Open Access Research Article
PATENT MISUSE IN THE TECHNOLOGY INDUSTRY: A CRITIQUE
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Article Details
PATENT
MISUSE IN THE TECHNOLOGY INDUSTRY: A CRITIQUE
Keywords: Intellectual property Rights, Patent,
Technology, Patent Misuse, Patent Regulations
AUTHORED BY - TARUN SHARMA
LLM (IPR)
HNLU RAIPUR
7003515388
This research paper
provides a critical analysis of patent misuse within the technology industry.
Patents play a vital role in promoting innovation and protecting the rights of inventors.
However, concerns have been raised regarding the potential for patent misuse,
particularly in the dynamic and fast-paced technology sector. The purpose of
this study is to examine the concept of patent misuse and evaluate its
implications within the technology industry. The paper begins by exploring the
definition and scope of patent misuse, highlighting its various forms and
manifestations.
Next, this paper
defines why patent-responsible use is the need of the hour and how to patent
misuse has economic and societal impacts on the technology industry. It
examines how patent trolls and non-practicing entities exploit patents for
litigation purposes, diverting resources away from productive innovation. The
consequences of patent misuse on market competition, consumer welfare, and
overall industry growth are examined in detail. Furthermore, this research paper critiques the
existing legal framework and regulatory mechanisms governing patent misuse. It
analyses the effectiveness of current laws and policies in deterring and
addressing patent misuse in the technology industry. Finally, the study
concludes by proposing recommendations to mitigate patent misuse and foster a
more balanced and innovation-friendly environment within the technology
industry. These recommendations encompass both legislative reforms and industry
practices to promote fair and responsible patent use, discourage abusive
behaviour, and enhance competition and innovation.
Through a comprehensive
examination of patent misuse in the technology industry, this research paper
aims to contribute to the ongoing discourse on intellectual property rights and
innovation policy. It provides valuable insights for policymakers, legal
practitioners, industry stakeholders, and researchers concerned with striking
the right balance between patent protection and fostering a competitive and
thriving technology ecosystem.
INTRODUCTION
The concept of patents
can be traced back to ancient civilizations such as Greece, Rome, and China,
wherein innovators received temporary exclusive rights to use their inventions.
Consider how, during the time of the Ancient Greeks, Archimedes’ creation of a
water screw for irrigation was awarded patent-like safeguards by the King of
Syracuse[1]. Similarly, in ancient Rome, there were no
official patents, but there were laws and practices in place to protect
inventors and their creations. For example, the Roman Senate granted a monopoly
to a particular glassmaker in the 1st century AD, allowing him exclusive rights
to produce and sell glass in Rome[2].
However, the modern concept of patents began to take shape in Europe in the
15th century, with the development of the printing press and the need to
protect the rights of inventors and publishers. The first recorded patent in
history was granted in Venice in 1474 to a glassmaker, for a new method of
making eyeglasses[3]. This
was followed by other European countries, such as England and France,
introducing their own patent laws in the 17th century.
India’s first patent law
was enacted in 1856 by the British colonial government[4].
After India gained independence in 1947, the Indian government realized the
importance of patent protection for the country’s economic growth. In 2005, India further amended its patent law
to comply with the TRIPS requirement that patent protection is to be extended
to 20 years from the filing date. The law also allowed for the grant of
compulsory licenses in certain circumstances, such as public health
emergencies. The problem of patent misuse in the technology industry is crucial
to study due to its impact on innovation and competition. Patent misuse can
result in higher costs, limited consumer choice, and stifled technological
advancements. It is important to understand the legal and ethical issues
surrounding patent misuse to promote a fair and competitive market for
technological innovation.
CONTENTIONS FOR PROMOTING RESPONSIBLE
PATENT USAGE
Supporters of eliminating
patent misuse argue that the current approach taken by the Federal Circuit
severely limits the effectiveness of the misuse doctrine in curbing abusive
patent practices[5]. Under
this approach, any actions by patent owners that do not meet the strict
anticompetitive effects/antitrust standard, even if they grant rights beyond
the scope of the patent itself, remain unchallenged. Recent events have shown
that patent owners are going beyond seeking returns from products or services
that fall outside the patent claims or extend beyond the patent’s expiration.
They are disrupting industry standards, engaging in reverse settlement
payments, impeding others’ productive activities, imposing restrictive
licensing terms in the medical field, and hindering innovation. Attempts to
address these issues through antitrust law have been consistently rejected by
the courts due to the absence of provable anticompetitive effects[6].
This suggests that the heightened misuse standard set by the Federal Circuit
creates a significant enforcement gap. In the current legal landscape, it is
not enough to argue that misuse prevents patent owners from imposing costs on
others. It is crucial to determine whether the challenged actions result in net
harm to the overall system.
Furthermore, pursuing
misuse claims incurs substantial costs in terms of litigation, discovery, and
appeals, even though they are rarely upheld[7].
These expenses, along with the blanket unenforceability sanction, impose
significant social costs and discourage patent access. To justify the existence
of the misuse doctrine, it must demonstrate unique overall benefits.
PATENT
MISUSE: - DEBRISING THE PRINCIPLES
The phrase “patent misuse” refers to
several categories of illegal conduct carried out by the holder of the patent.
The affirmative defense of “patent misuse” acknowledges that a patent owner may
misuse the exclusive privilege they have as a consequence of the grant of a
patent. Patent abuse cannot be used as a weapon in an affirmative defense
rather, an alleged infringer may only raise it once the patent owner files a
lawsuit to enforce the patent’s exclusive right. After the patent infringement
lawsuit has been filed, the accused infringer must prove that the patentee has
unlawfully enlarged the ‘physical or temporal scope’ of the patent grant with
unfair competition consequence in order to effectively rely on the patent abuse
defense. The patent will not be enforced even if it is legitimate if the
accused infringement can show that the patent holder participated in illegal
activity. The notion of inequitable behaviour, which similarly serves to render
the entirety of a patent invalid, and patent abuse are comparable in this
regard.
The first instance of patent abuse
was in the case of Adams v Burke[8] The court ruled that
the patentee loses all monopoly rights over a product when the patentee makes
its first approved sale of the device, making the product the full property of
the buyer. The product is transferred with the same rights to subsequent
owners, who may use it in the same manner as the original owner. The doctrine
of exhaustion was developed out of this case.
Patent misuse was first
acknowledged as a legitimate claim by the US Supreme Court in the case of Motion
Picture Patents Co. v. Universal Film Manufacturing Co.[9]
According to the ruling of the court, a patent does not provide its owner the
right to limit the use of licensed items that use its patented process.
Although in later laws, Supreme Court rulings, and judgments from the Court of
Appeals for the Federal Circuit have changed the basis of the claim, this
established patent abuse as an affirmative defense to patent infringement.
The court in the case of Princo Corp.
v. International Trade Commission and U.S. Philips Corp.[10]
held that “the defense of patent misuse is not available to a presumptive
infringer simply because a patentee engages in some kind of wrongful commercial
conduct.” The United States Supreme Court supported the legality of licensing
the use of tied or other related items together with the initially patented
product in the well-known case of Henry v. A.B. Dick Co.[11]
the Inherency Doctrine which evolved in this case, as it is commonly referred to
as, holds that a patent owner has the inherent right to use his right to
license his product on any terms and conditions he chooses, rather than having
exclusive rights over it.
Also, in the case of Brulotte v. Thys
Co.[12] the US Supreme Court
held that it is abuse of a patent for a party to seek royalties beyond the
expiration of the patent. The court also laid down a test for a condition when
a business accuses a patent owner of misusing their rights, then the claim must
meet two requirements:
I.
The
legal patent was employed to alter the results of corporate operations.
II.
The
anti-competitive impacts went beyond what the patent covered.
PATENT MISUSE CLAIM
A patent misuse claim is a legal
defense raised by a defendant in a patent infringement lawsuit. It alleges that
the plaintiff, who owns the patent, has engaged in anticompetitive behaviour by
using the patent in a way that exceeds the scope of the patent’s legal
protection.
Examples of patent misuse include:
I.
Tying:
The patent owner requires the licensee to purchase additional products or
services in addition to the patented product as a condition of obtaining the
license.
II.
Price
fixing: The patent owner sets the price of the patented product or service
higher than it would be in a competitive market.
III.
Refusal
to license: The patent owner refuses to license the patent to a potential
licensee who competes with the patent owner, thereby limiting competition.
If a court finds that the patent
owner has engaged in patent misuse, it may refuse to enforce the patent or
limit its legal protection. This can result in the patent becoming less
valuable or even invalid.
DIFFERENT
TYPES OF PATENT MISUSE PRACTICES
I.
A
patent holder may misuse their patent in one of three ways:
II.
The
holder or owner of the patent violates the antitrust laws.
III.
Bad
or malicious intent of the patent owner or holder
IV.
wilfully
broadens the patent’s claims or its scope.
In order to remind patent owners of
their rights, Kaufman & Canoles[13]
defined what patent abuse is not. Misuse of a patent does not include:
I.
Protection
of a patent from infringement
II.
refusing
to provide a patent license to a certain person
III.
A
patent license that comes with a requirement that the purchaser additionally
purchase another good or patent license
IV.
using
one’s own creation in a way that encourages patent infringement by third
parties
Patent misuse refers to the improper
use of a patent, such as using it to stifle competition or gain an unfair
advantage in the market. In the technology industry, patent misuse can occur in
several ways, such as:
·
Patent Trolling:
Patent trolls are companies or individuals who acquire patents with the sole
purpose of suing other companies for infringement. They do not produce any
products or services but make money by suing others who they believe are
infringing on their patents. This practice is seen as abusive and harmful to
innovation.
A remarkable case of Patent Trolling
in India is Ericsson v. Micromax[14]
case of 2013. Ericsson, a Swedish multinational telecommunications company,
accused Micromax, an Indian smartphone manufacturer, of infringing on several
of its standard essential patents related to 2G, 3G, and 4G technologies.
Ericsson demanded that Micromax pay a royalty fee for the use of these patents.
Some critics of the ruling saw it as an example of patent trolling, as Ericsson
was accused of demanding excessive royalty fees for patents that were essential
to the mobile phone industry. However, others argued that Ericsson was merely
trying to protect its intellectual property rights and that Micromax had no
right to use Ericsson’s patented technology without paying a royalty fee.
Overall, the Ericsson versus Micromax case highlights the complex legal issues
surrounding patent infringement and the use of standard essential patents in
the technology industry. Micromax initially refused to pay and argued that
Ericsson’s royalty demands were excessive and unfair. However, in 2014, the
Delhi High Court ruled in favor of Ericsson and ordered Micromax to pay a
royalty fee of 1.25% on the sale price of its devices that use Ericsson’s
patents.
·
Anti-competitive
behaviour: Some companies may use their patents to limit competition by forcing
other companies to pay high licensing fees or blocking them from using certain
technologies. This can stifle innovation and harm consumers by limiting their
choices.
A landmark case of
anti-competitive behaviour in patent in India is Competition Commission of
India (CCI) vs. Ericsson India Private Limited[15] (2016): This case involved
allegations against Ericsson, a leading mobile phone technology company, of
abusing its dominant market position by charging excessive royalty fees for its
standard-essential patents (SEPs) for wireless communication standards. The CCI
found Ericsson guilty of anti-competitive practices and imposed a penalty of
Rs. 1,000 crores (approximately USD 135 million) on the company.
The case was significant
as it ratifies the prior judgement in the case of Ericsson v. Micromax which
royalty asked by Ericsson was considered by the Delhi HC as reasonable.
·
Standard essential patents (SEPs): SEPs are patents that cover technologies that are essential
to industry standards. Companies that own SEPs have a responsibility to license
them on fair, reasonable, and non-discriminatory (FRAND) terms to ensure that
they are used to benefit the industry as a whole. However, some companies may
abuse their SEPs by demanding excessive licensing fees or refusing to license
them altogether.
A remarkable case of SEPs is FTC v. Qualcomm Inc.[16]
(2019), in which the Federal Trade Commission (FTC) accused Qualcomm, a leading
manufacturer of cellular technology, of engaging in anti-competitive behavior
in its licensing practices. Specifically, the FTC alleged that Qualcomm used
its dominant market position to charge excessive royalties and exclude
competitors from the market. The FTC alleged that Qualcomm violated its
obligation to license its SEPs on FRAND terms by charging royalties that were
excessive and by refusing to license its patents to competitors. Qualcomm
argued that its licensing practices were lawful and that the FTC’s case was
based on flawed legal and economic theories. Ultimately, the court held that
Qualcomm’s licensing practices violated antitrust laws. The court found that
Qualcomm had used its market power to extract excessive royalties from its
customers and to exclude competitors from the market. The court ordered
Qualcomm to renegotiate its licensing agreements on FRAND terms and to cease
its anti-competitive practices.
·
Patent thickets:
Patent thickets refer to situations where there are numerous patents covering a
particular technology, making it difficult for other companies to enter the
market without infringing on those patents. This can lead to a lack of
innovation and competition in the industry.
Lemelson Medical, Education & Research Foundation,
LP v. United States[17] (2005): This case involved Jerome
Lemelson, a prolific inventor who had obtained numerous patents related to bar
code scanning technology. Lemelson’s patents were so broad and numerous that
they effectively created a “patent thicket” that made it difficult for others
to develop and market competing products. The Lemelson case highlighted the
need for patent law to balance the interests of inventors with the need for
competition and innovation. It also demonstrated the potential dangers of
allowing a single individual or entity to control a large number of patents in
a particular technology area.
·
Evergreening of Patent: Evergreening of patents refers to the practice of extending
the life of a patent by filing for additional patents on minor variations or
improvements of the original invention. This practice is often used by
pharmaceutical companies to extend their monopolies over specific drugs, even
after the original patent has expired.
One of the landmark cases related to the
evergreening of patents is Novartis AG v.
Union of India[18]
(2013): In this case, Novartis challenged the Indian Patent Office’s decision
to reject its application for a patent on a beta-crystalline form of the drug
Imatinib Mesylate (sold under the brand name Glivec). The patent was rejected
on the grounds that it did not meet the criteria for patentability under Indian
law, and that it was an attempt to evergreen the original patent on Imatinib
Mesylate. The case went all the way to the Indian Supreme Court, which
ultimately upheld the rejection of the patent. The court held that the
beta-crystalline form of Imatinib Mesylate was not a new invention, but rather
a minor modification of the existing drug. The court also reaffirmed the
importance of balancing the interests of patent holders with the public
interest in affordable access to essential medicines. The Novartis case was
significant in that it established a clear legal framework for assessing the
validity of patents on minor modifications or improvements of existing drugs,
and reinforced the importance of preventing the evergreening of patents in the
pharmaceutical industry.
EXISTING
LEGAL AND POLICY FRAMEWORKS IN PREVENTING PATENT MISUSE
The existing legal and policy
frameworks in preventing patent misuse are designed to balance the interests of
patent holders with the public interest in promoting innovation, competition,
and access to essential goods and services. These frameworks are intended to
prevent abuses of patent rights, such as the use of patents to stifle
competition or to charge excessive prices for essential goods.
In India, the Patents Act, of 1970[19], contains
provisions to prevent patent misuse by the owner. The relevant sections are:
Section 84[20]
- This section empowers the Controller General of Patents, Designs and
Trademarks to grant compulsory licenses for patents in certain circumstances,
such as when the patent owner has refused to grant a license on reasonable
terms, or when the patented invention is not being worked in India, after the fulfillment
of 3 years from the grant of the patent[21].
The three main grounds on which the Controller General can grant compulsory
licencing are:-
1. Reasonable requirement of the public
in respect of the patented invention has not been met
2. The patented invention is not
available to the public at a reasonable price.
3. That the patented invention has not
been working in the territory of India
Section 66[22]
- The Central Government has the authority to declare a patent or its
implementation harmful to the country or detrimental to the public. If such a
declaration is made after allowing the patent holder to present their case, it
will be published in the Official Gazette, and as a result, the patent will be
considered revoked.
Section 85[23]
- allows the Central Government to revoke a patent if it deems the patent or
its exercise to be detrimental to the State or prejudicial to the public. The
process involves giving the patentee an opportunity to be heard before making a
declaration of revocation in the Official Gazette. Once the declaration is
published, the patent is considered to be revoked.
The Patent Act of 1970, in its
current form, does not contain a specific provision addressing patent misuse.
Unlike some other jurisdictions, such as the United States, the Act does not
explicitly define or regulate the concept of patent misuse. Patent misuse
refers to the improper use or enforcement of a patent, such as engaging in
anti-competitive practices or imposing unreasonable restrictions on the use of
patented technology. However, while the Act lacks a direct provision on patent
misuse, other provisions of the Act, such as those pertaining to compulsory
licensing and revocation, may indirectly address instances of misuse. In such
cases, parties may need to rely on general principles of contract and
competition law to address potential abuses or improper behaviour related to
the exercise of patent rights.
In the United States, the primary law
governing patents is the Patent Act, 35 U.S.C. §1 et seq. The relevant sections
that address patent misuse by the owner are:
Section 271(d)[24]
- This section provides that patent owners cannot use their patents to
unreasonably restrain trade or create a monopoly. If a patent owner is found to
have misused their patent in this way, they can be held liable for antitrust
violations.
Section 282[25]
- This section allows anyone to challenge the validity of a patent in court,
including on the grounds that the patent owner has engaged in patent misuse.
Section 287[26]
- This section limits the damages that a patent owner can recover in a patent
infringement lawsuit if they have engaged in certain types of patent misuse.
In the European Union, patent misuse
is primarily addressed under Article 101[27]
of the Treaty on the Functioning of the European Union (TFEU) and the
corresponding provisions of national competition laws. Article 101 of the TFEU
prohibits agreements between companies that restrict competition within the EU,
including agreements that have the purpose or effect of preventing,
restricting, or distorting competition. This can include agreements related to
the use or licensing of patents.
National competition laws in the EU
member states also include provisions addressing patent misuse. For example, in
the United Kingdom, the Competition Act 1998 prohibits anti-competitive
agreements and abuse of a dominant market position, including the abuse of
intellectual property rights such as patents.
In addition, the European Commission
has issued guidelines on the assessment of licensing agreements involving
intellectual property rights, including patents. These guidelines provide
guidance on how to assess the anti-competitive effects of licensing agreements
and how to determine whether such agreements are compatible with EU competition
law.
Overall, patent misuse is addressed
under a combination of EU and national competition laws, as well as guidelines
issued by the European Commission.
WAY FORWARD TO STOP AND REGULATE
PATENT MISUSE
Here are some proposed ways and
suggestions through which patent misuse can be properly regulated and hence
stopped: -
1.
Strengthening Antitrust Laws: Enhancing antitrust regulations and enforcement mechanisms
can help deter patent misuse. This includes stricter scrutiny of
anti-competitive practices such as patent thickets, strategic acquisitions, and
exclusive licensing agreements that stifle competition and hinder innovation.
2.
Clearer Definition of Patent Misuse: Introducing a clear and comprehensive definition of
patent misuse within the patent laws can provide a solid foundation for
identifying and addressing instances of misuse. This definition should
encompass practices that harm competition, innovation, and public interest.
3.
Mandatory Patent Disclosure: Requiring patent holders to disclose more detailed
information about the scope and nature of their inventions can help prevent
vague or overbroad patents. This transparency can discourage frivolous
litigation and promote a more efficient examination process, reducing the
potential for misuse.
4.
Limiting Patent Assertion Entities (PAEs): Implementing stricter regulations on
patent trolls and non-practicing entities (NPEs) can curtail their ability to
engage in abusive litigation tactics. This can involve measures such as
requiring PAEs to demonstrate a legitimate business purpose for asserting
patents or imposing penalties for bad faith litigation.
5.
Promoting Patent Education and Awareness: Increasing public awareness and
understanding of patents, their limitations, and the consequences of misuse can
empower inventors, start-ups, and businesses to navigate the patent landscape
more effectively. Educational programs and resources can help foster
responsible patent practices and discourage misuse.
6.
Streamlined Patent Examination Process: Improving the efficiency and quality of patent
examination procedures can contribute to preventing patent misuse. A timely and
rigorous examination can reduce the likelihood of invalid or overly broad
patents being granted, preventing their misuse later on.
7.
International Collaboration: Encouraging collaboration and harmonization of patent laws and
policies among different jurisdictions can address the challenges posed by
cross-border patent misuse. This can involve sharing best practices, aligning
standards, and enhancing cooperation in enforcing patent rights while
preventing misuse.
8.
Patent Policy Review and Reform: Regular review and updating of patent laws and policies to
adapt to the evolving technology landscape can help address emerging issues
related to patent misuse. Stakeholders, including industry experts, academia,
and public interest groups, should be actively involved in this process to
ensure balanced and effective reforms.
By implementing these proposed
measures, it is possible to create a stronger deterrent against patent misuse
while promoting innovation, competition, and public welfare. The collective
efforts of policymakers, legal institutions, industry players, and the public
are crucial in establishing a patent system that encourages responsible and
productive use of intellectual property rights.
CONCLUSION
In conclusion, the issue of patent
misuse in the technology industry is a complex and multifaceted problem that
requires careful consideration and examination. This research paper has
demonstrated that patent misuse has the potential to stifle innovation, increase
market power, and harm consumers. Additionally, it has been shown that patent
trolls and other entities may engage in abusive practices that result in
significant negative externalities.
Given the complexity of the issue, it
is clear that further research is needed to understand the extent of patent
misuse and to develop effective policy solutions. Specifically, there is a need
for more empirical research that can provide insights into the impact of patent
misuse on innovation, competition, and consumer welfare. Furthermore, there is
a need for policymakers to explore new approaches to addressing patent misuse,
including the use of antitrust laws, the development of patent pools, and the
promotion of open-source technologies. In addition to research and policy
interventions, it is also essential to educate stakeholders about the negative
consequences of patent misuse. This includes educating policymakers, industry
leaders, and the public about the importance of patent rights, but also about
the risks of over-restricting access to technologies and stalling innovation.
Overall, the issue of patent misuse
in the technology industry is a critical area that requires ongoing attention
from scholars, policymakers, and industry stakeholders. It is hoped that this
research paper will contribute to a more informed and constructive discussion
of this important issue, and help to identify effective solutions that promote
innovation, competition, and consumer welfare.
[1] Waddell E, ‘A Brief History of
Patents’ (CSY, 24 February 2021)
<https://csy-ip.com/a-brief-history-of-patents/> accessed 26 June
2023
[2] Id.
[3] Id.
[4] (Official website of Intellectual
Property India)
<https://ipindia.gov.in/history-of-indian-patent-system.htm> accessed
26 June 2023
[5]Federal Circuit’s en banc decision
in Princo, 616 F.3d 1318
[6] Ark. Carpenters Health and Welfare
Fund, Paper, A.F. of L. v. Bayer AG (In re Ciprofloxacin), 604 F.3d 98 (2d Cir.
2010)
[7] USM Corp. v. SPS Technologies,
Inc., 694 F.2d 505, 512 (7th Cir. 1982)
[8] Adams v. Burke, 84 U.S. 17 Wall.
453 453 (1873)
[9] Motion Picture Patents Co. v.
Universal Film Manufacturing Co 43 U.S. 502 (1917)
[10] Princo Corp. v. Int'l Trade
Comm'n, 616 F.3d 1318 (Fed. Cir. 2010)
[11] Henry v. A.B. Dick Co., 224 F.2d
195 (9th Cir. 1955)
[12] Brulotte v. Thys Co., 379 U.S. 29
(1964)
[13]What Does and Does Not Constitute
Patent Misuse > Intellectual Property & Franchising Law >
Blog > Kaufman & Canoles’ (Kaufman & Canoles, 12
November 2018)
<https://www.kaufcan.com/blog/intellectual-property-and-franchising-law/what-does-and-does-not-constitute-patent-misuse/>
accessed 26 June 2023
[14]Ericsson v. Micromax, (2013) 107
DRJ 395 (India)
[15]To Promote and Sustain an Enabling
Competition Culture through Engagement and Enforcement That Would Inspire
Businesses to Be Fair, Competitive and Innovative; Enhance Consumer Welfare;
and Support Economic Growth.’ (Competition Commission of India) & lt;https://www.cci.gov.in/>
accessed 26 June 2023
[16] Federal Trade Commission v.
Qualcomm Inc., 411 F. Supp. 3d 658 (N.D. Cal. 2019)
[17] Lemelson Medical, Educ. &
Research Found. v. United States, 518 F.3d 1346 (Fed. Cir. 2008)
[18] Novartis v. UOI, [2013] 13 S.C.R.
148
[19] The Patent Act, 1970, No. 39, Acts
of Parliament, 1970 (India)
[20] Id.
[21] Id.
[22] Id.
[23] Id.
[24]United States Patent Act, 35 U.S.C.
(2021)
[25] Id.
[26] Id.
[27]Treaty on the Functioning of the
European Union, May 9, 2008, O.J. (C 115) 47.
Article Information
PATENT MISUSE IN THE TECHNOLOGY INDUSTRY: A CRITIQUE
Authors: TARUN SHARMA
- Journal IJLRA
- ISSN 2582-6433
- Published 2023/08/24
- Issue 7
About Journal
International Journal for Legal Research and Analysis
- Abbreviation IJLRA
- ISSN 2582-6433
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