Open Access Research Article
Digital Privacy Of Children – A Need For Special Legislation
Published Paper
Article Details
Digital Privacy Of Children –
A Need For Special Legislation
Authored By - Merlin Mary D,
B.A.B.L(HONS) LL.M
Department of Constitutional Law and Human Rights
Guest Faculty,
The School of Excellence in Law,
The Tamil Nadu Dr Ambedkar Law University
Tamil Nadu- 600096
Department of Constitutional Law and Human Rights
Guest Faculty,
The School of Excellence in Law,
The Tamil Nadu Dr Ambedkar Law University
Tamil Nadu- 600096
Contact: 8939242402
Email: merlinmary1997@gmail.com
ABSTRACT
Key words:
DATA PROTECTION; PERSONAL DATA; CYBER
CRIME; PARENTAL CONSENT; DIGITAL LITERACY
The lives of children in this digital
age are mediated by digital technology. They use mobile devices to access
internet for academic purpose and entertainment. The pandemic situation has
increased the usage of mobile and other digital gadgets by the children. Some
study found that the screen time has increased among children because of online
classes. Thus, access to digital environment has become part of children lives
in this digital age. On the one hand, the digital environment exposes children
to diverse information and helps in their development. Simultaneously, it has
got negative impact on child’s physical and mental well-being. Though internet
acts as the information-hub, it poses serious threat to child’s online safety. However,
there is no comprehensive law dealing with the protection of privacy of
children in digital environment. Other countries have adopted special law
dealing with privacy of children. With increasing usage of online platforms by
children and young adults, there are serious concerns about their privacy, safety
and responsible use of such platforms. Children are more vulnerable to online
crimes and this paper sets out the pressing need for special legislation to
deal with digital privacy of children. The paper has been split into three sections.
The first section elucidates the risks and harms to children in cyberspace. The
second section of this paper spells out the international concern of privacy of
children in digital environment. The
third part expounds the national framework on data protection and privacy. It
exposes the challenges in promoting the online safety of children with
reference to the Digital Data Protection Bill, 2022. It presses the need to
enact a special legislation to protect children from cybercrimes and to promote
responsible use of internet.
I.
INTRODUCTION:
The right to privacy is not a new
concept. Yet, in recent times, privacy has gained more momentum than ever
before. In the digital age the need to protect privacy has become very
important as there is more threat to the private life of individuals. With the advent
of internet and technology, there have been so many concerns about it. One such
concern is right to privacy in digital environment. People use internet and
technology for various reasons and they leave their footprint in the digital
platform by leaving behind personal information. Recently there have been so
many issues and cases regarding tracking of individual activities by different
applications, websites, giant corporations etc. Data has become most valuable
asset. Data protection is necessary in the digital age to prevent invasion of
privacy and other crimes related to it.
Today, we are living in information
and technology world and we are profiled. Whether we consent with knowledge or
not, we provide our details to the authorities presuming that the information
will be secure. While providing such details or personal information we press
the button ‘agree’ enabling them to trade our personal information, which
increases the risk of using it for unlawful or illegitimate purposes. The
reality is we are being stalked by algorithms who profile us using our details.
There are so many threats associated with these internet activities where are
data are being mined and stored without our knowledge.
Thus
in this digital age, privacy and data protection has become one of the most
important concerns at both national and international level. This is because
violation and abuse of right to privacy may affect all individuals,
particularly women and children. The rise in new online platforms, apps and
other internet sources which collects and processes information from people
using it, has become a major threat to information privacy. It is very
important to protect and respect the right to privacy, both online and offline
to prevent violence and crime against women and children. Children are the most vulnerable groups
likely to be affected by the violation and abuse of privacy which includes
cyber stalking, cyber bullying and harassments.
Undoubtedly,
the digital era benefits child’s development in countless ways. The digital age
has opened up many new opportunities for people around the world. However, the
threats to privacy, both in the digital space and out of it, are rising at
alarming rates. Unfortunately, children are particularly vulnerable to these
kinds of attacks. The importance of children’s right to privacy has manifested
itself anew in the context of digital technologies. The existing framework primarily
addresses the issues related to child safety as well as data processing, but
not the protection of his/her dignity and reputation. This article highlights
why the existing national and international frameworks are not enough to
protect children’s digital privacy. There needs to be more stringent measures
in place to ensure that children are safe online.
II.
RISKS AND
HARM TO CHILDREN IN DIGITAL ENVIRONMENT:
Exposure to harmful content and
contact:
Internet has made it possible for
anyone to upload contents from anywhere in the world. These content providers,
often new and unprofessional content providers may be indifferent or ignorant
to the rules and regulations which their own territories adhere to. The consequence
of these factors is that children using the internet may risk exposure to
content which may pose a risk of harm for example, in the form of sexually
explicit content.
The internet enables communication in
many forms, allowing contact with both known and unknown individuals. The children
using digital platforms are exposed to harm either as recipient of abusive
messages or as a sender sending their personal information to unknown
individuals. This includes cyber grooming, where adults known or unknown to the
child take advantage of these digital platforms to sexually exploit the child.
Victims of various cybercrimes:
The 2014 report of the Parliamentary
Committee on Information Technology recognized that the online bullying of
children by their peers was probably far more common than other offences.[1].Cyber
bullying may involve “abuse and/or harassment by teasing or insulting victims’
body shape, intellect, family background, dress sense, mother tongue, place of
origin, attitude, race, caste, class, name calling, using modern
telecommunication networks such as mobile phones (SMS/MMS) and Internet (chat
rooms, emails, notice boards and groups).”[2]
While such hurtful online behaviour is unlikely to be considered as an offence
under Indian law, the severity, frequency and pervasiveness of such messages
can cause significant distress to the targeted child. The incidence of such
exposure is bound to increase as mobile technology, images and videos become
easier to access. The potent combination of anonymity, immediacy and reach in
the case of cyber bullying adds to the challenge.
One of the worst types of cybercrime
in the world is online defamation. With easy access to internet and other
social media networks, there has been potential increase of posting offensive
content against a person. The harm caused to a person by the online publication
of defamatory statements about him or her can be greater than verbal and
offline statements and can have vastly more damaging consequences. For children
in particular, the effects of online communication of sensitive personal
information, images or videos can be devastating and intimidating.
Another serious issue is revenge pornography.
Children especially teens share with consent their private pictures to
boyfriends/girlfriends. This has the risk of other person circulating such
content obtained from the child. Revenge pornography is the sharing of private,
sexual materials, either photos or videos, of another person without their
consent and with the purpose of causing embarrassment or distress. The images
are sometimes accompanied by personal information about the subject, including
their full name, address and links to their social media profiles.[3]
There are other similar crimes
against children in the cyberspace. Digital environment has become a platform
for more criminals to commit crimes at their leisure. Crimes such as online
sextortion, online sexual exploitations are increasing. However, very few
incidents are reported. In addition to this, there is behavioural harm like
internet addiction, selfie trends where children try to gain attention by exposing
themselves in the social media platforms.
Today, laws and policies try to
address these issues and provide penal provision to curb all such crimes.
However, we lack in tech-sound measures to provide a safer digital platform.
Policies identify the privacy issues and frame a privacy policy but such
policies are only to control the information of individual. Despite coming up
with so many policies and legislative frameworks and recommendations, digital
environment needs a sound digital policy framework and educating children more
about the harms and risks in the digital platform is significant.
III.
INTERNATIONAL CONCERN
ON ONLINE PRIVACY OF CHILDREN:
The
United Nations Convention on the Rights of Children (UNCRC) is an important
international human rights treaty adopted to protect the rights of the children
as children are more prone to abuses and exploitation. The UNCRC was adopted in
the year 1989 and entered into force in 1990. This international agreement is
legally binding on the member countries. It consists of 54 articles that lists
various rights of children and provides measures to be taken by the government
to implement the child rights. The Convention is based on the principle of
non-discrimination and best interest of child. The Convention has got three
optional protocol.
Right to privacy:
Every child has the
right to privacy. Article 16 of the Convention provides that every child has
the right to privacy, home and communication. They should be protected from
unlawful attacks on reputation and honour. The Convention states that the
government should protect the children from sexual
exploitation and sexual abuse, including by people forcing children to have sex
for money, or making sexual pictures or films of them.[4]
All forms of abuse and exploitation are serious intrusion into the right to
privacy of the children. It is a serious attack on their dignity and they are
the most vulnerable group. Therefore, States must ensure protection to every
child which defiles their dignity which in turn affects their right to life.
Right to life doesn’t mean mere existence but it includes everything which
makes life meaningful and worthy. Sexual abuse and other forms of exploitation
of children crush their life and no amendments in future will cure their
trauma. Therefore, it is very important and necessary to safeguard children
from social evils. They should take steps to prevent sale and trafficking of
children.[5]
Every child with a disability should enjoy life at par with other children.
Government should take necessary steps to remove all the obstacles for children
with disabilities to become independent and to participate actively in the
society.[6]
Disabled children are taken advantage of and are abused. They must be given
special attention.
Online Privacy and data protection:
Today, in the
digital age children have become victims of various online crimes. The
Committee on the Rights of the Child (CRC) published Draft document of General
comment No. 25 (2021)[7]
on children’s rights in relation to the digital environment. It speaks about
children’s right to privacy in digital environment. The use of online platforms
by the children has risen now due to pandemic situation. It is the duty of the
State to ensure a safe digital environment to children. The document provides
that interference with a child’s privacy is only permissible if it is neither
arbitrary nor unlawful. Any such interference should be allowed only if it is
permissible by law, which is intended to serve a legitimate purpose, and
designed to observe the best interests of the child. It must not conflict with
the objectives or provisions of the Convention.
The activity of
children in online platform may pose certain threats to their right to privacy.
Data are routinely collected by the data processors as most of the online
platforms require information for the proper functioning. The CRC in its
General Commentary provides that a data may include information about
children’s identities, activities, location, communication, emotions, health
and relationships. Certain combinations of personal data, including biometric
data, can uniquely identify a child.[8]
There are digital practices, such as automated data processing, profiling,
behavioural targeting, mandatory identity verification, information filtering
and mass surveillance which are becoming routine. The CRC in its comment
expresses its concern that such digital practices may lead to arbitrary or unlawful
interference with children’s right to privacy and may have adverse consequences
in their later part of lives.
Therefore,
it requires the States parties to take legislative, administrative and other
measures to ensure that children’s privacy is respected and protected by all
organizations and in all environments that process their data especially
digital platforms. It states that the national legislation should contain
strong safeguards, transparency, independent oversight and access to remedy. States
parties should require the integration of privacy-bydesign into digital
products and services that affect children.
It is the duty of the States to regularly review privacy and data
protection legislation and ensure that procedures and practices prevent privacy
invasion or accidental breaches of children’s privacy.[9]
It also provides
that children, based on their capacity or their parents or guardians or care
givers’ consent must be sought before processing data. The consent obtained
must be free. It also requires the data processors to make such stored data to
be accessible to the children and their parents and to rectify any inaccurate
data. They must also be allowed to withdraw consent where the data stored is
inappropriate and not used for legitimate purpose. Therefore, it is the duty of
the States parties to ensure access of stored data, rectify data that are
inaccurate or outdated and delete data unlawfully or unnecessarily stored by
public authorities, private individuals or other bodies, subject to reasonable
and lawful limitations.
Further, it adds
that the data protection legislation should not arbitrarily limit the children
from exercising their other rights. For example, right to expression. The
digital environment has discriminatory, pornographic and other exploitative
information. It also contains false information and information that provokes
children to engage in harmful or unlawful activity. While using internet many
inappropriate content pops up. All these information may come from different
sources including sexual offenders or other content creators. Therefore, the
States must design and implement a children- friendly policy and guidelines to
protect them from harmful content and thus enable safety in digital
environment.
IV.
INDIAN
PRIVACY LAW – ISSUES AND CHALLENGES IN SAFEGUARDING CHILDREN IN DIGITAL
ENVIRONMENT:
Privacy – Fundamental to life:
The right to privacy is an inherent
right of every human being. The Apex Court held that the right to privacy is a
constitutional right and it forms the core of right to life and personal
liberty.[10] Thus,
the right to privacy though not expressly recognised under the Constitution, it
is an implicit right under Art 21.
Art 21 of the Constitution of India
guarantees right to life and personal liberty. Art 21 states that “no person
shall be deprived of his life and personal liberty except according to
procedure established by law.” It guarantees two rights: right to life and
right to personal liberty which are natural rights.
Right to life and Privacy:
The
right to life is fundamental to the very existence of every human being. The
term ‘life’ in Art 21 doesn’t mean mere animal or physical existence but it
includes all those aspects of life, which makes a man’s life meaningful,
complete, and worth living. It is the only article in the Constitution that has
received the widest possible interpretation by the judiciary. Many rights have
found shelter under the roof of Art 21. For example, right to life includes
right to dignity, right to health, right to privacy etc. Thus, Art 21 includes
everything that forms core element of life. It is through this widest
interpretation of Art 21, the right to privacy was recognised. Just because
such a right has not been given expressly in the Constitution doesn’t mean that
it doesn’t exist. One has to understand that the right to privacy is a natural
right. The Supreme Court observed that natural rights inherent in human beings because they are
human and are not bestowed by the State. This right exists equally on every human
being irrespective of class or strata, gender or orientation.[11]
This observation makes it clear that natural rights are inalienable rights as
they are inseparable from human personality. Thus right to privacy is inherent
in every human being.
The right to life means a dignified
life. Privacy is an important element to live a dignified life. Privacy ensures
that every person can lead a life of dignity by securing inner recesses of the
human personality from unwanted intrusion.
Right to personal liberty and
privacy:
The expression personal liberty is a
comprehensive term. Personal liberty is autonomy or freedom of an individual to
make one’s choice without any unlawful restriction or coercion or interference
by the State or other external restrains. In order to exercise personal
liberty, privacy is essential. Privacy forms the basis of all liberty because
it is in privacy that the individual can decide how liberty is best exercised.
It recognises individual autonomy and the right of every person to make
essential choices which affect the course of life. In doing so privacy
recognises that living a dignified life is necessary for a human being to
fulfill the liberties and freedoms which are the cornerstone of the
Constitution.
Though the Constitution does not
expressly declare a right to privacy, the said right is essential ingredient of
personal liberty. As already said, privacy protects the autonomy of the
individual to control choices in one’s life. It is privacy which recognises
individual’s ability to control vital aspects of his or her life. The personal
choices governing a way of life are innate to privacy.
Understanding
Privacy in Digital environment:
Impact of pandemic has
led to the boom of E-learning and edu-tech platforms. Also, children born after
2010 (Generation Alpha), have grown up in a fully digital world. This means
that children are online more than ever and their personal data is being
accessed and used at increasingly greater rates. However, laws relating to
children in India deals with the penal aspect of crimes against children.
Therefore, special law for children’s privacy is the need of the hour. Our laws
do not focus on designing a safer digital space.
First, we should understand that the
term “privacy” is not possible to be defined. It is said that attempt to define
privacy has ended up only in classifying it based on the ways it is violated or
infringed. Solove has rightly asserted
that privacy is best understood as a “family of different yet related things.”[12]
Thus, privacy has been classified into seven types in the context of emerging
new technologies:[13]
i.
Privacy of person: The privacy of person also
known as ‘bodily privacy’ protects the integrity of individual’s body. It is
the right to protect the body from intrusions and tortures and to keep body
functions and characteristics such as biometrics private.
ii.
Privacy of behaviour and action:
This aspect
of privacy includes the sensitive issues such as sexual orientation, sexual
behaviour and action, religious activities etc. This privacy of personal
behaviour covers activities both at public and private places.
iii.
Privacy of Communication: This type of privacy is
about conversations in telephone, mail and other forms. It aims to prevent the
interceptions of communications and recording or unlawfully accessing the
messages. The privacy of communication enables free discussion and to dissent
and thereby enables growth of communication sector.
iv.
Privacy of data and image: The privacy of data and
image is to control access of one’s data and image. Today this privacy is very
important more than ever as people use online platforms to share their data and
images.
v.
Privacy of thoughts and feelings:
The privacy
of thoughts and feelings is the right of individual to share or not to share their
feelings and thoughts.
vi.
Privacy of location and space: Today technology has enabled
tracking and monitoring of individual movement. The privacy of location and
space means that the individual have the right to move in public or any space
without being identified and monitored.
vii.
Privacy of association: The privacy of association
speaks about right to associate with whoever they wish.
Thus, privacy in digital
environment is concerned more about consent, choice and control of one’s
personal information and everything that falls under the private zone of
individual. Privacy being a dynamic concept takes different shapes in different
context.
Data Protection Bill, 2022 on privacy of children:
The laws in India protect
children from abuse and provides safeguard to them. IPC, POCSO, IT Act play a
major role in dealing with offences committed against children. However, laws
cannot deter crimes against children. Ensuring child’s privacy is the joint
responsibility of their parents/ guardians and stakeholders handling their
data. Online privacy is concerned with the control of one’s personal data. The current
law mandates the data controllers to obtain consent of the data subject prior
to collection of their personal data. But there is no separate provision differentiating
the consent of the minors/ children. It just provides a general provision on
consent of data subject. This has led to criticism as the Indian Contract Act
makes the minors incompetent to contract. Their consent has no legal validity
till they attain majority. Therefore, obtaining consent of the parent/ guardian
to collect child’s data is necessary. However, most parents take help of their
children to use and access internet and other digital platforms. Applications
that require age data request users to enter their date of birth. And it is easy for the minors to enter
desirable input regarding age making them appear as over 18.In this case they are still children but the content that
will be presented to them would be those that are meant for adults including
content that might be disturbing or those involving use of alcohol and
gambling. Additionally, in their privacy policies, applications sometimes state
that they are not suited for and restricted from users under 18. Here, data
fiduciaries avoid liability by placing the onus on the user to declare their
age and properly read and understand the privacy policy.
Parental Consent under the 2022 Bill:
Under the draft Digital Personal Data Protection Bill, 2022 ("2022 Bill"), a
"child" means an individual who has not completed eighteen years of
age.[14] The
Bill mandates the data fiduciaries to obtain verifiable parental consent before
processing their personal data.[15] Additionally, the 2022 Bill also restricts
any tracking or behavioural monitoring of children or targeted advertising towards
children. Treating individuals under 18 as children may not be suitable for
data privacy governance since children between 13 and 18 use digital platforms
to avail different services for academic purposes. It is not possible for them
to get parental consent every time they switch platforms. The children below 18
years may be categorised based on their mental maturity. Children between 13
and 18 maybe treated as young adults. Even IPC speaks about the mental maturity
of the children below 18 years. And children between 12 and 18 years can be
punished for offences committed by them. And children between 16 and 18 years
of age can be tried for heinous offences. Therefore, classifying children below
18 years based on mental maturity is necessary. Our government has taken this
conservative view as children below 18 years are more vulnerable to
cybercrimes. However, gating them and requiring parental consent every time
they access internet and other platforms, would act as a barrier. Therefore,
educating children about cyberspace, risks and harms attached to it and the
consequences of every act done in digital platforms may be taught in schools as
a practical session. Educating children alone can make them more safe and
prevent them from unnecessary risks.
V.
CHALLENGES
IN SECURING SAFE CYBERSPACE – NEED FOR SPECIAL LAW:
Principle of Consent: As discussed
already, the proposed Bill is based on the principle of consent. Classifying
children on certain factors like age, maturity, purpose of internet usage or
access to platforms are to be considered. Even educated adults blindly consent
to the terms and conditions of the policies. Both children and adults must be
aware of the terms of the policies to which they consent to. Also, some
applications wouldn’t work if we do not give consent and deny permission to
access our personal information. Such norms leave us with no option but to
agree to the terms and conditions to enable access to the concerned platform.
The Bill makes provision for withdrawal of consent by the data subject. This
could affect the access to particular service when we deny consent.
No Special Law: India has special laws that protect and prevents
children from various crimes committed against them in physical environment. Very
few provisions deal with online crimes committed against children. As such, it
would be better if we enact a separate law for child’s privacy protection
rather than covering them under the ambit of data protection bill. A
comprehensive legislation that focuses on dealing with every aspect of digital
activity of children and its consequences would secure a safe cyberspace for
children.
Lack of technology savvy skills: Developing technological traits
and using them in our daily life would resolve many concerns about privacy.
Technology skills are crucial in one’s life and authorities who are appointed
for redressing grievances and other legal issues must have sound knowledge
about cyber security and other technical knowledge. Hence, educating children
and adults about cyber laws and safe and responsible use of technology is fundamental.
Address and redress: Our laws are concerned with addressing the
problem and redressing them. However, focus on address and redress alone
doesn’t achieve the object and purpose of law. Address and redress do not nip
the crimes in the bud. Emphasizing on designing a safer platform for children,
devices and applications that are child-friendly and limited access can be
made.
Ignorance of Digital knowledge/ Digital literacy: Children cannot
escape from risks and harms attached to digital environment unless they are
educated and trained to use it safely. Ignorance of digital knowledge can
mislead the children and increase the risk of becoming victims of cybercrime.
Hence, including a subject on digital world is indispensable in this digital
age.
Quick response and Redressal: Immediate response on the part of authorities
in taking necessary actions when faced with serious issues is important. Most
cybercrime against children go unreported. Children must be aware of the
redressal mechanism and quick response can impart confidence in the minds of
public. Instead of treating them as victims and sensitising the issue, it is
important to teach them their right to complaint against violation of their
rights and take appropriate action against immediately. Redressal mechanism
must be child-friendly.
Awareness on ways and means to elude risks and responsible use of
digital platform: People tend to be
indifferent towards things they are unaware of. No matter how serious the issue
is, only when they have sufficient knowledge in the subject matter, they engage
and be a part of government policies in promoting safer and responsible use of
digital environment.
Thus, the existing framework has got so many challenges in
protecting the privacy of children. Therefore, it is necessary to enact a
separate law throwing special attention on the privacy of children in digital
environment. Internet usage has become inevitable among children of digital
age. It is suggested that we create a
new digital environment for children where they grow and develop safe and enjoy
crime-free digital space. This cannot be achieved without a comprehensive law
on digital privacy of children. Also, the existing legal framework or the
proposed Bill on data protection is insufficient to uphold and protect the
right to privacy of children in digital environment. Hence, need for a special
law is expedient.
VI. CONCLUSION:
This paper has stressed on the need for laws that safekeep
children online. Given the growing reach of digital technology among children,
there is dire need for a special law dealing with data privacy rights of
children. Other countries have laws to protect the online privacy of child.
Children are prone to sharing personal information without much thought. As a
consequence, they pose risk to themselves and suffer from mental trauma of
being a victim to online crimes. Therefore, creating or designing a safe zone
for children is necessary. Special apps can be designed for them where there is
no threat of privacy violation. Phones and gadgets are now available at cheap
cost, where even children have a personal mobile phone. Devices for children
which have limited access to networks and other platforms will safeguard
children from serious crimes committed against them.
Digital privacy is more
concerned with the data protection and information privacy. Though the 2022
Bill deals with the information privacy of individuals where information are
collected, regulated and processed on the principle of consent, the Bill does
not protect privacy. It regulates privacy based on our choice and consent.
Therefore, this Bill does not protect or safeguard children from any harm or
threat. It just stores and regulates the personal data of children based on the
consent of the parents/ guardians. Hence, this paper emphasizes the need for
special legislation to address the privacy issues of children. And to take
measures to design a safe digital environment for children.
[1] Standing Committee on Information
Technology (2013-14), Fifteenth Lok Sabha, Ministry of Communications and
Information Technology, Department of Electronics and Information Technology,
“Cyber Crime, cyber security and right to privacy” 52nd Report , New
Delhi, February, 2014.
[2] Jaishankar,
K., Cyber Bullying: Profile and Policy Guidelines. Tirunelveli: Department of
Criminology and Criminal Justice, Manonmaniam Sundaranar University, 2009.
[3] Be
Aware B4 You Share. Revenge Porn, The Facts
www.gov.uk/government/uploads/system/uploads/attachment_data/file/405286/revenge-pornfactsheet.pdf
[4] Art 34, UN Convention on Rights of Child, 20
Nov 1989. Available at https://www.ohchr.org/en/instruments-mechanisms/instruments/convention-rights-child.
[5]
Art 35 Ibid.
[8] Para 68 of General comment No. 25
(2021)[8]
on children’s rights in relation to the digital environment.
[9] Refer Para 70 of the General
comment No. 25 (2021)[9] on
children’s rights in relation to the digital environment.
[10] Justice K.S.Puttaswamy(Retd)
and Anr v. Union of India, (2017)
10 SCC 1.
[12] Solove, Understanding Privacy, 9.
[13] Rachel Finn and David Wright,
Michael Friedewald, Fraunhofer ISI, “Seven Types of Privacy” 2013. Available at : https://www.researchgate.net/publication/258892458.
Article Information
Digital Privacy Of Children – A Need For Special Legislation
Authors: Merlin Mary D
- Journal IJLRA
- ISSN 2582-6433
- Published 2023/03/29
- Volume 2
- Issue 7
About Journal
International Journal for Legal Research and Analysis
- Abbreviation IJLRA
- ISSN 2582-6433
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