Data Protection Bill and Right to Privacy- An Analysis

Reading time: 8-10 minutes.

On December 11, 2019, the Minister of Electronics and Information Technology, Ravi Shankar Prasad introduced “The Personal Data Protection Bill” in the lower house. The bill aims to ensure, inter-alia, the protection of individuals’ privacy in relation to their personal data, the transparency of organisations and institutions processing personal data, and to establish a Data Protection Authority (hereinafter referred to as “DPA”), for the various purposes that the Bill seeks to fulfil. The Bill is the response of the Government of India to the long-standing need for a “data protection regime” to protect citizens’ personal data that they knowingly or unknowingly provide to various internet websites.

The Government of India constituted a Committee of experts on Data Protection on 31st July 2017, which was headed by Justice B. N. Srikrishna, to examine the issues pertaining to the Data Protection in India, and the report of this Committee was submitted on 27th July, 2018. Later, the Government placed the Bill in public domain, for feedback and suggestions from various stakeholders, ministers and consultants. Based on these suggestions the Union Cabinet approved a revised Personal Data Protection Bill, 2019, on December 4th, 2019. Later, the Bill was introduced in the Lok Sabha on December 11, 2019 and was referred to a Joint Select Committee of both the houses.

The right to privacy has been recently recognised as a fundamental right emerging primarily from Article 21 of the Constitution, in Justice K.S. Puttaswamy (Retd.) v. Union of India. To make this right meaningful, it is the duty of the State to put in place a data protection framework which, while protecting citizens from dangers to informational privacy originating from State and Non-State actors, serves the common good. It is this understanding of the State’s duty that the Committee must work with, while creating a data protection framework.

Major Features of the Bill:

The Bill regulates the processing of personal data by States, companies incorporated in India, and international companies dealing with personal data of individuals in India. The Bill sets out the fiduciary data responsibilities (i.e. the body deciding the intent and means of processing personal data) that certain accountability and transparency steps must be taken when detecting the data. The Bill requires personal data to be handled by data fiduciaries only if the data principal (i.e. the person to whom the data relates) has given his permission.

The Bill further provides a legal framework for the collection and use of personal information. While providing a collection of rights and obligations for the processing of personal data, the Bill proposes the creation of a DPA, to control and implement the legal structure. The Bill also vests the Central Government with substantial standard-setting powers and tasks the DPA with implementing the same. An important characteristic of the Bill is, its broad scope of applicability. If implemented, it would apply to all companies other than those expressly exempted across India. This will involve any organization that collects data using automated means. The DPA shall have the power to define small entities based on turnover, data volume handled and data collection purposes.

Further, the Bill makes consent an important factor to the proposed data protection framework. The Bill also proposes that the personal data of individuals should be accessed only on the basis of free, informed and detailed consent, with provisions that allow such consent to be withdrawn. Any processing of data without such approval would constitute a breach, which could result in penalties under Sections 11 and 57 of the Personal Data Protection Bill, 2019. Section 11 of the Bill establishes a separate category of ‘sensitive personal data’ and states that such data can only be processed with ‘explicit consent’.

There are certain grounds mentioned in Section 12 of the Bill, in which personal data can be processed without the consent. The grounds are, if personal data is required for the benefit of principal data, legal proceedings, response to medical emergencies or for the maintenance of law and order. The Bill also allows the Central Government to guide data fiduciary to include confidential personal data or non- personal data so that the Central Government can better plan the delivery of services or formulate evidence-based policies. According to the Bill, data fiduciaries must institute mechanisms for age verification and parental consent when processing sensitive personal data of children as stated under Section 16. Further, under Chapter V, the Bill gives certain rights, like the right to obtain confirmation whether data has been accessed or not, right to correct the erroneous personal data and the right to be forgotten.

“The right to be forgotten” reflects a major part of the legislation. Under Section 20, the data principal is entitled to avoid the continued disclosure of his personal data if the purpose of the data has been served, if the consent of the data principal has been removed or the data has been unlawfully released. The Bill also empowers the DPA to take measures to protect individual rights, prevent abuse of personal data and ensure compliance with the bill.

Negative Aspects of the Bill:

Although there are many strong and progressive provisions in the Bill, there are some provisions and features of the Bill which tend to raise significant concerns regarding the effectiveness of the Bill in protecting the data of citizens. They are dealt with in the subsequent paragraphs: 

  • Harm and Damage to Privacy:

The Bill defines ‘harm’ in a manner which appears problematic for many stakeholders. Any discriminatory treatment or denial or removal of a service, resulting from the assessment of the data principle would be protected under it, according to the concept of damage. This Bill talks about discrimination in general, which imposes severe restrictions on business activities because many businesses have to discriminate on different grounds for the smooth functioning of business. In reality, according to the Indian Constitution, only certain types of discrimination are problematic. Within the Bill, risk of harm is concern when determining what kind of protection and privacy protections should have to be implemented into the design of business policies. The focus on this controversial concept of harm should create a significant problem for various companies, as several times they have to remove specific services from customers when discriminating on the basis of data collected from them.

  • Voluntary User Verification:

Another criticism that the Bill has faced, is its clause that allows the businesses to provide users with options to voluntarily check their identity. If users do not check their identities, they are going to be a candidate for government surveillance or analysis. This provision would raise the risk of data breaches and entrench control in the hands of major social media companies who can afford such verification systems to be installed and maintained. In addition, this will also increase the risk of user privacy breaches. It also ignores the aspect that, sometimes, social media anonymity brings benefits like whistleblowing and stalker protection.

  • No Consent- Transfer of Non-Personal Data:

The Bill also mandates companies to share non-personal data with the Government, on the grounds of public good and planning. This will not only significant privacy concerns, but it will also have a disastrous impact on companies, as many a times, companies keep trade secrets in the form of non-personal data and on its being shared, they might suffer a setback.


The Personal Data Protection Bill is India’s move towards providing, inter-alia, data privacy for its people and avoiding misuse of their data. It places great emphasis on the individual’s consent before taking up his/her data for any purpose. It also has provisions for the establishment of an Indian Data Protection Authority to ensure proper enforcement of the proposed Bill. It is a long-awaited legislation, as India did not have a comprehensive law to protect its citizens’ data, leaving citizens unarmed while being exposed to a world full of cyber-crimes.

While impressive on certain counts, the Bill also has disappointing aspects, such as putting a strong emphasis on harm without adequately identifying it, making it mandatory for businesses to exchange non-personal data. The major weakness in the Bill, however, for which it earned flak from many lawyers, academics, and politicians, is the clauses that grant exemptions to the Government, through which they can allow any Government agency to circumvent the proposed Act. This clause raised significant and relevant questions about the Government’s intentions, with Justice BN Srikrishna, whose committee prepared the draft law in 2018, calling it an attempt to turn India into an Orwellian State.

Today the internet has become an integral part of our lives. Almost all the things that we do, whether public or private, official or unofficial, include the use of the internet. A large amount of data is transferred whilst performing these activities. In such a situation, ensuring data security is important, because a person’s data in the wrong hands, can have serious repercussions. There are cases where users’ data privacy has been violated, knowingly or unknowingly, by social media sites like Facebook and WhatsApp.

Therefore, a law that seeks to protect citizens’ privacy is quintessential. The Personal Data Protection Act is intended to meet this obligation. However, it is mired with certain shortcomings that can end up offering very little of the protection that the legislation promises. But the Bill also has scope for change, as it has been referred to a Joint Parliamentary Commission. The panel is expected to discuss the Bill’s shortcomings and to come up with a Revised Draft Bill that will provide Indian people with a promising legislation that delivers on the data privacy promise.

Authors: Kadam Nikitha from Army Institute of Law & CH Suswani from DSNLU.

Editor: Astha Garg, Junior Editor, Lexlife India.

Transfer of judges

Reading time: 6-8 minutes.

“When justice has to triumph, it will triumph…Be with the truth—Justice will be done.” These were the words of Justice S. Muralidhar, the third most senior judge of the Delhi High Court, as he delivered his farewell speech to a large gathering of his colleagues from the Bench and the Bar.

On the night of February 26, when a part of Delhi was still burning, the Central Government notified the transfer of Justice Muralidhar to the Punjab & Haryana High Court. The next morning saw the social media flooded with posts questioning the intention behind the transfer. Many media outlets questioned it too and Justice Muralidhar became the judge who was transferred for reprimanding the police over their inaction. This was the birth of controversy and the Centre was in the middle of it.

The controversy

In his own words, February 26 was the longest day of Justice Muralidhar’s career. It marked the fourth day of the Delhi riots. At 12.30 am Justice Muralidhar sat down to deal with a Public Interest Litigation (PIL) filed by Rahul Roy that sought safe passage of ambulances carrying the riot victims. Later, on the same day, he along with Justice Talwant Singh heard another PIL from the Chief Justice’s board.

It was while hearing this PIL that Justice Muralidhar stated that the city won’t see a repeat of the 1984 anti-Sikh riots, at least not under the watch of the court. He reprimanded the police over their inaction and directed them to register FIRs against leaders including Anurag Thakur, Parvesh Verma, Abhay Verma and Kapil Sharma for alleged hate speech that led to violence in Northeast Delhi. He also directed for the constitution of a Special Investigation Team (SIT), deployment of army and compensation to the injured and the dead among other things.

His stance filled the people with hope which was soon taken away when close to midnight the Central Government issued the notification of the transfer of Justice Muralidhar to the Punjab & Haryana High Court. It was not taken to be a routine transfer because of its hurried manner and was instead being called a punitive action for speaking against the leaders of BJP, who is in power at the Centre.

Ravi Shankar Prasad, the Law Minister of India defended the midnight transfer order and stated that it was a decision that had already taken place two weeks back. This controversial notification came in furtherance of the recommendation made by the Supreme Court Collegium headed by the Chief Justice of India, S A Bobde which on February 12 had recommended the transfer of Justice Muralidhar along with two other judges. The collegium did not specify any reason for the transfers, as has been the practice.

This transfer recommendation was condemned by the Delhi High Court Bar Association, which not only abstained from work for a day as a mark of their protest but also demanded the collegium to revisit its decision and recall it. Justice Muralidhar—who is known for deciding cases such as the Sajjan Kumar case, Naz Foundation case, and Hashimpura massacre case, clarified that his opinion was sought by the SC collegium concerning his transfer and that he had no issues with it. He has since then taken charge at the Punjab & Haryana High Court and is the second most senior judge there.

Procedure for transfer of judges in India

The procedure for transfer of judges from one High Court to another in India is governed by the Supreme Court collegium headed by the Chief Justice of India. Apart from the CJI, the collegium consists of the Chief Justice of the High Court from which the judge is to be transferred, the Chief Justice of the High Court to which he would be transferred, and one or more senior-most Supreme Court Judges.

The collegium headed by the CJI makes the recommendation for the transfer which is referred to the Government of India along with the views of all the judges involved in making the recommendation. This recommendation is then submitted by the Union Law Minister to the Prime Minister who then advises the President on the transfer of the concerned High Court Judge. Once the transfer is approved by the President, the transfer is announced and then notified in the Gazette.

Legal/Constitutional provisions

The provisions of Article 222 of the Constitution of India govern the procedure of transfer of a judge from one High Court to another.

This article has an absence of guidelines concerning the transfer of judges and has been a part of many judicial interpretations over the years. In Union of India v Sankalchand H. Sheth [(1976) 17 Guj LR107], the transfer of Justice Sheth was challenged because such transfer had taken place without the consent of the Judge and without consulting the CJI. In this case, it was held that the transfer of judges cannot be made without consulting the CJI and must be made only in public interest..

The decision of the Sankalchand H. Sheth case was followed in S. P. Gupta v Union of India [(1982) 2 SCR 365] which is also known as “the First Judges case”. The decision, in this case, gave the primacy to the Executive and not the CJI in matters of appointments and transfers.

The Supreme Court Advocates-On-Record Association v Union of India [AIR 1994 SC 268], commonly known as “the Second Judges Case”, overruled the decision of the First Judges Case. It gave back the primacy to the Judiciary in matters of appointments and transfers. The Hon’ble Supreme Court also established that the CJI will form his opinion by taking into account the views of two senior-most judges of the Supreme Court. It was also held that the opinion of the CJI was also determinative in mattes of transfers.

It was in 1998 that the then President K. R. Narayanan sought the opinion of the Supreme Court concerning judicial appointments and transfers. The Supreme Court thus laid down that the sole recommendation of Chief Justice of India does not constitute “consultation” to fall within the meaning of Article 222. The recommendation for appointments and transfers must be made by the CJI in consultation with four senior-most judges of the Supreme Court. 

Criticism of the system

The transfer of Justice Muralidhar is not a sole case of a transfer that was met with controversy. Similar cases have erupted in the past as well and have forced some questions to be raised on the Supreme Court Collegium.

The transfer of a judge from one High Court to another can be made only in the name of public interest and for better administration of justice. However, on more than one occasion, the transfer orders of High Court Judges have left the people wondering as to what manner of public interest is being fulfilled by such transfers. There are rarely any explanations or reasons given behind the recommendations; the people are merely expected to have faith in the working of the said collegium, even though it has promoted opaqueness rather than transparency.

The 1970s saw the supersession of many senior Supreme Court judges for appointment for the office of Chief Justice of India. Similar was the issue in transfers of High Court Judges. There was a lot of arbitrariness and bias that reeked out of these decisions. It was only in the later years that the Hon’ble Supreme Court through its decisions put a check on executive arbitrariness by giving a primacy to the judiciary in matters relating to appointments and transfers of judges. It also stated that “the plurality of judges in the formation of the opinion of the Chief Justice of India” will act as an in-built check on any further bias or arbitrariness.

The Second Judges case and the Third Judges case laid down guidelines and norms that were supposed to stop the erosion of independence of judiciary. And yet, there are instances of transfers of Justice Rajiv Shakdher of Delhi High Court, Justice Jayant Patel of Gujarat High Court, and more recently the transfer of Madras High Court Chief Justice V K Tahilramani which force out the question — has the judiciary become complacent about its own independence?

Scope of improvement

History is proof that the power of transfer of High Court Judges has been abused. Despite the Supreme Court’s decisions on this subject which clearly state that a transfer cannot be a punitive measure, the feeling of a judge’s transfer being an act of punishment persists. Time and again the transfers of High Court Judges from Justice Jayant Patel to Justice Muralidhar are met with controversy and the lack of explanation on the part of the collegium fuels it further. Merely making the recommendations of transfer public is not an act towards transparency.

Judicial reforms are the need of the hour to maintain the faith of a common citizen in the Courts of law. The Supreme Court has in many decisions established the importance of a “reasoned decision”. It has stated that recording of reasons is “the heartbeat of every conclusion” and “the lifeblood of judicial decision making”. It is, thus, time for the Apex Court to revisit its reasoning. After all, when the law of the land is the same for everyone, then, why should the case of transfer of judges be not treated with the same principles of a reasoned decision?


Justice Muralidhar was transferred amid protests. His transfer was already marred with controversy as the SC collegium did not state any reason for making such a recommendation of the transfer. The non-stating of reasons has been a practice of the collegium and has on more than one occasion raised questions. The controversy was further fueled when the transfer was notified at around midnight. A routine transfer was suddenly shrouded with clouds of doubts and suspicions.

Even though the recommendation was made two weeks before, it was not welcomed by the legal fraternity. The government’s hurried and abrupt notification sowed the seeds of mistrust and a disappearing faith in the minds of the common people. A lack of reasoning and explanation led way to more conjectures.

The Judiciary needs to remain independent to ensure the delivery of justice. And in doing so, it is also the responsibility of the Judiciary to ensure that the faith of the people is not lost in the Courts of law. Transfer of Judges must be without any speck of bias or arbitrariness. Stating reasons behind the transfers can go a long way in ensuring the transparency of the process

Author: Shalu Bhati from Campus Law Centre, Faculty of Law, University of Delhi.

Editor: Ismat Hena from Faculty of Law, Jamia Millia Islamia.

Explained: Adjusted gross revenue (AGR)

Reading time 6-8 minutes.

Recently, a three-Judge Bench of the Supreme Court of India held, while deciding the issue of the over-expanded definition of Adjusted Gross Revenue (AGR), that the telecom Companies are required to submit within 3-months, the AGR dues to the Department of Telecommunication (DoT) vide its order dated 24th October 2019. By this order, Vodafone-Idea were greatly aggrieved, because of the continuing trends of its increased losses in the Indian Telecom Industry.

Thereby, a review petition was preferred by the Major Telecom Industries for extending the deadline for depositing AGR dues to DoT. In line of the same, a DoT officer released an order in respect of taking “no coercive actions/steps” against the Telecom Industries who haven’t paid their AGR dues clearly refuting and violating the October Order of the Hon’ble Supreme Court of India.

When the bench heard of the development, they rejected the review petition. Further, they condemned the action of DoT Officer for issuing such office order for nullifying the operation & execution of the Apex Court’s Judgment, and thereby held that till Friday, i.e. 21st February 2020, a handsome amount is to be deposited so as to show bona fide intent of the Telecom Companies.

They also directed to initiate contempt proceedings against the officer who published such order and asked the DoT to withdraw the same at earliest opportunity. Before 17th March 2020, the entire amount of ₹50,000 Crore was ordered to be deposited by the Vodafone-Idea Telecom Company.

This immediate deposition of amount has raised great concern for this major company, whose survival is at stake, as it is already in huge debt, and deposition of AGR dues may bring the company down, to the extent of winding up or restoration.

Significance of this development

The development must be seen in light of the international instance of evasion of the payment of Spectrum and License Fees from the Major Telecom Companies which has accounted an AGR due of ₹1.47 lakh Crore, which these companies have to pay to the Government. The wake of the Hon’ble Supreme Court of India’s decision has probably come at a time when these companies themselves are struggling for their survival, and especially Vodafone-Idea.

The significance of this development, which has ordered the Telecom Companies to pay their respective AGR dues to the Government, which in the line of Statistics are as follows:

  1. Vodafone Idea- ₹53,038 Crore
  2. Bharti Airtel- ₹35,586 Crore
  3. Other State Owned BSNL & MTNL and other shut and Bankrupt Telecoms- ₹58,376 Crore.

The decision has come right on time, when the auctions for 5G Spectrum are being called on in April-May, this year, which not only account for the realisation of the debt amount, but will also focus on the effective restoration of debt-laden Telecom Industry in India.

Quoting the words of Smt. Nirmala Sitaraman, who goes on to state as follows,

I don’t think I am looking at it purely from what the government will collect. This particular development in the telecom sector is something which all of us has watched, going through the proceedings of the court… it would not be right for me to just comment and say we are looking at this number or that”, she also state that, “It is fairly complex issue. The industry and affected parties are also in touch with the government. we are engaging with them; the department is engaging with them. We will be addressing this in more comprehensive manner”.

Thus, this development will surely account for great upsurge in the Revenue of the Government. But, the main problem which is to be tackled is that the debt-laden Telecom industry should not be adversely affected, which might seem to be over burdening the people by virtue of increased tariffs and other additional charges.

The main aim now is to revive the Telecom Industry and to realise the due debts and AGRs, whose actual picture and framework will be clear in coming future, as assured by the Budget Speech of Smt. Nirmala Sitharaman, Minister of Finance, Government of India.

What is AGR?

Adjusted Gross Revenue (AGR) was a relief mechanism which was granted to the Telecom Companies in the year of 1999. It was when the Liberalisation of the Telecom Industry took place in 1994 by virtue of the formulation of National Telecom Policy, 1994 the Telecom Industry need to seek for license at stipulated fixed rates, so to provide some relief, a revenue sharing model was introduced by the Government in the name of Adjusted Gross Revenue, which relaxed the steep fixed rate of license.

Under the AGR mechanism, the mobile telephone operators were required to share a percentage of their AGR with the government as annual license fee (LF) and spectrum usage charges (SUC). License agreements between the Department of Telecommunications (DoT) and the telecom companies define the gross revenues of the latter. AGR is then computed after allowing for certain deductions spelt out in these license agreements. The LF and SUC were set at 8 per cent and between 3-5 per cent of AGR respectively, based on the agreement.

Accordingly, the AGR is defined to include according to Government as all the charges which are calculated based on all revenues earned by a telco, including non-telecom related sources also such as deposit interests and asset sales, which was disputed by various Telecom Companies so as to only include or comprise the revenues generated from telecom services. It is worthy to quote, that Supreme Court has upheld the former definition over the latter.

Reason for bringing AGR and why was it introduced?

As the Indian Economy was liberalised in the year 1994 and with the advent of high License Fees (LF) and Spectrum Usage Charges (SUC), it was difficult for the Indian Telecom Industry to survive in the open economy. To get a mid-way relief for Telecom Operators, the AGR mechanism was introduced, which accounted for sharing of the LF and SUC between the Mobile Telecom Companies, so that burden of such heavy fixed fees is shared and collective good can be achieved.

Another benefit which could be conventionally seen as the impact of AGR was the shift from Monopoly to Duopoly, so that competition is reduced and ultimate good of the whole is seen.

Critical analysis of AGR

The objective behind bringing the AGR mechanism was that of benefitting the Telecom Operators which immunes them from high rates of LF & SUC’s. But with time, irresponsible character and non-payment of AGR dues by the Mobile Telecom Operators have led to the SC’s latest decision for depositing the AGR due to the Government.

It is appropriate to quote here that the Telcos were riding the boom period and enjoying profits without foreseeing the possibility of losing out in the court battle on the AGR dispute; they presumed themselves as ‘too-big-to-fail’ companies. But it was not the case, as the Introduction of Reliance Jio with consecutive increase in debt and decrease in consumer ratio, has brought the Telecom Operator in the situation of recklessness and danger.

The debate dates back to the time of the 1999 telecom policy that witnessed a major shift from the policy of government charging a fixed license fee from the telecom service providers to a newly-agreed revenue sharing basis system that saw telcos enjoying less financial stress compared with the earlier regime.

The problems began when telcos disputed the structure and composition of the new AGR formula and began contesting it legally and started engaging with regulators. One must note that even when telcos stopped paying the share under the AGR and litigation began, the industry’s gross revenue was growing rapidly between 2004 and 2015 from Rs 4,855 crore in the financial year 2004 to Rs 2.3 lakh crore in the financial year 2015.

Telcos have been making huge profits through rapid expansion and even from non-core activities. Bharti Airtel and Vodafone India, the two prominent players, also witnessed a hike in their revenues and presence.

Thus, the concept of AGR was brought with good intent, but the mala fide intentions of the Telecom Operator brought them into huge danger.

Impact on Telecom Industry

The major impact of this decision shall be on the Vodafone Idea which is worst hit by the implementation of AGR, given that it only had ₹12,530 crore of cash and equivalent reserves as of December 2019, while bearing a gross debt of ₹1.2 trillion.

It is worthy to note that Reliance Jio, the latest entrant in the sector is the only profitable telco, facing licence fee and SUC dues of only Rs 41 crore, whereas Vodafone Idea is already struggling with falling revenue, a shrinking user base, combined quarterly losses of nearly Rs 5,000 crore, and a negative free cash flow along with debt of more than Rs 99,000 crore. Moreover, Free talktime, late fee waivers and rebates on pre-paid vouchers for telecom consumers be also waived off in the light of the said judgment by the Telecom Operators, whereby directly impacting the common people.

In the words of the industry expert, “It’s not just the telecom operators that have been hit by the Supreme Court’s ruling on Adjusted Gross Revenue, even consumers will bear the brunt of the decision. Operators will stop offering discounts and waivers because they do not want to be in a situation where they have to pay revenue share to the government on income that they did not receive.”

This situation can be understood with the help of an example, where with ₹10 voucher you would get 10 minutes of talktime and extra 2 minutes free, now the company’s need to pay the due on ₹12 and not ₹10, for the extra free benefit as well.

He also says that operators will be left with no flexibility. “Operators will have to pay revenue share on revenue they have not earned but are presumed to have earned because of the discounts,” said an executive at a top operator. “There will be a serious impact on operators’ overall cost of operations. This will force them to raise tariffs and consumers will again have to pay for erroneous regulations.”

To conclude, it is noteworthy to quote here the words of our Telecommunication Minister, Mr. Ravi Shankar Prasad, who states that,

“The judgment represents a significant event with respect to the company… we will evaluate our next steps. The judgment has financial implications, which we are reviewing,” Vodafone Idea said. It said Thursday that it may file a review petition in the apex court. Besides waiving off or lowering penalty and interest, the government is working out a broader relief package for the industry that could include reassessing moratorium on payment for spectrum installments, offsetting input tax credit worth Rs 36,000 crore against future payments, and reducing licence fee by two percentage points to 6% by decreasing the contribution to the Universal Service Obligation Fund (USOF) and also said the government was working on spectrum pricing reforms.”

With the advent of time, we will get to know the actual impact and burden on the ultimate consumer per the change of tariff plans and policy of Telecom Operators in the light of the said realisation of AGR dues on them.

Author: Harshit Sharma from Amity Law School, Amity University Madhya Pradesh (AUMP), Gwalior, Madhya Pradesh.

Editor: Anna Jose Kallivayalil from NLU, Delhi.