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EXPLORING THE REALMS OF THE LAW OF PATENT IN INDIA TO UNDERSTAND THEIR EFFECT ON THE CORPORATE REGIME BY: AABHAS SHARMA & DR. REKHA VERMA
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EXPLORING THE REALMS OF THE LAW OF
PATENT IN INDIA TO UNDERSTAND THEIR EFFECT ON THE CORPORATE REGIME
AUTHORED BY: AABHAS SHARMA
LLM(IP) 2nd Semester, Amity Law
School,
Noida, INDIA
Enrollment No.-A03104422028
CO AUTHOR: DR. REKHA VERMA
Assistant Prof. Amity Univeristy
Uttar Pradesh, Noida, INDIA
ABSTRACT
The scope
of the study is to understand the current realm of patent law in India. The
study also aims at comparing the development of the said laws in India as
compared to the international standards and the benchmarks set. The study is
mainly limited to the laws in India and comparison is done from other countries
time and again wherever felt necessary. The study also looks into the
international development of patent law at the international level.
INTRODUCTION
A patent gives an inventor a privilege or right to
utilise his creation exclusively for his own financial gain for a predetermined
amount of time. The invention is made available for public use after the
necessary amount of time has passed, ending the inventor's control over it. The
government or the competent sovereign authority issues an instrument known as a
patent to the inventor. Any country's success depends on entrepreneurship and
innovation. It is essential for the quick development of a developing nation.
When an inventor is permitted to benefit from their innovation, the spirit of
entrepreneurship is fostered and even applauded. The role of patent law is now
clear. Making the inventor's intellectual talent his "property" and
granting it protection from being used by others protects the innovator's
profits. A spirit of entrepreneurship is encouraged as the inventor gets fairly
compensated for his idea. The entrepreneur wouldn't be compensated for his
innovation in the absence of a proper and established patent law, which would
demotivate and dissuade future entrepreneurs from pursuing their original ideas
as a business.
A patent provides a privilege or a right to an
inventor, in the form of a monopoly, to use his invention for a certain period
of time, for his own personal financial gain. After the passage of appropriate
time, the invention is made open to public use and the inventor loses his
monopoly over his invention. Patents are granted to the inventor by the
government or an appropriate sovereign authority in the form of an instrument.
The Supreme Court in Bishwanath Prasad Radhey Shyam v. Hindustan Metal
Industries,[1]
“stated that the object of patent law is to encourage scientific research, new
technology and industrial progress”.
Innovation and entrepreneurship are the key to success
of any nation. It is crucial for the fast-paced development of a growing
country. The spirit of entrepreneurship is encouraged and even rewarded when
the entrepreneur is allowed to make profits from his or her invention. Here is
where patent law comes in. It secures the profits of the innovator by making
his intellectual genius his ‘property’ and grants it protection from being used
by others. As the innovator is properly rewarded for his invention, there is a
spirit of entrepreneurial growth. In the absence of proper and well-established
patent law, the entrepreneur wouldn’t be rewarded for his innovation and would
demotivate and discourage other entrepreneurs from pursuing their innovative
idea in the form a business. To that effect, the Supreme Court in Rai
Prakash v. Mangat Ram Chowdhry,[2] said, “The
effect of grant of patent is the quid pro quo. Quid is the knowledge
disclosed to the public and quo is the monopoly granted for the term of the
patent.”
WIPO[3]
defines patent in the following words:
“A patent is an exclusive right granted for an
invention, which is a product or a process that provides, in general, a new way
of doing something, or offers a new technical solution to a problem. To get a
patent, technical information about the invention must be disclosed to the
public in a patent application.”
When it comes to creative innovations and
manufacturing processes, patent protection is awarded for a duration of twenty
years. What it is, in essence, is a territorial protection that may be
purchased or licenced. Patent protection ensures that inventions cannot be
commercialized without the prior written consent/authority of the patent owner,
who is known as the patentee. When an innovation is protected by various patent
regulations, the owner of the patent has the ability to determine who may or
may not be allowed to commercially uses the protected inventions, depending on
the conditions. A patent serves as an incentive for the innovator to continue
working on his or her invention.
In order to obtain a patent, an application must be
submitted to the patent office. It is the responsibility of the national patent
office or the regional patent office to grant patents on the basis of
applications that have been filed to the competent authorities. It should be
noted that every country has its own national patent office as well as its own
national patent law when it comes to the protection of original ideas. After
being issued, patents offer holders exclusive rights to the invention for a
defined period of time. During this time, others are prohibited from copying,
using, or selling the invention.
It is possible to obtain patent protection for
inventions that provide solutions to specific problems in the field of science
and technology. Product or method development are two examples of inventions
that are commonly made. In order for an invention to be patentable (i.e.,
novel, non-obvious, innovative step, utility, and so on), an application must
be filed with the patent office, and the invention must meet all of the
requirements for being patented in order for it to be patented.
Patents are intended to encourage disclosure, rather
than concealment, of intellectual property. A patent application is published
as a patent document, and a patent is subsequently issued by the patent office
as a patent. A patent application is published as a patent document. Patents
cover a wide range of items, including processes, commodities, apparatus, and
industrial uses, as well as inventions that are associated with them. Patents
as an Intellectual property right are essential in encouraging the growth of
innovation, which in turn acts as the foundation for the formation of new
companies.
A ‘right’ in the normal sense of words is an ‘entitlement’
over something or someone. They are the underlying normative principles that
govern what is expected of or due to persons under an existing legal system. In
the words of the famous jurist of Analytical School of Law, John Austin,
“A party has a right when another or others are bound
or obliged by law to do or forbear towards or in regards to him”.
Ihering also defines rights in a simple manner as
“legally protected interests”. The Supreme Court defined a ‘right’ in
correlation to duties in the landmark case of State of Rajasthan v. Union
of India[4]
as:
“In strict sense, legal rights are correlatives of
legal duties and are defined as interests whom the law protects by imposing
corresponding duties on others. but in a generic sense, the word ‘right’ is
used to mean an immunity from the legal power of another, immunity is exemption
from the power of another in the same way as liberty is exemption from the
right of another, Immunity, in short, is no subjection.”
Although rights have been categorised in many ways and
types, for the purpose of this research study, we look at the following
categorisation of rights Tangible Rights are often also called proprietary
rights. These rights are those rights which an individual has over tangible
things. These rights are over tangible property and are associated with the
same. Tangible property, as opposed to intangible property (which is dealt in
intangible rights) is such which can be seen and felt, such as rights arising from
ownership of land, houses, car or other such property and related to the same.
Intangible rights are those rights which are granted in relation to intangible
property. Intangible property is characterised as the creations of the mind of
an individual which the individual seeks to protect through the process of law.
Such rights arise over the creations of the mind and seek to protect the same.
These are also known as the intellectual property rights which are protected by
law. At the very basic level, these are of three types- Patent, Copyrights and
Trademarks.
A patent provides a privilege or a right to an
inventor, in the form of a monopoly, to use his invention for a certain period
of time, for his own personal financial gain. After the passage of appropriate
time, the invention is made open to public use and the inventor loses his
monopoly over his invention. Patents are granted to the inventor by the
government or an appropriate sovereign authority in the form of an instrument.
The Supreme Court in Bishwanath Prasad Radhey Shyam v. Hindustan Metal
Industries,[5]
“stated that the object of patent law is to encourage scientific research, new
technology and industrial progress”.
Innovation and entrepreneurship are the key to success
of any nation. It is crucial for the fast-paced development of a growing
country. The spirit of entrepreneurship is encouraged and even rewarded when
the entrepreneur is allowed to make profits from his or her invention. Here is
where patent law comes in. It secures the profits of the innovator by making
his intellectual genius his ‘property’ and grants it protection from being used
by others. As the innovator is properly rewarded for his invention, there is a
spirit of entrepreneurial growth. In the absence of proper and well-established
patent law, the entrepreneur wouldn’t be rewarded for his innovation and would
demotivate and discourage other entrepreneurs from pursuing their innovative
idea in the form a business. To that effect, the Supreme Court in Rai
Prakash v. Mangat Ram Chowdhry,[6] said, “The
effect of grant of patent is the quid pro quo. Quid is the knowledge
disclosed to the public and quo is the monopoly granted for the term of the
patent.”
WIPO[7]
defines patent in the following words:
“A patent is an exclusive right granted for an
invention, which is a product or a process that provides, in general, a new way
of doing something, or offers a new technical solution to a problem. To get a
patent, technical information about the invention must be disclosed to the
public in a patent application.”
When it comes to creative innovations and
manufacturing processes, patent protection is awarded for a duration of twenty
years. What it is, in essence, is a territorial protection that may be
purchased or licenced. Patent protection ensures that inventions cannot be
commercialized without the prior written consent/authority of the patent owner,
who is known as the patentee. When an innovation is protected by various patent
regulations, the owner of the patent has the ability to determine who may or
may not be allowed to commercially uses the protected inventions, depending on
the conditions. A patent serves as an incentive for the innovator to continue
working on his or her invention.
In order to obtain a patent, an application must be
submitted to the patent office. It is the responsibility of the national patent
office or the regional patent office to grant patents on the basis of
applications that have been filed to the competent authorities. It should be
noted that every country has its own national patent office as well as its own
national patent law when it comes to the protection of original ideas. After
being issued, patents offer holders exclusive rights to the invention for a
defined period of time. During this time, others are prohibited from copying,
using, or selling the invention.
It is possible to obtain patent protection for
inventions that provide solutions to specific problems in the field of science
and technology. Product or method development are two examples of inventions
that are commonly made. In order for an invention to be patentable (i.e.,
novel, non-obvious, innovative step, utility, and so on), an application must
be filed with the patent office, and the invention must meet all of the
requirements for being patented in order for it to be patented.
Patents are intended to encourage disclosure, rather
than concealment, of intellectual property. A patent application is published
as a patent document, and a patent is subsequently issued by the patent office as
a patent. A patent application is published as a patent document. Patents cover
a wide range of items, including processes, commodities, apparatus, and
industrial uses, as well as inventions that are associated with them. Patents
as an Intellectual property right are essential in encouraging the growth of
innovation, which in turn acts as the foundation for the formation of new
companies.
The scope of the study is to understand the current
realm of patent law in India. The study also aims at comparing the development
of the said laws in India as compared to the international standards and the
benchmarks set. The study is mainly limited to the laws in India and comparison
is done from other countries time and again wherever felt necessary. The study
also looks into the international development of patent law.
Ø The aim of this particular research is to understand
the system of Patent Law in India and to study in depth the effect patents have
on the business and corporate regime in India.
Ø This research study explores the path the
international law took while development of patent law.
Ø This research study examines in depth the development
of patent law in India.
The study also aims at exploring the current remedies
available for the infringement in patent law.
Interdependence
between business strategies and IPR
The definition of a strategy is "a method or plan
chosen to bring about a desired future, such as the achievement of a goal or
solution to a problem." It is "the art and science of planning and
marshalling resources for their most effective and efficient use." It is a
broad strategy for achieving one or more objectives amid "uncertain
conditions."
Max McKeown contends that "strategy is about
shaping the future" and is the human endeavour to achieve "desirable
ends with available means," whereas Henry Mintzberg describes strategy as
"a pattern in a stream of decisions" to contrast with a view of
strategy as planning. Strategy is described by Dr. Vladimir Kvint as "a
system of finding, formulating, and developing a doctrine that will ensure long-term
success if followed faithfully."[8]
Any company or corporation must have a plan since the
resources at their disposal to accomplish their own objectives are sometimes
extremely restricted.
- Setting goals,
- deciding on steps to attain
the goals, and
- mobilising resources to carry out the activities are typically
included in strategy.
A strategy explains how the means (resources) will be
used to accomplish the ends (goals). This usually has to decide on a plan.
Creating a patent strategy is a crucial part of the business plan for many
organisations. The following are the explanations for why a corporation should
have a patent strategy.
1- Patents help a company build its own market share and
cover margins,
2- Patents help a company defend the market share it has
created for itself against rivals and infringers.
3- Patent research helps greatly in enhancing the R &
D and product development efforts.
4- Patent can help cement joint ventures, strategic
partnership and acquisitions.
5- Patents can also help a company in securing finance,
reducing the cost of capital, and help for development of different sources of
revenue.
Hence, a patent strategy means aligning business
ambitions with the patenting efforts. Patent strategy is a real and definable
aim and goal for organizations that wish to engage in the effort.
Simply put, a company's patent strategy is the
alignment of patents with the scope and content of a business ambition
associated with a particular commercial activity.
It can be said that, patent strategy = business
ambition + patents aligning this ambition.
The patent strategy specifies the primary corporate
objectives of the corporation beginning in the development period. A long-term
roadmap to direct the creation of a profitable patent portfolio is provided by
well defined business objectives. A corporation should have the following in
mind in particular while developing such strategies:
- List the company's business objectives;
- identify key industry participants (competitors, partners,
customers);
- identify technology and/or product directions (within company
within industry);
- meet with attorney to discuss core patent strategy;
decide whether a patent portfolio will be used
offensively, defensively, for marketing purposes, or a combination of these.
For a certain period of time (twenty years), the
patent holder is the only one permitted to use, market, and import the
protected item or procedure. One or more of such rights may be delegated by the
patent holder to a third party through a licence. The pinnacle of intellectual
property is a patent that covers a core component of an original technological
development. These types of patents can be utilised to introduce a successful
product, boost operational income during lean periods, or even earn a profit
with no product at all.
Some businesses provide its research and development
department (R&D) adequate funding so that they may invent new things, rely
on them to develop new goods and services, and generate royalties.
When a corporation aggressively licences its patents
to rivals, it deprives the competitors of funds that they would have used for
initiatives like their own R&D. This is also referred to as "the $ 2
swing"—that is, every dollar in incoming licencing from a rival firm
subtracts $1 from that competitor's programmes and adds $1 to the licencing
company's. This results in a relative difference of two dollars between the two
businesses.
The pharmaceutical industry's efforts to safeguard the
novel medications they release on the market serves as an example of an
offensive portfolio. The time it takes to bring a new product to market, from
idea to pharmacy, is typically 12 years. The average cost of research and development
for each product is above $1 billion, even though only approximately 5,000 of
them reach the market. To guarantee market exclusivity for a while, drug
manufacturers rely on their offensive patent portfolios patents on key aspects
of the new medicine, such as its active component composition and mode of use.
This enables pharmaceutical corporations to make a profit, repay their
investment, and capture market share.
Examine the strength of rival patent portfolios for
the offensive portfolio (the sword) to uncover the possibility of rival
counterattacks. Analyse rival goods for potential infringement with regard to
the Sword portfolio and weigh the benefits and risks of a stop and desist
order.
A defensive patent is one that is primarily used to
protect a business against a lawsuit for patent infringement. A defensive
patent can defend the patent holder by enabling it to file a countersuit
following an infringement lawsuit or even if the rival files a lawsuit for
another reason.
A defensive patent is one that is registered for
defence purposes rather than to be enforced to collect royalties or to bar
rivals.
Defensive patents provide their owner two types of
protection.
1- In addition to permitting the patent holder to
countersue, this clause also forbids others from submitting applications for
identical or related inventions.
2- Patents can occasionally serve as effective defences
against patent-holding rivals who might be reluctant to sue you for
infringement for fear that you would suit them back.
A patentee's defence against his own rivals may
occasionally be provided by a patent or bundle of patents.
The defensive patent can safeguard a company's future
development route for continuing growth and expansion, while the offensive
patent can generate more money.
A defensive patent strategy is accumulating a lot of
patents to use as defence in the event that a business is sued by a rival. This
tactic can be used to negotiate litigation settlements. This could comprise:
1. A corporation facing litigation may utilise its own
collection of patents to compel a swift settlement.
2. A corporation that is being sued may respond with
patents from its own library.
3- As a type of settlement, a piece of a company's
patent portfolio may be licenced.
Defensive patenting is a tactic that is generally used
by businesses that are well-known for producing a certain kind of product.
These businesses acquire patents that are slightly relevant to the primary
invention in addition to patents that are comparable to the primary patent.
This makes it tough for other companies to produce identical goods without
stealing the innovator's ideas. Additionally, this guarantees their market
debut will be delayed; Defensive patents offer their owner protection in the
methods listed below.
- Against a counter-claim, the full range of patents can be employed
as a defensive tool;
- Cross-licensing is one way to boost a company's negotiation position
with regard to rivals;
- Used defensively when a rival threatens the patentee in a relevant
technological field;
- To prevent future applicants from entering the field;
- To ensure freedom of operation; or
- To prevent competitive goods from reaching the market.
Design Around Techniques
A design-around strategy entails identifying the
patent's indication of claim coverage. Design around usually entails a thorough
examination of the patent specification, a close examination of the prior art
that was cited and used in support of the patent application, and a close
examination of the prosecution history of the patent application to determine
whether the applicant made any damaging admissions about the invention during
prosecution.
The terms used in the patent's claims are precisely
defined by the patent agent performing the design around analysis by applying
the laws governing patent claim construction or claim interpretation in the
forum jurisdiction; claim interpretation varies from jurisdiction to jurisdiction.
Use "means plus function claim language," advises the patent agent.
The attorney will likely prepare his analysis in the
form of an opinion'. Such opinions may be quite helpful in jurisdictions that
recognize some form of 'wilful infringement". In U.S. patent agents are
not allowed to prepare opinions.
A patent application should certainly protect what the
inventor is doing and what they want to do. The goal is not to create an
invention that is cool, the goal is not to get patent, but rather the goal is
to make money. So, one must consider what it is one wants to do with a patent
as a part of an overall business strategy.
The main purpose of this chapter is to summarise the
findings, reach conclusions, and provide relevant, reasonable ideas and
recommendations based on the complete research study and the individual
analysis of the findings of the prior chapters.
After going through the various legal resources
available and looking at the facts and data available at hand, it is quite
clear that the Patent Law in India is well established.Recent amendments in the
legislations also show that significant efforts are being made on a regular
basis to facilitate and streamline the patent filing process and reduce the
costs of filing patents. In spite of the current standing fact, it is also true
that we still have a long way to go in terms of international standards, given
the rate at which the developed countries and their multinational corporations
and huge conglomerates are filing patents and constantly looking for new things
to patent and creating new trends in the patent law on which we are sometimes
lagging behind.
At the onset of this research study, Introduction,
defines what constitutes a right and how a patent is regarded as an
intellectual property right. It enables the reader to completely comprehend the
definition of the term 'right,' which is frequently used in a variety of
contexts, and it then goes on to link that understanding of a right to
Intellectual Property Rights, as well as introducing the patent as
anintellectual property right.
The next part of the research study, Interlinkage
of patent law with business and corporate makes a connection between the
fields of patent law as an area of study on the one hand, and the interests of
business and corporate strategy on the other in this chapter. This part goes on
to explain the significance of strategy formulation in an organisation, as well
as how patents are used at various times and in various ways to attain the
final goals of an enterprise or organisation at the conclusion of the chapter.
The sword and shield strategies of patenting which are used by the
organisations are explained. The sword and shield strategies of patenting are
the very basic strategies which are followed by organisations while deciding
their business strategies around patent filing.
SUGGESTIONS
After thoroughly going through each and every facet of
law relating to patent in India, the researcher through the medium of this
research study humbly proposes the following suggestions and guidelines for the
various stakeholders in the field of law to study and improve upon the current
situation.
- Although
the situation regarding patent filing has improved tremendously in the
past few years, the situation is still far from pleasant. It still takes
an average time of 2-4 years to get a pending patent approved in India.
During this time duration, even after receiving a receipt of patent pending
from the respective patent office within a few weeks, there is no remedy
as such available to the party who has filed a patent. A suit for
infringement of patent can only be brought forward when a patent has been
granted. A claim cannot be made if a patent is pending before the patent
office. As such, the situation becomes very demotivating for the party who
has filed the patent as the tag of ‘patent pending’ is insufficient to
drive away those who seek to infringe the invention sought to be patented.
Thus, an important step to rectify the situation could be that some legal
weightage could be awarded to the receipt of ‘patent pending’ by the
patent office keeping in mind the priority date on which the application
was made. This would be a critical step in improving the situation as at
the very least in cases of infringement at least a suit for injunction can
be brought forward and locus standi for that suit would exist. If the
injunction is to be granted on the infringement or not would then depend
upon the facts of the case and be upon the court to decide. Thus, in such
a scenario, the party filing their patent before the patent office can
easily rest assured and focus on the patent application and invention
without worrying about their invention being infringed as the title
‘patent pending’ would have legal weightage.
- The
last few years have shown the reduction in pendency of patent
applications. But still, the number of pending applications is still quite
high. In 2017, the number of pending patent applications before the patent
office was 2,32,000. This number saw a reduction as in 2020, the number of
pending patents was 1,15,750. Although the number has gone down by quite a
margin, but 1,15,750 is still a huge number. The load on the patent
offices is still quite huge and there is a need to improve the workforce
to ensure that the pendency of patents can go down further and the
examination of patent applications can be done extensively. The current
load on the patent office may also lead to situations where the current
workforce is being overburdened with work and as a result, the quality of
examination of patent applications may go down. Thus, increasing the
workforce and bringing in skilled employees can certainly help in reducing
the pendency of patents as well as improving the quality of examination of
patent applications so that the claims raised in the future can be settled
easily and disposed of readily.
- The
conditions of work and pay scale of the Indian patent examiners also needs
an overall improvement. The workers have a huge workload and the pay
offered for the services is quite low as compared to the payment and other
job benefits of their foreign colleagues in developed countries. The
workload which an employee in a patent office as a patent examiner has to
face is also quite high as compared to the European Patent Office or the
United States Patent and Trademark Office. While a patent officer in the
above two organisations would handle an average of 7-8 patent applications
a month, a patent examiner in India may have to handle at least 40 patent
applications a month. This amount of workload is huge and puts undue
pressure upon the patent examiners currently employed by the IPO. This is
one of the factors which leads to high patent application pendency and may
also sometimes lead to bad patent examinations or bad patents being
granted which may cause a problem when claims for the patents are filed
and suits are filed before courts for the enforcement of the patent.
- The
pay scale of the patent office employees and opportunities of promotion
also need improvement. A patent examiner in India is paid almost less than
one third of what the patent examiners in developed countries and
well-established patent offices (USPTO or EPO) get paid. The gap in payment
is huge and can be demotivating for the employee, especially considering
the huge workload he already has to deal with. The criteria for promotion
of talent is also quite unclear at the moment in patent offices in India.
Many patent examiners have claimed that the patent office is not offering
performance-based growth opportunities as are available in other
institutes and scientific organisations or even the private sector. This
often leads to lower level of job satisfaction for the patent examiners and
a high attrition rate in patent offices. This issue needs to be resolved
and job satisfaction and growth opportunities in patent offices need to be
improved. Creating such opportunities in the patent office would attract
more skilled employees into the system. With more skilled employees and
lesser workload, the pendency of patents would reduce and the quality of
examination of patent applications would also see a huge improvement. As a
result, it would lead to an overall improvement of the system.
- The
international community is growing with leaps and bounds with regards to
patent law and we need to catch up with them. New trends are being seen,
one such being the patentability of blockchain programs. As already seen
in the, blockchain programs are growing at a steady pace and defining the
new benchmarks of technology. Many companies are now using blockchain
programmes in different and innovative ways to improve upon their products
and services provided. The developed countries which started the trend are
already riding on it with many patents filed which seek to protect their
blockchain programs. In India, however, the situation regarding the
patentability of blockchain programmes is still not so clear. Section 3(k)
of the India Patents Act lists that ‘computer programmes, per se’ are not
eligible for patent protection. Currently, computer programmes are
eligible for protection under copyright laws. There are many debates and
judicial interpretations around the words ‘per se’ in the language of
Section 3(k) but there is no clear path yet as to the patentability of
blockchain programs. At such a time, the legislature needs to step in to
clarify the situation. An amendment in Sec. 3(k) is required so as the
controversy and doubt surrounding the words ‘per se’ in the section can be
resolved. With a clear path, India would also be able to ride the train of
patenting blockchain programs with full force.
[1]Bishwanath
Prasad Radhey Shyam v. Hindustan Metal Industries (1979) 2 S.C.C. 511.
[2]Rai
Prakash v. Mangat Ram Chowdhry A.I.R. 1978 Del. 1.
[4]State
of Rajasthan v. Union of India, A.I.R. (1977) S.C. 1361.
[5]Bishwanath
Prasad Radhey Shyam v. Hindustan Metal Industries (1979) 2 S.C.C. 511.
[6]Rai
Prakash v. Mangat Ram Chowdhry A.I.R. 1978 Del. 1.
[8]Barad
M. (2018) Definitions of Strategies. In: Strategies and Techniques for Quality
and Flexibility. Springer, Cham. https://doi.org/10.1007/978-3-319-68400-0_1
Article Information
EXPLORING THE REALMS OF THE LAW OF PATENT IN INDIA TO UNDERSTAND THEIR EFFECT ON THE CORPORATE REGIME BY: AABHAS SHARMA & DR. REKHA VERMA
Authors: AABHAS SHARMA, DR. REKHA VERMA
- Journal IJLRA
- ISSN 2582-6433
- Published 2023/06/14
- Issue 7
About Journal
International Journal for Legal Research and Analysis
- Abbreviation IJLRA
- ISSN 2582-6433
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