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Summary
 PROFESSIONAL ETHICS - RESEARCH PROJECT

On
CASE ANALYSIS: KUNAL KAMRA V. UNION OF INDIA: CONTEMPT OF
COURTS ACT VIS A VIS FREEDOM OF SPEECH & EXPRESSION

MAHARASHTRA NATIONAL LAW UNIVERSITY, AURANGABAD

Submitted to

Submitted by

KAJAL MHASAL (2019/BALLB/19)

BA LLB (HONS.) SEMESTER-X

Under the guidance of

Prof. Amruta Chavan

MNLU, Aurangabad

16 April, 2024
 CASE ANALYSIS: KUNAL KAMRA V. UNION OF INDIA

RECOGNITION

I would like to express my heartfelt gratitude to Prof. Amruta Chavan for giving me
opportunity to work on this project titled on Case Analysis of Kunal Kamra v. Union of India:
Contempt of Courts Act vis a vis Freedom of Speech & Expression. I tried to do my best to
gather information about the project in a number of ways in order to present a clear picture of
the given project subject.

Page 2 of 15
 CASE ANALYSIS: KUNAL KAMRA V. UNION OF INDIA

DECLARATION

I, the undersigned, solemnly acknowledge that the project report on CASE ANALYSIS:
KUNAL KAMRA V. UNION OF INDIA., is based on my own work completed under the
supervision of my professor during the course of my studies. I say that the assertions made
and the findings reached are the product of my study. I also certify that:

I. The report's material is original, and it was produced by me under the general
guidance of my supervisor.
II. The work has not been applied to any other college for any other degree, diploma,
or credential in this university or any other Indian or foreign university.
III. In preparing the research, I followed the university's guidance.

IV. When I use materials (data, analytical research, and text) from other sources, I
credited them in the report's text and included their contact information in the
references.

Kajal Mhasal

2019/BALLB/19

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 CASE ANALYSIS: KUNAL KAMRA V. UNION OF INDIA

TABLE OF CONTENTS

 RECOGNITION .................................................................................................... 2
 DECLARATION.................................................................................................... 3
 TABLE OF CONTENTS ...................................................................................... 4
 ABSTRACT ............................................................................................................ 5
 SIGNIFICANCE OF THE STUDY ..................................................................... 5
 OBJECTIVE OF THE STUDY ............................................................................ 6
 CONTEMPORARY LEGAL RELEVANCE ..................................................... 6
 RESEARCH METHODOLOGY ......................................................................... 7
 RESEARCH QUESTION ..................................................................................... 7
 SCOPE & LIMITATIONS OF THE STUDY ..................................................... 7
 INTRODUCTION.................................................................................................. 8
 CHALLENGES TO THE AMENDMENT ......................................................... 9
 QUESTIONS OF LAW ....................................................................................... 10
 OBSERVATIONS OF THE COURT (JUSTICE GS PATEL'S OPINION) . 10
 ANALYSIS ........................................................................................................... 12
 OBSERVATIONS OF THE COURT (JUSTICE NEETA GOKHALE'S
OPINION)............................................................................................................. 13
 ANALYSIS ........................................................................................................... 14
 CONCLUSION .................................................................................................... 15
 REFERENCES..................................................................................................... 15

Page 4 of 15
 CASE ANALYSIS: KUNAL KAMRA V. UNION OF INDIA

ABSTRACT

The case of Kunal Kamra v. Union of India1 holds contemporary relevance in the context of
debates surrounding freedom of speech and expression, media freedom, judicial independence,
and political discourse in India. This abstract explores the multifaceted implications of the
case, including its significance for understanding the boundaries of permissible criticism,
satire, and dissent directed towards state institutions and public figures. It highlights the case's
role in sparking discussions on media ethics, the responsibilities of journalists and comedians,
and the challenges posed by online platforms in regulating content while upholding free
speech. Additionally, the abstract delves into the case's implications for judicial accountability,
transparency in contempt proceedings, and the delicate balance between protecting judicial
integrity and ensuring public scrutiny. It underscores the broader implications of the case for
political and social discourse, constitutional interpretation, and the global landscape of
democracy and governance. Overall, the case of Kunal Kamra v. Union of India serves as a
lens through which to examine contemporary issues at the intersection of law, politics, and
society, offering valuable insights into the complexities of democratic governance and civil
liberties in India and beyond.

SIGNIFICANCE OF THE STUDY

1
 Upholding Free Speech: The decision reaffirms the sacrosanct nature of the
constitutional guarantee of free speech, emphasizing its protection against undue state
encroachment.
 Rejection of Arbitrary Censorship: Justice Patel condemns the amended Rule
3(1)(b)(v) of the IT Rules 2021 as vague and overbroad, posing a threat to critical
discourse and debate.
 Constitutional Principles: The judgment invokes Article 19 and Article 14 of the
Constitution, arguing that the amended rule infringes upon fundamental rights and lacks
reasonable standards.
 Importance of Judicial Review: The decision underscores the role of judicial review
in curbing potential abuses of power by government entities, particularly in
safeguarding democratic principles.

1
2024 SCC OnLine Bom 360.
Page 5 of 15
 CASE ANALYSIS: KUNAL KAMRA V. UNION OF INDIA

1
 Recognition of Digital Regulation: While acknowledging the need to combat
misinformation, the judgment insists on the importance of balanced regulation that
respects free speech rights.

OBJECTIVE OF THE STUDY

1. To provide a case study for students, legal practitioners, policymakers, and civil society
organizations to deepen their understanding of constitutional law, judicial processes,
and the dynamics of power and accountability in a democratic society, fostering
informed debate and dialogue on contemporary legal and political issues.

CONTEMPORARY LEGAL RELEVANCE

The contemporary relevance of studying18the case of Kunal Kamra v. Union of India lies in its
implications for several key aspects of Indian society and governance:

1. Freedom of Speech and Expression: In the context of increasing debates surrounding

freedom of speech and expression in India, particularly in the digital age, this case sheds
light on the boundaries of permissible criticism, satire, and dissent, especially when
directed towards state institutions and public figures. It provides insights into how the
judiciary navigates the tension between protecting free speech and maintaining the
dignity and authority of the courts.

2. Media Freedom and Press Ethics: Given the involvement of a comedian and a
journalist in the case, it raises questions about the role of media, including social media,
in shaping public discourse and holding institutions accountable. The case prompts
discussions on journalistic ethics, the responsibility of media professionals, and the
challenges posed by online platforms in regulating content while safeguarding freedom
of expression.

3. Judicial Independence and Accountability: The case highlights issues related to

judicial independence and accountability, including the use of contempt powers to
safeguard the judiciary's integrity. It invites scrutiny of the judiciary's response to
criticism and the transparency of contempt proceedings, fostering discussions on the

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 CASE ANALYSIS: KUNAL KAMRA V. UNION OF INDIA

need for accountability mechanisms that balance judicial autonomy with public
scrutiny.
11
RESEARCH METHODOLOGY

The study is based on the secondary source of information. Data is collected from books,
Journals, websites. An analysis of Several articles, books and others records connected with
the topic had been done. A while later, the gathered materials specifically classified
understanding to their pertinence. Under each topic, the sub-subjects framed and comparative
thoughts gathered into similar index and dissimilar thoughts treated independently.
5
Mode of Writing
A descriptive and analytical method of writing has been followed.
Mode of Citation
A uniform mode of Citation has been followed.

RESEARCH QUESTION

Provide an analysis of the case of Kunal Kamra v. Union of India.

SCOPE & LIMITATIONS OF THE STUDY

1. 6Data Availability: The availability of comprehensive and up-to-date data on land

acquisition processes and their impacts in Maharashtra 6may be limited, potentially
affecting the depth and accuracy of the study's analysis.
2. Regional Variations: Maharashtra is a diverse state with varying socio-economic and
environmental contexts across different regions. The study may not capture all regional
nuances and disparities in land acquisition practices and their impacts.
3. Time and Resource Constraints: Conducting a thorough study of land acquisition
processes in Maharashtra requires significant time, resources, and expertise. The study's
scope may need to be limited to specific aspects or case studies to address resource
constraints.
4. Complexity of Legal Issues: The legal framework governing land acquisition in
Maharashtra is complex, with overlapping laws, regulations, and judicial
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 CASE ANALYSIS: KUNAL KAMRA V. UNION OF INDIA

interpretations. The study may face challenges in interpreting and analyzing legal
complexities accurately.
Overall, while the study aims to provide a comprehensive analysis of the legal relevance of
studying the process of land acquisition in Maharashtra, it is important to acknowledge these
scope and limitations to ensure the rigor and validity of its findings and conclusions.

INTRODUCTION

The constitutional validity of the 2023 amendment to Rules 3(1)(b),2 3(1)(b)(v),3 and 7 (the
"Amendment") of 10the Information Technology (Intermediary Guidelines and Digital Media
7
Ethics Code) Rules, 2021 (the "Intermediary Rules") was contested. The Bombay High Court
rendered a split decision in Kunal Kamra v. Union of India and related matters on January
31,2024.
The Division Bench, which included Justices GS Patel and Neela Ghokale, heard the case.
While Justice Neela Ghokale's ruling upheld the Amendment, Justice G.S. Patel's struck it
down, citing it as being beyond the scope of Article 144, 19(1)(a),5 19(2),6 19(1)(g),7 and 19(6)
of the Indian Constitution and Section 79 of the Act.8
The Central Government (the "CG") was notified of the aforementioned Amendment on April
6, 2023. It gives the CG the power to establish a Fact Checking Unit (the "FCU"), whose job
it is to find any "fake, false, or misleading" information about "its businesses" on internet media
platforms. The judgement rendered by Justice GS Patel is summarized in this article.

2 4
Rule 3(1)(b) of the Information Technology (Intermediary Guidelines and Digital Media Ethics Code)
Amendment Rules, 2023.
3
Rule 3(1)(b)(v) of the Information Technology (Intermediary Guidelines and Digital Media Ethics Code)
Amendment Rules, 2023.
4 3
Article 14 of the Constitution of India, 1950.
5
Article 19 (1) (a) of the Constitution of India, 1950.
6
Article 19 (2) of the Constitution of India, 1950.
7
Article 19 (1) (g) of the Constitution of India, 1950.
8
Section 79 of the Information Technology Act, 2000.
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 CASE ANALYSIS: KUNAL KAMRA V. UNION OF INDIA

CHALLENGES TO THE AMENDMENT

The Information Technology Act, 2000 (the "Act"), Sections 79, 87(2)(z),9 and (z)(g),10 as well
as the Amendment's ultra vires, were the main grounds raised by the petitioners in their
challenge to the Amendment.
The petitioners argued that by transferring ownership of user content from the content
creator/user to the intermediary/service provider, the amended Rule 3(1)(b)(v) in conjunction
with Rule 7 of the Intermediary Rules11 has a "chilling effect." According to Rule 3(1)(b)(v) of
the Intermediary Rules, intermediaries are indirectly required to abide by the FCU's decisions.
If they do not, they will not have the protections against third-party content that are outlined in
Section 79 of the Act.
The petitioners also argued that the Amendment is too broad and ambiguous because terms like
"business of the government," "fake," "false," and "misleading" are not clearly defined. Such
ambiguity may cause the amended Rule to be applied arbitrarily. It was also noted that there
were significant differences between the criteria used to assess the authenticity of "Business of
the Central Government" content and other content. It was observed that the Amendment
mandates that the FCU serve as an arbiter of truth for any content pertaining to Central
Government business. Notably, the purpose and knowledge of the user who posted the content
were disregarded when determining whether it was "fake, false, or misleading." This is in stark
contrast to other types of content, where the intention and knowledge of posting content is a
determining factor in curtailing such content.

15
It was contended that the right to truth cannot be understood as part of the freedom of speech
provided by Article 19(1)(a), particularly in cases when the CG's mechanism is to determine
what constitutes "true and accurate information." The petitioners relied on established fact-
checking procedures that are common in print media as well as court precedents from both
American and Indian jurisprudence to support their claims. It's interesting to note that there
was also a contention that a constitutional amendment was the only way to expand Article
19(2), not delegated legislation or rules.

9 9
Section 87(2)(z) of the Information Technology Act, 2000.
10
Section 87(z)(g) of the Information Technology Act, 2000.
11 16
Rule 7 of the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Amendment
Rules, 2023.
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 CASE ANALYSIS: KUNAL KAMRA V. UNION OF INDIA

In addition, it's noteworthy to mention that there are currently more than 17 petitions ongoing
in several High Courts contesting the Intermediary Rules' entire constitutionality. A couple of
the petitioners in two of these cases have also been given protection against coercive action by
the CG for not implementing the Intermediary Rules. The High Court proceedings have been
halted by the Apex Court through an interim order, and the CG has also filed an SLP (C) No.
11163 of 2023 for the transfer of all such challenges to the Apex Court.

QUESTIONS OF LAW

The primary points that the High Court examined are summed up in the following legal
questions for the sake of conciseness.
a. Whether the Amendment which imposes restrictions on online content are in violation of13the
fundamental right guaranteed under Article 19(1)(a) and 19(1)(g) of the Indian Constitution?
b. Whether the Amendment violates Sections 79 and 87(2)(zg) of the Act?
c. Whether the Amendment 8infringes on the fundamental rights envisaged under Article 14 of
the Indian Constitution?
d. Whether the CG has the authority to impose prior restraints on the publication of material
that may be defamatory of the State or its officials?
e. Whether the Amendment meets the tests of reasonableness, necessity, and proportionality in
restricting19the fundamental right to freedom of speech and expression?

OBSERVATIONS OF THE COURT (JUSTICE GS PATEL'S OPINION)

The Court reaffirmed and underlined that any limitations on the right to free speech and
expression must be sensible, justified, and compliant with Article 19(2) of the Indian
Constitution. Accordingly, the Court observed that any legislation that restricts a fundamental
right must be limited to the legal bounds under Articles 19(2) to 19(6). It took this cue from
Minerva Mills v. Union of India12. The Central Government's (the "CG") argued that the
limitations under Articles 19(2) and 19 (6) were exhaustive and that any additions or
modifications to the same had to go through a legislative process, was also ruled to be in

12
(1980) 3 SCC 625.
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 CASE ANALYSIS: KUNAL KAMRA V. UNION OF INDIA

conflict with the Amendment. It was further decided that the Amendment did not pass any of
the standards established in the seminal ruling of Shreya Singhal v. Union of India13.

The principles pertaining to the extent and constraints of freedom of speech and expression,
the necessity of precise rules and guidelines when enforcing limits, and the ideas of vagueness
and overbreadth in legislation have all been extracted by the Court with the assistance of Shreya
Singhal. The Court noted that the Act's broad and extensive definition of "information" cannot
be narrowed down by judicial action, keeping these principles in mind. Consequently, the Court
emphasized that in order to prevent arbitrary and ambiguous limitations on the right to free
speech and expression, the relevant laws must contain explicit principles and standards.

The Court noted that it is invalid to classify material by distinguishing between online posts
about the "business of the Government" and other types of content. It was decided that
segregating information about the Central Government's operations for special treatment
amounted to class legislation, which is prohibited under Articles 14 or 19. Referring to State
of Rajasthan v. Mukan Chand and Ors,14 the Court noted that any categorization under a
statute must have a meaningful relationship to its statutory goal and that the CG does not, by
itself, form a separate class to warrant such preferential treatment.

The government itself established the Fact Checking Unit (the "FCU"), which is being
constituted to ascertain the "truth" of information published with regard to the government's
business. The Court expressed its opinion that this clearly casts doubt on the credibility of the
aforementioned fact checking institution. The Court questioned the arbitrary criteria used by
the FCUs to assess whether material is fraudulent, deceptive, or misleading in addition to
emphasizing the lack of clear-cut guidelines as intended by the Evidence Act of 1872.15 In this
context, the Court asked, "Quis custodiet Ipsos custodes?" referring to which fact checker will
evaluate the FCU's operation in turn. The Court further noted that no guidelines or process for
the operation of the FCU were provided with the Amendment, nor were there any materials to
rely on or procedures to follow. The Court also noted that the Amendment did not provide a
hearing procedure before the FCU before the FCU could label anything on the internet as "fake,
false, or misleading." It has been decided that the FCU's unclear process and the absence of a

13
(2015) 5 Supreme Court Cases 1.
14
1964 SCR (6) 903.
15
The Evidence Act of 1872.
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 CASE ANALYSIS: KUNAL KAMRA V. UNION OF INDIA

hearing mechanism established by the Amendment violate the established natural justice
norms.

The Court further stated that a separate FCU was not required to determine the accuracy of the
information pertaining to government business on online platforms because the Press
Information Bureau ("PIB"), which has a mechanism in place to weed out false or misleading
information with regard to government policies, is sufficient.

The Court also cited the Gujarat Mazdoor Sabha and Anr v. State of Gujarat,16 five-fold test,
which lays out five requirements that a law must meet in order to avoid being deemed to be
violative of or infringing upon basic rights. The Court ruled that the Amendment does not pass
each of the five requirements outlined in the document. Furthermore, with respect to the
Executive's authority under Article 73, the Court determined that the Amendment is not
covered by Article 73(1)(a) because the term "business of the Government" has not been
defined.
ANALYSIS

The ruling by Justice GS Patel concluded that laws governing the restriction of free speech
cannot be vague or unrestricted, and it firmly relied on progressive rulings such as those
rendered by Bennet Coleman,17 Shreya Singhal,18 and Minerva Mills19. In this ruling, the
Court has elevated the ideals of natural justice while examining the FCU's function in verifying
the accuracy of information pertaining to government business.

The ruling also explores the subjective nature of "truth" and asks whether it is feasible to
determine the veracity of material that has been released in an objective manner. It has been
noted that the FCU's definition of "fake, false, or misleading" information and content lacks
guidelines and is instead left up to the judgment of the organization's members. In an innovative
move, the Court expanded the scope of material covered by Article 14's equal treatment clause
in this ruling. When information about other people is not supplied with such safeguards, it was
noted that information about government business could not be put on a high horse and could
not have a specific mechanism to weed out phony or incorrect information.

16
(1998) 2 GLR 1135.
17
(1972) 2 SCC 788
18
(2015) 5 Supreme Court Cases 1.
19
(1980) 3 SCC 625.
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 CASE ANALYSIS: KUNAL KAMRA V. UNION OF INDIA

The idea that there should be communal responsibility in ensuring that the ability to
communicate material on the internet or public domain is not misused is welcomed even though
the Hon'ble Court struck down the Amendment. In light of this, the Court has further noted that
as dissent and disagreement are essential components of democracies, laws that do not fall
within the parameters set forth in Article 19(2) should not be allowed to strangle them. As a
result, the ruling makes it abundantly evident how crucial it is to defend and preserve
fundamental rights in the digital era and serves as a warning to the government that laws
governing the right to free speech and expression cannot be arbitrary, vague, or in breach of
fundamental rights guaranteed under the Constitution.

OBSERVATIONS OF THE COURT (JUSTICE NEETA GOKHALE'S OPINION)

The Court noted that the FCU's constitution would aid in determining the accuracy of
information that is purposefully shared regarding government business in the event that there
was no system in place to verify it. The Court clarified that the FCU's function under the
Intermediary Rules is to identify information pertaining to any government activity that is
provided through intermediaries. The Court pointed out that the FCU is neither authorized or
empowered to order the intermediary to remove any such information. The intermediary has
the authority to make the same decisions, and anyone who feels wronged by one of these
choices may appeal to the Grievance Redressal Mechanism as outlined in the Intermediary
Rules. The Court added that in the event that if there is any grievance with regard to the
functioning of the FCU, then an aggrieved person can approach a Court of law for the same.

The Court noted that there isn't a "chilling effect" on the right to free speech in this particular
instance. The Amendment excludes opinions expressed by an individual and only addresses
false and misleading material that is disseminated with malicious intent. Additionally, if
someone has a complaint about how the FCU classified material, they can file it with the
appropriate authorities. The Court ruled that the purpose of the Amendment was to prevent the
dissemination of incorrect information rather than to silence critics of policies or facts.

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 CASE ANALYSIS: KUNAL KAMRA V. UNION OF INDIA

The Court noted that in relation to information, the terms "fake, false, and misleading" are to
be regarded in their usual sense and do not include references to satires, parodies, comments,
etc. As a result, they cannot be described as vague. The Court further ruled that the government
is in the best position to give accurate information about how its business is being conducted,
and that the vagueness of the term "Business of the Government" cannot be used as justification
for invalidating the Amendment.
The Court held that the contested Amendment passes the proportionality test and falls within
the purview of reasonable restrictions under Article 19(2), citing the rulings of the Apex Court
12
in Justice K.S. Puttuswami and Anr v. Union of India20 and People's Union for Civil Liberties
v. Union of India.21

ANALYSIS

The Court firmly concluded that the Amendment falls within the purview of Article 19(2) and
does not in any way violate 8the right to freedom of speech and expression, even as it upheld
the Amendment. The Court underlined that the spread of misinformation, deception, and one-
sided information all work together to create an ignorant public and threaten democratic
integrity. The conclusion is that the efficacy of democratic processes is adversely affected by
various types of information distortion together.
According to the Court, the Intermediary Rules have their own grievance redressal procedure.
If a user feels that they have been misled, faked, or misleadingly flagged by the FCU under the
Amendment, they 7can file a grievance through the grievance redressal mechanism. The
government cannot decide whether to pursue a grievance through the grievance redressal
mechanism; only a competent court with jurisdiction can make the final decision.

The Court additionally concluded that neither the intermediary nor the user is penalized by the
Amendment if they cannot legally challenge the decision in court. Information is qualified
according to knowledge and intent, and the Amendment does not restrict its substance unless
it is untrue or inaccurate. The Court restated that the terms "fake" and "false" should be used
with malice in mind and should be interpreted normally. The Court gave much thought to the
fact that the FCU's job is to verify the accuracy of information on government activity, not to

20
2019 (1) SCC 1.
21
(2007) 12 SCC 135.
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 CASE ANALYSIS: KUNAL KAMRA V. UNION OF INDIA

suppress any information. The Court emphasized that if information which is false, fake and
misleading is knowingly shared with mala fide intentions, then the same affects the citizen’s
right to participate in a democratic environment, since access to true and authentic information
is of utmost importance.

CONCLUSION

In conclusion, the Kunal Kamra v. Union of India case represents a critical turning point in
India's current legal discourse, particularly with regard to judicial accountability, media ethics,
and freedom of speech. This case emphasizes the changing dynamics between individual rights
and institutional integrity through its careful analysis of the bounds of acceptable criticism and
dissent. The case also emphasizes how crucial the judiciary is in maintaining democratic ideals
and constitutional values while juggling conflicting interests. Because of this, researching this
case offers insightful information about the difficulties of navigating the digital media world,
the intricacies of contemporary governance, and the continuous pursuit of a society that is more
just and equal. Through examining the legal, social, and political aspects of this case, scholars,
practitioners, and policymakers can contribute to a more informed and robust public discourse
on fundamental rights, the rule of law, and the dynamics of power in contemporary
democracies.

REFERENCES

1. 17https://www.barandbench.com/law-firms/view-point/an-analysis-of-kunal-kamra-vs-
union-of-india
2. https://www.thehindu.com/opinion/op-ed/judicial-clarity-on-free-
speech/article67866821.ece
14
3. https://thewire.in/rights/it-rules-fact-check-kunal-kamra-petition-bombay-hc

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11% Overall Similarity

Top sources found in the following databases:
8% Internet database 1% Publications database
Crossref database Crossref Posted Content database
8% Submitted Works database

TOP SOURCES
The sources with the highest number of matches within the submission. Overlapping sources will not be
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civilsdaily.com
1 3%
Internet

ukcatalogue.oup.com
2 <1%
Internet

O. P. Jindal Global University on 2019-04-16

3 <1%
Submitted works

legalserviceindia.com
4 <1%
Internet

vdocuments.mx
5 <1%
Internet

University of North Texas on 2023-11-29

6 <1%
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The WB National University of Juridical Sciences on 2024-03-01

7 <1%
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National Law School of India University, Bangalore on 2009-12-16

8 <1%
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Sources overview
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The WB National University of Juridical Sciences on 2020-03-12

9 <1%
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algindia.com
10 <1%
Internet

aarf.asia
11 <1%
Internet

Tilburg University on 2024-01-17

12 <1%
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rtn.asia
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Internet

NALSAR University of Law Hyderabad on 2023-07-18

14 <1%
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National Law University, Orissa on 2013-10-26

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lawstreet.co
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National Law University New Delhi on 2023-05-05

17 <1%
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18 <1%
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ecoi.net
19 <1%
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Sources overview
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Excluded from Similarity Report

Small Matches (Less then 10 words) Manually excluded sources
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EXCLUDED SOURCES

barandbench.com
18%
Internet

EXCLUDED TEXT BLOCKS

any
www.barandbench.com

Section 79 of the Act.The petitioners also argued that the

www.barandbench.com

and other content. It was

www.barandbench.com

was
www.barandbench.com

is based on my own work completed under thesupervision of

The British College on 2021-07-12

that the assertions madeand the

The British College on 2021-07-12

general
Cyryx College, Maldives on 2021-11-11

and text) from other sources, Icredited them in the report's text and included their ...
The British College on 2021-07-12

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 Similarity Report ID: oid:26404:57407663

V. UNION OF INDIA
National Law School of India University, Bangalore on 2010-09-12

the case of Kunal Kamra v. Union of India

Symbiosis International University on 2023-10-23

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