Case BriefsSupreme Court

Supreme Court: Taking a significant step towards gender equality, the Division Bench of Sanjay Kishan Kaul and Hrishikesh Roy, JJ., issued interim direction permitting the women candidates to take part in the National Defence Academy (NDA) examination.

Noticeably, the three modes of recruitment of officers in the Indian Army are through the National Defence Academy (NDA), Indian Military Academy (IMA) and Officers Training Academy (OTA). NDA and IMA are modes of direct entry through UPSC; whereas, through OTA, women are commissioned along with men, both through UPSC and Non-UPSC mode of entry. They are granted Short Service Commission, both men and women, and subsequently are considered for grant of Permanent Commission.

ASG, Ms Aishwarya Bhati submitted before the Bench on behalf of the Union government that a policy decision should not be interfered by an interim measure. It was her submission that subject to certain conditions laid down by the Supreme Court in Ministry of Defence v. Babita Puniya, 2020 (7) SCC 469, ten streams are open for women officers in army.

Pointing out the apparent gender biasness on the part of Army, the Bench asked, whether in the ten streams is there recruitment of male officers from the NDA route? Expressing disappointment over the reply of the Army, the Bench stated,

“We would have expected a more considered affidavit on policy decision based on gender equality more specifically keeping in mind the observations of this Court in Babita Puniya’s case (Supra).”

In view of the impending examination and on hearing counsel for parties, the Bench issued interim direction permitting the women candidates to take part in the NDA examination scheduled for 05-09-2021, subject to further orders from the Court. The Union Public Service Commission (UPSC) was directed to take out the necessary corrigendum in view of the interim orders and give it wide publicity so that the intent of the order is translated into benefit at the ground level.

Similarly, taking note that the process of admitting girls in Sainik Schools had already started and it would be further expanded, the Bench commented on non-inclusion of girls in Rashtriya Indian Military College (RIMC),

“It is stated that it is a 99 years old institution which will complete 100 years next year. The question is whether it completes its 100 years with gender neutrality or not!”

Since the matter has direct relation with admission in NDA programmes, the Bench scheduled it on 09-09-2021 for consideration.[Kush Kalra v. Union of India, Writ Petition(s)(Civil) No.1416 of 2020, 18-08-2021]


Kamini Sharma, Editorial Assistant has reported this brief.


Appearance by:

For Petitioner(s): Petitioner-in-person, Chinmoy Pradip Sharma, Sr. Adv., Mohit Paul, AOR, Sunaina Phul, Adv. and Irfan Haseib, Adv.,

For Respondent(s): Aishwarya Bhati, Ld. ASG, Archana Pathak Dave, Adv., Ruchi Kohli, Adv., Chinmayee Chandra, Adv. and Arvind Kumar Sharma, AOR

Case BriefsSupreme Court

Supreme Court: In major win for women Officer in Indian Army, the division bench of Dr. DY Chandrachud* and MR Shah, JJ has held that the administrative requirement imposed by the Indian Army authorities while considering the case of the Women Short Service Commissions Officers (WSSCO) for the grant of Permanent Commission (PC), of benchmarking these officers with the officers lowest in merit in the corresponding male batch is arbitrary and irrational.

The Court hence, directed that the such requirement shall not be enforced while implementing the decision in Secretary, Ministry of Defence v. Babita Puniya;, (2020) 7 SCC 469.

Benchmarking with the Lowest Male Officer

The chart produced before the Court by the Army provided for

(i) The number of male officers passing out;

(ii) The number of male officers granted PC; and

(iii) The percentage of those granted PC under (ii) as a proportion of the officers passing out in (i).

The Court, however, noticed that the chart suppressed an important feature which is the number of officers who had not opted for being considered for PC (described in the parlance as ‘non-optees”). In other words, the percentage of male officers granted PC has been computed in the chart without disclosing the factual details of the number of male officers who had not opted for PC.

“Only when the number of “optees” is considered against the “non-optees”, can the percentage of male officers who were successfully granted PC be accurately determined. This is a significant omission on the part of the Army authorities from which an adverse interference must be drawn.”

The Policy Letter dated 15 January 1991 provides that the issue of applying competitive merit arises only if more than 250 officers fulfill the cut-off grade annually. If the number of officers who achieved the 60 per cent cut-off is less than 250, then evidently there is no requirement of assessing inter se competitive merit among the officers who meet the minimum threshold.

The statistics advanced by the Army authorities disclosed two things:

  1. In a number of years between 1994 and 2010, the ceiling limit of 250 had not been crossed. If the ceiling limit of 250 had not been crossed, the justification which has been offered for benchmarking women officers against the lowest male officers of the corresponding batch turns out to be specious and a red-herring. Evidently, in their anxiety to rebut the submission of the petitioners in regard to the disparity in the percentage of male and female officers granted PC, the statistics which have been placed on the record, completely demolish the case for benchmarking.
  2. In certain years such as 1999, 2000, 2001, 2004, 2005, 2006 and 2007, the ceiling of 250 was crossed for the male officers. This again belies the claim that benchmarking is crucial to maintain the integrity of competitive merit for grant of PC, as envisaged by the Policy Letter dated 15 January 1991. The data, in fact, shows that in several years, the ceiling was crossed, which is an indicator of the fact that it has not been applied as a rigid norm.

The benchmarking criterion plainly ignores that in terms of the MoD Policy Letter dated 15 January 1991 a cut-off of 60 per cent was prescribed and a cap of 250 officers who would be granted PC annually was laid down. Competitive merit was required to be assessed only where the number of eligible officers exceeds the ceiling of 250.

Hence,

“There can be no manner of doubt whatsoever that the attempt to apply the benchmark of the lowest selected male officer is a ruse to deviate from the judgment of the Court and to bypass the legitimate claim of the WSSCOs.”

Reliance on Annual Confidential Reports

“A formalistic application of pre-existing policies while granting PC is a continuation of these systemic discriminatory practices. WSSCOs were continued in service with a clear message that their advancement would never be equal to their male counterparts. Their ACR evaluations made no difference to their careers, until PC was granted to them by a court mandate in Babita Puniya (supra).”

The evaluation process which has been followed in the case of the WSSCOs has clearly ignored that the writing of their ACRs was fundamentally influenced by the circumstance that at the relevant time an option of PC was not available for women. Even as late as October 2020, the authorities have emphasized the need to duly fill in a recommendation on whether or not WSSCOs should be granted PC.

Further, there has been a flawed attempt to peg the achievements of the WSSCOs at the 5th/10th years of service thereby ignoring the mandate that the last ACR ought to be considered and the quantitative performance for the entire record of service must be assessed. Considering the ACRs as on the 5th or 10th year of service for grant of PC would have been appropriate, if the WSCCOs were being considered for PC at that point of time. However, the delayed implementation of the grant of PC to WSSCOs by the Army and considering of ACRs only till the 5th/10th year of service has led to a situation where, in effect, the Army has obliviated the years of service, hard work and honours received by WSSCOs beyond their 5th/10th year of service and relegated them back to a position they held, in some cases, more than 10 years ago.

“The lack of consideration given to the recent performance of WSSCOs for grant of PC is a disservice not just to these officers who have served the nation, but also to the Indian Army, which on one hand salutes these officers by awarding them honours and decorations, and on the other hand, fails to assess the true value of these honours when it matters the most – at the time of standing for the cause of the WSSCOs to realise their rights under the Constitution and be treated on an equal footing as male officers who are granted PC.”

Hence, in light of the systemic discrimination that women have faced in the Army over a period of time, to call for the adoption of a pattern of evaluation that accounts and compensates for this harsh reality is not to ask for ‘special and unjustified treatment’. Rather, it is the only pathway for the attainment of substantive equality. To adopt a symmetrical concept of equality, is to empty the antidiscrimination guarantee under Article 15, of all meaning.

“It is not enough to proudly state that women officers are allowed to serve the nation in the Armed Forces, when the true picture of their service conditions tells a different story. A superficial sense of equality is not in the true spirit of the Constitution and attempts to make equality only symbolic.”

Medical Criteria

While the medical criterion was not held arbitrary per se, the Court took note of the fact, that these 615 WSSCOs are being subjected to a rigorous medical standard at an advanced stage of their careers, merely on account of the fact that the Army did not consider them for granting them PC, unlike their male counterparts. Had they been considered for the grant of PC then, as the respondents were directed to do by the decision of the Delhi High Court, they would have met the norms of eligibility in terms of medical parameters. Their male counterparts who were considered for and granted PC at that time are not required to maintain SHAPE 1 fitness to be continued in service.

The Army authorities have stated that the medical criterion has been sufficiently adjusted to take into account age related factors. However, the Army authorities are insistent to apply the medical criteria as of today, while simultaneously attempting to freeze the ACRs of the WSSCOs at the 5th or 10th year of service. Indirect discrimination coupled with an exclusionary approach inheres in this application.

“The timing of the administration of rigorous standards is a relevant consideration for determining their discriminatory impact, and not just an isolated reading of the standards which account for differences arising out of gender.”

The WSSCOs have been subject to indirect discrimination when some are being considered for PC, in their 20th year of service.

“A retrospective application of the supposedly uniform standards for grant of PC must be modulated to compensate for the harm that has arisen over their belated application. In the spirit of true equality with their male counterparts in the corresponding batches, the WSSCOs must be considered medically fit for grant of PC by reliance on their medical fitness, as recorded in the 5th or 10th year of their service.”

Directions 

(i) The administrative requirement imposed by the Indian Army authorities while considering the case of the Women Short Service Commissions Officers (WSSCO) for the grant of Permanent Commission (PC), of benchmarking these officers with the officers lowest in merit in the corresponding male batch is held to be arbitrary and irrational and shall not be enforced while implementing the decision in Secretary, Ministry of Defence v. Babita Puniya,(2020) 7 SCC 469

(ii) All women officers who have fulfilled the cut-off grade of 60 per cent in the Special No 5 Selection Board held in September 2020 shall be entitled to the grant of PC, subject to their meeting the medical criteria prescribed by the General Instructions dated 1 August 2020 and receiving disciplinary and vigilance clearance;

(iii) For the purpose of determining the fulfillment of the medical criteria shall be applied at the following points of time:

(a) At the time of the 5th year of service; or

(b) At the time of the 10th year of service, as the case maybe.

In case the officer has failed to meet the medical criterion for the grant of PC at any of these points in time, the WSSCO will not be entitled to the grant of PC. Further, a WSSCO who was in the TLMC in the 5th/10th year of service and subsequently met the SHAPE-1 criterion after the one year period of stabilization, would also be eligible for grant of PC. Other than officers who are “non-optees”, the cases of all WSSCOs, including the petitioners who have been rejected on medical grounds, shall be reconsidered within a period of one month and orders for the grant of PC shall in terms of the above directions be issued within a period of two months;

(iv) The grant of PC to the WSSCOs who have already been granted PC shall not be disturbed;

(v) The WSSCOs belonging to WSES(O) – 27 to 31 and SSCW(T&NT) 1 to 3 who are not considered to be eligible for grant of PC after the above exercise, will be extended the one-time benefit of direction (c) and (d) in Babita Puniya (supra);

(vi) All consequential benefits including the grant of time scale promotions shall necessarily follow as a result of the directions contained in the judgment in Babita Puniya (supra) and the present judgment and steps to do so shall be completed within a period of three months from the date of the judgment;

(vii) The candidature of Lt. Col. Navneet Lobana, Petitioner No. 3 in Writ Petition (C) 1109 of 2020, will be reconsidered for grant of PC in terms of the above directions. In case the officer is not granted PC, she will be allowed to complete her M.Tech degree course for which she has been enrolled at the College of Military Engineering, Pune and shall not be required to pay or reimburse any amount towards the course;

(viii) In accordance with pre-existing policies of the respondents, the method of evaluation of ACRs and the cut-off must be reviewed for future batches, in order to examine for a disproportionate impact on WSSCOs who became eligible for the grant of PC in the subsequent years of their service; and (ix) During the pendency of the proceedings, the ASG had assured the Court that all the serving WSSCOs would be continued in service, since the Court was in seisin of the proceedings. There shall be a direction that this position shall continue until the above directions of the Court are implemented and hence the serving WSSCOs shall be entitled to the payment of their salaries and to all other service benefits.

While concluding the analysis, the Court

“We must not forget that those women officers who have remained in service are those with the tenacity to hold on and to meet the exacting standards of performance of which the Indian Army has made her citizens proud. (…) The WSSCOs before us are not just women who have dedicated their lives to the service of the Army, but are women who have persevered through difficult conditions as they trudged along a lengthy litigation to avail the simplest of equality with their male counterparts. They do not come to the Court seeking charity or favour. They implore us for a restoration of their dignity, when even strongly worded directions by the Court in Babita Puniya (supra) have not trickled down into a basic assessment of not subjecting unequals to supposedly “neutral parameters”.”

[Lt. Col. Nitisha v. Union of India, 2021 SCC OnLine SC 261, decided on 25.03.2021]


*Judgment by: Justice Dr. DY Chandrachud

Know Thy Judge| Justice Dr. DY Chandrachud

ALSO READ

Grant permanent commission to all women officers in Army who opt for it within 3 months: SC to Centre [Full report]

Case BriefsTribunals/Commissions/Regulatory Bodies

The National Human Rights Commission, NHRC, India has expressed serious concern over the rising incidents of sexual assault and, taking suo motu cognizance of media reports in this regard today, issued notices to Centre, States and UTs calling for reports on SOP to deal with such cases and use of Nirbhaya Fund.

The Commission has observed that there is a dire need for all the stakeholders to come together to work jointly to get rid of this evil.

Issuing the notices, the Commission has further observed that the largest democracy of the world, which has adopted the longest written constitution and has a rich cultural heritage of gender equality, is today being criticized for having the most unsafe environment for women. The incidents of rapes, molestation, gender-based discrimination and other such atrocities against women have, unfortunately, become routine media headlines.

The Commission has said that these incidents indeed involve violations of the human rights of the victims. It is well awake to the seriousness of the issue. Being the apex body for the protection and promotion of human rights at the national level, it considers its intervention into the matter necessary to understand as to where the state agencies and other stakeholders are lacking on their part and what can immediately be done.

There have been constitutional and statutory provisions to ensure that the women are not subjected to any kind of discrimination and harassment but there is an alarming trend indicating that things are getting worse amounting to a violation of right to life, liberty, dignity and equality of women across the country.

Recently, a number of such cases have been reported by the media wherein, the women have been subjected to sexual abuse, utmost cruelty and inhuman treatment by the perpetrators showing grave disrespect towards law. There have been instances where the incidents have been reportedly, occurred due to gross negligence by the administration and the law enforcing public agencies.

In Telangana, a 26-year-old veterinarian was reportedly, brutally gang-raped and killed by four accused persons. The culprits not only outraged the dignity of the victim but also killed her and burnt her body. As per media reports, the brother of the victim had approached the Shamshabad police station at around 11.00 PM reporting that his sister is unreachable for the last two hours but his worries were shrugged off by the police personnel and after occurrence of the incident, the FIR was also registered after delay. Though the accused have been arrested but had the timely action been taken by the police, the gruesome incident could, perhaps, be stopped. In another incident, a 25-year-old law student was also reportedly gang-raped by a group of armed men, in Ranchi, Jharkhand.

In another media report, carried today on 02.12.2019, a 6-year-old girl was and strangled with her school belt in Tonk district of Rajasthan on 01.12.2019. The victim was reportedly missing since the previous day. The police have not made any arrest in this case. There have been number of such cases occurred across the country during the recent past. All these incidents have indicate that making stringent laws and funds for the victims alone cannot change the scenario unless the police officers are specially trained and their attitude towards women’s issues also changes.

There seems to be a lack of “Standard Operating Procedure” (SOP) to deal with such kind of incidents and panic situations. It is alleged that whenever anyone goes to a police station for help after disappearance a major or minor female member, the answer of the police officials generally remains that she might have gone with someone. This humiliating and stereotype mindset is needed to be changed. There is need to effectively address the core issue as this serious challenge has not only created an atmosphere of fear and uncertainty in our society but has also badly tarnishing the image of our country.

Through media reports, the Commission has also come to know that the amount made available under the “Nirbhaya Fund” has been reduced and also not being appropriately utilized by the state governments. A news report, carried today on 2.12.2019 reveaLS that since the year 2014, the UT of Chandigarh has been given a sum of rupees 7.46 crores under Nirbhaya Fund but the administration has spent only 2.60 crore out of it. Mere announcements of schemes, making of laws and formation of funds are not going to serve the purpose unless these are properly implemented.

The Commission, knowing that the subject is being looked into by various fora, has issued notices to the Chief Secretaries of all the State and UTs calling for a report within 6 weeks about the status of Nirbhaya Fund in their states including the details about availability of the fund and the money spent, during last 3 years.

The Commission has also issued notices to the Directors General of Police of all the states and UTs calling for their response within 6 weeks about the Standard Operating Procedure and the best practices adopted by them to deal with the matters relating to sexual abuse and atrocities against women including the details of the action taken against the police officers/officials found insensitive and guilty of negligence towards issues related to women.

The Commission has also considered it necessary to call for a detailed from the Secretary, Union Ministry of Women and Child Development, giving details about the schemes/guidelines initiated by the union government and status of their implementation, including Nirbhaya Fund, by the States/UTs. The response is expected within 6 weeks.

Hot Off The PressNews

Supreme Court: The 3-judge bench of Ranjan Gogoi, CJ and Deepak Gupta and Aniruddha Bose, JJ has sought response from the Bar Council of India on a plea seeking measures for women lawyers such as safety in courts, maternity benefits and the old age pension.

The bench issued notice to the BCI and its chairperson Manan Kumar Mishra on the PIL, filed by advocate Indu Kaul, which listed out incidents of sexual harassment against women lawyers in different court premises including the Delhi High Court and the trial courts.

The plea sought formulation of social security measures by the apex bar body in coordination with state bar councils to ensure that women lawyers are strengthened.

“The chamber blocks in the court premises have no police person deployed. Male and female rest rooms which have common wall are often found poorly lit which again makes it vulnerable for lady advocates when they use the facility,”

The petition said their safety and security ought to be made the “first priority” in the legal profession where gender disparity cannot be “overlooked”.

“Gender disparity cannot be overlooked in the legal profession where any successful lady advocated is attributed motives for her success which can be as hurting as her character assassination. Safety and security ought to be made the first priority. Lady advocates will withhold themselves from contesting elections of bar associations and bar councils as her male colleagues envy her success from the very first day,”

It further said that as per BCI Model Scheme, at the retirement age of 60 years, a lady lawyer’s position becomes pitiable as her practice diminishes due to poor health and her family still nourishes the impression that being an advocate she must be capable of earning her livelihood. Through social security measures there must be a provision for pension when she opts out of active practice.

It also mentioned the death of Darvesh Yadav, the first woman chairperson of Uttar Pradesh Bar Council who was shot dead by a male colleague in the premises of Agra district court last month. Instead of compensating Yadav’s family out of its own Advocate Welfare’ Fund, issued a press release demanding the compensation from the State Government.

The plea also submitted,

“Bar Councils from different states and BCI collect a huge amount of money on the sale of Advocates’ Welfare Stamp affixed mandatorily on every Vakalatnama irrespective of the fact that the case is criminal, jail petition, of women, old and indigent persons and/or PIL. … BCI as a statutory body is bound to formulate social security measures for providing financial assistance which is a part of it as a body corporate to bear the corporate social responsibility.”

(Source: PTI)

Case BriefsHigh Courts

Karnataka High Court: Krishna S Dixit, J. dismissed a petition in limine, filed against an order of the Senior Civil Judge; on the ground of insufficiency of provisions of law and inability of the petitioner to support the legal contentions.

The petitioner herein was a party in a final decree proceeding arising out of a suit for partition and is aggrieved by the dismissal of his obstructor application under Order 21 Rule 97 and 101 read with Section 151 of Code of Civil Procedure, 1908 to re-adjudicate the rights of the parties. Hence, this petition.

Issue: Whether a Hindu widow, on contracting marriage, is divested of the property that has been vested in her by way of succession to the estate of the deceased husband?

The petitioner was represented by H.V. Manjunatha and  R. Manjuladevi who contested that respondent had contracted second marriage after the death of her first husband and therefore, she was divested of the property inherited from the deceased husband upon remarriage. Hence, there was a need for fresh adjudication of rights qua the respondent.

The Court’s conclusion consisted of a two-fold observation. Firstly, for an obstructor’s application, accrual of an independent cause of action which obstructs the execution of a decree is required. Secondly, contentions have to be supported by provisions of law or rulings, which the petitioners failed to do. It was held that a widow cannot be deprived of property by mere remarriage, subject to any just exceptions. A widow is the full owner of the property (Section 14 of Hindu Succession Act, 1956) and therefore such stipulations do not align with the intent of the legislature to bring gender equality.

High Court laid emphasis on Cherotte Sugathan v. Cherotte Bharathi, (2008) 2 SCC 610 and noted that the contested Hindu Widows’ Remarriage Act, 1856 also stood repealed by the Parliament which further elucidated on the above-mentioned question of law. In light of the aforesaid rationale, the Court dismissed the petition in limine.[A.N. Amruth Kumar v. A.N. Vanitha, 2019 SCC OnLine Kar 683, decided on 13-06-2019]

Case BriefsHigh Courts

Uttaranchal High Court: Sharad Kumar Sharma, J. allowed a writ petition which was preferred against the action of the respondent of not extending the benefits to the petitioner which were available to the dependents of freedom fighter under various schemes floated by Government of India and State Government as well under the Act called as “Uttar Pradesh Public Services (Reservation for Physically Handicapped Dependents of Freedom Fighter and Ex-Servicemen) Act, 1993” on the premise that the petitioner would not be entitled to the benefit because she happens to be granddaughter (daughter’s daughter) of the deceased freedom fighter and would not be covered in the definition of family.

Tapan Singh, learned counsel for the petitioner argued that petitioner since being daughter’s daughter was a member of the family of deceased freedom fighter, irrespective of the fact that she was married or not, that ought not deprive the petitioner of availing the benefit under the freedom fighter scheme on the premise that she is married granddaughter of the deceased freedom fighter, It was also argued that such practices were an encouragement to gender discrimination. While further citing Isha Tyagi v. State of U.P., 2014 SCC OnLine All 15982, the counsel highlighted how such law will lead to gender discrimination as grandson (i.e. son’s son) of the freedom fighter was included under the definition of the ‘dependents of the family’ of freedom fighter in that eventuality that granddaughter i.e. daughter’s daughter or son should also be entitled to the benefit under the scheme. It was vehemently averred that such discrimination for the compassionate appointment was violative of Articles 14 and 15 of the Constitution. In Isha Tyagi, it was held that, “benefit of the horizontal reservation for descendants of freedom fighters shall extend both to descendants of a freedom fighter tracing their lineage through a son or through a daughter irrespective of the marital status of the daughter. Neither a married daughter nor her children would be disqualified from receiving the benefit of the reservation which is otherwise available to them in their capacity as descendants of a freedom fighter. Whether, in a given case including the present, an applicant is truly a descendant of a freedom fighter is undoubtedly for the authority to verify.”

High Court, observed that judgment in Isha Tyagi, is concurred by a Full Bench of Uttaranchal High Court as well and there was no contradictory remark on it. Thus, the law had been laid down by the judges who bar such discrimination. It was stated by the Court, that ratio of earlier judgments would be applicable in relation to an extension of the benefit of the daughter, granddaughter or grandson of the freedom fighter as they cannot be discriminated on the basis of gender discrimination.

Accordingly, the writ petition was disposed of with a direction that there cannot be any gender discrimination in relation to claim raised by the petitioner being the daughter’s daughter of the freedom fighter. [Ruchika Tomar v. State of Uttarakhand, 2019 SCC OnLine Utt 483, decided on 01-05-2019]

Conference/Seminars/LecturesLaw School News

Tamil Nadu National Law School, Tiruchirappalli in collaboration with Oxford Human Rights Hub, Oxford University, United Kingdom is organised “International Conference on Affirmative Action and the Sustainable Development Goal of Gender Equality” from 22nd- 23rd September, 2018.

The inaugural session was successfully concluded with the Conference Convenors, Prof.Dr. Kamala Sankaran and Prof. Sandra Fredman welcoming the discussants and presenters, followed by the keynote address by Hon’ble Justice Indira Banerjee, Judge Supreme Court of India. The inaugural session ended with a closing address by the Conference Coordinator Mr. Rahul Hemrajani, Assistant Professor of Law, TNNLU. This conference brought together scholars, practitioners and students working in the fields of law, statistics, economics, sociology, anthropology, public policy, gender studies and other social sciences, to explore the link between AA policies that favour women in positions of leadership and achieving target 5.5. of the SDGs. There were six technical session in the conference with only four papers were presented in the seminar.

The sessions were chaired by eminent practitioners and jurists such as Prof. M.P. Singh, Chancellor, Central University of Haryana, Justice (Dr.) S. Muralidhar, Delhi High Court,Dr. Meghan Campbell, University of Birmingham, United Kingdom, Ms. Dorothy Thomas, Partner, Shardul Amarchand Mangaldas & Co, Chennai,Prof. Sandra Fredman, Rhodes Professor of the Laws of the British Commonwealth and the United States, University of Oxford. Also, the papers were presented by students and scholars across the globe.

The conference concluded with roundtable discussion on these issues. The conference have fostered a plethora of ideas, and we hope this will bring us all a step closer to achieving the goals we have set forth as a global community.