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ACCESS TO AFFORDABLE MEDICINE- WHETHER COMPULSORY LICENSING AN APPROPRIATE MECHANISM
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ACCESS TO AFFORDABLE MEDICINE-
WHETHER COMPULSORY LICENSING AN APPROPRIATE MECHANISM
AUTHORED BY
- ANJALI S NAIR
(LLM
BUSINESS LAW)
Amity
Institute of Advanced Legal Studies, Noida
Abstract
Pharmaceuticals
are an inalienable requirement of the public health. India before the
implementation of TRIPs was a major distributor of generic drugs. In the Indian
market, manufacturers were free to manufacture generic drugs using different
manners or processes. However, the patents in the field of pharmaceuticals are not
regulated before TRIPs. The introduction of product patents in the field of
pharmaceuticals granted global protection of intellectual property rights to
drug manufacturers. Necessary amendments were introduced in the Indian Patent
Act to grant protection to pharmaceuticals backlashing the generic drug
industry of India. While implementing intellectual property rights protection
TRIPs failed to consider the needs of LDCs with the least drug manufacturing
capacity. It is essential to consider that the protection of pharmaceuticals
under patent has led to monopoly resulting in the non-accessibility of
affordable drugs in LDCs. Despite the protection of pharmaceutical patents has
led to the infringement of health care needs of low low-income population. In order
to remedy the situation, the importance of Compulsory licensing was depicted in
the DOHA Declaration. Compulsory licensing was implemented to prevent
monopolistic rights of patent holders. However, the ambiguities in the
insertion of compulsory licensing in the Indian Patent Act failed the essential
outcome of accessible medicines. Even after 20 years, the compulsory license
was granted only once. Therefore, this paper will focus on all such issues
related to compulsory licensing of pharmaceuticals in India.
Keywords: Pharmaceutical
Patent, Right to Health, Compulsory Licensing, Grant of Patent,
INTRODUCTION
Article 21[1] of
the Indian Constitution guarantees every person and citizen of India the right
to life and the right to personal liberty. Further, Article 47[2] of
the Indian Constitution declares that it is the duty and obligation of the
state to improve public health. In addition, Article 12 of the International
Covenant on Economic, Social, and Cultural Rights (ICESCR) adopted by India
asserts that nations have to facilitate the right to health. Thus, the Indian
government operates under the premise that medicines are critical to the
healthcare needs of India’s population and must be both available and
affordable. Indeed, this paradigm is the foundational basis for India’s vision
for the right to health under Article 21 of the Indian Constitution. Thus,
Indian policymakers strive to meet India’s constitutional obligations for the
right to health while promoting its innovation ecosystem and safeguarding the
legitimate business interests of MNCs.
In 1856, India made its first
initiative to grant patents to inventors. Under British Rule, India enacted the
First major legislation in 1911. India was a British colony till 1947, and most
of the patents granted during the period were to foreigners. During the time of independence, India’s
Pharmaceutical sector was dominated by MNCs. The post-independence laws were
framed for the development of the indigenous pharmaceutical industry in India
with the recommendations made by the Tek Chand Committee and Ayyangar
Committee. In 1953 the Patent Bill recommended by the Tek Chand Committee
modelling the Patent Act 1949 of the United Kingdom lapsed. The patenting of
Medicines and Food was introduced under the Patent Bill 1965 by the Ayyangar
Committee. In 1972, after repeated expert reports and deliberations in
Parliament, the India Patents Act of 1970 came into force.
The 1970 Act underwent three major
amendments to formulate the Indian legislation following the Trade-Related
Aspects of Intellectual Property Rights (TRIPS) introduced in the Uruguay Round
of General Agreement on Trade and Tariffs (GATT). The Patent Act 1999
introduced the product patent to medicines in India Trip’s member country.
India as a developing country availed ten years of transition period. During this period any application for
pharmaceuticals will be processed under the mailbox system. However, the EMR
system nullified the exemption of transition period granted by the TRIPS. India
was forced to implement EMR and mail – box system after US Complaint for
non-implementation.
By the 20th century the
pharmaceutical industry in India had taken its form as allopathic medicines,
the patent granted to medicines aimed to further development of the
pharmaceutical sector. For the production and development of new drugs, the R&D
efforts play a major role. Hence the pharmaceutical industry met with
incredible R&D expenditure. Providing exclusive rights to the inventor as
to making and selling of pharmaceuticals grants incentives to the inventor
which further can be invested in the R&D. implementation of TRIPS, helped
the pharmaceutical industries to develop new drugs by the brand name thereby
reserving its exclusive use by patenting it.
While this shift led to the development
of the pharmaceutical industry, it led to the downfall of the Indian generic
drug export market. The medicines being an inevitable element of public health,
many countries including India made arrangements for patenting them. Till 1999
India granted only process patents to the pharmaceuticals thereby the end
product was not patented and the process of manufacturing them was granted
protection. Hence many manufacturers who used different ways to manufacture
similar medicines were not held liable as they used non-infringing processes.
This mechanism allowed Indian companies to manufacture Generic medicines in
India using non-infringing methods. This fostered pharmaceutical availability at
affordable prices not only in India but also in the other country market.
India is a welfare nation to protect the
inalienable rights of every person and citizen of India including the right to
health. India adopted ICESCR where it obliged the duty to facilitate the right
to health under article 12 of ICESCR. The constitution of India obliges the Indian
government to provide accessible and affordable medicines to the Indian
population under Article 47 of the Indian Constitution. Thus, even when
promoting the development and innovation of the country, the Indian
constitution constantly imposes a duty on the Indian government to strive for the
protection of public health as a superior goal. However, the legal framework of
TRIPS provides a monopoly to the patent holders in raising the drug prices
beyond the capacity of poor sections especially in a developing country like
India have infringed the accessibility of affordable medicine restricting the right
to life. As declared by Minister Indira
Gandhi at the World Health Assembly, Geneva, in May 1982, India’s policy on
Patents has been the “idea of a better world is one in which medical
discoveries will be free from patent and there will be no profiteering from
life and death”, can lead to a better framework were medicines are accessible
to all sections of society irrespective of their earning capacity.[3]
The Doha Declaration on the TRIPS
Agreement made arrangements to formulate a solution for the hazards faced by
economically disadvantaged countries concerning the non-accessibility of
affordable medicines to the low-income population. It reassured the importance
of the issuance of compulsory licenses when patentable medicines are not
accessible to the public. Doha Declaration has further issued circumstances
that constitute a national emergency or urgent circumstances which grant the
countries the right to take away exclusive rights granted to the patent owners
of pharmaceuticals and the criteria to decide this was left to the discretion
of the exporting nation.
Even though India implemented the
declaration by the 2005 amendment which inserted Section 84 of the Indian
Patent Act, 1970 however compulsory licensing has several loopholes that act as
a hurdle to attain the real object of the declaration.
THE CONCEPT OF COMPULSORY LICENSING
The grant of the patent provides
exclusive rights to the inventor for a certain period of time. Even though the
law permits exclusive rights, it also takes precaution that exclusive right
granted will not lead to monopoly. Hence it provides certain restrictions so
that the rights granted cannot be abused. This indeed protects the rights of the
patentee and promotes fair competition in the market. Thus, compulsory
licensing is the mechanism that provides arrangements to revoke the patent
granted when the invention is not accessible to the public to restrict
monopoly. The concept of compulsory licensing first evolved in France. Under
the French Patent Law 1791, if the patent holder fails to work on a patent
within 2 years the patent will be revoked. This arrangement is said to be the
origin of the compulsory licensing mechanism.
However, the same mechanism was in
practice in the United Kingdom, when the granted patent was held void if the
grants were prejudicial or inconvenient to the King’s subjects. The power to restrict
monopoly was first vested in the Board of Trade in 1883. By 1919 it was
transferred through different authorities including the Judicial Committee of the
Privy Council, the Court, and finally to the Comptroller. Further, the patent
law expanded its scope to include food and medicines. Under the Statute of
Monopolies Act the compulsory licensing mechanism was framed as to restrict the
monopoly.
In India, the post-colonial period
patent laws followed the UK Patent Act model being a British Colony. Before the
Patent Act of 1970, most of the patents were granted to foreigners, who were
reluctant to work on their inventions in India. As with any other underdeveloped
country, India’s population was also facing non-accessibility to medicine.
Thus, the Ayyangar committee implemented the compulsory licensing mechanism
with the major reason being the non-working of the invention in the Indian
market.
The provisions of compulsory
licensing were first given by the Patent Act 1970. The Compulsory license
provisions were substantiated by the Licences of Rights. The compulsory license
Chapter XVI consists of Sections 82-94. However, once India became a party to
the TRIPS Agreement, the sections related to Licences of Rights were removed.
Currently, Sections 82 to 94 address compulsory licensing under the Patent
Amendment Act of 2000. In India as per Section 84(1) of the Patent Act,
compulsory licensing can only be granted after the expiry of 3 years when an
application is made to the controller.
COMPULSORY LICENSING IN THE FIELD OF PHARMACEUTICALS
Domain for patent has been multidimensional
as Article 27 of TRIPs guarantees a patent for any invention, whether product
or process in all fields of technology. Therefore, Pharmaceutical manufacturers
developing medicines which are inventive and capable to cure diseases can apply
for grant of patent for their inventions. The inventions include new medicines
as well as processes or methods of manufacturing them. The pharmaceutical
manufacturing company is concerned about the formula of new medicine as well as
the method of their preparation. When this information is disclosed in the
market can often lead to the production of generic medicine, leading to a loss
of revenue. As a result, the patenting of these medicines as well as the process
guarantees them protection from infringement.
Article 19(1)(g)[4] of
the Indian constitution guarantees freedom of trade, thus pharmaceutical
manufacturers use the patent as a safety measure to establish their trade even
outside India. Guaranteed rights to the patentee improve protection from
infringement thereby flourishing their trade. The grant of exclusive rights
provides significant revenue which is deviated to the research and development
(R&D) of the medicines. Indeed, the protection of rights promotes further
development with a significant improvement of revenue. According to Robinson,
“Patent privilege differs from an
odious monopoly in that it does not deprive the public of an existing right but
rather prevents only the exercise for the limited time of the new direction
marked out by the inventor”.[5]
Granting protection only for a
particular period, after which the invention is open to the public is an
effective mechanism to prevent infringement. However, in India, the protection
period continues to 20 years which in turn restricts the low-income Indian
population regarding pharmaceutical accessibility at affordable prices. At this
point, the 2 major provisions of the Indian constitution granting freedom of
trade under Art 19 and the right to life under Article 21 conflict with each
other. As a result in certain situations
including national emergencies, the compulsory licensing of medicines was
granted immediately after the granting of the patent.
TRIPS AGREEMENT AND COMPULSORY LICENSING
To counter abuses of patent rights,
TRIPS (Agreement on Trade-Related Aspects of Intellectual Property Rights) was
adopted by WTO in 1994. The Agreement gave the provision to protect
intellectual property balancing the availability of inventions to the public.
TRIPS doesn’t use the term ‘compulsory license’ as such. However, according to
Article 31[6] of
the TRIPS Agreement, a patent can be used by the government or third parties
authorized by the government, without the authorization of the right holder.
Article 13 allows member countries to
implement limitations with regard to special cases, that do not conflict with the
normal exploitation of work. Article 30 of the TRIPs agreement allows members
to provide limitations to the exclusive rights conferred by the patent.
Article 21[7] of
the TRIPS agreement balances the rights of the patentee as well as the
availability of the patent. It provides provisions as to the availability of patents
to all without any discrimination as to the place of invention, field of
technology, or whether the products are imported or locally produced. [8]
Further Article 31, provides certain conditions as to the use of the patented
invention without the authorization of the patent holder by the government as
well as by a third party after the application of voluntary licensing made to
the patentee. Article 40[9] substantiates
this provision by granting the right to the member countries to implement their
legislation with licensing practices and conditions when exclusive rights are granted
to harm the competition and trade.
EFFECTS OF DOHA DECLARATION ON COMPULSORY LICENSING
Doha Declaration on the TRIPs
Agreement and Public Health was adopted to implement the TRIPs agreement by recognizing
the power of the member countries to take measures to protect public health.
The major implementation of the declaration is regarding the flexibility of
TRIPs for the access to medicines.
The declaration has granted the right
to determine what constitutes a national emergency to the member state. In such
a situation the member states have been granted the right to grant compulsory
licensing and freedom to determine grounds for granting compulsory licensing.
Even though TRIPS provided a lot of
benefits there was a need for amendment in TRIPS which was fulfilled by the Doha
Declaration in November 2001 which allowed the member country to issue
compulsory licenses to produce drugs for export to the countries having fewer
or no manufacturing capacity of drugs.
“Governments should adopt and
implement legislation that facilitates the issuance of compulsory licenses.
Such legislation must be designed to effectuate quick, fair, predictable and
implementable compulsory licenses for legitimate public health needs, and
particularly with regards to essential medicines. The use of compulsory
licensing must be based on the provisions found in the Doha Declaration and the
grounds for the issuance of compulsory licenses left to the discretion of
member governments”[10]
Section 92[11]
of the patent, the act provides for the circumstances which allow central
government to make the declaration as to the granting of compulsory licensing.
These circumstances include:
a) National emergency
b) Extreme urgency
c) Public non-commercial use.
In the above-mentioned circumstances,
the provision of granting compulsory licensing after 3 years, is not applicable.[12]
In such circumstances, the patent application can be made immediately after the
grant of the patent.[13]
When an application is filed by any person controller shall grant a compulsory
license with the terms and conditions to make the patented invention available
to the public at the lowest price. While granting the compulsory license the
Controller should be aware of his role to balance the rights of the patentee
and to make it available to the public at a reasonable rate. However, granting
of compulsory licensing is possible only after the Central Government makes the
notification in the Official Gazette.
The provisions have been implemented
to allow the Government to take urgent steps at times of public health crisis,
including HIV, AIDS, Tuberculosis, Malaria, and other epidemics.
Section 100 provides patents for
government use. It states that the government can acquire the patented
invention for its use in return for some compensation to the patentee. The
government is required to notify the patentee about the use and extent of use
of the invention. The patentee however can challenge such a use or the terms of
such use. Section 102 states that the
government can acquire the patented invention for public purposes. The patent
holder loses all the rights to the invention and gets some compensation in
return. The patent holder cannot challenge the acquisition but can ask for more
compensation.
LEGAL SCENARIO IN INDIA
In December 2010 when Natco
approached Bayer to grant the voluntary license to manufacture Nexavar whereas Bayer
turned it down. The drug is used in the treatment of Renal Cell Carcinoma (RCC)
and Hepato Cellular Carcinoma (HCC). The drug was priced at INR 2.8 lakh for a
monthly therapy by Bayer which was claimed to be sold at INR 8800 for a monthly
therapy by Natco. Then in 2011, Natco applied to the Controller for the grant
of compulsory license under Section 84, stating that the patented invention was
not available to the public at a reasonably affordable price. The compulsory
license was granted, which allowed a royalty of 6% which was later raised to 7%
on the appeal of Bayer. Even after three years of the compulsory license, Bayer
has not amended the price of the drug. It is selling the drug at the same price.
This could lead to the revocation of Bayer’s patent under Section 85, as it is
found that the public requirements of the drug have still not been satisfied.
Section 85 says that if a single patient is away from access to the drug, the
public requirements cannot be said to be satisfied.[14]
The application for the grant of a compulsory
license for Dasatinib was filed by BDR in march 2013. Dasatinib is sold by
Bristol-Myers Squibb. It is used in the treatment of chronic myeloid leukemia.
In India, a month's therapy of this drug costs about INR 1 lakh. BDR
Pharmaceutical claimed to sell the drug at INR 8,100 for a month of therapy. However,
the application was rejected by the Patent Office because the prima facie case
has not been made out by BDR Pharma under Section 84, to obtain a voluntary
license for the drug from the patent holder. Later in 2014, the Health Ministry
planned to compulsory license Dasatinib under Section 92. But, the Department
of Industrial Policy and Promotion (DIPP) turned it down stating that the use
of Section 92 is impermissible as no national emergency or national urgency
situation is prevailing in the country.[15]
THE NEED TO REFORME COMPULSORY LICENSES
Finally, after
discussing India’s implementation of TRIPs flexibility to allow accessibility
of affordable drugs, it can be argued that Indian initiatives to provide
affordable medicines are suffering various loopholes.
"The
TRIPS Agreement should be interpreted and implemented in a manner supportive of
WTO members' right to protect public health and, in particular, to promote
access to medicines for all. "[16]
The DOHA
declaration under paragraph 6 provided wit the effective tool of compulsory
license, obligating the member states to use the compulsory license to promote
public health balancing the protection of patent’s rights. However, the
Compulsory licensing mechanism faced drawbacks, which are depicted as follows:
1.
Long-term legal battle
Section 84
provides the conditions for granting compulsory licensing. As per the provisions
of the Indian Patent Act, it can be depicted that a compulsory license minimum
of 4-year period is required. Compulsory licensing can be granted only after the
expiry of three years from the granting of the patent. Further, it requires the
efforts of the applicant to get voluntary licensing within a reasonable period
of 3 months. Further, every application
for compulsory license shall be decided within one year. This can be further
depicted from the records given below:
|
SL No.
|
Name Of
Applicant
|
Year Of Filing
Application
|
Date of
Granting Application
|
|
1.
|
Natco
|
2001
|
09/03/2012
|
|
2.
|
BDR
Pharmaceutical International
|
2001
|
29/10/2013
|
|
3.
|
Lee pharma
|
2002
|
19/01/2006
|
The above data
depicts a serious concern over the time required to grant patent protection in
India. The Nato is the one and only company to which compulsory licensing was
granted. The time period to obtain compulsory licensing shows about 11 years of
legal battle. Similarly BDR Pharmaceutical International and Lee Pharma battled
for compulsory licensing for unfortunately could not secure the same, this
trend shows the difficulty of obtaining compulsory licensing and the waiting
period required for the same.
2.
The definition of national emergency
Section 92
allows to grant compulsory licensing in the circumstances of National emergency
or in the circumstance of extreme urgency or in the case of public non-commercial
use. However, the definition of National emergency are extreme urgency has not
been yet defined.
The TRIPs
agreement put forward the strategy of National emergency undefined to allow
flexibility to its member countries to define the situation according to their
public policy. The DOHA Declaration has depicted the need to define the
scenario of a national emergency according to the needs of each member State to
protect public health. National emergency have been defined by various UK The United Kingdom's Civil Contingency
Act 2004 defines an emergency as "An event or situation threatens damage
to human welfare only if it involves, causes or may cause loss of human life,
human illness or injury, homelessness, damage to property, disruption of supply
of money, food, water, energy or fuel, disruption of system of communication,
disruption of facilities for transport, or disruption of services relating to
health.”[17]
As the
definition is vague, it causes a huge confusion concerning the application of
this provision. This profession has been incorporated under the Doha
declaration to grant compulsory licensing to protect public health. As the
circumstances of granting the compulsory licensing is not defined it fails the
objective of DOHA declaration.
3.
Trends during pandemics
The scenario of
the HIV crisis in South Africa in 1990, shows the picture hoe the TRIPs
agreement could affect an LDC in the non-accessibility of pharmaceuticals. The
South African government's implementation of the Medicines and Related
Substances Act 1997 shows the efforts made by the government to protect its
country from health crises. This initiative was made as the government cannot
afford high-cost ANTI-HIV drugs from the US. The government introduced Parallel
importation of drugs as well as licensing for manufacturing of the drugs. This appealed
to various MNCs.
COVID-19, still
a serious threat affected the public health systems of various countries since
December 31, 2019. Declaring COVID as a pandemic from 11th March,
led to huge international concern over the matter. The Pandemic has taken over
1.5 million of life by November 2020. The limited manufacturing of vaccines and
non-availability of vaccines oxygen cylinders and other drugs related to the
treatment of covid faced by various developed as well as developing countries. The
trends of patent applications filed during the pandemic as per the report of
WIPO ‘Exploring COVID-19
Vaccine Patents’[18] is
given below:
The above data
clearly shows the patent application filed for COVID-19 drugs and therapeutic
peaked from March to May 2020. The declaration of COVID-19 as a pandemic on 11
March shows the need for the vaccines in the month of March. Still, about 120
applications have been filed during that period of urgency. This shows the need
for a stricter definition of national emergency so that the member states could
make major steps at the time of the pandemic including compulsory licensing. The
urgent situations of the pandemic were used by various MNCs to protect their
profit by patenting the drugs. The MNCs are using the patent as a strong tool
to protect their profit, not their intellectual property rights. The US asked
their MNCs to reduce their price in their territory during the outbreak of
Antrax. However, no initiatives were taken by the US to reduce the cost outside
their territory in order to make them affordable for the developing and least
developed countries. In this scenario India has made a drastic approach to wave
the intellectual property patents. India and South Africa on 2nd
October 2020, made a joint proposal for waiver of patent on the therapeutics
and drugs concerning COVID-19 pandemic. Two years of battle have ended as WTO
adopted the Ministerial decision on TRIPs agreement for the Partial waiver of
intellectual property rights on COVID-19 vaccine on June 2022. However the same
was opposed by developed nations including Australia, Brazil, Canada, EU, Switzerland,
Japan, Norway, UK and US. This shows the egotistical strategy of the developed nations to enhance
their national income by allowing their MNCs to marketize the health care needs
of LDCs.
CONCLUSION
“One should not forget
that the patents represent an interventionist instrument, ultimately for the
sake of community welfare. Thus intervention to restrict some of the effects of
patents may be required, when the community welfare is no longer served.”
Michael Kern
TRIPS and the Doha Declaration
considered compulsory licenses as a life-saving weapon to meet the cry of LDCs.
The main aim of compulsory
licensing is to improve access of the public to patented expensive medicines.
It also helps the development of the generic pharmaceutical industry in
developing countries like India. In low-income countries. It plays a
significant role by allowing the government to import affordable medicines from
any part of the world. But if a country goes on a spree to grant compulsory
licenses as a regular measure for abuse of IPRs and anti-competitive practices
then it may shrink the foreign direct investment of a country. This arrangement
can lead to low investment in R&D. This may restrict the formation of new drugs
as well as processes.
Even though compulsory licensing is
an effective initiative to implement the TRIPs Agreement, it cannot be the most
appropriate mechanism. An appropriate definition for national emergency still
remains a question to be considered. This criticism itself restricts the major
outcome. Declaration of national emergency being a question prohibits
appropriate steps during urgent situations like the COVID-19 pandemic. The
government has to take appropriate steps to enlist the “essential medicines”
according to the Indian scenario. The drug which is restricted to the major
portion of the Indian population should be enlisted. The definition which
includes an exhaustive list of these drugs should be framed. The government can
also use the provision to acquire the patented invention for its use in return for
some compensation to the patentee can also aid in providing affordable
drugs.
[1] INDIA CONST, art 21.
[2] Ibid.
[3] Chander Udhay Singh, Indian
Patent Act of 1970 has fettered the transfer of technology to India: Govt,
India Today,
www.indiatoday.in/magazine/economy/story/19840615-indian-patent-act-of-1970-has-fettered-the-transfer-of-technology-to-india-government-803049-1984-06-14.
[4] Supra no1.
[5] Robert A. Choate and William H.
Francis, Patent Law, Trade Secrets- Copyrights-Trademarks, (West publishing Co.
Second Edition 76, 1981).
[6] Agreement on Trade Related
aspects of Intellectual Property Rights, Apr. 15, 1994, Marrakesh Agreement
Establishing the World Trade Organization, Annex 1C, 1869 U.N.T.S. 299, 33
I.L.M. 1197 (1994) [hereinafter TRIPS Agreement] Article 31.
[7] ibid.
[8]Indian Patent Act, 1970, Act of
Parliament, 1970 (India), Chap XVI, sec 31.
[9] supra no7.
[10] The United Nations
Secretary-General’s High-Level “Panel on Access To Medicines” (Sept 2016), p.27
Recommendation 2.6.1 (b). In addition, recommendation 2.6.1 (c) urges the
revision and adoption of the Doha Declaration paragraph 6 decision.
https://www.politico.eu/wp-content/uploads/2016/09/HLP-Report-FINALSept-2016.pdf
(last visited on March 12, 2025)
[11] Supra note9.
[12] Indian Patent Act, 1970, Act of
Parliament, 1970 (India), Chap XVI, sec. 84.
[14] Bayer corporation v. Natco
Pharma Limited, 2014(60) PTC 277(BOM).
[15] Bristol-Myer Squibb Company
& Ors vs Mr. J D Josh, I.A.No.15720/2009.
[16] World Trade Organization,
Ministerial Declaration of 14 November 2001, WTO Doc. WT/MIN(01)DEC/1,41 ILM
746,2002 Para 6.
[17]
National Emergency Definition, Duhaime's Law Dictionary,
http://www.duhaime.org/LegalDictionary/N/NationalEmerge ncy.aspx (Last visited
on 19 March, 2025)
[18] Exploring COVID-19 Vaccine
Patents, WIPO, https://www.wipo.int/en/web/patent-analytics/exploring-covid-19-vaccine-patents,
(Last visited on March 20, 2025)
Article Information
ACCESS TO AFFORDABLE MEDICINE- WHETHER COMPULSORY LICENSING AN APPROPRIATE MECHANISM
Authors: ANJALI S NAIR
- Journal IJLRA
- ISSN 2582-6433
- Published 2025/03/29
- Issue 7
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International Journal for Legal Research and Analysis
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- ISSN 2582-6433
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