Generally, a Central Law becomes operative on the day the President signs it. In a similar vein, a State Law takes effect the day the Governor signs it. The commencement of a statute designates the day the law officially goes into force, while the operation of a statute is the process by which a law is put into action. Statutes can operate in two ways: prospectively, to regulate events and activities that are occurring right now, or retrospectively, to regulate previous deeds and events that may affect an obligation or right that already exists.

"Retrospective operation of law" refers to the application of a legal provision to events or situations that occurred before the relevant statute was enacted. The legal ramifications of acts taken prior to the passage of these laws are modified or changed. A retroactive law creates or imposes a new liability for an act done before the law's introduction, which eliminates or diminishes an existing entitlement. Nevertheless, the law does not apply retroactively to punitive provisions. The broad norm of prospective operation of law, which governs future activities without changing the nature of past transactions carried out in reliance on the then-applicable law, is broken by retrospective laws.

The Indian Constitution forbids the retrospective implementation of an Act or a law, unless the statute expressly states that it is retrospective in character. If a law is implemented retroactively and isn't mentioned by the Act explicitly, it will be considered unlawful or unconstitutional. The Indian constitution's Article 20 (1) shields citizens against ex post facto law, sometimes referred to as retrospective operation of the law, which modifies the legal ramifications of decisions made before the law's passage. The question that arises during the application of retrospectivity is whether a statute or law that creates a new responsibility or eliminates or degrades an existing entitlement should be given a retrospective impact.

Research Questions:

1. Constitutional Constraints on Retrospective Legislation in India:
   Investigate the boundaries set by the Indian Constitution regarding retrospective laws, particularly focusing on Articles 20(1) and 21.
    
2. Impact on Legal Certainty:
   Assess how retrospective statutes impact legal certainty and the rule of law in India, considering the implications for businesses and individual rights.
    
3. Judicial Responses to Retrospective Application:
   Examine key judgments by the Supreme Court of India dealing with retrospective laws, such as in the cases of taxation, criminal law, and administrative decisions.
    
4. Comparative Study of Retrospective Laws in India vs. Other Democracies:
   Contrast how retrospective legislation is handled in India with practices in other democratic countries, identifying lessons and best practices.

Objective of the Study:
Analyze constitutional restrictions on retrospective legislation in India and their implications for fundamental rights. Statement of Research Problem:
The retrospective application of statutes in India presents complex legal and ethical issues, particularly concerning fundamental rights and legal predictability. This research seeks to address the gap in understanding the constitutional constraints, judicial responses, and the broader implications of such laws on individuals and businesses. By examining the practical outcomes and judicial interpretations, the study aims to evaluate the fairness and impact of retrospective legislation, contributing to informed debates and guiding potential legislative reforms in India. Hypothesis:

1. The retrospective application of statutes in India adversely affects legal certainty and undermines public confidence in the legal system.
2. Judicial scrutiny moderates the impact of retrospective laws, ensuring they align with constitutional provisions and fundamental rights.

Research Methodology:
A mixed research approach is applied to study the subject at hand and develop a deeper and more thorough understanding of this topic. This study combines descriptive and analytical research. Scope and Limitation of the Study:
The scope of this study on the "Retrospective Application of Statutes" focuses on analyzing constitutional provisions, judicial interpretations, and their practical implications in India, alongside a comparative international perspective. The research aims to explore the impact on legal certainty and individual and business rights. However, the study faces limitations such as the availability of comprehensive legal judgments, regional variability in legal applications, and potential biases in judicial interpretation. Additionally, the evolving nature of legal frameworks may affect the study's long-term relevance and findings. Chapterisation:
The research paper is organized into nine chapters. Chapter I, labelled Introduction, offers a summary of the issue and the complete study technique, hypothesis, research question, and so on. Chapter II discusses the meaning and definition of retrospectives. Chapter III discussed the Constitutional Framework. Chapter IV discussed the General Application of Retrospective Operation of Statutes. Chapter V discussed the Principles Derived from Judicial Interpretations. Chapter VI discussed the Examples of retrospective Laws in India. Chapter VII discussed the Landmark Case Laws. Chapter VIII discusses the Applicability of the retrospective operation of statutes in different Democracies. Chapter IX gives the Conclusion and Suggestions.

Meaning And Definition Of The Word "Retrospective"

As stated in the introductory part, the law applies in two ways: retrospective and prospective. The literal meaning of the word "retrospective" is "directed to the past; contemplative of past situations, events, etc. looking or directed backward, retroactive, as a statute." [1] Retrospective Laws are laws passed today, that change what was legal or illegal yesterday. In other words, they are made ex post facto � after the fact � to change what people's rights and responsibilities were in the past.[2]

The literal meaning of the word "retrospective legislation" is "Legislation that operates on matters taking place before its enactment, e.g. by penalizing conduct that was lawful when it occurred."[3] The meaning of retrospective law was elaborated in the case of State Bank's Staff Union (Madras Circle) v. Union of India.[4]

While referring to enactment, it was noted that the word "retrospective" could refer to several different things, including altering an existing contract, reopening a previously closed transaction, altering accrued rights and remedies, or altering a procedure. A retrospective law takes away or otherwise affects vested rights that have been acquired under existing laws, or it creates new obligations, imposes new duties, or attaches new disabilities to past transactions or considerations.[5]

In Zile Singh v. State of Haryana,[6] it was observed that it is a fundamental rule of construction that every statute is prima facie prospective unless it is made to have retrospective application expressly or by necessary implication. However, the general rule is applicable whenever the main objective of a statute is to affect vested rights, impose new burdens, or undermine existing obligations. Unless the statute expressly states that the legislature intended for it to affect pre-existing rights, it is assumed to be prospective only.

So, the word "retrospective" has considerable importance in legal language, that is why it was discussed by higher in many cases.

Constitutional Framework

Article 20 (1) "No person shall be convicted of any offense except for violation of a law in force at the time of the commission of the Act charged as an offense, nor be subjected to a penalty greater than that which might have been inflicted under the law in force at the time of the commission of the offense."[7]

While retrospective legislation operates retroactively, a prospective law establishes rights and duties for the parties ensuing in the future. It is referred to as ex post facto law in the constitution. Generally speaking, unless the laws specifically state otherwise, any new legislation or amendment is always regarded as prospective. The Indian constitution's Article 20(1) restricts the creation of retroactive criminal laws.

According to the article, a person cannot be tried or found guilty twice for the same crime; rather, a person can only be found guilty if they have broken an existing law. A new statute that criminalizes certain behaviors does not mean that an act done by someone in the past is an offense. Additionally, the clause prohibits an accused party accused of any offense from subsequently facing a harsher punishment. Nonetheless, the appropriate inference in the legal system is the beneficial construction of a statute. The following law will be applied retroactively for the benefit of individuals if the goal of the retrospective law is to lessen the studious penalty for an infraction. Nonetheless, our legal system permits and recognizes retroactive legislation that creates civil liability for actions taken in the past.[8]

General Application of Retrospective Application of Statutes

Substantive laws: Retrospective laws are typically used in a nation to change the severity of a given crime's punishment. They might be sentenced to a shorter term by being put into a more serious category or having the crime's punishment reduced. However, how different laws are treated about retroactive laws also differs. Only laws that impact people's substantive rights are eligible for a retrospective operation, which allows them to be applied to previous occurrences. For instance, an act considered punished two years ago by the court is no longer considered a crime with retroactive effect. The individual would be released and it would apply to him.[9]

Procedural laws: The aforementioned, however, does not apply to procedural legislation. Generally speaking, procedural laws function in prospective rather than retrospectively. The Act substantially diminishes certain vested rights while introducing a new duty or transaction due to its retroactive implementation. Therefore, only substantive laws are subject to the retrospective operation of laws; procedural laws are not.

Principles Derived from Judicial Interpretations

Retrospective application of statutes, a concept deeply rooted in legal systems worldwide, holds significant implications for justice, fairness, and legal certainty. In India, the principles governing retrospective application have been subject to extensive judicial scrutiny and legislative deliberation.

1. Presumption against Retroactivity:
   In Indian jurisprudence, there exists a strong presumption against retroactive application of statutes. This presumption is rooted in principles of fairness, legal certainty, and the protection of vested rights. Courts have consistently upheld this presumption, emphasizing the need for clear legislative intent to justify retroactive application.^[10]
   
   In State of Punjab v. Amar Nath Chawla (1980), the Supreme Court of India reiterated the principle that statutes should be prospective unless there is clear and express language indicating retrospective application. The court held that retroactive legislation should be the exception rather than the rule, and any ambiguity in legislative intent should be resolved in favor of prospective operation.
    
2. Exceptions to the Presumption:
   While the presumption against retroactivity is strong, Indian courts recognize certain exceptions where statutes may be applied retrospectively. These exceptions are typically based on legislative intent, necessity, or considerations of justice.
   
   In Union of India v. V.K. Sharma (1990),[11] the Supreme Court considered the retrospective application of a statute aimed at providing relief to victims of wrongful detention. Despite the absence of explicit retroactive language in the statute, the court held that the legislative intent to provide relief to the aggrieved parties justified its retrospective application.
    
3. Legislative Intent and Equitable Consideration:
   Determining the retroactive effect of statutes often involves an examination of legislative intent and equitable considerations. Indian courts interpret statutes in light of their purpose, context, and effect on rights and obligations. Equitable considerations, such as fairness and justice, play a crucial role in assessing the retroactive application of laws.
   
   In Commissioner of Income Tax v. Vatika Township Pvt. Ltd. (2015),[12] the Supreme Court analyzed the retrospective amendment of tax laws affecting real estate transactions. The court emphasized that while legislative intent was crucial, equitable considerations, such as protecting legitimate expectations and avoiding undue hardship, must also be taken into account when applying statutes retroactively.
    
4. Constitutional Constraint:
   The retrospective application of statutes in India is subject to constitutional constraints, particularly regarding fundamental rights and principles of justice. Any retroactive law that impairs vested rights or violates constitutional guarantees may be struck down by the courts as unconstitutional.
   
   In Indira Nehru Gandhi v. Raj Narain (1975),[13] the Supreme Court examined the constitutional validity of retrospective amendments to election laws. The court emphasized that retroactive legislation must not infringe upon the fundamental rights enshrined in the Constitution, including the right to equality and the right to a fair trial.
    
5. Clarity of Constitutional constraints:
   In determining the retroactive effect of statutes, Indian courts closely scrutinize the clarity of legislative intent. Unambiguous language indicating retrospective application is crucial to overcome the presumption against retroactivity.
   
   P. Kasilingam v. PSG College of Technology (1980) [14] The Supreme Court held that where the language of a statute is explicit and unequivocal in expressing retroactive intent, courts must give effect to such intent, even if it results in retrospective application. However, in the absence of clear legislative language, the presumption against retroactivity prevails.
    
6. Impact on Substantive Rights:
   The retroactive application of statutes may significantly impact substantive rights, including contractual rights, property rights, and civil liberties. Indian courts assess the retroactive effect of statutes by considering their impact on vested rights and legitimate expectations.
   
   K.S. Paripoornan v. State of Kerala (2007)[15] - The Kerala High Court examined the retrospective application of a statute affecting property rights. The court emphasized that retroactive laws must not unfairly deprive individuals of their vested rights or disturb settled legal expectations, particularly in matters involving property.
    
7. Avoidance of Arbitrary and Discriminatory Application:
   Retroactive statutes should be applied consistently and without arbitrariness or discrimination. Indian courts ensure that retroactive laws do not unfairly target specific individuals or groups, but instead serve legitimate public purposes.
   
   Manohar Lal Sharma v. Principal Secretary (2014)[16] - The Delhi High Court reviewed the retrospective application of a law imposing restrictions on the sale of fireworks. The court emphasized the importance of ensuring that retroactive measures serve a valid public interest and are not arbitrarily applied to disadvantage-specific stakeholders.
    
8. Balancing Retroactive Justice with Legal Certainty:
   While retroactive laws may serve the interests of justice in certain cases, Indian courts strive to balance retroactive justice with the need for legal certainty and stability in the legal system. Courts consider the potential disruptive effects of retroactive application on settled legal expectations and commercial transactions.
   
   Raval & Co. v. K.G. Ramachandran (1974)[17]:
   The Supreme Court emphasized that while courts may uphold retroactive laws in the interest of justice, they must also consider the need for legal certainty and predictability in commercial transactions. Retroactive measures should not unduly disrupt established contractual rights or business practices.

Examples of retrospective Laws in India
In India, there are several instances of retroactive statutes. Several more laws have been introduced in India, even though the majority of these laws deal with taxes.

The Karnataka Scheduled Caste and Scheduled Tribe (Prohibition of Transfer of Certain Lands) Act, 1978,[18] this act had a retroactive character. The purpose of this Act was to make it illegal for members of the Scheduled Castes and Scheduled Tribes to receive land grants from the government. Before the legislation's adoption, this regulation also applied to land owned by Scheduled Tribes and Scheduled Castes. Not even the members of the SC and ST groups were permitted to buy the property they owned.

The Tamil Nadu Land Acquisition (Revival of Operation, Amendment, and Validation) Act, 2019,[19] the constitutionality of this act was recently affirmed by the Supreme Court and would be implemented retroactively until 2013. The Supreme Court rationalized its ruling by stating that safeguarding the general public interest is the legislature's fundamental duty. The legislature is in charge of defending citizens' rights and making sure there is a democratic political system in place. Therefore, any action taken to accomplish this goal is regarded as constitutional, and the petitioner's argument that it did not adhere to the separation of powers principle is wholly unfounded. Any legislation that does not explicitly forbid something can be applied retroactively for the benefit of the public without experiencing any repercussions.

Landmark Case Laws:
In many cases, the Courts of law dealt with the matter regarding the retrospective application of statutes, not only in India but outside of India too.

Calder v. Bull (1798)[20]:
In this landmark case, the Supreme Court of the United States grappled with the question of whether the Connecticut legislature's decision to revive an already adjudicated claim violated the ex post facto clause of the U.S. Constitution. The Court held that retroactive laws could not be applied to impair vested rights or disturb final judgments. This case laid the foundation for the principle that retroactive laws should not infringe upon fundamental rights or upset settled expectations.

Landgraf v. USI Film Products (1994)[21]:
The U.S. Supreme Court in this case outlined a two-step test for determining whether a statute should apply retrospectively. First, courts must ascertain whether Congress expressly stated the statute's temporal reach. Second, absent clear congressional intent, courts must consider whether the retroactive application would have a substantive impact on rights, liabilities, or duties. This case underscores the importance of legislative intent and the need to balance fairness and predictability in applying laws retroactively.

Golaknath v. State of Punjab (1967)[22]:
In this landmark case, the Supreme Court of India ruled on the Parliament's power to amend fundamental rights guaranteed by the Constitution retroactively. The Court held that fundamental rights could not be abridged or taken away by constitutional amendments, whether prospective or retrospective. This case led to the 24th Amendment Act of 1971, which explicitly granted Parliament the power to amend any part of the Constitution, including fundamental rights, without any limitations regarding retroactive effect.

Keshavananda Bharati v. State of Kerala (1973)[23]:
While not directly addressing the retrospective application of statutes, this case is significant for establishing the doctrine of the basic structure of the Constitution. The Supreme Court held that Parliament's power to amend the Constitution was not unlimited and could not alter its basic structure. This decision indirectly influenced future cases involving retrospective application of statutes by affirming the supremacy of the Constitution and its core principles.

Baijnath Kedia v. CIT (1971)[24]:
In this case, the Supreme Court laid down the principle that a statute could be applied retrospectively if it merely clarifies the existing law without altering its substance. The Court held that if a statute is declaratory of the previous law, it can have retrospective operation, but if it changes the previous law, it will operate prospectively unless there is a clear intention to give it retrospective effect.

G.V. Venkataswami Naidu & Co. v. CIT (1959)[25]:
This case established the principle that a statute cannot be given retrospective operation to impose a new liability or take away an existing one unless such intention is clearly expressed or necessarily implied. The Court emphasized the importance of legislative intent in determining the retrospective application of statutes.

R.C. Jall v. Union of India (1994)[26]:
In this case, the Supreme Court held that retrospective amendments to tax laws must be interpreted strictly. The Court stated that when a statute is unambiguous, there is no room for interpretation, and the intention of the legislature must be gathered from the language of the statute. This case underscores the principle that retrospective taxation should be subject to strict scrutiny to avoid arbitrariness.

M.P. Varghese v. ITO (1981)[27]:
Here, the Supreme Court clarified that a statute cannot be construed retrospectively if it takes away or abridges vested rights acquired under existing laws. The Court emphasized that the legislature cannot be presumed to have intended to take away vested rights except by express enactment or necessary implication.

M.P. Sugar Mills v. State of U.P. (1980)[28]:
This case dealt with the retrospective application of a sales tax amendment. The Supreme Court held that retrospective operation of a statute is not favored, especially when it affects substantive rights. The Court stated that unless there is express provision or necessary intendment, a statute should not be given retrospective effect to the prejudice of a substantive right.

These cases guide the principles governing the retrospective application of statutes in India, emphasizing the importance of legislative intent, clarity of language, and protection of vested rights. They underscore the need for caution and scrutiny when considering retrospective legislation to ensure fairness and legal certainty.

Applicability of retrospective operation of statutes in different Democracies

1. United Kingdom (UK): In English law, there is an assumption that statutes do not have a retroactive effect unless expressly specified. However, there is no reason to prevent the implementation of legislation if it has a clear intention to be applied retroactively. The Wireless Telegraph (Validation of Charges) Act of 1954 serves as an illustration of this, as it established the legal framework for the wireless licensing payments that have been collected throughout the past fifty years. The Supreme Court made it quite evident in the Walker v. Innospec Ltd. and Ors., 2017 ruling that any statute will be prospective in nature unless the express purpose of the Court is otherwise indicated.
    
2. Australia: In Australia, rules that relate to previous events can be made retroactively by both state and federal governments. But in Australia, this has consistently been challenged for being against the law. This is the case because everyone must be aware of the law for them to be able to abide by it, according to the Australian concept of the rule of law. The first challenge to the retrospective operation was made in the case of R v Kidman (1915). Nonetheless, the High Court held in this case that while the Constitution restricts the authority of the Australian Parliament, neither the State Legislatures nor the Parliament are restricted in their ability to enact retroactive laws.
    
3. France: Article 2 of the Napoleonic Code, often known as the Code Civil, outlawed the creation of ex post facto laws in France. The fundamental argument made in this article is that legislation shouldn't be retrospective; rather, it should only consider the future. One of France's highest authorities, the Constitutional Council, eventually decided that retroactive laws can be implemented as long as they didn't go beyond a certain point. Like in India, the council usually also introduces retroactive tax regulations. The penalties outlined in ex-post facto laws are still forbidden in criminal law, except in situations in which the offender stands to gain from the legislation.
    
4. United States of America (USA): It is forbidden for Congress in the United States to enact any legislation after the fact. This is one of the relatively few limitations placed on the federal and state governments by the United States of America Constitution. The Court considered the four types of invalid ex-post facto statutes in the Calder v. Bull (1798) ruling, which it used while making its decisions about ex-post facto cases. That being said, the prohibition against ex post facto laws has not always held true. The Adam Walsh Child Protection and Safety Act, which was introduced in 2006, established new registration requirements for sex offenders who had been found guilty of such crimes as well as those who had committed them in the past.

Conclusion and Suggestions
This research paper on the "Retrospective Application of Statutes" in India concludes that while retrospective laws can sometimes be necessary for justice or administrative convenience, they often pose significant challenges to the principles of legal certainty and predictability. The analysis reveals that such statutes can undermine public trust in the legal system and adversely affect individual and business planning. Judicial review has proven to be a crucial mechanism in safeguarding constitutional guarantees against arbitrary retrospective legislation. However, inconsistencies in judicial decisions and the broad discretionary powers sometimes exercised by the legislature highlight the need for more stringent safeguards.

• Clear Legislative Guidelines: The Indian legislature should establish clearer guidelines for when and how retrospective laws can be enacted, possibly including a requirement for a supermajority in Parliament for their passage to ensure broader consensus.
• Enhanced Judicial Scrutiny: The judiciary should maintain rigorous scrutiny of retrospective laws to ensure they meet strict criteria of public interest and necessity while adhering closely to constitutional principles.
• Public Consultation: Before passing any retrospective legislation, a mandatory public consultation process should be implemented to gather input from potentially affected parties and to enhance transparency.
• Legal Certainty Principle: Introduce a principle of legal certainty in the legislative process, wherein laws that significantly alter previous understandings or agreements are avoided unless necessary.
• Periodic Review Mechanism: Establish a mechanism for the periodic review of the impact of retrospective laws, allowing for adjustments or repeals based on real-world impacts and feedback.

By implementing these suggestions, the Indian legal system could better balance the need for legislative flexibility with the principles of fairness, certainty, and trust in the rule of law.

Bibliography:
Books:

• Basu, D. D. (2015). Commentary on the Constitution of India. 8th ed. LexisNexis.
• Bhatia, G. (2019). The Transformative Constitution: A Radical Biography in Nine Acts. Harper Collins India.
• Jain, M. P. (2017). Indian Constitutional Law. 7th ed. LexisNexis.
• Khosla, M. (2018). The Indian Constitution. Oxford University Press.
• Singh, M. P., & Chandra, S. (2021). Indian Constitutional Law: Text, Cases and Materials. 3rd ed. Eastern Book Company.
• Verma, S. K., & Afzal Wani, M. (Eds.). (2016). Law and Morality. Universal Law Publishing
• Sathe, S. P. (2003). Judicial Activism in India: Transgressing Borders and Enforcing Limits. Oxford University Press India.

Journal Articles:

• Sarkar, P., & Kumar, R. (2020). Retrospective Amendments and the Rule of Law: An Analysis of Indian Tax Laws. Journal of the Indian Law Institute, 62(2), 134-158.
• Tripathi, S. C. (2021). Retrospective Legislation in India: A Critical Study. "Legal Studies Research Paper."

Online Resources:

1. Live Law: https://www.livelaw.in/top-stories/supreme-court-retrospective-rule-construed-unless-clear-manifest-intention-181050
2. SCC Online: https://www.scconline.com/blog/post/2022/09/02/retrospective-retroactive-quasi-retroactive-explained-ibc-statute-interpretation-legal-news-legal-updates-supreme-court-legal-research/
3. Indian Kanoon: https://indiankanoon.org/search/

End-Notes:

1. Retrospective, available at: https://www.dictionary.com/browse/retrospective (last visited on April 20, 2024).
2. Retrospective Laws, available at: https://www.ruleoflaw.org.au/principles/retrospective-laws (last visited on April 20, 2024).
3. Retrospective Legislation, available at: https://www.oxfordreference.com/display/10.1093/oi/authority.20110803100417142 (last visited on April 21, 2024).
4. AIR 2005 SC 3446.
5. Principles Relating To Retrospective Operation Of Statutes, available at: https://www.brillopedia.net/post/principles-relating-to-retrospective-operation-of-statutes (last visited on April 22, 2024).
6. AIR 2004 SC 5100.
7. The Constitution of India, art. 20(1).
8. Applicability Of Retrospective Laws In India, available at: https://www.brainboosterarticles.com/post/applicability-of-retrospective-laws-in-india (last visited on April 23, 2024).
9. Retrospective operation of statutes, available at: https://blog.ipleaders.in/retrospective-operation-of-statutes/#General_application_of_retrospective_operation_of_statutes (last visited on April 24, 2024).
10. Principles Relating To Retrospective Operation Of Statutes, available at: https://www.brillopedia.net/post/principles-relating-to-retrospective-operation-of-statutes (last visited on May 1, 2024).
11. AIR 1990 SC 32.
12. AIR 2015 SC 1.
13. AIR 1975 SC 2299.
14. 1995 AIR SC 1395.
15. AIR 1995 SC 1012.
16. AIR 2014 SC 514.
17. AIR 1974 SC 818.
18. The Karnataka Scheduled Castes And Scheduled Tribes (Prohibition Of Transfer Of Certain Lands) ACT, 1978, available at: https://www.indiacode.nic.in/bitstream/123456789/7812/1/2_of_1979_%28e%29.pdf (last visited on April 24, 2024).
19. Tamil Nadu Government Gazette Extraordinary, available at: http://www.stationeryprinting.tn.gov.in/extraordinary/2019/451_Ex_IV_2.pdf (last visited on April 25, 2024).
20. Calder v. Bull, 3 U.S. (3 Dall.) 386 (1798).
21. United States v. Detroit Lumber Co., 200 U.S. 321, 337.
22. AIR 1967 SC 1643.
23. AIR 1973 SC 1461.
24. AIR 1970 SC 1436.
25. AIR 1959 SC 359.
26. AIR 1962 SC 1281.
27. AIR 1981 SC 1922.
28. AIR 1979 SC 621.

Written By:

• Abubakar Shamsi (B.A. LL.B (Hons.), 5th Semester - Jamia Millia Islamia, New Delhi, 110025
• Rushed Ali (B.A. LL.B (HONS.), 5th Semester - Jamia Millia Islamia, New Delhi, 110025