth should go to education institution because government was apprehending a lot of turbulence and political dramas in the state and it was preventing people from meeting each other, so they restricted the movement by applying Section 144 of CRPC.

Miss Anuradha Bhasin a journalist, an executive editor of Kashmir Times of Srinagar Edition being a petitioner in this case raised the crucial constitutional issues about the essentiality of the internet for modern press. She pointed out that as from 6 August, 2019 the newspaper had not been published, so this could lead to an end to print media without internet.

She argued that without a valid reason the government cannot suspend such right under Suspension Rules, the government should have valid reason for suspension it cannot be done capriciously or whimsically. She further contended that the government needs to find a way to balance the measures necessary to maintain national security and rights of the citizens. She further contended that earlier imposition as temporarily but now this imposition occurs for more than 100 days.

Now a second writ petition was filed by a member of parliament Mr. Ghulam Nabi Azad, he argued that state cannot claim any kind of privilege before the court for reiterating such order. He also argued that the government has created national emergency kind of situation because there was nothing going in the state still government resumed it on its own that there might be some political disturbance in the state and based on this baseless or unreasonable the government has created an emergency like situation in the state because there was neither internal nor external disruption present in the state. He contended that there might be a group of people who wants to disturb public peace and tranquility so in order to restrict certain group the government cannot compromise the freedom of speech and expression of the entire state. Imposing restrictions on internet not only impacts freedom of speech and expression but also impacts freedom to carry on any trade, profession or business under Article 19 (1) (g) of Constitution of India.

In reply to this the government argued that Jammu and Kashmir militancy situation has to be taken into account as there has been militancy since a very long time, Armed forces Special Power Act has been in continuous affect and there has been complete destruction of public peace and order. It was also held that order of restrictions on movement and internet shutdown were imposed after taking proper circumstances and was not capriciously. If this preventive measure would not be taken than this would have created an external and internal militancy and which would have been known in the history and could lead to a huge barbarity. These circumstances were compared with 2016 terrorist attack and said that similar actions were taken by the officials. It was further held by the government that protecting citizens is foremost duty of the state and in order to protect the peace there need to issue of such kind of orders. It was also contended that segregating agitators from peacemakers is an impractical approach, it was concluded by the government that all the orders were passed were according to the procedure mentioned in the suspension rules and intention behind restricting internet was not only about social media but also  about dark web.


  • Whether the freedom speech and expression and freedom to practice any profession, or to carry on any occupation, trade or business over internet is a part of the fundamental rights protected by Article (19) (1) (a) and Article (19) (1) (g) of the Indian Constitution.?
  • Whether freedom of the press of the petitioner was violated due to the restrictions?
  • Whether restrictions imposed under Section 144 CRPC were valid? Whether the government can claim exemption from producing all of the restrictions orders?
  • Whether prohibition on internet access by the government is valid or not?


  • Ms. Vrinda Grover representing petitioner contended that due to several restrictions imposed on the press the petitioner is not able to function properly as petitioner is an executive editor in Kashmir Times. She contended that print media bog down due to inaccessibility of internet, which is absolutely necessary for modern press.
  •  Restriction on internet is halting the right to free speech and it should be tested on the basis of proportionality and reasonability or test of essentiality. She further contented that public order and law and order are not same.
  • Mr. Kapil Sibbal argued that the authority orders should be produced before the court and cannot be subjected to privileges.
  • He argued that emergency can be declare by Union of India only I limited circumstances but here neither any internal disturbance nor external aggression were present  for imposing restrictions. With respect to Section 144 of Cr. P.C. the learned Senior Counsel argued that such an order is made with law and order but there is no violation of any law and order.
  • He argued that the Magistrate order under Section 144 of Cr. Pc. Can’ not be passed to public in general rather it must be specifically against the people and it is necessary for a state to identify the person.
  • He further argued that the imposition on internet are made under Indian Telegraph Act 1885 needs to follow the provisions of section 5 of telegraph act  in the view of Article 19 of the Constitution.     
  • He argued that restriction not only impact freedom of speech and expression but also violates right to trade. He also focused on less restrictive measure such as restricting only social media website like Facebook and Whatsapp could have been passed as it has been done in India already in case of human trafficking and child abuse website.
  • Mr. Huzefa Ahmadi argued that order under Section 144 should be based on the objective material and mot merely on speculation. Lastly it was submitted that the restrictions are imposed for temporary but remain lasted for 100 days which should be taken into account.
  • Ms. Meenakshi Arora pointed on the Proportionality principle relied on the case of K. S. Puttaswamy Vs. Union of India where the test of proportionality was upheldtherefore she contended that proportionality of measure must be determine while imposing restrictions.


  • Mr. Attorney General K.K. Venugopal argued that the background of terrorism in the state of Jammu and Kashmir be taken into account, he relied upon National Investigation Agency Vs Zahoor Ahmed Shah Watali, he submitted that this court has taken the problem of terrorism in the state before while deciding the above mentioned case.
  • The learned Solicitor General Tushar Mehta submitted that the background of the state of Jammu and Kashmir has seen a lot of physical digital cross terrorism. He also argued that petitioner was incorrect in submitting that public movement was restricted, he justified that by submitting that individual movement had never been restricted.
  • He further pointed out that whole region were imposed with restrictions, Ladakh region were exempted from restrictions, he argued that people were leading their ordinary lives, like all newspaper, television, radio channels were functioning including Srinagar from  where the petitioner Ms. Anuradha Bhasin working.
  • He argued that order passed under section 14 were preventive in nature and were in order to safeguard public security. On its own knowledge the Magistrate can pass the order on the basis of his previous knowledge and history or background of the state.
  • He further contended that there were enough facts in the knowledge of the Magistrate on which facts he passed the orders under Section 144, he argued that there were provocative speeches and messages were being transmitted. And which was valid reason for imposing orders.
  • He further submitted that internet was never restricted in Jammu and Ladakh region, he refers to various photographs, tweets and messages of political leaders of Kashmir which are misleading and found against the sovereignty and integrity of the country.
  • H lastly argued that that order of restriction were passed under Suspension Rules and are in compliance with it.


Article 19 of the Constitution of India (1) All citizens shall have the right

(a) To freedom of speech and expression;

(b) To assemble peaceably and without arms;

(c)To form associations or unions;

(d) To move freely throughout the territory of India;

(e) To reside and settle in any part of the territory of India; [and]

 2* * * * *

(g) To practice any profession, or to carry on any occupation, trade or business.

[(2) Nothing in sub-clause (a) of clause (1) shall affect the operation of any existing law, or prevent the State from making any law, in so far as such law imposes reasonable restrictions on the exercise of the right conferred by the said sub-clause in the interests of [the sovereignty and integrity of India,] the security of the State, friendly relations with foreign States, public order, decency or morality, or in relation to contempt of court, defamation or incitement to an offence.]

(3) Nothing in sub-clause (b) of the said clause shall affect the operation of any existing law in so far as it imposes, or prevent the State from making any law imposing, in the interests of  [the sovereignty and integrity of India or] public order, reasonable restrictions on the exercise of the right conferred by the said sub-clause.

(4) Nothing in sub-clause (c) of the said clause shall affect the operation of any existing law in so far as it imposes, or prevent the State from making any law imposing, in the interests of  [the sovereignty and integrity of India or] public order or morality, reasonable restrictions on the exercise of the right conferred by the said sub-clause.

(5) Nothing in 1[sub-clauses (d) and (e)] of the said clause shall affect the operation of any existing law in so far as it imposes, or prevent the State from making any law imposing, reasonable restrictions on the exercise of any of the rights conferred by the said sub-clauses either in the interests of the general public or for the protection of the interests of any Scheduled Tribe.

(6) Nothing in sub-clause (g) of the said clause shall affect the operation of any existing law in so far as it imposes, or prevent the State from making any law imposing, in the interests of the general public, reasonable restriction.[9]

Section 144 of Criminal Procedure Code

. Power to issue order in urgent cases of nuisance or apprehended danger .—(1) In cases where, in the opinion of a District Magistrate, a Sub-divisional Magistrate or any other Executive Magistrate specially empowered by the State Government in this behalf, there is sufficient ground for proceeding under this section and immediate prevention or speedy remedy is desirable, such Magistrate may, by a written order stating the material facts of the case and served in the manner provided by section 134, direct any person to abstain from a certain act or to take certain order with respect to certain property in his possession or under his management, if such Magistrate considers that such direction is likely to prevent, or tends to prevent, obstruction, annoyance or injury to any person lawfully employed, or danger to human life, health or safety or a disturbance of the public tranquility, or a riot, or an affray.

(2) An order under this section may, in cases of emergency or in cases where the circumstances do not admit of the serving in due time of a notice upon the person against whom the order is directed, be passed ex parte.

(3) An order under this section may be directed to a particular individual, or to persons residing in a particular place or area, or to the public generally when frequenting or visiting a particular place or area.

(4) No order under this section shall remain in force for more than two months from the making thereof: Provided that, if the State Government considers it necessary so to do for preventing danger to human life, health or safety or for preventing a riot or any affray, it may, by notification, direct that an order made by a Magistrate under this section shall remain in force for such further period not exceeding six months from the date on which the order made by the Magistrate would have, but for such order, expired, as it may specify in the said notification.

(5) Any Magistrate may, either on his own motion or on the application of any person aggrieved, rescind.[10]

Section 5 of the Indian Telegraph Act, 1885, Power for Government to take possession of licensed telegraphs and to order interception of messages.

(1) On the occurrence of any public emergency, or in the interest of the public safety, the Central Government or a State Government or any officer specially authorized in this behalf by the Central Government or a State Government may, if satisfied that it is necessary or expedient so to do, take temporary possession (for so long as the public emergency exists or the interest of the public safety requires the taking of such action) of any telegraph established, maintained or worked by any person licensed under this Act.

(2) On the occurrence of any public emergency, or in the interest of the public safety, the Central Government or a State Government or any officer specially authorized in this behalf by the Central Government or a State Government may, if satisfied that it is necessary or expedient so to do in the interests of the sovereignty and integrity of India, the security of the State, friendly relations with foreign States or public order or for preventing incitement to the commission of an offence, for reasons to be recorded in writing, by order, direct that any message or class of messages to or from any person or class of persons, or relating to any particular subject, brought for transmission by or transmitted or received by any telegraph, shall not be transmitted, or shall be intercepted or detained, or shall be disclosed to the Government making the order or an officer thereof mentioned in the order: Provided that press messages intended to be published in India of correspondents accredited to the Central Government or a State Government shall not be intercepted or detained, unless their transmission has been prohibited under this sub-section.


Court while addressing the first issue held that freedom of speech and expression is an integral part of Article 19 (1) (a). Here court used the judicial precedent- Indian Express V Union of India which declared the freedom of print media is an important right under Article 19 (1) (a) also used the case of Odyssey Communications Pvt. Ltd. V Lokvidhyan Sanghatana in which it was held that the right of citizens to exhibit film is covered under Article19 (1) (a). Court held that internet is one of the most vital medium to broadcast information and hence freedom of speech and expression through internet is a fundamental right and government can impose restrictions only if it falls under reasonable restrictions under Article 19 (2). The Court further held that the right to freedom of speech and expression and right to carry on business, trade or occupation under Article 19 (1) (a) and Article 19 (1) (g) using internet as a medium are constitutionally protected. It was proclaimed that there should be reasonable ground behind restricting the internet access and should be laid down by Article 19 (2) and Article 19 (6).

Court while addressing second issue rejected this plea because the order of restriction did not contain any stoppage of publication of any newspaper. Therefore the Court couldn’t discover the legitimacy and since the petitioner has resumed publications, hence Court held that it is not violating the freedom of press of the petitioner and government is protecting freedom of the press. In Channing Arnold Vs The Emperor, (1914) the Privy Council stated that: “the freedom of the journalist is an ordinary part of the freedom of the subject and to whatever length, the subject in general may go, so also may the journalist, but apart from the statute law his privilege is no other and no higher. The range of his assertions, his criticisms or his comments is as wide as, and no wider than that of any other subject.” It was thus not doubted that the freedom of the press is a valuable and sacred right protected by the Indian Constitution.[11]

Court while addressing third issue held that power cannot overthrow legitimate expression of idea or exercise of any democratic right, Court held that the section 144 can only be imposed in case of emergency and held that small disturbance does not lead to breach of public order. Only the local administration and state government can decide whether there is any threat to public peace or not, as public order, crime are state subjects. The state must provide relevant information which is needed to the public as Article 19 along with freedom of speech and expression includes right to information. The state does not have any right to pass law based on anticipation of danger. Hence it could not be valid ground to refuse the production of order.

Court while addressing fourth issue held that in order to determine the Constitutional legality of the internet shutdown there should be considered two elements i.e. Procedural elemental and substantive element. The Suspension Rules under Section 7 of Telegraph act was passed in 2107 and allowed restriction on the internet for safety measures. These safeguards were that first, the suspension orders may be issued only by the Secretary to the Government of India in the Ministry of Home Affairs or by the Secretary to the State Government in charge of the Home Department. In unavoidable circumstances another official not below the rank of a Joint Secretary to the Government of India may issue the orders provided that the competent authority approves the orders within 24 hours of its issuance. Without approval the suspension must be lifted within 24 hours. The orders must include reasons for the suspension and its copy must be sent to a Review Committee consisting of senior State officials. The reasons should not only explain the necessity of the suspension but also the “unavoidable” circumstance which necessitated the order.[12] In addition Section 5 (2) of Telegraph act permitted suspension orders only in case of public emergency i.e. presence of emergency is required for passing the order of internet shutdown. However Suspension rule did not defines maximum duration of suspension order.

The Court held that government cannot hide anything from public domain section 144 is imposed by the government. The Court recognizes internet as a vital element in today’s life or time and declares freedom of speech and expression as a part of fundamental right. Court ordered to follow the test of proportionality to satisfy that there is no violation of natural justice. The Court did not deflected the restriction on internet and movement of citizen however the judges widened the scope of freedom of speech and expression by including the right to access to internet as a fundamental right and it can only be restricted under the circumstances of national security. Court held that suspension should follow proper safeguard.


In this case we particularly learned about “technical judicial standards” to interpret and decide the problems related to Article 19 (1) (a) and Article 119 (1) (g) and its impact to clause (2) and (6) respectively. The use of section 144 can’ not be done to suppress the opinion or any democratic right which ensures that freedom of speech and expression can’ not be violated for any political gain or by whims of the authorities. This judgment has opened the door for the judicial review of restrictions. Here the court focused on the importance of internet in today’s time, this case is ray of hope in darkness as this case recognized freedom of speech and expression over internet as a fundamental right.

The Court in this case focused upon the balance between individual liberty and national security by ensuring right to know. There is a problem with the judgment that it does not talked about constitutionality of the suspension rule. But this judgment directly emphasizing principles of reasonability, proportionality and necessity, as the Magistrate is bound to the balance of limitation and rights. The judgment also recognized the freedom of press within the ambit of freedom of speech and expression. Internet being most crucial in modern time where it is being used in almost all fields so depriving its access would hamper so many opportunities, information and many new things.

At the most, it becomes an academic exercise and coherence can probably be achieved by future pronouncements of the Court. The importance of the Internet from strategic to mundane affairs cannot be downplayed. In conclusion, the following observations of the Honorable Supreme Court warrant attention –

“Law should imbibe the technological development and accordingly mould its rules so as to cater to the needs of society. Non-recognition of technology within the sphere of law is only a disservice to the inevitable.”[13]



[2] Special Message to The Congress on The Internal Security of The United States, (last visited June 23, 2023).

[3] Freedom Of Speech On Campus- ERC, (last visited June 23,2023).

[4] Freedom of Speech and Expression, expression.html (last visited June 23, 2023).

[5] Indian Express Newspapers (Bombay)(P) Ltd. & Ors. V. Union of India & Ors (1985) 1 S.C.C. 641.

[6] Internet Access and COVID-19: A Constitutional Argument To Right, (last visited June 23, 2023).

[7] Ibid.

[8] Ibid.

[9] The Constitution of India, 1950, Article 19. 

[10] The Code of Criminal Procedure, 1974, Section 144.

[11] Bhasin vs. Union of India- Global Freedom of Expression, (last visited June 24, 2023).

[12] Ibid.

[13] Indian Law Journal, visited June 25, 2023).

Leave a Reply