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FROM PRECISION TO CONFUSION: THE FALLOUT OF LITERAL INTERPRETATION IN VIDARBHA VERDICT BY – MUSKAN & ABHIGYAN THAKUR
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FROM PRECISION TO CONFUSION: THE
FALLOUT OF LITERAL INTERPRETATION IN VIDARBHA VERDICT
AUTHORED BY – MUSKAN
Research Associate, Insolvency and
Bank Board of India
CO-AUTHOR - ABHIGYAN THAKUR
High court of Jharkhand
The Supreme Court in an order dated 12
July, 2022 ruled out that the use of the word ‘may’
for S.7(5)(a) of Insolvency and
Bankruptcy Code, 2016, hereinafter referred as IBC provides the adjudicating
authority with discretionary power to admit or reject an application made by
the financial creditor for initiation of CIRP with the reasoning that the
establishment of ‘debt’
and ‘default’ merely
gives right to the financial creditor to file an application under the
concerned provisions but doesn’t mandatorily necessitates the admission of such
application by the adjudicating authority.
This article aims to examine the
question of whether the proceedings under S.7 of IBC, even after fulfilling the
test by establishing a ‘debt’ and ‘default’,
for a financial creditor, shall remain pending until there is a
resolution granted to the related disputes. The article aims to critique the
decision of Supreme Court as being violative of the objectives of IBC and
analyse the legal reasoning and its impact on the CIRP.
Background:
Vidarhbha Industries Power Limited is
a company which generates electricity using Coal-Fired Thermal Power Plant in
Maharashtra. Through a bidding process, Vidarhbha Industries Power Limited won
a contract to set up a power project, later converted into an independent power
project. The Maharashtra Electricity Regulatory Commission (MERC) approved the
Power Purchase Agreement (PPA) between Vidarhbha Industries Power Limited and
Reliance Industries Limited which allowed Reliance Industries Limited to buy
power from Vidarhbha Industries Power Limited.
In 2015, MERC set final tariffs for
Vidarhbha Industries Power Limited power plant for the financial year 2014-2015
and 2015-2016. MERC capped the tariffs for the years 2016-2020 even after the
request to adjust for the increased cost of coal by Vidarhbha Industries Power
Limited. The Appellate Tribunal of Electricity (APTEL) awarded Vidarhbha
Industries Power Limited a sum of Rs.1730 Crores in 2016 which was never
receieved by Vidarhbha Industries Power Limited as MERC challenged the award in
Supreme Court, for which the appeal is pending, leaving Vidarhbha Industries
Power Limited without funds and unable to clear the dues pending to its
creditors.
Axis Bank Limited, the financial creditor
of Vidarhbha Industries Power Limited filed an application to initiate CIRP
under S.7(2) of IBC before the National Company Law Tribunal (NCLT), Mumbai for which Vidarhbha
Industries Power Limited filed a Miscellaneous Application before NCLT seeking
stay on the proceedings, until the delivery of the judgement of the appeal
filed by MERC in the Supreme Court, giving reasoning that Vidarhbha Industries
Power Limited is financially healthy and it is only because of the pending
appeal, the debts are due and could not be paid at that moment. However, NCLT
rejected the application seeking stay, holding S.7 as mandatory and holding
that, the appeal pending would have no impact on the proceedings of CIRP under
S.7 of IBC. Vidarhbha Industries Power Limited approached NCLAT, which held
that the there is no justification to stall the CIRP process, therefore, the
appeal stands dismissed.
In 2021, Vidarhbha Industries Power
Limited filed an appeal before Hon’ble Supreme Court and the question of
whether the Adjudicating Authority can decline to admit an application under
S.7(5)(a) even after fulfilling the test by establishing a ‘debt’ and ‘default’ for a financial creditor was brought into limelight.
The Supreme Court ruled out that the
use of the word ‘may’ for S.7(5)(a) of IBC does provide the adjudicating
authority with discretionary power to admit or reject an application made by
the financial creditor for initiation of CIRP with the reasoning that the
establishment of ‘debt’ and ‘default’ merely gives right to the financial
creditor to file an application under the concerned provisions but doesn’t
mandatorily necessitates the admission of such application by the adjudicating
authority.
The decision provided by the Supreme
Court lacks some issues identified in this judgement.
Issues:
1.
Whether the Adjudicating
Authority can decline to admit an application under S.7(5)(a) even after
fulfilling the test by establishing a ‘debt’ and ‘default’ for a financial creditor?
2.
If the Adjudicating Authority
declines to admit an application under S.7(5)(a) even after fulfilling the test
by establishing a ‘debt’ and ‘default’ for a financial creditor, is it
not violative of the objectives of IBC?
3.
Can a pending proceeding, be a
ground to reject an application under S.7(5)(a) for a financial creditor? Did
the judgement give rise to ambiguity for the grounds of the adjudicating
authority having a discretionary power to admit the application under S.7(5)(a)
for a financial creditor?
The
Discretionary power of Adjudicating Authority
NCLT when looked into the matter,
emphasised on the importance of IBC
“19.
The Code is a special legislation. The chief object of which is to decide the
Petition in a time bound manner and take adequate steps to see that the
Corporate Debtor remains a going concern even during the process of CIRP.
20. The Hon’ble Apex Court in Swiss Ribbons v.
Union of India & Anr. : (2019) 4 SCC 17 have set the tone for the
proceeding before the Adjudicating Authority in order to make all endeavour to
dispose of the matter in a time bound manner.
The observation of the Hon’ble Court
may profitably be quoted as under:
“As
is discernible, the Preamble gives an insight into what is sought to be achieved
by the Code. The Code is first and foremost, a Code for reorganisation and
insolvency resolution of corporate debtors. Unless such reorganisation is
effected in a time-bound manner, the value of the assets of such persons will
deplete.
xxx xxx xxx
Timely resolution of a corporate
debtor who is in the red, by an effective legal framework, would go a long way
to support the development of credit markets.
xxx xxx xxx
The timelines within which the
resolution process is to take place again protects the corporate debtor’s assets from further dilution, and also protects all its
creditors and workers by seeing that the resolution process goes through as
fast as possible so that another management can, through its entrepreneurial
skills, resuscitate the corporate debtor to achieve all these ends.”
21. The observation would indicate
that no other extraneous matter should come in the way of expeditiously
deciding a Petition either under Section 7 or under Section 9 of the Code. The
inability of the Corporate Debtor in servicing the debts or the reason for
committing a default is alien to the scheme of the Code. The averments made in
the instant Application would indicate that various factors apparently hindered
the Corporate Debtor from carrying on its business. There were disputes between
the Corporate Debtor and the recipient of the energy as well as the change in
supply chain management of the recipient of the energy may also have
contributed to the lack of confidence between the entities. Be that as it may,
the dispute of the Corporate Debtor with the Regulator or the recipient would
be extraneous to the matters involved in the Company Petition. The decision in
the matters pending before the Hon’ble Apex Court and other authorities
would hardly have any bearing and impact on the issues involved in the present
Company Petition under Section 7 of the Code.
22. This Authority is required only to
see whether there has been a debt and the Corporate Debtor defaulted in making
the repayments. These two aspects when satis^ed would trigger Corporate
Insolvency. Therefore, the decision of the Authorities as well as of the Hon’ble Apex Court would not affect the proceedings before this
Authority one way or the other. Therefore, we are of the considered opinion
that this Authority need not stay its hands from considering the Company
Petition as prayed for. As it is, there has been a considerable delay in
disposal of the Company Petition. It will accordingly be appropriate that the
Company Petition is disposed of as expeditiously as possible. Hence ordered.
The Application be and the same is rejected on contest. There would however be
no order as to costs.”
After passing this judgement, when
brought up in the appellate court, NCLAT held:
“On consideration of the issues raised
in this Appeal we are of the considered opinion that the Appellant has no
justification in stalling the process and seeking stay of CIRP, which in
essence has manifested in blocking the passing of order of admission of
Application of Respondent under Section 7 of I&B Code. There is no merit in
Appeal as we find no legal infirmity in the impugned order. The Adjudicating
Authority is conscious of the mandate of law and the course it has to take as
per I&B provisions, which practically stands stalled. This is
impermissible. The now of legal process cannot be permitted to be thwarted on
considerations which are anterior to the mandate of Section 7(4) & (5) of
I&B Code. The Appeal being devoid of merit is dismissed. However, we do not
propose to impose any costs.”
The Supreme Court held:
The language of S.7(5)(a) of IBC
compared to S.9(5) of the IBC, it can be clearly observed that the use of word ‘may’
in S.7(5)(a) and the use of word ‘shall’ in S.9(5) serves different purposes
for both provisions. Therefore:
“89. In this case, the Adjudicating
Authority (NCLT) has simply brushed aside the case of the Appellant that an
amount of Rs.1,730 Crores was realisable by the Appellant in terms of the order
passed by APTEL in favour of the Appellant, with the cursory observation that
disputes if any between the Appellant and the recipient of electricity or
between the Appellant and the Electricity Regulatory Commission were
inconsequential.
90. We are clearly of the view that
the Adjudicating Authority (NCLT) as also the Appellate Tribunal (NCLAT) fell
in error in holding that once it was found that a debt existed and a Corporate
Debtor was in default in payment of the debt there would be no option to the
Adjudicating Authority (NCLT) but to admit the petition under Section 7 of the
IBC.
91. For the reasons discussed above,
the appeal is allowed.”
Breakdown of S.7 IBC
S.7(5)(a) of IBC, 2016 says that
“Where the Adjudicating Authority is
satisfied that—
(a)
a
default has occurred and the application under sub-section (2) is complete, and
there is no disciplinary proceedings pending against the proposed resolution
professional, it may, by order, admit such application”
This implies that once twin test of
debt and default has been establishedn and the adjudicating authority is
satisfied that the default has occurred then it may admit the application of
the financial creditor. The use of the word ‘may’ gives a discretionary power
to the adjudicating authority which was brought up in this case.
It has become evident from a closer
examination of S.7(5)(a) that the adjudicating authority only needs to satisfy
itself to the extent of occurrence of default, the completion of the
application and credentials of the proposed resolution professional. The
criteria to trigger the CIRP is the occurrence of default. As per Innoventive
Industries Ltd. V. ICICI Bank and Anr., the Supreme Court interpreted
the provisions of S.7(5)(a) focusing on the process and criteria for the
admission of application to initiate CIRP and observed that the adjudicating
authority has been granted the freedom to withhold the admission of CIRP only
until the procedural requirements are satisfied. It stated that “The moment
the adjudicating authority is satisfied that a default has occurred, the
application must be admitted unless it is incomplete, in which case it may give
notice to the applicant to rectify the defect within 7 days of receipt of a
notice from the adjudicating authority.”
“30. On the other hand, as we have
seen, in the case of a corporate debtor who commits a default of a financial
debt, the adjudicating authority has merely to see the records of the
information utility or other evidence produced by the financial creditor to
satisfy itself that a default has occurred. It is of no matter that the debt is
disputed so long as the debt is “due” i.e. payable unless interdicted by
some law or has not yet become due in the sense that it is payable at some
future date. It is only when this is proved to the satisfaction of the
adjudicating authority that the adjudicating authority may reject an
application and not otherwise.”
“59. The obligation of the corporate
debtor was, therefore, unconditional and did not depend upon infusing of funds
by the creditors into the appellant company.”
In this perspective, the SC made it
obligatory for adjudicating authority to admit the application and along with
that declared that the adjudicating authority can reject the creditor’s
application only if it isn’t convinced that the default has occurred based on
the evidence provided and not otherwise. It also states that irrespective of
any additional financial support, the Corporate Debtor has an unconditional
obligation to repay debt. The same was reiterated in the case of E.S.
Krishnamurthy V. Bharath Hi-Tech Builders Pvt. Ltd. and it was also
held that the adjudicating authority cannot force the involved parties to
negotiate a settlement. Therefore, the interpretation of SC in Vidarhbha
Industries Power Limited V. Axis Bank Limited for S.7(5)(a) of IBC
appears to be incorrect and goes against the legislative intent.
Intention of
IBC
The SC in Innoventive Industries case
held that the focus needs to be triggering of CIRP by establishment of default
and not on the disputes raised by the Corporate Debtor. In the Swiss Ribbon’s
case, it was highlighted that the primary objective of IBC is the resolution in
a time bound manner. The judgement laid down in this case, deviates from the
foundational principles laid out in the Bankruptcy Law Reforms Committee (BLRC)
report which says that “The Committee set the following as objectives
desired from implementing a new Code to resolve insolvency and bankruptcy:
1. Low time to resolution.
2. Low loss in recovery.
3. Higher levels of debt financing across
a wide variety of debt instruments.”
IBC aims to initiate CIRP quickly to
prevent the economic value of the assets from depleting and to maximise returns
to the creditors. The SC also held that the 14-day timeline to determine the
admissibility of a CIRP application, if extended, must record the reasons for
the breach of timeline. Despite this clear intent, as provided in BLRC report
that “The Code will ensure a time-bound process to better preserve economic
value.” The case was delayed for more than an year since the application
fir CIRP was filed and due to the pendency of the appeal, no action was taken.
In contrast with the timelines of IBC, the judgement in this case held that
there’s no fixed time limit within which the application under S.7 must be
admitted. This judgement therefore, undermines the legislative intent,
increases delays and violates the objectives of IBC.
Chaos in Courts
While relying on this judgement, in
the case of Bank of Maharashtra V. Newtech Developers & Developers
Pvt. Ltd., NCLT exercised its discretionary power to reject the
application by giving the reasoning that even after the establishment of ‘debt’
and ‘default’, which according to the BLRC report and intention of IBC is
enough to trigger the CIRP and admit the application, would have negatively
impacted the interests of homebuyers who had invested in the projects.
However, a contrasting judgement
passed in the case of Indusland Bank Ltd. V. Hacienda Projects Pvt. Ltd.,
wherein the corporate debtor pleaded that despite the ‘debt’ and ‘default’,
the overall financial health of the company was good and still viable, since it
has almost completed the Project, NCLT while admitting the application for
CIRP, held that if the company would have been financially sound, it wouldn’t
have defaulted in the payment of its debt. Therefore, the sole parameter of
completion of Project can’t judge the overall health and viability of the
company.
In another case of Central Bank
of India V. Simplex Infrastructures Limited, NCLT held that “it is
seen that the Corporate debtor is undergoing a transient insolvency due to a
financial failure and it is a matter of time that it is able to liquidate these
awards and payoff the creditors in good time which is in any case not going to
be short, even if the management of the enterprise is changed, the business
model of the Corporate Debtor being prudent.”
“7. (xv) Furthermore since the business
model of the Corporate Debtor is not a faltered one- it works as a construction
company on EPC and other form of contracts - the larger issue of the quality of
the tender documents, the competition in the sector, the delay in the execution
of the works due to various hinderances – both attributable to the owner and
attributable to the Corporate Debtor and also various permutations thereof – remains
unchanged even after the change of management through the resolution process.”
(xvi) As such we are not satisfied in
terms of Section 7 (5)(a) that this application needs to be admitted for if
that was done it might create a larger harm to the Corporate Debtor.”
In the case of State Bank of
India V. Krishidhan Seeds Pvt Ltd, NCLT held that “the facts which are
placed before us by the corporate debtor make us think that it is not proper
for us to admit the corporate debtor in CIRP at once. We do not wish to reject
this application also. In our considered opinion, the management of the
corporate debtor is trying hard to take the company out of the debt trap. We
must give them some time. We believe their intention to settle the dues with
other creditors. Hence, instead of admitting the corporate debtor in CIRP or
rejecting this application, we think it proper to keep this proceeding in
abeyance for six months from today. We make it clear that if the corporate
debtor fails to settle the due debts, we will pass further orders. We further
direct the Corporate Debtor not to sale the mortgaged assets of the Corporate Debtor
to SBI without consent of the State Bank of India.”
In the case of HDFC Bank Ltd. V.
John Energy Ltd., NCLT held that “We put on record that the other
lenders are ready to cooperate with the Corporate Debtor to pull itself out of
the debt trap. Only HDFC Bank wants us to admit the Corporate Debtor in CIRP
for their own reasons which we do not wish to endorse.
22. So, on considering all the above
facts, and more particularly, the Corporate Debtor has in its hand the
contracts worth of Rs.711.18 Crores whereas total debt payable to HDFC Bank is
Rs. 86.21 Crores and other lenders are ready to restructure the loan, we hold
that it is not proper on our part to admit the Corporate Debtor in CIRP at once
at this stage.”
Since the discretionary power being
established in Vidarbha judgement, the trend of citing this judgement has
introduced a broader array of considerations. It has led to NCLT keeping the
application at abeyance on the ground that it believes that the company’s
management is trying to fix its financial standing and therefore are willing to
give the company some time to settle debts.
The Supreme Court’s judgement in the
case of M. Suresh Kumar Reddy V. Canara Bank & Ors., held that “it was clarified by
the order in review that the decision in the case of Vidarbha Industries was in
the setting of facts of the case before this Court. Hence, the decision in the
case of Vidarbha Industries cannot be read and understood as taking a view
which is contrary to the view taken in the cases of Innoventive Industries and
E.S. Krishnamurthy . The view taken in the case of Innoventive Industries still
holds good.”
This Supreme Court judgement for
holding S.7(5)(a) as mandatory is at complete odds with the Vidarbha verdict
which holds it to be discretionary. However through this ruling, it has been
made clear that the discretionary power of the Adjudicating authority cannot be
entertained in the cases of established defaults. The reliance of Vidarbha
Industries was placed as:
“86. Even though Section 7(5)(a) IBC
may confer discretionary power on the adjudicating authority, such
discretionary power cannot be exercised arbitrarily or capriciously. If the
facts and circumstances warrant exercise of discretion in a particular manner,
discretion would have to be exercised in that manner.
87. Ordinarily, the adjudicating
authority (NCLT) would have to exercise its discretion to admit an application
under Section 7 IBC and initiate CIRP on satisfaction of the existence of a
financial debt and default on the part of the corporate debtor in payment of
the debt, unless there are good reasons not to admit the petition.
88. The adjudicating authority (NCLT)
has to consider the grounds made out by the corporate debtor against admission,
on its own merits. For example, when admission is opposed on the ground of
existence of an award or a decree in favour of the corporate debtor, and the
awarded/decretal amount exceeds the amount of the debt, the adjudicating
authority would have to exercise its discretion under Section 7(5)(a) IBC to
keep the admission of the application of the financial creditor in abeyance,
unless there is good reason not to do so. The adjudicating authority may, for
example, admit the application of the financial creditor, notwithstanding any
award or decree, if the award/decretal amount is incapable of realisation. The
example is only illustrative.”
Despite this Supreme Court judgement,
the grounds for the discretionary power to be exercised by NCLT is still
ambiguous. The ruling clarified that the discretion is limited and he
application must be generally be admitted if there’s an established default.
However, it didn’t provide a clear framework for what constitutes as valid
grounds for the rejection of the application. It’s been made quite clear that
the NCLT may refuse admission if there are substantial reasons not to do so,
but it doesn’t specify definite set of criteria for such rejection.
Additionally, both the Supreme Court’s judgement deviated from the foundational
principles laid out in BLRC report, which clearly states that:
“1. The law must explicitly state that
the viability of the enterprise is a matter of business, and that matters of
business can only be negotiated between creditors and debtor. While viability
is assessed as a negotiation between creditors and debtor, the final decision
has to be an agreement among creditors who are the financiers willing to bear
the loss in the insolvency.
2. The legislature and the courts must
control the process of resolution, but not be burdened to make business
decisions.
3. The law must set up a calm period
for insolvency resolution where the debtor can negotiate in the assessment of
viability without fear of debt recovery enforcement by creditors.”
xxx xxx xxx
“8. The law must ensure that time
value of money is preserved, and that delaying tactics in these negotiations
will not extend the time set for negotiations at the start.”
Further the BLRC in its 2015 report in clause 3.2
has defined the insolvency of two types:
“Financial failure – a persistent mismatch between
payments by the enterprise and receivables into the enterprise, even though the
business model is generating revenues, or
Business failure – which is a breakdown in the
business model of the enterprise, and it is unable to generate sufficient
revenues to meet payments.”
Not only this, the BLRC report also
explains the role of the adjudicator as :
“The Committee recommends that the
role of the Adjudicator needs to be carefully laid out so as to both minimise
undue burden on the judiciary while simultaneously ensure the fairness and
efficiency of insolvency resolution. This is done through two sets of
recommendations from the Committee. The Committee recommends that the
Adjudicator will focus on ensuring that all parties adhere to the process of
the Code. For matters of business, the Committee recommends that Adjudicator
will delegate the task of assessing viability to a regulated Insolvency
Professional (Burman and Roy, 2015). The Adjudicator will be more directly
involved in the resolution process once it is determined that the debt is
unviable and that the entity or individual is bankrupt.”
“Resolution phase I: A calm period for
insolvency resolution
The Committee recommends two phases of
resolution, once a procedure of default resolution has been triggered. The first phase is a
collective negotiation to rationally to assess the viability of the debt. The
Committee recommends that the assessment must be ensured a calm period where
the interests of the creditors can be protected, without disrupting the running
of the enterprise. This calm period is implemented in two orders passed by the
Adjudicator. One is an order passing a moratorium on all recovery actions or
filing of new claims against the enterprise. The other is by putting in place
an insolvency professional who has the powers to take over the management and
operations of the enterprise.
Resolution phase II: Bankruptcy as an
outcome of insolvency resolution
The Committee recommends that
bankruptcy is an outcome of resolving insolvency. If the debtor and creditors
agree to change the terms of their contract during the negotiations to keep the
enterprise as a going concern, then the enterprise is viable, and the
insolvency resolution process is closed. If the negotiations fail to deliver a
solution, then the enterprise is unviable, and is deemed bankrupt. The Code
then specifies that bankruptcy resolution is immediately triggered.”
The BLRC report clearly outlines that
the viability of an entity shall not be a question of judicial discretion but
rather a business decision between creditors and the corporate debtor. This
implies that the role of the adjudicator is limited to ensuring all parties
adhere to the process laid down in the code. For the case of determining
financial viability, the adjudicator shall delegate it to the Insolvency
Professional. It shall only be after the determination of the debt as unviable
by Insolvency Professional, the adjudicator can be more directly involved for
resolution process. In order to evaluate the viability, the first phase shall
be managed by the Insolvency Professional which is appointed by the
adjudicator. However, the adjudicating authority in Vidarbha judgement, made an
early decision by assessing the debtor’s viability by acknowledging that the
financial problems are temporary and the business plan is sound. The decision
of the tribunal to deny the application shall have been limited to keeping the
attention on procedural matters rather than get unduly involved in the business
decisions.
Vidarbha judgement by interpreting
S.7(5)(a), allowed judicial discretion in assessing the viability of the entity
which evidently implied for a violation of the principles of BLRC report. The
objective of IBC to provide for a time-bound and predictable insolvency
resolution process, preserving the economic value of the assets of the
corporate debtor for its maximisation and ensuring equal rights to all
creditors is compromised by such discretion. This has clearly upheld the
legislative intent of IBC.
Conclusion
The decision of the Supreme Court in
Vidarbha Industries case, prioritises the Corporate Debtor over the legislative
intent of the code and its objectives i.e. resolution of insolvency in a time
bound manner, maximisation of the economic value of assets, promotion of
entrepreneurship, availability of credit and equal rights to all creditors.
This verdict gave rise to the existing management to keep the control to itself
rather than promoting financial discipline brought by IBC to prevent from defaulting.
The objective of IBC is to increase availability of credit but the cost of
credit increases if it’s stuck with sick units. It created a new category of
default for all the debtors to seek shelter under the new found ground of ‘temporary
default’. The BLRC report clearly emphasised on the role of the adjudicator to
be limited to overseeing proceedings and not involved itself in business
decisions.
References
1.
2022 SCC OnLine SC 841
2.
(2019) 4 SCC 17
3.
(2018) 1 SCC 407
4.
Civil Appeal Nos. 8337-8338 of 2017
5.
Civil Appeal Nos. 8766-8767 of 2019
6.
C.P. (IB) No.2465/NCLT/ND/2019
7.
C.P. (IB) No 419/NCLT/ND/2022
8.
(2022) 3 SCC 161
9.
Civil Appeal No.7121 of 2022
10.
Civil Appeal No.372 of 2017
11.
C.P (IB) No.186/KB/2021
12.
C.P (IB) 500/NCLT/MP/2018
13.
C.P (IB)/02(AHM)2022
14.
C.P. (IB) No.2456/NCLT/ND/2019
15.
The report of the Bankruptcy Law Reforms Committee Volume
I: Rationale and Design, November 2015
Article Information
FROM PRECISION TO CONFUSION: THE FALLOUT OF LITERAL INTERPRETATION IN VIDARBHA VERDICT BY – MUSKAN & ABHIGYAN THAKUR
Authors: MUSKAN, ABHIGYAN THAKUR
- Journal IJLRA
- ISSN 2582-6433
- Published 2025/03/18
- Issue 7
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