Judicial Activism or Judicial Tyranny

The topic, “Judicial activism or judicial tyranny” is selected by me when Mr. M.V. J. K. Kumar has asked me for an article. The term “judicial tyranny” one may think tends to convey frustration and disappointment against the process of Judicial Activism. Various High Courts and Supreme Court have been disturbed by the recent trend of abusing the process of law by unscrupulous persons frequently under the garb of Public Interest Litigation (PIL) or Social Interest Litigation (SIL) to sub-serve their own interest, not public interest or social interest. Generally speaking, no person has a right to waiver of the locus standi rule and Court should permit only when it is satisfied that the carriage of proceedings is in the competent hands of a person, who is genuinely concerned in public interests and is not moved by other extraneous considerations, so also the Court must be careful to ensure that the process of the Court is not sought to be abused. This is the solemn duty of the Court to protect the society from the so called protectors of the society and, thus, while entertaining PIL, the Court should be conscious and try to ascertain the bona fides of the petitioner and further find out whether he is really a public spirited person or he has approached the Court to settle his ulterior score through the legal process. It is settled law that when a person approaches the Court of equity in exercise of its extraordinary jurisdiction under Article 226 of the Constitution of India, he should approach the Court not only with clean hands but with clean mind, clean heart and with clean objectives. The Courts must do justice by promotion of good faith and prevent the law from crafty evasions. Courts must maintain the social balance by interfering where necessary for the sake of justice and refuse to interfere where it is against the social interest and public good. No litigant has a right to unlimited drought on the Court time and public money in order to get his affairs settled in the manner as he wishes. Easy access to justice should not be misused as a licence to file misconceived and frivolous petitions.

Secondly, it is possible for one to think that “judicial activism” has become “judicial tyranny” when he sees that the Court in its new activist role has transgressed its legitimate role assigned to it under the Constitution. If one looks into the Constituent Assembly debates it can be discerned that although the Assembly on the one side wanted the Supreme Court to have a wide jurisdiction in dealing with issues regarding fundamental rights, on the other side it was skeptical about giving to it such jurisdiction to deal with social and economic policies.

Jawaharlal Nehru, Prime Minister, who was present at the inauguration of the Supreme Court of India on 28th January, 1950, had cautioned thus:

“No Supreme Court and no judiciary can stand in judgment over the sovereign will of Parliament representing the will of the entire community. If we go wrong here and there it can point out, but in the ultimate analysis, where the future of the community is concerned, no judiciary can come in the way. And if it comes in the way, ultimately the whole Constitution is a creature of Parliament. But it is obvious that no Court no system of judiciary can function in the nature of Third House, as a kind of Third House of correction. So it is important that with this limitation the judiciary should function.”

Alladi Krishnaswami Ayyar and T.T. Krishnamachari had said that the provisions of the Constitution do not make the judiciary an imperirum in imperio.

Dr. Ambedkar had said:

“I do not see how five or six gentlemen sitting in the Federal of Supreme Court examining laws made by the Legislature and by the dint of their own individual conscience or their bias or their prejudice be trusted to determine which law is good and which law is bad.”

Similarly, Alladi Krishnaswami Ayyar, another prominent member of the Constituent Assembly had said:

“Our Constitution instead of leaving it to the Courts to read necessary limitations and exceptions seeks to express in a compendious form the limitations and exceptions recognized in any welt ordered state. It cannot be denied that there is a danger leaving the courts by judicial legislation so to speak to read necessary limitations according to idiosyncrasies and prejudices it may be of individual judges.”

The Indian Supreme Court according to the framers was not meant to be a participant in policy making for the governance of the country. It was not intended that this institution would ever be in the centre of the national activity, or concerned with functions of government. Therefore, the activist role of the judiciary in enacting legislation by issuing directions to regulate inter-country adoption or by laying down guidelines as to how sexual harassment of working could be combated, are cited by opponents of judicial activism as examples of outright legislation as is enacted by the Legislature. These opponents also cite the judgment in Kesavananda Bharati vs. State of Kerala A1R 1973 SC 1461 and contend how could an unelected Court decide what the Constitution should contain? Should such power no rest with a representative body such as Parliament? They say that even the U.S. Supreme Court did not have such power. Thus, for an onlooker of judicial process, judicial activism seems to be judicial tyranny when the judicial process was abused or misused by unscrupulous persons under the garb of P or where he thinks that the Court transgressed its limits or role assigned to it under the Constitution. Being a sitting judge of a Constitutional Court, it will be inappropriate for me to speak out in support or opposition of the above thinking of the opponents of judicial activism.

Judicial activism in recent time has become a controversial subject and it has drawn many critics and opponents, particularly from the side of the political executive and the legislative bodies. It cannot be gainsaid that undeniably one can see the misuse and abuse of the process of law, in invoking the power of judicial review of the Constitutional Courts under the garb of PIL or SIL. This unhealthy and objectionable development was noticed by the Courts themselves and they have warned and cautioned against the movers of such PILs and SILs and in certain cases they were made accountable for the abuse by awarding exemplary costs. Your speaker too has had such experiences in dealing with few cases of PILs as a Judge of Andhra Pradesh High Court and Karnataka High Court, presently as Chief Justice of Chhattisgarh High Court. He expressed his righteous indignation against the misuse of the process of the PIL, in a recent case, in Mani Shankar Pandey vs. Union of India (2006 (I) MP JR-CG-25) and Others in the following words:

‘This case beings to the fore how a noble, laudable and public justice-oriented legal process, that is what we call “Public Interest Litigation” which is essentially and initially meant to provide legal representation to previously unrepresented groups and citizens, can he misused and abused by unscrupulous persons without any element of public interest wither in their hear or in mind, to have their consideration and as a vexatious measure.”

In that case, the petitioner claiming to be a pro bono publics complained that the 5 respondents therein was granted ‘no objection certificate’ to shift his Fuel Outlet from the existing place to some other place in utter violation of certain guidelines and some prescribed by the National Highways Authority and he contended that if 5 respondent is permitted to shift the Fuel Outlet, it would be totally dangerous to public safety and road safety and it would cause inconvenience to motorists travelling in the National Highway 200 resulting in frequent accidents. On appearance of the 5 respondents and other official respondents it was brought to the notice of the Court that the petitioner had drawn a large quantum of fuel from the Fuel Outlet of the 5 respondent and when the 5 respondents demanded payment of outstanding dues, the petitioner being annoyed by the said demand, filed the writ petition as pro bono public. While dismissing the writ petition with exemplary cost of Rupees Fifteen Thousand, the Chief Justice observed.

“(13) Before including a word or two about the accountability of the petitioner in moving a Constitutional Court by way of petition under Article 226 of the Constitution under the garb of PIL. The time of the Court is public time; it is neither of the Judges nor the time of the litigant or his counsel; the public time should be spent judiciously and economically; insistence of such rule is absolutely necessary particularly in the context of alarming pendency of cases in Law Courts a other judicial and quasi-judicial for a today The Courts time should not be allowed to be misused or abused by unscrupulous litigants or busy-bodies in the garb of PILs. This is also responsibility cast on the learned members of the Bar in espousing the cause of public by way of PlLs Lawyer plays a very crucial and important role in public interest litigation. His duty and responsibility to the Court in a Public Interest Litigation case is even greater in comparison to usual cases. The Lawyers repertoire and forensic skills and craftsmanship are central of institutional reforms. An Advocate is an integral part of administration of Justice. The legal fraternity and judiciary are the two sides of the same coin. The Court would not be wrong in expecting that every advocate would conduct himself in responsible manner and assist the Court properly in discharge of these legal and constitutional obligations. They do act, plead and advocate the cause of the clients but their duty of Court is much higher than that of serving their clients. It is stated that every advocate is an amicus curiae, a friend of the Court; his first loyalty is to the Court and not to his client. The Court’s time is not meant for the satisfaction of the ego of a judge who presides over the Court that he knows the whole law correctly and there cannot be a second opinion on the point addressed to the Court, not to satisfy the counsel himself who appears for a party that he could put forth any plea or point irrespective of its tenability in the legal premise, nor to please a party sitting behind his counsel that his counsel did argue the case on his behalf marvellously and to his satisfaction. Adjudicatory deliberations in a Law Court are serious pursuits, and they should receive responsible and constructive co-operation from both the partners of the institution, and both of them shall practice and do everything at their command to save the precious time of the Court without sacrificing justice. Such a course has become imperative necessity in the Constitutional Courts where the accumulation of the cases is alarming as well as long pending. Fruitful management of the Court’s time is need of the hour and that cannot be achieved without constructive cooperation between the Bar and the Bench.

(14) Time has come for the Constitutional Courts not only to nip the unscrupulous and unjustified PILs at the bud but also to make the movers of such PILs accountable in concrete terms. Mere disapproval of such PILs by the Courts by way of observation in the judgment will not help the public justice in the long run. The State spends huge sums of money out of the limited resources to provide, maintain and conduct apparatus of adjudicatory processed. If the Court finds that the adjudicatory process is abused or misused wantonly by a person under the garb of PIL, it is but necessary to make him accountable for his litigative luxury, in order to subserve the public interest. Public interest will never be permitted to suffer in a Public Interest Litigation. That can be achieved by imposing exemplary costs. One cannot have the pleasure of an unjustified PIL at the cost of the public paying Rs. 100/ towards Court fee. a pittance when compared to the actual cost incurred by the State.

(15) The Supreme Court in Janata Dal vs. H.S. Chowdary AIR 1993 SC. 892 expressed its total displeasure and disgust in wasting the Court’s time on account of trumpery proceedings initiated under the garb of PILs in the following words:

“It is depressing to note that on account of such trumpery proceedings initiated before the Courts innumerable days are wasted which time otherwise could have been spent for the disposal of cases of the genuine litigants. Though we are second to none of fostering and developing the newly invented concept of PIL and extending our long aim of sympathy to the poor, the ignorant, the oppressed and the needy whose fundamental right are infringed and violated and whose grievances go unnoticed, unrepresented and unheard; yet we cannot avoid but express our opinion that while genuine litigants with legitimate grievances relating to civil matters involving properties worth hundreds of millions of rupees and criminal case in which persons sentenced to death facing gallows under untold agony and persons sentenced to life imprisonment and kept in incarceration for long years, persons suffering from the undue Delay in service matters, Government or private persons awaiting the disposal of tax cases wherein huge amounts of public revenue or unauthorized collection of tax amounts are locked up, detenus expecting their release from the detention orders, etc., – are all standing in a long serpentine queue for years with the fond hope of getting into the Courts and having their grievances redressed the busy bodies, meddlesome interlopers wayfarers or officious interveners having profit either for themselves or as proxy of others or for any other extraneous motivation of for glare of publicity break the queue muffling their facts by wearing the mask of public interest litigation and get into the Courts by filing vexatious and frivolous pet and thus criminally waste the valuable time of the Courts and as a result of which queue standing outside the doors of the Court never moves which piquant situation creates a frustration in the minds of the genuine litigants and resultantly they lose faith in the administration of our judicial system.”

(16) A person who desires to persist with his view point despite the fact that the point which he canvases before a judge has no legs to stand by the binding decisions of the larger Benches of the Court and in the process wastes the Court’s time shall be made to pay the price for the wastage of public time, at least notionally, it not fully. Such course is a ‘must not only to curb unjustified and vexatious PlLs but also to do justice to the public. The observation of the Supreme Court in S.P. Anand vs. H.D. Deve Gowda (1996) 6 SCC 734 is apt to be quoted:

“…………it must also be borne in mind that no one has a right to the waiver of the locus standi rule and the court should permit it only when it is satisfied that the carriage of proceedings in the competent hands of a person who is genuinely concerned in public interest and is not moved by other extraneous considerations. So also the Court must be careful to ensure that the process of the Court is not sought to be abused by a person who desires to persist with the point of view almost carrying it to the point of obstinacy by filing a series of petitions refusing to accept the Court’s earlier decisions as concluding the point. We say this because when we drew attention of the petitioner to earlier decisions of this Court, he brushed them aside, without so much as showing willingness to deal with them and without giving it a second look, as having become stale and irrelevant by passage of time and challenged their correctness on the specious plea that they needed reconsideration he had no answer to the correctness of the decisions. Such a casual approach to considered decisions of this Court even by a person well versed in law would not be countenanced. Instead, as pointed out earlier he referred to decisions on cow slaughter cases, freedom of speech and expression, uniform of civil code etc. We need say no more except to point out what indiscriminate use of this important lever of public interest litigation would be blunt the lever itself.

(17) After necessary reflection, we are of the considered opinion that the instant Writ Petition is not a bona fide PIL and it is filed by the petitioner under the garb of PIL for an oblique consideration and as a vexatious measure to harass the fifth respondent to settle a score with him.”

I, therefore, think that the case noted above and the like would be in the back-drop of one’s psyche when he condemns judicial activism as Judicial tyranny, but, there is no need for us to be obsessed with such cases while taking stock of the efficiency can utility judicial activism as the legal process to sub-serve and public interest.

The power of judicial review vested in the High Courts and the Supreme Court under the Indian Constitution is held to be basic feature/basic structure of the Indian Constitution and that cannot be abridged or taken away even by Constitutional amendments. The role of judicial review and its role in democracy need hot be over-emphasized. It is known to all of us. Judicial review means overseeing by the judiciary of the exercise of power by other co-ordinate organs of government with a view to ensuring that they remain confined to the limits drawn upon their powers by the Constitution. There are two models of judicial review. One is a technocratic model in which judges act merely as technocrats and hold a law invalid it is ultra vires the powers of the legislature. In the second model, a Court interprets the provisions of a Constitution liberally and in the light of the spirit underlying it and keeps the Constitution abreast of the times through dynamic interpretation. A court giving new meaning to a provision so as to suit the changing social or economic conditions or expanding the horizons of the rights of the individual is said to be an activist Court. Judicial activism can be positive as well as negative. A Court engaged in altering the power relations to make them more equitable is said to be positively activist and the Court using its ingenuity to maintain the status quo in power relations is said to be negatively activist. The decisions of the U.S. Supreme Court in the case of Dred Scott vs. Stanford 60 U.S. 393 (1856) and Lochner vs. New York 198 U.S. 45 (1904) were examples of negative judicial activism, whereas the decision of that Court in Brown vs. Board of Education 347 U.S. 483 (1954): 98 L. Ed. 87 is an example of positive activism. In Dred Scott (supra) the U.S. Supreme Court upheld slavery as being protected by the right to property ad in Lochner (supra) it held a law against employment of children as violative of the due process clause of the Constitution. In Brown vs. Board of Education (supra), the Court held that segregation on the ground of race was unconstitutional and void. Activism is related to change in power relations. A judicial interpretation that furthers the rights of the disadvantaged sections or imposes curbs on absolute power of the State, or facilities access to justice is a positive activism. Judicial Activism is not an aberration but is a normal phenomenon and judicial review is bound to mature into judicial activism. Judicial Activism also has to operate within limits. These limits are drawn by the limits of the institutional viability, legitimacy of judicial intervention, and resources of the Court. Since, through judicial activism is bound to be political in nature. Therefore, it cannot be gainsaid that through judicial activism, the constitutional court becomes an important power centre of democracy.

The Indian Supreme Court has evolved from a positive Court into an activist Court over the last fifty five years and more. The journey towards activism has been slow and imperceptible. This transformation in the role of the Court has synchronized with the political change that came about in India during the last fifty-five years. The increased role of the Court was legitimized by the increasing pluralization of the Indian polity, the need to have a counter-majoritarian check on democracy, and relative erosion of the high profile of the political leadership that prevailed before Independence.

The Supreme Court of India started off as a technocratic Court in the 1950s but slowly started acquiring more power through constitutional interpretation. In fact the roots of judicial activism are to be seen in the Court’s early assertion regarding the nature of judicial review. In A.K Gopalan vs. Madras AlR 195O SC 27, 34 although the Supreme Court conceived its role in a narrow manner, it asserted that its power of judicial review was inherent in the very nature of the written constitution. The Supreme Court held that “the inclusion of Articles 13(1) and (2)/n the Constitution appears to be a matter of abundant caution. Even in their absence, if any of the fundamental rights was infringed by any legislative enactment, the Court has always the power to declare the enactment; to the extent it transgresses the limits, invalid.” The posture of the Supreme Court as a technocratic Court was slowly changed to be activist Court In Sakal Newspapers Private Ltd vs India AIR 1962 SC 305 it held that a price and page schedule that laid down how much a newspaper could charge for a number of pages was as being violative of freedom of the press. The Court also conceived a doctrine of gibing preferred position to freedom of speech and expression, which includes freedom of the press, over me freedom to do business. The Supreme Court held that a newspaper was not only a business; it was a vehicle of thought and information and therefore could not be regulated like any other business. In Balaji vs. Mysore AIR 1963 SC 649, the Supreme Court held that while the backward classes were entitled to protective discrimination, such protective discrimination should not negate the right to equality and equal protection of law. It held that backwardness should not be determined by caste alone but by secular criteria, though caste could be one of them, and that the reserved seats in an educational institution should not exceed fifty per cent of the total number of seats. In Chitralekha vs. State of Mysore A1R 1964 SC 1823, similar restrictions were imposed on the reservation of jobs in civil services. These are examples of judicial activism of the early 1960s.

In early years of the Indian Supreme Court, the inconvenient decisions of the Supreme Court were overcome through the device of constitutional amendments. The first, the fourth and the seventeenth constitutional amendments removed various property legislations from the preview of judicial review. Therefore, a debate on the scope of the Parliament’s power to amend the Constitution started. A question was raised before the Court in 1951 in Shankar Prasad vs. Union of India AIR 1951 SC 458 whether Parliament could use its constituent power under Article 368 so as to take away or abridge a fundamental right. The Court unanimously held that the constituent power was not subjected to any restriction. That question was again raised in Sajjan Sing vs, State of Rajasthan AIR 1965 SC 845 and this time two Judges responded favourably, though theirs was a minority view. In 1967, L.C. Golaknath vs. State of Punjab AIR 1967 SC 1643 that minority view became the majority view, by a majority of six against five. It was held that Parliament could not amend the Constitution so as to take away or abridge the fundamental rights. In Keshavananda vs. State of Kerala (supra) eleven put of thirteen Judges held that Golaknath had been wrongly decided. However, while conceding that the constituent power under Article 368 extended to every Article of the Constitution, the majority of seven against six Judges held that such power could not be exercised so as to destroy or tamper with the basic feature or the basic structure of the Constitution. What is basic structure could be articulated by the Court from time to time through cases. This virtually meant that the Court would have the last say in respect of the Constitution. When that decision was given, it had few takers, but it acquired legitimacy over a period of time. The first event that helped it gain legitimacy was the emergency of 1975. Although in Indira Gandhi vs. Raj Narain AIR 1976 SC 2299 the Supreme Court struck down the Constitutional (Thirty-Ninth Amendment) Act, which sought to validate the election of Indira Gandhi being violative of the basic structure of the Constitution upheld her election on merits. In subsequent years, several attempts were made to bury the doctrine of basic structure but it survived. The Court has used that power with maximum restraint and that power remains as an ultimate counter-majoritarian check upon democracy.

When we look at post-emergency activism, we would see the Supreme Court distancing from legal positivism. The Supreme Court took advantage of several opportunities to expand the rights of the people through liberal interpretation of the constitutional provisions regarding the right to equality and the right to personal liberty. The Supreme Court departed from its earlier strategy of constructing each Article of the Constitution separately and started interpreting the bill of rights as a whole. It gave expansive meanings to the words life’, personality liberty and ‘procedure established by law’ contained in Article 21 of the Constitution to protect the rights of justice-starved millions like bonded labour, unorganized labour, prisoners, hutment dwellers, pavement dwellers and all other kinds of have-nots and to take up cudgels for the ordinary citizen by coming down heavily against abuse of powers by and inaction of the public authorities. The activist Court in its new role handed down many opinions to make basic human rights meaningful to the deprived and vulnerable sections of the community and assure them social, economic and political justice. By such expansive interpretation it recognized the rights of under trial prisoners, prison inmates, and children under juvenile delinquency Acts and re-examined the validity of the provisions of the penal law sanctioning death sentence, and recognized the right to privacy, the right to a speedier trial, the right to an independent judiciary, and the right to efficient and honest governance etc. Thus, the rights given by the bill of rights were therefore given maximum expanse so as to make them real expressions of liberty, equality, and justice. The preamble of the Constitution no longer remained a mere decoration, but, became the source of the basic structure of the Constitution and the State actions could be scrutinized not merely in terms of their compatibility with specific provisions but in terms of their compatibility with the broad principles of constitutionalism such as secularism. The Indian Supreme Court while liberally interpreting the rights, it could not stop at merely those rights that had been recognized as judicially enforceable rights known as civil liberties. The Constitution of India includes socio-economic rights such as the right to primary education (Article 45), the right to adequate means of livelihood [Article 39(1)[ or the right to work (Article 41) in the directive principles of state policy contained in Part IV of the Constitution. These social and economic rights have been recognized in the Universal Declaration of Human Rights [Article 23(1)], right to work [Article 23(3)] right to just and favorable remuneration; (Article 26) right to education and the. International Covenant on Economic, Social and Cultural Rights [Article 7(a) right to fair wage and Article 6 right to work]. It was generally felt and it is true also that these rights cannot be effectively made enforceable through judicial process. They require legislative and executive action. But, the Supreme Court declared the right to educations [Unni Krishnan vs. State of A.P (1993) 1 SCC 645 the right to shelter [OIga Tellis vs. Bombay Municipal Corporation AIR 1986 SC 180: (1985) 35CC 545 and the right to childhood [M.C. Mehta vs State or Tamil Nadu (1996) 6 SCC 756: AIR 1997 SC 699 as being part of the fundamental right to life and. personal liberty guaranteed by Article 21 of the Constitution. The Court by incorporating the above rights within the fundamental right to life and personal liberty made them enforceable.

The Indian Supreme Court and the High Courts expanded judicial access in furtherance of its activist role by entertaining letters from persons interested in opposing illegal acts, allowing social activist organizations or individuals to take up cudgels on behalf of the poor and disadvantaged sections who possessed neither knowledge nor resources for activating the legal process; and permitting citizens to speak on behalf of a large unorganized by silent majority against bad governance, wrong development, or environmental degradation. The wide definition of ‘life’ and ‘liberty’ as interpreted by the Courts helped various types of issues to come before the Courts. The doors opened by the Constitutional Courts in pursuance of its determination to keep open the legal process more participatory and democratic led to the PILs being used liberalIy for various types of reliefs, such as for protecting the fundamental rights of undertrial prisoners in jails, amelioration of the conditions of detention in protective homes for women, for medical check-up of remand home inmates, prohibition of traffic in women and relief for their victims, for the release of bounded labour, enforcement of other labour laws, e.g. full and direct payment of wages to workers or prohibiting the employment of children in construction work, acquisition of cycle- rickshaws by licensed rickshaw pullers, relief against custodial violence to women prisoners while in police lock up, for environmental protection for enforcement of gender equality and protection from sexual harassment and the like.

One may find the activist role of the judiciary resulting in law-making also. There was no law to regulate the adoption of children by foreigners. In Lakshmi Kant Pandey vs. Union of India AIR 1987 SC 232 the Supreme Court laid down directions for regulating such adoptions and these directions have been in force for more than nineteen years. Similarly, when women’s organization approached the Supreme Court with a request to lay down guidelines as to how sexual harassment of working women could be combated, the Supreme Court in Visaka vs. State of Rajasthan (1997) 6 SCC 241: AIR 1997 SC 3011 responded by laying down guidelines and also declaring them to be the law made by it under Article 141 of the Constitution.

The activist role of the Indian Supreme Court was also seen when it chose to review the satisfaction of the President while proclaiming emergency under Article 352 of the Constitution of India or dismissing the State Government under Article 356 of the Constitution. It was earlier thought that the satisfaction of the President was non-justiciable. In 1977, in State of Rajasthan vs. Union of India AIR 1977 SC 1361 the Supreme Court opened the door slightly for judicial review on limited grounds of ultra vires and mala fide exercise power, though it did not strike down the impugned action therein. in S.R. Bommal vs. India (1994) 3 SCC 1: AIR 1994 SC 1918 the Supreme Court by a majority of six judges against three held that the President’s satisfaction under Article 356 of the Constitution was justiciable. Kesavananda Bharati and S.R. Bommal (supra) are two sign-mark decisions and if I may say no, these decisions made the Supreme Court of India very powerful, the most powerful among all the Apex Courts in the World Thus it could be seen that activist role of the Constitutional Courts in India has undeniably sub— served the interest of the people of India both in peace-time and war-time. It acted like formidable majoritarian check on democracy, it protected the freedoms and liberties of the people and protected socio-economic rights of the people particularly, those people who due to their socio-economic and political disabilities lacked access to justice system. Looking from that angle, judicial activism on the part of the Constitutional Courts has been exploited abused and misused by some unscrupulous and non-deserving persons, natural or legal or on the ground that in some cases the crossed Lakshmana Rekha as claimed in some circles of critics.

[Source: Souvenir published at the time of National Tax Conference held at Hyderabad.]

*Reproduced with permission from the AIFTP Journal – October 2008 issue.