Criminal Law: Offences against the State

Reading time : 10 minutes

Introduction

The Indian Penal Code, 1860 deals with offences according to Chapter VI against the Administration (Section 121 to Section 130). These codes are meant to guarantee patient security of the state as a whole. In the case of crimes against the State, such as life imprisonment or the death penalty, the survival of the State may be shielded by the awarding of substantial penalties. Offenses against both the state and the government in order to disrupt public peace and tranquility, public order and national integration.

Waging War

Waging war means an effort to try to accomplish any objective of public nature by some force and violence. Such a war happens when many individuals rise and gather against the State in order to use violence and intimidation to procure an object of public nature. In addition to establishing an offence against State, the objective and inclination are taken into account and not the murder or even the force.

The phrase ‘waging war’ should be comprehended in the broad sense and can only imply waging war in the manner usual in war. Overt activities such as the selection of persons, guns and ammunition are not included. In the international context, this form of war often does not involve an inter-country war involving military operations between two or more countries.

In accordance with Section 121, it has been made clear that ‘war’ is not conventional warfare between countries, but it is a form of war to join or organize an uprising against the Government of India. Waging war is a form of extreme violence to achieve some public objective.

Waging War against Government of India

Section 121 of Section 123 of the Code concerns the conduct of wars against the Government of India. Here, the phrase ‘Government of India’ is used in a much broader sense, that is, to conclude the Indian State which originates the authority and responsibility of authority from the will and consent of its people. In other words, this term means that while the State receives the power of authority from Foreign Public Laws, the authority is, however, vested and exercised by the representative government by the citizens of the territory.

The following are deemed to be necessary offences under Section 121, as they need to be proven in addition to establishing an offence for war against the Government of India:

The Accused must have;

  • Waged war; or
  • Attempted to wage war; or
  • Abetted the waging of war.

Such a war must be against the state;

The sentence requires either life imprisonment or the death penalty under this clause. It is also possible to levy a fine in such situations.

In a wider context, the term ‘whoever’ is used and is not only limited to those who owe allegiance to the existing government. Even the Supreme Court of India cannot justify whether or not foreign nationals entering the territory of India should be held guilty in order to impede the functioning of the government and to destabilize society.

For example, the first and primary offence committed by the appellant and other conspirators in the case of the Mumbai Terror Attack (Md.Ajmal Md.Amir Kasab @Abu … vs State Of Maharashtra) was the offence of waging war against the Government of India. The attack, targeted at Indians and India, was by foreign nationals. This attack was aimed at accelerating communal tensions, affecting the country’s financial situation and, most importantly, demanding that India surrender to Kashmir. Accordingly, the appellant was rightly found guilty, under Sections 121, 121A and 122 of the Code, of declaring war against the Government of India.

Conspiracy to Wage War

In 1870, Section 121A was introduced to IPC. It notes that in order to establish a conspiracy, it is not mandatory that any act or criminal omission should take place explicitly.

Two types of conspiracies are discussed in this section:

  • Conspiring, inside or without India, to commit an offence punishable by Section 121 of the Code.
  • Conspiring to overawe, that is to say, bullying the government by means of criminal force or a simple display of criminal force.

The penalty under this provision includes, along with a fine, imprisonment for ten years or life imprisonment. Such punishment may be provided both by the central government and the government of the state.

  • Preparation to Wage War

The plans for war are governed by Section 122 of the IPC. There is a distinction between the attempt to commit the offence and the planning. The core elements of this section are:

  • Compendium of men, weapons and ammunition.
  • There must be a purpose to wage war or make preparations to wage war for such compendium.
  • The accused must partake in such compendium.
  • The war should be perpetrated against the Government of India.

The penalty under this provision is either life imprisonment or, along with a fine, imprisonment for ten years.

For example, if printing material is found in the accused’s room along with other items, then they are neither considered objectionable nor infuriating. Therefore, under this clause, the accused cannot be prosecuted.

  • Concealment to Facilitate Design to Wage War

The concealment of design to wage war is dealt with in section 123 of the IPC. The essential principles of this section are:

  • There has to be a presence of a layout which is prepared to wage war against the Government of India.
  • The deception should be developed with the purpose of promoting the war against the Government of India.
  • The person should be identifying about the concealment of the design.

Under this clause, the penalty is imprisonment of up to 10 years along with a fine.

In the Parliament attack case, for example, the defendant had plot data along with a terrorism scheme. Accordingly, his unlawful omission made him liable under IPC Section 123.

  • Assault on President or Governor of State

Whoever, in order to induce or compel the President of India or the Governor of any State to exercise or refrain from exercising, in any manner whatsoever, any of the lawful powers of that President or Governor, assaults or wrongfully restrains, or attempts, by criminal force or the demonstration of criminal force, to unlawfully restrict or overrule, or attempts to override, such President or Governor, shall be punishable with imprisonment of either depiction for an imprisonment which may extend to seven years, and shall be liable to penalty.

This offense is Cognizable and Non-Bailable and it may shall be tried by Court of Session.

Sedition

Sedition is dealt with here in section 124A. Under this Section, any individual who by:

  • Words, spoken or written; or
  • Signs; or
  • Representations visible; or
  • Otherwise;

It is punishable by taking or even threatening to bring hate or excite disaffection to the Government of India (including the feeling of antagonism and treachery) with:

  • Life imprisonment in certain cases together with a fine; or
  • Imprisonment in certain cases for up to three years along with a fine; or
  • Fine.

Essential Ingredients of Section 124A

  • Words, Sign, Visible Representation or Otherwise

Sedition may be achieved by words, written or spoken, by signs, or by visual representation in different ways. Music, publications, presentations (films and puppets), sculptures, photos, cartoons, drawings, and all other techniques are seditious deeds.

Under sedition, whether or not the seditious publications are being used by the real authors is immaterial. In such a circumstance, the editor, publisher or printer is equally liable as the author. Thus, whoever wrote or used it is guilty of sedition for the intent of thrilling disaffection. In the event of the accused pleading that he did not approve the article, the accused is responsible for the burden of evidence. In addition, if the accused is unaware of the substance of the article or paper written, he is not guilty under this clause because the intention is absent.

Sedition does not simply consist of words spoken or written, but may also be of other kinds, such as signs and visual representation. For example, a woodcut or engraving of any sort may illustrate this.

  • Conveys or Endeavors to Carry into Abhorrence or Contempt

The phrase ‘brings or threatens to carry hate or contempt’ tries to disagree less with or interfere less with the freedom of speech.

Writers in the national press, for example, are not permitted to write or indulge in unethical or dishonest motives. A writer is not considered seditious when he publishes an article with a cool, unsentimental and dispassionate outlook and addresses his small emotions that may or may not cause a man to think. If, however, the article goes beyond and has unjust, immoral and deceptive motives, then it is known that such an article is seditious.

  • Excite Disaffection

Disloyalty and all other feelings of enmity are part of the word’ disaffection.’ An act of disaffection must be aroused among individuals in order to amount to sedition. In other words, among the citizens of the state, the feeling of disaffection must be stirred up.

The disaffection can be aroused in several ways as per this section, such as:

  • Poem,
  • Aphorism,
  • Discussion, historical or metaphysical,
  • Drama, etc. 

In order to settle for sedition, publication is required. The publication, including articles, may be of any form and manner.

  • Undertaking depredation with the Government of India on territories of Force at ease – Section 126

Whoever commits depredation in the territories of any Power in alliance or in peace with the Government of India, or makes arrangements for depredation in the territories of any Power, shall be punished by imprisonment of any description for a period of up to seven years, and shall also be liable for the fine and forfeiture of any property used or intended for use in the depredation or for acquisition of such property.

Punishment for the offense – 7 Years + Fine + Land forfeiture

Cognizable Knowable Not-Bailable, tried by The Session Court

  • Receipt of war or predatory property referred to in sections 125 and 126

Whoever possesses any property which is known to have been taken into account in the commission of any of the offences referred to in sections 125 and 126 shall be punished by imprisonment of either description for a period of up to seven years, and shall be liable for the fine and forfeiture of the assets so obtained.

This offense is cognizable, non-bailable and shall be tried by Court of Session.

  • Nasir khan v. State of Delhi, Appeal (crl.) 734 of 2003

“The Supreme Court observed that it is a fundamental right of every citizen to have its own political theories and concepts and to work through their constitution.” Arun Jaitley narrowly avoided conviction for sedition in 2015. In a Facebook post, he had denounced the Supreme Court for shooting down the government’s proposed National Judicial Appointments Commission.

In response, under Section 124A, a judicial magistrate had ordered that he be booked. The High Court of Allahabad came to his rescue, stating that they should have a ‘pernicious propensity’ to cause public disorder for any words to become seditious. The sedition law continues to be invoked, despite such stringent interpretations of the section, in circumstances where even the prerequisites of such a charge are not met.

Conclusion

In governing and maintaining public order, crimes against the state play a key role. The citizens of the state have a right to criticize the government’s policies, but they should not abuse their freedom to hurt the people or the government around them. It is a punishable offence to wage war against India and against authority. In the case of attack against them, the law also covers high officials, such as the President, the Governor of every State, etc. Most notably, one of the most serious cognizable crimes against the State is deemed to be sedition. It can therefore be assumed that, for the betterment of the State, the State must limit the liberty of the citizens of the country.

Author: Avnip Sharma

Editor: Kanishka Vaish, Editor, LexLife India.

Criminal law: Criminal Breach and Criminal Misappropriation

Reading time : 8 minutes

Introduction

For a crime to be committed, there has to be a presence of both actus reus and mens rea, which essentially means the physical state of a person and the mental state of the person. Now while we talk about the intention of the criminal, one must not forget the fact that every criminal has a mala fide intention (except in some cases) where he/she has some hidden malice set aside which leads him to committing the crime. Today, we are going to explore Section 403 and Section 405 of the Indian Penal Code, 1860.

Section 403 talks about the Criminal Misappropriation of Property, while Section 405 talks about the Criminal Breach of Trust.

Criminal Breach of Trust

The Section 405 of the Indian Penal Code defines the Criminal Breach of Trust as,

Whoever, being in any manner entrusted with property, or with any dominion over property, dishonestly misappropriates or converts to his own use that property, or dishonestly uses or disposes of that property in violation of any direction of law prescribing the mode in which such trust is to be discharged, or of any legal contract, express or implied, which he has made touching the discharge of such trust, or wilfully suffers any other person so to do, commits “criminal breach of trust”

Criminal Breach of trust in simplified terms is equivalent to a person who has dishonestly and with a presence of mala fide intention has misappropriated the property entrusted to him/her and then disposes it (sold the property, gave the property for rent) without the permission of the real owner of the property by considering the property as his own is said to have committed criminal breach of trust. Furthermore, it also mentions that if the person who dishonestly disobeys any kind of legal contract, be it in the expressed form or the implied form, he/she has said to have committed an offence under section 405 of the Indian Penal Code, 1860. Let us understand this with the help of illustrations:

  1. A, being executor to the will of a deceased person, dishon­estly disobeys the law which directs him to divide the effects according to the will, and appropriate them to his own use. A has committed criminal breach of trust.
  2. A is a warehouse-keeper. Z going on a journey, entrusts his furniture to A, under a contract that it shall be returned on payment of a stipulated sum for warehouse room. A dishonestly sells the goods. A has committed criminal breach of trust.

While we talk about the Criminal Breach of Trust, it is important for the readers to understand the kind of relationship established. There are various kinds of relationships established when it comes to the legal point of view, master-servant, parent-child et cetera. Similarly, as it was observed under Jaswantrai Manilal Akhaney v. State of Bombay, AIR 1956 SC 575 that a relationship is created the transferor and the transferee where the transferor is the real owner of the property and the transferee has the legal custody of the property for the benefit of the transferor himself or the transferee has the custody of the property only for the benefit of the transferor himself or someone else.

Essentials of Criminal Breach of Trust

As it was mentioned above, for committing a crime the mens rea plays a pivotal part when it comes to classification of an offence under section 405 of IPC, 1860. Looking back at the definition of Criminal Breach of Trust, the word “entrustment” holds great importance. As observed under Ramaswami Nadar v. State of Madras, AIR 1958 SC 56, the word entrusted is very important as it is essential to prove that the entrustment took place by the transferor to the transferee to prove the required crime as such. The same was observed under Sadhupati Nageswara Rao v. State of Andhra Pradesh, AIR 2012 SC 3242: (2012) 8 SCC 547: 2012 (7) JT 512: 2012 (7) SCALE 63: 2012 Cr LJ 4317.

After the entrustment factor, there is one more factor highlighted under the Sadhupati Nageswara Rao case. This case also highlighted the second essential factor for inviting an offence under Section 405. The second factor is the mala fide/dishonest intention that then proved to be the driving force that resulted in the breach. Following this, it has to be proved that the accused had misappropriated or converted the property in his/her custody to the detriment of the persons who had entrusted it.

Criminal Misappropriation of Property

Section 403 of the Indian Penal Code, 1860 defines Criminal Misappropriation of Property as,

Whoever dishonestly mis-appropriates or converts to his own use any movable property, shall be punished with imprisonment of either description for a term which may extend to two years, or with fine, or with both.

Criminal Misappropriation of Property as defined above could be broken down to the transfer of property from the transferor to the transferee in a dishonest fashion/manner for their own benefit, be it monetary or otherwise. Let us understand this with the help of illustrations:

  1. A takes property belonging to Z out of Z’s possession, in good faith, believing, at any time when he takes it, that the property belongs to himself. A is not guilty of theft; but if A, after discovering his mistake, dishonestly appropriates the property to his own use, he is guilty of an offence under this section.
  2. A, being on friendly terms with Z, goes into Z’s library in Z’s absence, and takes away a book without Z’s express consent. Here, if A was under the impression that he had Z’s implied consent to take the book for the purpose of reading it, A has not committed theft. But, if A afterwards sells the book for his own benefit, he is guilty of an offence under this section.

As we have now understood the meaning and practical examples of the Criminal Misappropriation of Property, it is also essential to understand the ingredients highlighted under the case U. Dhar v. State of Jharkhand, AIR 2003 SC 974. The two major ingredients highlighted under this case were ‘dishonesty’ and ‘misappropriate’. Furthermore, it was also mentioned that the words ‘converts to his own use’ is necessary to prove an offence under Section 403 of the Indian Penal Code, 1860 as observed under Ramaswami Nadar v. State of Madras, AIR 1958 SC 56.

Difference between Criminal Misappropriation of Property and Criminal Breach of Trust

In misappropriation, the property is obtained by some casualty or otherwise. In criminal breach of trust, the property is obtained due to the true vested interest by the owner on the offender. The property is misappropriated by the offender for his own use. In criminal breach of trust, the property is misappropriated for his own personal use. A breach of trust includes criminal misappropriation, but the converse is not always true.

So these are some of the differences between the above mentioned offences. Now, if we look at more of the differences from the side of the technicalities as mentioned under section 403 and section 406 (Punishment for criminal breach of trust), we will find that the offence of Criminal Misappropriation of Property is bailable in nature and is triable by any magistrate, however, when it comes to criminal reach of trust, it takes the form of non-bailable offence which is only triable by the Magistrate of the first class.

Conclusion

To conclude with, the readers explored the nuances and intricacies of the Section 403 and 405 of the Indian Penal Code, 1860 which talks about criminal misappropriation of property and criminal breach of trust, respectively. When we speak about the above mentioned crimes, they are often in front of the eyes where the offenders take advantage of the lack of legal knowledge amongst the common man who doesn’t understand the perplexities of these sections, prima facie. Hence, there should be awareness drives and campaigns especially for the illiterate and for those who don’t understand in order to make the citizens of the nation aware about the laws prevailing in the country.  

Author: Abeer Tiwari

Editor: Kanishka Vaish, Editor, LexLife India.

Criminal law: Concept of Criminal Conspiracy

Reading time: 8-10 minutes.

“The mark of a civilized society is the willingness of the people to obey the unenforceable,” said Martin Luther King. Crime and Conspiracy are two facets of the same coin. While crime is bent on the idea of actus reus and mens rea, which is, a physical act and an ill intention, the conspiracy takes in a stance to correct the abuses acted out by the society that we live in.

 The origin of the history of criminal conspiracy is not very recent. Considering the complex nature of the act of criminal conspiracy, the first time it was given legal bearing was in the renowned case known as the ‘Poulters’ Case” which was decided in 1611.

In the Poulters case, the defendants conspired and falsely brought a case of robbery, against a single person, named ‘Stone’.  In place of the evidence presented in front of the grand jury, it held Stone innocent and acquitted him of all charges laid out by the defendants. Further, it was in the counter-suit filed by Stone that the court laid down the principle, what we know today as criminal conspiracy.

The court affirmed that the mere presence of conspiracy played out by the defendants, irrespective of whether Stone was falsely indicted or acquitted, lays down the gist of the offence and therefore can be considered as a crime and taken towards an indictment.

As we are aware that most of the laws governed in our country are inspired by English laws, the aforementioned theory can be retracted to a landmark case of Mulcahy v. R.  In the case, the House of Lords submitted that “A conspiracy consists not merely in the intention of two or more but in the agreement of two or more to do an unlawful act by unlawful means. So long as such a design rests in intention only it is only indictable. When two agree to carry it into effect, the very plot is an act in itself and the act of each of the parties promise against promise actus contra actum capable of being enforced if lawful, punishable if for a criminal object or for the use of criminal means.”   This case paved the way for criminal conspiracy in India. After the above-mentioned judgment, the Indian Penal Code was amended in 1870 to insert S.120-A IPC. Criminal conspiracy was considered a civil offence, initially. It was considered under the following two sections of the law.

  • Abetment in any offence; or
  • Conspiracy with criminal intent.

However, it was later considered to be as a criminal offence. Chapter V-A had been introduced in the code by the Criminal Law Amendment Act (8 of 1913).

Definition of ‘Conspiracy’

The offence of criminal conspiracy is defined under Section 120-A of Chapter V-A of the Indian Penal Code, 1860. According to Section 120-A, when two or more persons come together and agree to do, or cause something to be done, which constitutes an illegal act or a legal act carried forward by illegal means, such persons would be guilty of the commission of the offence of criminal conspiracy. In simpler terms, conspiracy refers to the meeting of minds for the commission of an offence. However, no such agreement would constitute the offence of criminal conspiracy, unless and until an act is performed in furtherance of such an agreement. The explanation attached to Section 120-A makes it clear that it is immaterial whether the illegal act committed in furtherance of such an agreement, is the focal point of the agreement or, is merely incidental to the performance of the ultimate goal of the agreement.

Relevant legal provisions

The relevant legal provisions under the Indian Penal Code which deal with the offence of criminal conspiracy are as follows:

  • Section 120A and Section 120B which deal with conspiracy as a substantive offence, i.e., an act, which in itself constitutes as a crime, and a punishment for the same;
  • Section 107, which deals with conspiracy as it being a form of abetment;
  • Section 121A which deals with an act constituting an offence of conspiracy to wage, attempt to, or abet war against the Government of India;
  • Section 310, Section 311, Section 400, Section 401 and Section 402, which deal with conspiracy as constituting involvement in the commission of an offence.

Punishment for Criminal Conspiracy

Section 120-B prescribes the punishment for the commission of the crime of criminal conspiracy. According to Section 120-B, if the parties involved in the conspiracy, conspired to commit an offence punishable with death, imprisonment for life or rigorous imprisonment for a term of two years or more, shall be punishable in the same manner as if he/she had abetted the commission of such an offence, if no explicit punishment for the commission of such a conspiracy has been provided for, by the Code. However, if the parties involved in the conspiracy, conspired to commit an offence punishable with terms not prescribed previously, such persons shall be sentenced to an imprisonment for a term not exceeding six months, or a fine, or both.

Salient features

Some of the salient features to constitute an offence of criminal conspiracy under the Indian Penal Code, are as follows:

  • There must be two or more person involved in the commission of the offence of criminal conspiracy.
  • There must be an agreement between the parties.
  • Such an agreement must be for the commission of an illegal act or the commission of a legal act by illegal means.
  • When the agreement is for the commission of a legal act by illegal means, an overt act must have been carried out by the parties in furtherance of the same, and the mere agreement is not sufficient to establish the commission of the crime.
  • The parties must be aware of the illegal object or the illegal means, for the agreement to constitute as a criminal conspiracy. [i]
  • The crime of criminal conspiracy is an incomplete or inchoate crime, which needs an additional substantive offence complementing it, to constitute as a crime punishable under the Code.
  • Criminal Conspiracy does not take place when the parties involved are husband and wife, of minor age, or is the person against whom the offence was sought to be committed.

Landmark judgments

It is very pertinent by now that the scope of crime and conspiracy is ever-growing and will always be open for various interpretations. The offence of criminal conspiracy can be sometimes challenging and complex in its application by the judiciary since the “art” of scheming is mostly always carried out in secrecy. Since its inception, there have been various landmark cases that showcase the interpretation by the courts in ascertaining the offence in its truest form.

  • Topan Das v.State of Orissa, AIR 1956 SC 33

The court in the aforementioned case stated that it is an established rule of the law that only one person cannot conspire and that there should be at least two persons for the same, and can be never be held guilty of criminal conspiracy since one cannot conspire with oneself.

  • B. Narsimha Rao v. Govt. of A.P

In this case, the appellant was convicted of an offence of criminal conspiracy along with seven others. However, he alone was charged with offences under Ss. 120-B, 409 and 471, IPC under section 5(1)(c) and 5(l)(d) read with section 5(2) of the prevention of corruption Act, 1947. Simultaneously, all the other co-conspirators were acquitted by the Trial Court and the High Court. In the end, the Supreme Court acquitted the accused on the facts that there had to be another person to communicate with and carry out the agreement and that a single person can never be accounted for conspiracy.

  • The State of Andhra Pradesh v. Subbaiah 1961 (2) SCJ 68

The Supreme Court in the above case contended that “where the matter has gone beyond the stage of mere conspiracy and offences are alleged to have been committed in pursuance thereof the accused can be charged with the specific offences alleged to have flown out of the conspiracy along with the charge of conspiracy. The court observed, “Conspiracy to commit an offence is itself an offence and a person can be separately charged with respect to such a conspiracy”.

  • State(Delhi Admn) v. V.C.Shukla

In the above case the court observed that:  “To prove a criminal conspiracy which is punishable under S. 120-B of IPC, there must be direct or circumstantial evidence to show that there was an agreement between two or more persons to commit an offence. This envisages that there must be a meeting of minds resulting in an ultimate decision taken by the conspirators regarding the commission of an offence. It is true that in most cases it will be difficult to get direct evidence of an agreement to conspire but a conspiracy can be inferred even from circumstances giving rise to a conclusive or irresistible inference of an agreement between two or more persons to commit an offence.”

  • LK  Advani v. CBI

In this case, the court submitted that since there was no prima facie evidence showing an alleged conspiracy and that the mere presence of a few assumed entries and loose sheets cannot entertain the above offence, the court humbly acquitted the accused on the counts of the offence of criminal conspiracy and further explained that to establish conspiracy there shall be evidence of acting on a common intention to carry out an illegal act.

Critical analysis

The main object behind the introduction of Section 120A and 120B to the Code, appears to be an attempt to curb criminal thoughts before they take the form of a concrete criminal act, detrimental to the society at large. According to Section 43 of the Code, an ‘illegal’ act under the Indian Penal Code would imply the commission of an offence, or of an act forbidden by law, or of an act which lays ground for a civil liability to arise. For the establishment of the offence of criminal conspiracy, the existence of an agreement between the parties is a sine qua non. This agreement may be express or implied, the important factor is consensus ad idem, i.e., meeting of minds. The agreement must be read as a whole and the object ascertained. It is not necessary that more than one person must always be convicted for the offence of criminal conspiracy, it is sufficient if the court is convinced that more two or persons were actually involved in the conspiracy. The offender might join the conspiracy from the start itself or at any time before the completion of the objective of the agreement, irrespective of the time of joining, each party to the offence would be held equally responsible. A criminal conspiracy is said to persist as long as the parties to the agreement continue to act in furtherance of the objects of the agreement.

Conclusion

The offence of criminal conspiracy is an exception to the general rule that in order to constitute a crime, both mens rea and actus rea must be involved, here merely guilty mind is sufficient to render a person guilty if the agreement was to commit an illegal act. However, an act, or actus reus becomes essential again if the object of the agreement was to do a lawful act by unlawful means. The criminal conspiracy can be inferred from the surrounding circumstances and the conduct of the suspected or the accused person. A person found to be guilty of criminal conspiracy, is punished under Section 120B of the Indian Penal Code, 1860. This Section of the Code, is slowly losing its essence and there is a need to ensure that due diligence is maintained in cases of criminal conspiracy to propagate true manifestation of the law and justice. The well-established principle of criminal law, ‘fouler the crime, higher the proof required’ must be kept in mind, and the sanctity of law upheld.

Authors: Disha Tulsyan from Symbiosis Law School, Pune and Salonee Nayak from School of Law, University of Petroleum and Energy studies, Dehradun.

Editor: Anmol Mathur from Symbiosis Law School, NOIDA.