Abstract
Freedom of speech and expression is a right to express one’s point of view and opinions freely by different methods and modes. For example, by speaking something or by writing something somewhere. Printing is also one of the forms of doing a seditious act, or even by making pictures. However, this right has certain issues also as if govt. restrict it then what should be the limit of its restrictions. Putting a restriction on such a right need great scrutiny. All those activities somehow incite people against the govt. by words and by which it creat difficulty to maintain the tranquillity of the Nation. It is something that incites violence. Freedom of speech and expression Do not give anyone license to commit offences. It is an assumption that the govt. may use this law as a tool to suppress dissent and justified criticism and there is also an apprehension that in the name of freedom of speech and expression some people are forgetting their limitation about how much to speak and what to speak. India is one of other largest democracy of the world in which freedom of speech and expression is the right which is celebrated like a festival. This paper will also be dealing with the right to freedom of speech and expression and its co-relation with sedition law in India. In this paper, the current cases related to sedition is dealt with. Its increasing rate percentage of conviction.
Keywords: Freedom of speech, misuse, rise in the case, conviction rate, democracy, restrictions.
Introduction
Freedom of Speech is the essence of democratic and functional government. In a democracy, freedom of speech plays animportant role in getting what people think of different issues such as political, economic, and social.[1]The fundamental right has been stated as the human right as it protects humans and a natural right as it is from the very inception of the world.[2]Several organisations working internationally have declared this right as it is a fundamental right.[3]Article 19 of the Indian Constitution mention it as a fundamental right to speak under freedom of speech and expression.[4] It includes the freedom of communication, freedom to express, and freedom to publish any opinion.[5]If a state imposes certain restrictions on freedom of speech, then it’s the State responsibility to look after those restrictions before passing them. The proper scrutiny must be followed.[6]
It is a crime, a crime against the whole society. Sedition embraces practices whether by words, deed or writing by some person which subvert and the laws of the nation. The word which is spoken basically against the government ultimately harm the integrity of the Nation. It contains all those practices which somehow excite discontent or dissatisfaction. Which may lead to civil war or may create a public disturbance. Sedition law is necessary to promote public order.[7]
Sir JAMES STEPHEN defined a seditious intention as “an intention to bring into hatred or contempt, or to excite disaffection against, the person of his Majesty, his heirs or successors, or the Government and the constitution of the United Kingdom by law established, or either House of Parliament, or the administration of Justice or to excite his Majesty’s subjects to attempt otherwise than by lawful means, the alteration of any matters in Church or State by law established…..or to raise discontent or disaffection amongst his Majesty’s subjects, or to promote feelings of ill will and hostility between different classes of such subjects.”
According to HALSBURY, the essence of the offence of treason lies in the violation of the allegiance owed to the sovereign.
It is wrong to say that fundamental rights are absolute. B.R Ambedkar in constitutional assembly debate once said that “It is a fundamental principle, long-established, that the freedom of speech and of the press, which is secured by the Constitution, does not confer an absolute right to speak or publish, without responsibility, whatever one may choose, or an unrestricted and unbridled license that gives immunity for every possible use of language and prevents the punishment of those who abuse this freedom.”[8]
STATEMENT OF PROBLEM
All the people of India have the right to freedom of speech and expression. Every individual can freely celebrate his right to speak. Our Constitution gives this right to speak but in a reasonable manner. This is something that is not absolute. It means we should take care before we speak. Nowadays, people know to raise their voice through different modes such as through print media or electronic media.
We need to know the reasonableness of the words which we have spoken as what we speak is not for us it for others. We need to understand the limits imposed on every citizen before speaking anything. We need to know it because it is the only way to maintain harmony in society. Like, if we continue speaking what we like and that is not liked by the listeners it will certainly affect the society or we can say that in a larger aspect it will harm the Nation, internally as well as internationally.
This paper will be specifically dealing with the sedition law and the freedom of speech and expression. As the fundamental right to speech is grossly misused now a day by the people. This paper will have research on the different current scenarios and the laws related to sedition and freedom of speech.
LITERATURE REVIEW
The paper contains a significant amount of primary data which is then corroborated with the secondary sources to justify the assumed hypothesis. The sources in the paper include excerpts from D.D. Basu, and has also perused The Indian Penal code, 1860. J.N Pandey and M.P Jain also have helped me to understand the nuances of freedom of speech and expression in more depth. The sources in the paper include excerpts from K.D Gaur, S.N Mishra and Ratanlal and Dhiraj Lal have helped me to understand the nuances of sedition Law. We get the overview of current thinking on the sedition by the online sources, such as opinida, Hindustan Times, the Hindu and other newspapers. We get a critical analysis of data available from the National Crime Report Bureau(NCRB), 2015-2020.
Historical background of sedition law in India.
The Indian Penal Code 1837 was drafted by Lord Macaulay which talks about sedition in section 113 which is now seen in section 124-A of the Indian Penal Code. The punishment that was decided during 1835 was “life imprisonment”. The amount of punishment which was suggested by Sir John Romilly, who was a chairman of the second pre-independent law commission was 5 year. Consequently, sedition was included as an offence under section 124A through Special Act XVII of 1870. This sedition law was introduced to punish an act of exciting feelings of disaffection towards the Government.
After all these circumstances, the British parliament in 1907 enacted the “Prevention of Seditious Meeting Act”. This Act prevents a group of people to meet together which might likely lead the offence of sedition to cause a disturbance with the object to overthrowing the Government.
In the very famous case Queen Empress v Bal Gangadhar Tilak,[9] he was charged for publishing an article in a newspaper invoking the example of the great Maratha warrior Shivaji to incite the overthrow of British rule. The detailed discussion of disaffection was interpreted widely by including hatred, enmity, dislike, hostility, contempt and every form of ill-will to the Government. Disloyalty is perhaps the best general term, comprehending every possible form of bad feelings to the Government. This was the first case of Sedition.
As the confusion related to the interpretation of the word “disaffection” still arises. To make it clear in the interpretation of the word “disaffection”, the legislature introduced Explanation III to the section which excluded ‘comments expressing disapprobation of the action of theGovernment, but do not intend to lead to an offence under the section.
After independence, this Sedition came for the first time in light in the case of “Romesh Thapar v State of Madras,[10] the Apex Court held that unless the freedom of speech and expression threaten the ‘security of or tend to overthrow the State’, any law restricting the same would not fall within the purview of Article 19(2) of the Indian Constitution. Due to this case, two new restrictions namely, ‘friendly relations with Foreign State’ and ‘public order’ were added in Article 19(2) in the year 1951 by the 1st amendment. Hon’ble Court further held that freedom of speech and expression could be restricted on the grounds of threat to national security and for serious aggravated forms of public disorder that endanger national security and not relatively minor breaches of peace of a purely local significance. The sedition law was challenged in Kedar Nath Singh Case,[11] in this case, the constitutional bench upheld the validity of sec. 124A and ruled that the very existence of the State will be in jeopardy if the Government established by law is subverted and hence its continued existence is an essential requirement for the stability of the State. At the same time, Court also tried to strike a balance between the right to free speech and expression and the power of the legislature to restrict such right observing thus that “the security of the State, which depends upon the maintenance of law and order is the very basic consideration upon which legislation, to punish offences against the State, is undertaken. Such legislation has on another hand, fully protect and guarantee the freedom of expression, which is the sine qua non of a democratic form of the Government that our Constitution has established. A citizen has a right to say or write whatever he likes about the Government, or its measures, by way of criticism or comment, so long as he does not incite people to violence against the Government established by law or to create public disorder.” Public disorder has been considered to be a necessary ingredient of sec. 124A after this judgment and it also became necessary to establish that the accused has done something, which would threaten the existence of the Government established by law or might cause the disorder.
FREEDOM OF SPEECH AND SEDITION
Democracy means Government of the people, by the people and for the people, every citizen of our country is entitled to participate in the democratic process and to make in a visible, free and general discussion of the public matters is essential.[12] It is one of the most important characteristics of democracy. Article 19(1)(a) says that all Citizen shall have the right to freedom of speech and expression. However, this right is subject to limitations imposed under Article 19(2) which empowers the State to put ‘reasonable’ restrictions on certain grounds such as Security of the State, friendly relation with a foreign state, public order, decency or morality, contempt of court, defamation, incitement of an offence and Sovereignty and integrity of India. The citizens have certain duties to perform. Democracy can function in its best possible way only when the State and the citizens perform their duties, and think first on the national level, and then on an individual.
While using the right of Freedom of Speech and expression, one cannot deny the fact that the right tofreedom of speech and expression in isolation is not enough. It is necessary to understand the gravity and the limitation covered under the right to speech. one who is exercising his right should also aware of all the aspect and fundamentals of the issue in discussion.
Another aspect that is to keep in mind is the ‘reasonable restrictions’ on the freedom of speech and expression. The state has the power to impose certain restrictions on the right to free speech if it harm, and the intensity of harm is that it threatens the very existence of the society; it disturbs the public order and results in chaos in the society.[13]
Section 124A IPC must be read in consonance with Article 19(2) of the Constitution and the
reasonableness of the restriction must be scrutinized based onthe facts and circumstances of each case.[14]
Sedition Law can be justified on two arguments. On the first argument, words that advocate violence and disobedience are dangerous in themselves, irrespective of whether any actual violence occurs. In a more generalised sense, what we speak, we intend. Speech is a type of action, and that the expression of an opinion is the same as an intention to affect that opinion.[15] On the second argument, we can say that seditious word is likely to incite or provoke of violence or disobedience.
A speech suggesting generally that the Govt. established by law in India was thoroughly dishonest and unfair and that steps should be taken either by violence or by the threat of violence to abolish it, comes within the provisions of section 124-A.[16]
Authorship of seditious material alone is not the gist of the offence of sedition. Distribution, circulation of seditious material may also be sufficient.[17]
Punishment for Sedition
Punishment for Sedition is given under section 124-A, IPC. The prescribed punishment is imprisonment for life, to which fine may be added, or with imprisonment which may extend to three years, to which fine may be added, or with fine. Sedition is a cognizable offence that is why a person can be arrested without a warrant and he cannot be granted bail as a matter of right as this offence comes under non-billable offences.
Recent Cases
Kanahiya Kumar
Kanahiya Kumar, Leader from Jawahar NavodayVidlaya (JNU), participated in an event organised by JNU student to mark the anniversary of terrorist Afjal Guru who attacked the Indian Parliament. At this event, a slogan was raised and it was also spread throughout the country. The slogan was “ ‘Bharat TereTukdeHonge’ and Afzal hum sharmindahain, tere katil jindahain’”
In a controversial video, there was a slogan raising voice by saying “Allah-u-Akbar” and “Naara-e-Taqbeer”, a stunning revelation was made about how rallies organised by Kanhaiya Kumar can be used to instigate 5 lakh Muslims to create riots.
Hon’ble Delhi High Court in his judgment observed that while exercising the right to freedom of speech and expression under Article 19(1)(a) of the constitution, one has to remember part IV, Article 51[18] which provides fundamental duties of every citizen, which from the other side of the same coin.[19]
Umar Khalid, Sharjeel Imam under sedition for instigating anti-Hindu Delhi riots.
Delhi Govt. gave sanction to the police to charge radical Islamist Umar Khalid, Shaejeel Imam, Former AAP leader Tahir Hussain, and others under sedition for their involvement in the Anti-HINDU Delhi riots cases. In this Anti-Hindu riot, more than 50 people died. Delhi govt. not only charge them but also sanction to prosecute protestors such as Natasha Narwal, DevanganaKalita, Ishrat Jahan, and 15 others, they all are connected with the Anti-Hindu Delhi riot. It was also alleged by the Delhi Police that Umar Khalid has hatched the conspiracy of the anti-Hindu Delhi riot during the Trump (US President) visit to India. The chargesheet against Imam revealed that he wanted to transform the anti-CAA protest into a nationwide movement. Similarly, Sharjeel Imam is accused of being involved in the conspiracy that led to the break-out of riots in the national capital.
Sharjeel Imam who is a member of the Delhi riot wanted Muslims to bring cities to halt. He instigated “Chakka Jam” and occupy the chicken’s neck. He intended to cut short the Northeast from the rest of India. He was not only instigating the Muslim of North-east India but he was also trying to instigate the whole Muslim community from India against the government. He spoke:
“If 5 lakhs Muslims are organised then we can cut the northeast from rest of India. If we cannot do it permanently, at least we can cut Northeast from India for months. Our responsibility is to cut the Assam from India then Govt will hear our voice. If we have to help the Assam then we will have to cut the Assam from the rest of India.”
Shaheen Bagh incident
Shaejeel Imam was the mastermind of this incident. The target and the aim were to disrupt peace and civil liberties in the name of protest with the help of the Muslim community by instigating them with their words.
Farmers Bharat band
From lots of propaganda such as anti-CAA, “burn the country post-Ayodha verdict” and Delhi riot, now we are on farmers protest which is alleged to be hijacked, funded and supported by Khalistanis. The Chakka Jaam and the Bharat Bandh is the replica of Shaheen Bagh. The only shift is the name from anti-CAA to farm bill. The motive is the same, the conduct is the same and the propaganda is the same. The word like “Hum Dekhenge” and the slogan such as “Jinnah while Azadi” cannot be said to be legitimate in a manner in which they are spoken.
Amulya Leona Noronha
She is a left-wing activist and arrested on charges of sedition. She was raising the slogan “Pakistan Zindabad” in a rally of AIMIM Chief Asadudin Owaisi. Amulya Leone done this act, not for the first time but she uses to speak such words and slogan on regular basis. It may lead to disrupting the peace of society. She, by her speeches always tries to incite people to disturb law and order. She is ultra-anti-Hindu. In her speech at a student protest, she shows his hatred and disaffection towards religion by a placard that stated “F**K Hindutva”.Amulya, in an interview, said that she is a paid, speaker. The organisers of the protest prepared a speech for her and she gets money after delivering those speeches.
KanganaRanaut
A film actress has been charged many times under sedition law. The Mumbai police allege that KanganaRanaut continuously by his tweets spread hatred in the young mind of society. It was further alleged that the Tweet gives provocation to cause riots and promote the culture of non-violence.
Hardik Patel
Hardik Patel who is a leader of the Patel community was arrested and charged with sedition law as he was allegedly advising a man from the Patel community to kill a policeman rather than committing suicide. Hardik Patel says, “If you have so much courage…then go and kill a couple of policemen. Patel never commits suicide,” Hardik Patel allegedly told Vipul Desai, who had announced that he would commit suicide in support of the agitation.
Vinod Dua
He is a journalist. He is charged under the sedition law, BJP leader Ajay Shyam registered an FIR for making a false allegation against BJP, especially Prime Minister. He was spreading false news through his YouTube channel. A similar complaint was also registered against him in Delhi for spreading false news regarding the Delhi riot and creating a public nuisance.
Aseem Trivedi
He is a cartoonist and was arrested on the charge of sedition for displaying cartoons during the Anna Hazare protest. According to the complaint filed against him was a derogatory sketch depicting the national Emblem and parliament in a bad light. The said sketch was viral and it hurts the sentiments of the nation.
Some of the Cartoon which is made by Aseem Trivedi is given under Figure A, Figure B and Figure C.
Binayak Sen
He was convicted for the offence of sedition by the lower court. It was alleged that the Sen was associated with the members of the Maoist group and involve in activities creating disloyalty and inciting people to act against the state, resulting in the killings of members of armed forces and the robbery of arms and ammunition. The Hon’ble court said that the right to freedom of speech and expression under Article 19(1)(a) of the Indian Constitution must be exercised reasonably, and does not extend to creating public disorder or disturbance of law and order.
Arundhati Roy
She has been charged under section 124-A for her remark on a Kashmir. She said that “Kashmir has never been an integral part of India”. It is a historical fact. Even the Indian government has accepted this.”
Praveen Togadia
He was booked under the sedition charges which includes an attempt “to wage a war against the nation”
SimranjeetsinghMaan
He is Shiromani Akali Dal President, she was booked under sedition charges. This is for the 65th time when he was booked under sedition charges. He had been accused of calling freedom fighter “Bhagat Singh a terrorist”.
By all the above factors we can easily understand that this will create a myriad of other factors like shaming India internationally. Protest like anti-CAA and farmers protest is not about the “right to protest” or what are they demanding from the government, it is all about bringing the Nation to Halt. TO disturb the harmony of the country. By such act of some people, the Country will humiliate in front of the International Community with the help of sold-out media.
Whether the protestors of farmers protest of Shaheen Bagh, irrespective of were they old and frail, if anyone will disrupt the nation and wanted to disbalance the integrity of the nation, they must be thrown to jail.
It doesn’t matter which govt is in ruling or which govt was or which govt will rule, it all about the country and its integrity. It is not about whether someone agrees with the policies of the govt or not. it does not bring the nation to a halt or even attempting to do so. If certain activities are happening, he must be charged with the sedition law and treated as an act of war against the state.
Statistics
As we can see in figure 1, how the sedition cases are increasing every year. In 2015, the number of sedition cases was 30[20]. In 2016 it increases to 35[21], an increase in 5 cases in a year. In 2017, the number of cases is 51[22]. In 2018 we can see that it reaches 70[23] cases and in 2019 it is maximum, i.e., 93[24] cases. In just 4 years it increases by 63 cases. This show how people are showing disaffection towards the government. This also shows, how people of our country misusing their right to freedom of speech and expression. As it is rightly said, freedom of speech and expression is the most celebrated right in India and is also one of the most abused rights in India.
The Downfall of the conviction rate is very high(Fig.2). In 2019 it falls down to 3.33%. It shows that sedition law is not harmful in itself to anyone. If somebody is charged under section 124-A, it doesn’t mean that he will be convicted at the end. After due enquiry, it is to be decided by the court whether he is guilty of an offence under section 124-A or not. Therefore, there is nothing to be scared of with this sedition law as the rate of conviction is very low and those who were convicted under this section are the hard heated case of India.
This low conviction rate also shows that only if you speak something which is very serious and which will certainly harm the integrity and sovereignty of the nation, then only you will be convicted under sedition law. Until and unless your word is not so harmful or without as such intention. There is nothing to worry about.
In the above-given figure(Fig.3), we can see the name of State which highest number of cases year wise. In 2015, Bihar is at a peak with 9 cases related to sedition whereas West Bengal, Karnataka and Kerala is having 4 and 3 cases respectively[25]. In 2016, Haryana with 12 cases hold the highest position followed by Uttar Pradesh, Karnataka and Kerala at 2nd and 3rd place with 6 and 3 cases respectively[26]. In 2017, Assam with 19 cases is a top[27]. In 2018, Jharkhand with 18 cases holds the highest position[28] and In 2019 Karnataka with 22 cases holds the highest number of cases in 2019 as well as the highest number of cases in the last 5 year. In the same year, Assam with 17 cases and Jammu and Kashmir with 11 cases.[29] The above fig.3 shows only top 3 State each year.
This also shows that our most celebrated right, that is right to freedom of speech and expression is how abused by several State. Karnataka, Kerala, Haryana, Assam and Jammu & Kashmir is the State and Union Territories where freedom of speech and expression is abused for many years. This shows the need for sedition law in India and also its proper implementation. These states are very close to our neighbouring countries and if it is not stopped by any means it will lead to hampering the integrity of our Nation.
Conclusion
Freedom of speech and expression is a constitutional right that is given to a man by birth. Like the right to life is a birthright, similarly, freedom of speech and expression is also a birthright. At the early stage of childhood, we are being taught what to speak, how to speak, and when to speak even how much to speak in front of others or to others. This lesson to us is taught in our home and schools. The right to freedom of speech is given to everyone, but it is not absolute. It is something that is given to us but In a controlled manner. We must think before speak. We must be accountable for what we speak. We must take care of the reasonability of what we speak. It is because what you speak will have to listen by others, so it is to be checked first that the other person wanted to hear to words or not or even the other person can hear that or not. so it is not something which you want to speak it is something that others want to listen to. It is Like you eat for yourself but you wore clothes for others to look good. Words are also the same. You speak for others not for yourself.
We are now seeing on the many aspects of protest in India, the people of other countries taking an interest. In this case, when the anti-CAA was on high, the international media and the people from other countries were taking an interest. Now also we can see in farmers protest. People from the UK and Canada getting involved. This creates a bad image and impact in the international arena which will certainly harm the country’s integrity and the government too.
The kind of slogan and words used by Kanahiya Kumar, Umar Khalid, Sharjeel Imam, Natasha Narwal, DevanganaKalita, Ishrat Jahan, Arundhati Roy, Praveen Togadia, and AmulyaLoenais not guaranteed in the constitution. Freedom of Speech and expression must be interpreted in a manner in which it should not disturb the harmony of society and integrity of the Nation.
The State Should take strict action against those who misuse freedom of speech and Expression by way on doing seditious acttherefore, whatever is necessary to keep peace in society, State must take such action to maintain balance. Lord Krishna said to Arjuna on a battlefield:
“What they are doing is adharma; what we are doing is also adharma, but we are doing it with the intention of establishing dharma.They are doing it with the intention of establishing adharma.”
[1] UOI v. Naveen Jindal, (2004) SC 1559 (India).
[2] Dharam Dutt v. Union of India, AIR (2004) SC 1295 (India).
[3] International Covenant on Civil and Political Rights,(ICCPR) 1966 art.19 (2), Universal Declaration of Human Rights (UDHR), 1948 art.19.; International Convention on the Elimination of All Forms of Racial Discrimination (adopted 21 December 1965, entered into force 4 January 1969) UNGA Res 2106 (XX) Art 5(d)(viii); Convention for the Protection of Human Rights and Fundamental Freedoms (adopted 4 November 1950, entered into force 3 September 1953) Article 10; ACHPR (adopted 27 June 1971, entered into force 21 October 1986) OAU Doc. CAB/LEG/67/3 rev. 5, 21 I.L.M.58 (1982) Article 9; American Convention on Human Rights (adopted 22 November 1969, entered into force 18 July 1978) 08/27/79 no 17955 (ACHR) Article 13.
[4]Chintaman Rao v. State of Madhya Pradesh, AIR (1951) SC 118 (India); State of Madras v. VS Rao, AIR (1952) SC 196 (India).
[5] Radha Mohan Lal v. Rajasthan High Court, AIR (2003) SC 1467 (India).
[6] State of Madras v. VG Row, AIR (1952) SC 196 (India).
[7] Reg. v. Alexander Martin Sullivan, (1868) 11 Cox CC 44.
[8] C.A.D ., Volume VII, Chapter 48, p. 236.
[9] (1897) I.L.R. 22 Bom. 112.
[10](1950) AIR 124, (1950) SCR 594 (India).
[11] (1962) AIR 955, (1962) SCR Supl. (2) 769 (India).
[12] Whitney v. California, 247 US 214.
[13] Gompers v. Buck’s Stove & Range Co., (1911)221 U.S 418.
[14] Om Kumar v. Union of India, AIR (2000) 3689 (India).
[15] R v Sharkey (1949) 79 CLR 121.
[16]Paramanand v. Emperor, AIR (1941) All 156, (1941) All LJ 26, 42 Cr LJ 46 (India).
[17]Raghuvir Singh v. State of Bihar, AIR (1987) SC 149 (India).
[18]Indian constitution Article 51- Promotion of international peace and security.
[19] Kanhaiya Kumar v. State (NCT of Delhi), (2016) 227 DLT 612 (India).
[20] National Crime Report Bureau,2015, https://ncrb.gov.in/sites/default/files/Statistics/Statistics-2015_rev1_1.pdf(accessed on 10 May 2021).
[21] National Crime Report Bureau,2016, https://ncrb.gov.in/sites/default/files/Crime%20in%20India%202016%20-%20Full%20Publication.pdf(accessed on 10 May 2021).
[22] National Crime Report Bureau,2017https://ncrb.gov.in/sites/default/files/Crime%20in%20India%202017%20-%20Volume%201_0_0.pdf(accessed on 10 May 2021).
[23] National Crime Report Bureau,2018https://ncrb.gov.in/sites/default/files/Crime%20in%20India%202018%20-%20Volume%201.pdf(accessed on 10 May 2021).
[24] National Crime Report Bureau,2019https://ncrb.gov.in/sites/default/files/CII%202019%20Volume%201.pdf(accessed on 10 May 2021).
[25]National Crime Report Bureau, 2015, https://ncrb.gov.in/sites/default/files/Statistics/Statistics-2015_rev1_1.pdf(accessed on 10 May 2021).
[26]National Crime Report Bureau, 2016, https://ncrb.gov.in/sites/default/files/Crime%20in%20India%202016%20-%20Full%20Publication.pdf(accessed on 10 May 2021).
[27]National Crime Report Bureau, 2017 https://ncrb.gov.in/sites/default/files/Crime%20in%20India%202017%20-%20Volume%201_0_0.pdf(accessed on 10 May 2021).
[28] National Crime Report Bureau, 2018, https://ncrb.gov.in/sites/default/files/Crime%20in%20India%202018%20-%20Volume%201.pdf(accessed on 10 May 2021).
[29] National Crime Report Bureau, 2019 https://ncrb.gov.in/sites/default/files/CII%202019%20Volume%201.pdf(accessed on 10 May 2021).
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