ALIGARH MUSLIM UNIVERSITY, ALIGARH
SUBJECT - MOTOR VEHICLES ACT
Topic- MOTOR VEHICLE TRIBUNAL
PROJECT WORK
(Session 2020-25)
Semester 2
Submitted to: Dr. Sajid Hamid Submitted by- Jamal Ahamad
Guest Faculty, Department of Law Roll No.: 20BALLB104
Enr. No.: GM-4660
INDEX
CONTENTS PAGE NO.
INTRODUCTION 3
CHAPTER I 4
CHAPTER II 4
CHAPTER III 7
CONCLUSION 14
BIBLIOGRAPHY 15
Page |2
INTRODUCTION
This Paper is based on study of Motor Vehicle Tribunal. Courts are the sole
institutions for providing justice to the citizens of the country. Due to certain
limitations in providing proper justice has resulted in creating a huge backlog for
the judiciary, to tackle this problem, new institutions for providing justice are
being set up because of different types of claims. In today’s world we can see
existence of different types of claims e.g., matrimonial claims, personal claims,
health claims, equity claims, insurance claims etc. And between these claims we
have accidental claims which have increased in present time with the
development of civilization. A new forum, i.e. Motor Accidents Claims Tribunal,
which substitutes Civil Court, has been created by the Motor Vehicles Act, for
cheaper and speedier remedy to the victims of accident of motor vehicles. Prior to
the Motor Vehicles Act, a suit for damages had to be filed with civil court, on
payment equal to the court fee. But, under the provisions of this Act, an
application claiming compensation can be made to the Claims Tribunal without
payment of fee1 . New provisions in Motor Vehicles Act, do not create any new
liability, and the liability is still based on law of tort and enactments like the Fatal
Accidents Act.
The Motor Vehicles Act, consolidates and amends the law relating to motor
vehicles. This has been amended several times to keep it up to date. The need
was, however, felt that this Act should, also take into account changes in the road
transport technology, pattern of passenger and goods movements, developments,
of the road network in the country and particularly the improved techniques in the
motor vehicles management.2
1
[Link], Law of Torts including Compensation under the Motor Vehicles Act, 469 (23rd ed. 2011).
2
The Motor Vehicles Act,1988 (Nov 7, 2021, 9:05 pm) [Link]
Page |3
CHAPTER I
Establishment and Composition of Tribunal
Section 165 of Motor Vehicles Act, 1988 empowers the State Government
to constitute Claims Tribunal to adjudicate upon claims for compensation
arising out of motor vehicle accidents, resulting in death or bodily injury to
persons or damages to any property of third parties. A State Government may, by
notification in the Official Gazette, constitute one or more Motor Accidents
Claims Tribunal(hereafter in this Chapter referred to as Claims Tribunal) for
such area as may be specified in the notification for the purpose of adjudicating
upon claims for compensation in respect of accidents involving the death of,
or bodily injury to, persons arising out of the use of motor vehicles, or damages to
any property of a third party so arising, or both 3. For the removal of doubts, it is
hereby declared that the expression “claims for compensation in respect of
accidents involving the death of or bodily injury to persons arising out of
the use of motor vehicles” includes claims for compensation under section
140 and section 163- A4 .A Claims Tribunal shall consist of such number of
members as the State Government may think fit to appoint and where it
consists of two or more members, one of them shall be appointed as the
Chairman thereof. A person shall not be qualified for appointment as a
member of a Claims Tribunal unless he is or has been a Judge of a High
Court, or is or has been a District Judge or is qualified for appointment as
a High Court Judge or as a District Judge.5
CHAPTER II (HISTORY)
Pre-1988 Position before the Motor Vehicle Act, 1988 came in to existence
The Motor Vehicles Act, 1939 was applicable for all type of Motor Accidents.
The Motor Vehicles Act, 1939, consolidates and amends the law relating to motor
vehicles. This has been amended several times to keep it up to date. The need
was, however, felt that this Act should, now inter alia, take into account also
changes in the road transport, technology, pattern of passenger and freight
3
[Link]
4
Ibid.
5
Ibid.
Page |4
movements, developments, of the road network in the country and particularly the
improved techniques in the motor vehicles management.
Various Committees6 , like, National Transport Policy Committee, National
Police Commission, Road Safety Committee, Low Powered Two – Wheelers
Committee, as also the Law Commission have gone into different aspects of road
transport. They have recommended updating, simplification and rationalization of
this law. Several Members of Parliament have also urged for comprehensive
review of the Motor Vehicles Act, 1939, to make it relevant to the modern – day
requirements. A Working Group was, therefore, constituted in January, 1984 to
review all the provisions of the Motor Vehicles Act, 1939 and to submit draft
proposals for a comprehensive legislation to replace the existing Act. This
Working Group took into account the suggestions and recommendations earlier
made by various bodies and institutions like Central Institute of Road Transport
(CIRT), Automotive Research Association of India (ARAI), and other transport
organizations including, the manufacturers and the general public, Besides,
obtaining comments of State Governments on the recommendations of the
Working Statement of Group, these were discussed in a specially convened
meeting of Transport Ministers of all States and Union territories. Some of the
more important modifications so suggested related for taking care of –
a. The fast increasing number of both commercial vehicles and personal vehicles in
the country.
b. The need for encouraging adoption of higher technology in automotive sector.
c. The greater flow of passenger and freight with the least impediments so that
islands of isolation are not created leading to regional or local imbalances.
d. Concern for road safety standards, and pollution-control measures, standard
. for transportation of hazardous and explosive materials.
e. Simplification of procedure and policy liberalization’s for private sector
. Operations in the road transport field.
f. Need for effective ways of tracking down traffic offenders7.
6
The Motor Vehicle Act, 1988, Statement of Objects and Reasons
7
Ibid.
Page |5
The Motor Vehicles Act, 1988
The Supreme Court in M. K. Kunhi Mohammed v. P. A. Ahmedkutty8 , has made
certain suggestions to raise the limit of compensation payable as a result of motor
accidents in respect of death and permanent disablement in the event of there being no
proof of fault on the part of the person involved in the accident and also in hit and run
motor accidents and to remove certain disparities in the liability of the insurer to pay
compensation depending upon the class or type of vehicles involved in the accident.
The above suggestions made by the Supreme Court have been incorporated in the Bill
of the Motor Vehicles.
The proposed legislation has been prepared in the light of the above background. Some
of the more important provisions of the Bill provide for the following matters, namely:
a. Rationalization of certain definitions with additions of certain new definitions of
new types of vehicles.
b. Stricter procedures relating to grant of driving licences and the period of validity
thereof.
c. Laying down of standards for the components and parts of motor vehicles.
d. Standards for anti-pollution control devices.
e. Provision for issuing fitness certificates of vehicles also by the authorized testing
stations.
f. Enabling provision for updating the system of registration marks.
g. Liberalized schemes for grant of stage carriage permit on non nationalized routes,
all-India Tourist permits and also national permits for goods carriages.
h. Administration of the Solatium Scheme by the General Insurance Corporation.
i. Provision for enhanced compensation in cases of “no fault liability” and in hit and run
motor accidents.
j. Provision for payment of compensation by the insurer to the extent of actual liability
to the victims of motor accidents irrespective of the class of vehicles.
8
M. K. Kunhimohammed v. P. A. Ahmedkutty, (4 SCC 284,1987) read more :
[Link]
Page |6
k. Maintenance of State registers for driving licences and vehicle registration.
l. Constitution of Road Safety Councils9 .
The Bill also seeks to provide for more deterrent punishment in the cases of certain
offences. The above suggestions which were incorporated in the Motor Vehicles Bill
received the assent of the President on 14th October, 1988 and came on the Statute
Book as Motor Vehicles Act, 1988. The Act came into force with effect from 1st July,
1989 replacing the Motor Vehicles Act, 193910 . The previous Motor Vehicles Act,
1939 was repealed by section 217 of the Motor Vehicles Act, 1988. Said section 217
also repealed all laws corresponding to the Motor Vehicles Act, 1939, then being in
force in any State immediately before the commencement of the Act of 1988 in the
respective states11.
CHAPTER III
Jurisdiction of Claims Tribunal
Jurisdiction of tribunal depends essentially on the fact whether there had been any use
of motor vehicle and once it has been established, tribunal’s jurisdiction cannot be held
ousted on findings that it is negligence of other joint tortfeasor and not of the motor
vehicle in question. A victim of an accident arising out of use of motor vehicles may
file their claim application to the Claims Tribunal within local limits of whose
jurisdiction the claimant resides or carries on business.
I. Pecuniary Jurisdiction
The pecuniary jurisdiction of the Claims Tribunal has a double implication i.e.
compensation in case of death or bodily injury and in respect of damage caused
to any property. Section 165 of the Act empowers the tribunal to award
compensation not only for death and bodily injury but also for damage to
property. As regards the former, there are three different provisions in the Motor
Vehicles Act, 1988, namely:
1. Compensation in certain cases on the principle of no fault, as provided in section
. of the Act.
9
Supra n.6
10
Supra n.6
11
Supra n.6
Page |7
2. Compensation on structured formula basis, under section 163-A of the Act
3. Compensation which appears to the Claims Tribunal to be just, under section . .
. 168 of the Act.
In the category of claims under 1. Above, i.e. compensation on principle of no fault,
compensation can be awarded either in cases of death or in cases of permanent
disablement of any person, and in either case, the fixed and different amounts have
been fixed respectively for death and permanent disablement. The relevant provisions
are sub-sections (1) and (2) of section 14012.
II. Exclusion of Civil Court’s Jurisdiction not Readily Inferred
The civil courts under section 9 of the Civil Procedure Code, have general and
overall jurisdiction to try all suits of a civil nature and a suit wherein the right to
property or to an office is contested is a suit of a civil nature. The bar of
jurisdiction of the civil court cannot thus, readily inferred, and the Supreme
Court in a classic decision in Dhulabhai v. State of Madhya Pradesh13 has
covered out as many as seven exceptions to a statutory bar created on
jurisdiction of the civil court, seven exceptions are as under:
1. “Where the statute gives finality to the order of the special tribunal, the civil
court’s jurisdiction must be held to be excluded if there is adequate remedy to
do what the civil courts would normally do in a suit. Such provision, however,
does not exclude those cases where the provisions of the particular Act have
been complied with or the statutory tribunal has not acted in conformity with the
fundamental principles of judicial procedure.
2. Where there is an express bar of jurisdiction of the courts, an examination of
the scheme of the particular Act to find the adequacy or the sufficiency of the
remedies provided may be relevant but is not decisive to sustain the jurisdiction
of the civil court. Where there is no express exclusion, the examination of the
remedies and the scheme of the particular Act to find out the intendment
become necessary and the result of the inquiry may be decisive. In the latter
case, it is necessary to see if the statute creates a special right or a liability and
provides for the determination of the right or liability and further lays down that
all questions provides the said right and liability shall be determined by the
12
Dr. [Link], “Law of Motor Accident Claims and Compensation” (2010) p.537
13
Dhulabhai v. State of Madhya Pradesh, AIR 1969 SC 78 read more:
[Link]
0CPC/Dhulabai%20vs%20state%20of%20MP%[Link]
Page |8
tribunal so constituted, and whether remedies normally associated with actions
in civil courts are prescribed by the said statute or not.
3. Challenge to the provisions of the particular Act as ultra vires cannot be
brought before tribunal constituted under that Act. Even the High Court cannot
go into the question on a revision or reference from the decision of the tribunal.
4. When a provision is already declared unconstitutional or the constitutionality
of any provision is to be challenged, a suit is open. A writ of certiorari may
include a direction for refund if the claim is clearly within the time prescribed
by the Limitation Act but it is not a compulsory remedy to replace a suit.
5. Where the particular Act contains no machinery for refund of tax collected in
excess of constitutional limits or illegally collected, a suit lies.
6. Question of the correctness of the assessment apart from its constitutionality
are for the decision of the authorities and a civil suit does not lie if the orders of
the authorities are declared to be final or there is an express prohibition in the
particular Act. In either case the scheme of the particular Act must be examined
because it is a relevant inquiry. An exclusion of the jurisdiction of the Civil
Court is not to be readily inferred unless the conditions above set down apply”.
III. Jurisdiction in Respect of Cases Where Accidents Occurred Prior to
Establishment of Tribunal
The existence of a claims tribunal on the date of accident is not a condition
precedent for entertaining a claim for compensation. A claim for compensation
can be entertained by a Tribunal even in respect of an accident which occurred
at a time when there was no claims tribunal for that areaIn New India Assurance
Co. v. Rukiyabai14 a motor accident took place within the jurisdiction of the
civil court at Nasik. There was no claims tribunal on the date when the accident
had occurred or on the date when the suit for compensation was instituted in the
Nasik. After the institution of the suit, the claims tribunal came to be
established, but even then the tribunal set up at Nasik had no jurisdiction to
entertain claim for compensation in respect of accidents which occurred at a
place within the territorial jurisdiction of the Nasik court. It was, therefore, held
that the notification establishing a tribunal at Indore could not come in the way
of the civil court at Nasik to proceed with the claim instituted therein when no
tribunal for that area was then in existence .
IV. Bar on jurisdiction of Civil Courts
14
New India Assurance Co. v. Rukiyabai, (ACC 499, 1985) read more : [Link]
Page |9
Section 175 bars the jurisdiction of Civil Courts where any Claims Tribunal has
been constituted. Where any Claims Tribunal has been constituted for any area,
no Civil Court shall have jurisdiction to entertain any question relating to any
claim for compensation which may be adjudicated upon by the Claims tribunal
for that area, and no injunction in respect of any action taken or to be taken by
or before the Claims Tribunal in respect of the claim for compensation shall be
granted by the Civil Court15 .
In Vatticherukuru Village Panchayat v. Nori Venkataraman Deehsithulu43it
was held by the apex court that the procedure before the tribunal is simple and
not hidebound by intricate procedure of pleadings and trial, admissibility of the
evidence and proof of facts according to law. Therefore, there is abundant
flexibility in the discharge of the functions with greater expedition and in
expensiveness.
In Gurbax Singh v. Financial Commissioner16it was held by the Supreme Court
that despite the bar on civil courts jurisdiction under a statute, if the special
tribunal or authority acts ultra vires or illegally, the civil court has power by
virtue of section 9 of the [Link] interfere and set matters right. If the
provisions of the statute have not been complied with or the statutory tribunal
has not acted in conformity with the fundamental principles of judicial
procedure, the civil courts have jurisdiction to examine such cases.
V. Bar on Jurisdiction of Consumer Dispute Redressal Forum
In Chairman Thiruvallurar Transport Corporation v. Consumer Protection
Council17 the deceased was travelling in an omni bus which met with an
accident while trying to avert a bullock – cart. It appears that when the bus
driver was in process of overtaking the bullock cart, the bullock got panickly
whereupon the driver swerved the bus to left and ran in to branches of a tree on
the roadside resulting in damage to the vehicle, the window panes having been
smashed. As the vehicle suddenly swerved and the driver applied the brakes the
deceased who was sitting in the centre of the rear seat was thrown in the front
and hit against the iron side bar, sustaining a serious head injury. Subsequently
he succumbed to the injury.
15
The Motor Vehicles Act, 1988, Section 175
16
Gurbax Singh v. Financial Commissioner, (SC 435,1990)read more: [Link]
[Link]/Encyclopedia/Browse/Case?CaseId=000991745000
17
Chairman Thiruvallurar Transport Corporation v. Consumer Protection Council, (SC 1384,1995) read more :
[Link]
P a g e | 10
The Consumer Protection Council, Tamil Nadu on behalf of the legal
representative of the deceased, lodged a complaint before the National
Commission under the 1986 Act claiming compensation. The appellant
contested the claim contending that the claimant i.e. the Council, had no locus
standi to maintain the action and in any case the National Commission had no
jurisdiction to entertain a petition since exclusive jurisdiction was conferred by
the 1988 Act on the Claims Tribunal constituted thereunder. The National
Commission contended the appellant, side stepped the question regarding
jurisdiction and without answering the same awarded Rs. 5.10 Lacs by way of
compensation with interest at 18% per annum with costs of Rs. 10,000/-. An
appeal against the judgement was preferred to the Supreme Court. The question
that arose for consideration was whether the National Commission had
jurisdiction to entertain the claim application and award compensation in
respect of an accident involving death of the deceased caused by the use of
Motor Vehicle. The Supreme Court without going in to depth of awarding of
compensation by National Commission to the victim, only answer the question
of law as to whether National Commission can entertain such case held that
National Commission has no jurisdiction whatsoever and was entirely wrong in
exercising jurisdiction and awarding compensation. However, in the facts and
circumstances of this case, the judgment pronounced by National Commission
was reversed and appellant were not entitled to recover the compensation
money already paid to the victim under the order’s of National Commission.
122 Hence, claims for compensation arising out of use of motor vehicles cannot
be adjudicated by any of the Consumer Disputes Redressal Forums
contemplated and created under Consumer Protection Act, 1986. The complaint
in the case of motor accident cannot be said to be in relation to any service hired
or availed of by the consumer because the injury sustained by the consumer has
nothing to do with the service provided or availed of by him if the injury is the
direct result of the accident.
VI. Jurisdiction of Tribunal, Where Collision Between Trains And Motor
Vehicle Occurred
In Union of India v. Satish Kumar Patel18 where there is negligence only of the
driver of the motor vehicle or where there is negligence both of the driver of the
motor vehicle and of the railway, a claim is entertainable by the motor accidents
18
Union of India v. Satish Kumar Patel, AIR 2001 MP 41 read more :
[Link]
P a g e | 11
claims tribunal. In Amritlal [Link] of India19where the truck driver was
warned by inmates of truck about approaching railway engine and there was
consequent collision between truck and the engine on unmanned railway level
crossing and resultant death of some of the passengers in the truck and injuries
to other inmates of truck, award of compensation by the tribunal was held
justified and the railways was held not liable since it is no duty of railways to
man all level crossings.
VII. Jurisdiction of Tribunal in India, where Accident occurred in Foreign
Country
A suit or proceeding can be filed in a court or tribunal having jurisdiction in
relation with the place where the cause of action or part thereof had arisen and
where a bus was booked at Delhi, part of cause action had arisen in India and
the claimants can file a claim in the tribunal having jurisdiction over place or
residence of claimant under section 166(2) of the Act20 . In the above case, a bus
for pilgrimage from Delhi to Kathmandu was booked at Delhi and vehicle was
registered in India. The bus fell into a river in the territory of Nepal. It was held
that a claim under section 163A of the Act was maintainable in a tribunal within
the State of Punjab. It was further held that the Motor Vehicles Operations and
Contiguous Counties Rules, 1963 had no application, since the rules could
operate only if the claim was filed in Nepal. Eventually, the insurer was held
liable. In Savara Pydi Raju v. T. Venkata Rao21 , it was held that as per
amended provisions of section 166(2) victims are entitled to make their claims
in any court having jurisdiction over place where accident occurred or over
place where they are residing.
VIII. Jurisdiction to Entertain Claim by Indigent Person
The tribunal has trapping of civil court for the purpose of taking evidence on
oath and of enforcing attendance of witnesses and compelling the discovery and
production of documents and material objects and for such other purposes as
may be prescribed, as section 169(2) of the Motor vehicle Act, 1988 has stated.
There is no direct reference of Order 33 of Civil Procedure Code which deals
with suits by or on behalf of indigent persons. In State of Haryana v. Darshana
19
Amritlal [Link] of India, 2004 ACJ 1976 (Raj.). read more: [Link]
20
Sarbati v. Anil Kumar, 2006 ACJ 2532 read more: [Link]
21
Savara Pydi Raju v. T. Venkata Rao, 2007 ACJ 2245 (AP). read more: [Link]
Versus-Anil-Kumar-2006-01-04
P a g e | 12
Devi22 the Supreme Court of India observed that the poor shall not be forced out
of the justice market by instance on court fee and refusal to apply the exemptive
provisions of Order XXXIII, Civil Procedure Code. So we are distressed that
the State of Haryana, mindless of the mandate of equal justice to the indigent
under the magna carta of our Republic, expressed in article 14 and stressed in
article 39A of the Constitution, has sought of leave to appeal against the order
of the High Court which has rightly extended the pauper provisions to the auto
accident claims. The reasoning of the High Court in holding trail under Order
XXXIII will apply to tribunals which have the trappings of the civil court finds
our approval and hence upheld the decision of the High Court. In Gulab Singh
Meruji v. Jayantilal Shankarlal Brahmin23 where a prayer was made for filling
the appeal as indigent person. The appellant was permitted to file the claim
before the tribunal as indigent person, but the claim was dismissed. Permitting
the appeal to be filed as indigent person the court observed that in the legal aid
programmes, whatever amount is paid as legal assistance to the litigant….that is
not repayable by the litigant. In the case where a person comes up with a prayer
that he may be permitted to file appeal as an indigent person…by permitting
him to file appeal as indigent person, payment of court fee is only being
deferred. So this court, while dealing with such applications, should be more
liberal which will advance the cause of justice to poor persons.
IX. Death Occurred Due To Heart Attack :
No Jurisdiction In National Insurance Co. Ltd v. Chandra Prava Barman24where
the insurer argued that admittedly the father of the claimant died on account of
heart attack and not due to vehicular accident, and that Motor Accidents Claims
Tribunal can award compensation only in connection with the liability of the
insurer on the insured which arises out of vehicular accident and not for any
remote cause. Holding this statement as well merited the High Court held that
the claim for death of the father might or could have been taken up under Law
of Torts and not by Motor Accidents Claims Tribunal, which has got limited
jurisdiction to deal with claims arising out of accident. Such a claim which has
been allowed by the tribunal could only be within the competence of the civil
court and not within the competence of the Motor Accidents Claims Tribunal.
22
State of Haryana v. Darshana Devi, 1979 ACJ 205 (SC) read more:
[Link]
23
Gulab Singh Meruji v. Jayantilal Shankarlal Brahmin, 2001 ACJ 346 (Guj.) read more:
[Link]
24
National Insurance Co. Ltd v. Chandra Prava Barman, 2001(2) TAC 698 (Guj.) DB. Read more:
[Link]
P a g e | 13
X. Tribunal Cannot Entertain Application for Claim in Case of Hit and Run
Accident
A plain reading of Rule 20 of the Solatium Scheme, 1989, makes it clear that an
application seeking compensation under the Scheme in case of hit and run
accidents is to be filed in Form 1 before the Claims Enquiry Officer of the Sub-
Division in which the accident had taken place. Thus, under the scheme, a
particular forum has been provided for claiming compensation in case of hit and
run motor accidents. This being the position, claimants claiming compensation
in cases of death or grievous hurt arising under the hit and run motor accidents
cannot file application before the Claims Tribunal, and the Claims Tribunal
having no jurisdiction in the matter, the order of the Claims Tribunal rejecting
the objection taken by the insurer as regards the maintainability of the
application cannot be allowed to stand . In Oriental Insurance Co. Ltd. v.
Rooplal Singh25 case it was held by the Patna High Court that the Claims
Tribunal must return such application to be filed before the Claims Enquiry
Officer of the concerned Sub-Division in which the accident had taken place
and such matter has to be agitated before the collector.
CONCLUSION
State Government may, by notification in the Official Gazette, constitute one or
more Motor Accident Claims Tribunal (hereafter in this Chapter referred to as
Claims tribunal) for such area as may be specified in the notification for the purpose
of adjudicating upon claims for compensation in respect of accidents involving the
death of, or bodily injury to, persons arising out of the use of motor vehicles, or
damages to any property of a third party so arising, or both.
A Claims Tribunal shall consist of such number of members as the State
Government may think fit to appoint and where it consists of two or more members,
one of them shall be appointed as the Chairman thereof. A person shall not be
qualified for appointment as a member of a Claims Tribunal unless he is or has been
a Judge of a High Court, or is or has been a District Judge or is qualified for
appointment as a High Court Judge or as a District Judge.
One more importance about Motor Vehicle Tribunal besides that it has taken away
some amount of load from the courts (Civil as well as Criminal) , is that it has
25
Oriental Insurance Co. Ltd. v. Rooplal Singh, 2000 ACJ 502 (Pat.) read more :
[Link]
P a g e | 14
increased the speed of disposal of cases being in the limits of cases being heard
properly, one main reason for this is the proper functioning of the Tribunal , only
matter related to Motor Vehicle is being entertained here. This innovative idea of
opening specialised Tribunals is proving to be a boon for the Judiciary as it is
effectively continuing its job for which it was instituted.
BIBLIOGRPHY
ARTICLES
Motor Accident Claims – A Historical Perspective , Justice S. C. Mathur
(1995) [Link]
An Analysis of Law relating to Accident Claims in India
[Link]
BOOKS
[Link], Law of Torts including Compensation under the Motor Vehicles Act
(23rd ed. 2011).
Claims Tribunal under Motor Vehicles Act, 1988 ([Link]
[Link])
Ram Singh, The Relationship between liability regimes and economic
development, A Study of Motor Vehicle Accidents in India (2012)
P a g e | 15
