Tag: legal profession

Categories
Litigation Skills

[Video] What traits are necessary for a career in litigation?

Apart from the necessary skills and the knowledge required to build and present a case before a judge, everybody knows that hard work is essential for a successful legal practice in the courts. But what else? Are there any other “x-factor” ingredients that successful litigators have but not many others have? We put this question to some of the brightest young minds working in Delhi’s courts. Watch the videos below to find out what attributes of character are necessary for a career in litigation.

So to sum up, a junior lawyer needs to have (a) the fortitude to handle long unpredictable hours, the financial uncertainty, and the mental and physical exhaustion of the early years in the profession; (b) a love for law and the profession; and (c) the skill to network and bring in work.

Categories
Litigation

Drafting need not be a chore if you reflect on what you want to tell the court

JSaiDeepak_OnTrialWith a series of posts that will appear here under the header “On Trial”, I want to give lawyers who are about to embark on their professional journey, a flavour of what I have learnt in six years as a trial and appellate litigator. I believe that although law schools equip students with some basic skills, by and large they do not prepare them for the rigours and demands of a law practice. I hope that my posts here will help them scale the learning curve faster and with fewer mistakes.

Another recent trend that I noticed was that students are keen to take “activist” positions without doing their research on the law as it exists. There is nothing wrong in taking positions or having opinions on matters of policy but lawyers need to first have clarity on what the law is before commenting on what the law ought to be. That apart, no matter how good one is at substantive law, it is important to know how to present and prove a case in a court of law. Command over procedure is equally important and procedure is best learnt through application and practice.

Introspect when you make errors

StressedLitigatorOnce you join the profession, you will realise that most experienced lawyers do not have the time to sit you down and explain how things work. You learn on the job and naturally, are bound to commit a lot of mistakes. The experience can be soul-shattering and may shake your confidence in yourself. What has helped me in these moments is the realisation that a lawyer must not only be a doer, but must also be a conscious observer of his actions. In other words, every time you goof up, your first instinct must be to look inward and be brutally honest, instead of passing the buck or making anyone else the scapegoat. This realisation led me to create my own “Mistakes Log” which has captured nearly every mistake I have committed in the last six years. I have preffered to assess the quality of my journey using the number and quality of my mistakes because success is the product of several factors, many of which are external and are beyond one’s power.

In these posts, I will draw on my experiences (both personal and vicarious) and share a few practical inputs. I will not, unless absolutely necessary, use much legalese or cite precedent because, thanks to the tools and databases available to most lawyers and even non-lawyers these days, it is not really difficult to read up on the case law on any issue, procedural or substantive. That said, it is important to bear in mind that individual journeys vary and consequently, the lessons drawn as well. Therefore, caveat lector applies to what I have to say.

I will write about aspects of both civil and criminal litigation. Under civil litigation, I will discuss pleadings, interim reliefs, discovery, the trial, oral arguments, and finally, appellate reliefs. Let us look at the general approach to drafting and pleadings first.

Orders VI to VIII of the Code of Civil Procedure, 1908 deal with pleadings. A pleading is defined in Order VI, Rule 1 to mean a plaint or a written statement. Orders VII (read with Section 26) and VIII deal with the requirements of a plaint and written statement respectively and the rules that govern pleadings generally are laid down in Order VI. Adherence to these rules, it is important to understand, is mandated only to the extent that the ends of justice are advanced. Departures from them are not uncommon in practice, nor are they frowned upon by courts unless they are egregious or fatal. This is not to trivialise or discourage adherence to these rules, it is merely an observation about the state of affairs.

In practice, when it comes to pleadings, the tendency is to play safe. This manifests in several ways – right from faithfully adopting boilerplates to making repetitive submissions for the fear of being accused of not denying an allegation or a claim or an assertion by the other side, so much so that even evidence affidavits turn out to be slavish reproductions of pleadings.

Drafting need not be a chore

Although there is a sense of safety in treading the conventional path and in reiterating, errors tend to creep in when templates are adopted without discrimination and that could cause embarrassment when they are scrutinised by the opposing side during trial. Also, from the litigator’s point of view, drafting becomes a chore as opposed to the active learning and simulation exercise it is supposed to be, which certainly does not bode well for the quality of the final product. So how does one go about drafting pleadings?

For starters, it would help to bear in mind that drafting is different from writing. Although good writing skills contribute to good drafting, being adept at English or at writing do not necessarily translate to good drafting. In fact, sometimes there is even a mismatch between the flair that people exude for spoken English and the quality of their writing, and even the converse holds good. Therefore, although a fair command over language and lucidity in writing are essential, what separates writing from drafting, is the realisation that:

(a) it has a real and serious bearing on the fortunes of a litigant.

(b) it caters to an audience that is trained in the law,

(c) it has to present the litigant’s case in the best possible manner while conforming to the requirements of the law, and finally

(d)it will be subjected to withering adversarial dissection by the opposing party (a draft looks great only until the opposing party steps into the picture).

Bearing all of this in mind helps lend sharpness to a draft. That said, given the critical role of pleadings, it is natural to be bogged down by the tedium and gravity of the process. So, given that in the initial years of practice, a litigator is primarily expected to be a researcher and a drafter, how does one quickly churn out sharp drafts and yet make it an engaging exercise?

Although it may not always be desirable or possible, crisp and concise pleadings make life easier for the litigator and the court, more so for the latter since it does not have the time or patience for rambling pleadings. In fact, the volume of pleadings invariably weans a court away from hearing a matter even if the dispute is otherwise fairly straightforward. That said, a litigator’s primary challenge in keeping pleadings to the point is to convince the client that volume of pleadings is not directly proportional to the strength of the case and certainly does not guarantee a successful outcome. This is where the litigator has to fall back on her or his client counselling skills to set reasonable expectations to the client. While it is true that not every client may be convinced, the effort is worth it.

Reflect on what you want to present to the court

The key to clear-cut pleadings is to spend time thinking about what one wishes to present to the court before starting to draft. This means that the broader and the narrower points must be broadly identified and supported with factual and legal research. Subsequently, the litigator must decide the sequence in which the points must be captured so that the court can quickly grasp the nub of the matter without having to wade through several pages. This sequence must not be treated as final because during the course of drafting, an alternate sequence of arguments may seem more logical, or appeal from a strategic perspective. Although this approach may seem time-consuming at first, the advantages of spending time on the matter before drafting will become apparent with time as one becomes more adept at identifying issues and developing a feel for the forum. After all, in our profession, hard work is not measured by the number of hours spent in thoughtless labour or the number of pages drafted. The effort lies in rumination.

J.Sai Deepak, an engineer-turned-litigator, is an Associate Partner in the Litigation Team of NCR-based Saikrishna & Associates. Sai is @jsaideepak on Twitter and is the founder of the blawg “The Demanding Mistress” where he writes on economic laws, litigation and policy. All opinions expressed here are academic and personal.

Categories
History Litigation

Robed and privileged – how advocates are protected against defamation proceedings for statements made by them in court

vijayaraghavannarasimhamMukul Rohatgi, the Attorney General for India, reportedly said during proceedings before the Supreme Court that the collegium had appointed many undeserving and inefficient judges to the apex court and high courts who went on to “create havoc” in the country. To argue that it was a myth that only judges could appoint good judges, he submitted in a closed envelope, a list of eight cases of what he called “bad appointments and selection” and referred to the questionable conduct of many judges.

Can proceedings be initiated against the Attorney General for these statements bordering on defamation? Do the affected lot have a remedy?

“In many settings, if we called someone a liar, cheat or incompetent or worse, we might be on the receiving end of a defamation claim. If we need to say that during litigation, we’re generally protected by the litigation privilege. The litigation privilege confers absolute immunity from defamation claims for statements made during both judicial and quasi-judicial administrative proceedings. The privilege applies to attorneys, parties, judges and witnesses. To qualify for such privilege, the statement must meet two general tests. First, it must have some reference to the subject matter of the litigation. Second, it must be made in connection with a judicial proceeding.”

This is the statement of law from American Jurisprudence. The privilege is traceable to the “public policy of securing to attorneys as officers of the court, the utmost freedom in their efforts to secure justice for their clients”. The privilege therefore, is absolute.

But for a subtle change made by the House of Lords recently in Arthur J.S Hall and Co. v. Simons, the British precedent would have been identical. Attorneys continue to enjoy absolute immunity in addressing courts during the proceedings from being sued either in civil law or under the criminal dispensation, but this case removed the immunity enjoyed by advocates from being sued for ‘negligence’.

Defended against a civil claim – many Madras High Court decisions

Closer home, on January 1, 1800, the legendary Eardley Norton was sued by Sullivan, a member of Madras Civil Service for defamatory conduct in addressing the members of the jury in a criminal trial. A full bench of five judges of the Madras High Court ruled that Norton enjoyed

The legendary Eardley Norton

The legendary Eardley Norton

absolute privilege from being sued in civil law for damages. In the absence of proof that Norton was actuated by malice and because the allegedly defamatory utterance was not alien or irrelevant to the matter in inquiry, the High Court accepted Norton’s defence, “I acted under my instructions: all I said and did was within the four corners of those instructions and my duty to my client compelled me to say what I said”.

On December 2, 1926, the Madras High Court relied on Sullivan v. Norton and decisions from the Bombay and Calcutta High Courts in Thiruvengada Mudali v. Thirupura Sundari Ammal and ruled that when the statement imputed with defamatory content was made in the course of a necessary line of submission to aid the cause of a client, then even the presence of malice will not override the presumption of good faith. Advocates who have been accused of defamatory conduct are also protected by the Bombay High Court’s decision in Navin Parekh v. Madhubala Shridhar Sharma, which in fact relied on the ninth exception to Section 499 of the Indian Penal Code, 1860.

When “imputation was made in good faith (which is always presumed) for the protection of interest of the person making it, or of any other person, or for the public good”, then such utterance would not amount to defamation. In February 2008, the Madurai Bench of the Madras High Court again rescued an advocate from facing criminal prosecution for allegedly making defamatory statements in the course of pleadings in a suit for partition.


CriminalDefamation_NinthExceptionA thinner defence against criminal defamation

All may not be lost for persons affected by such submissions. In its decision in Sanjay Mishra in March 2012, the Delhi High Court drew a subtle distinction between English and Indian law.
While in England, there is total immunity for a counsel for such conduct from being proceeded against either for damages in a civil action or under criminal law, that level of protection os confined to a civil action alone in India. Under the criminal law of defamation, the ninth exception to Section 499 actually enables parties to sue a counsel if they can demonstrate malice or a lack of good faith in the utterance or conduct. That, however, is too thin a line, especially in a case of the kind that the Attorney General was arguing – a one-off case, where the submissions were not too alien either.

Vijayaraghavan Narasimhan is an advocate practicing at the Madras High Court.

 

Categories
Corporate

Lock ins, ROFRs, tag alongs, drag alongs – understand the four types of transfer restrictions

Drafting_for_Business_Deepa_Mookerjee.jpgShareholders agreements, we all know, list the rights and obligations of the shareholders in a company and contain clauses that are vital for any M&A transaction. We have already discussed one such clause, the conditions precedent clause. Let us now study another set of clauses – commonly grouped under the term, ‘transfer restrictions’.

Consider the case of a foreign investor who intends to purchase 26 per cent of the shares of a company and has all the know-how and expertise to run the business. This investor’s participation is critical to the business and its Indian partner in the business would prefer that it does not exit the company. Even the foreign investor, mindful of its faith in the Indian partner, would not want the Indian partner to exit the company. The shareholders agreement therefore, would contain clauses that restrict the foreign investor and the Indian partner from transferring their shares to a third party.  A ‘transfer restriction’, simply put, restricts shareholders from transferring their shares in the company.

All doubts about the legality of transfer restrictions under the Companies Act, 1956 has been cleared by the proviso to Section 58(2) in the Companies Act, 2013. It clearly states that “any contract or arrangement between two or more persons in respect of transfer of securities shall be enforceable as a contract”.

While there is no formal clarification from the Ministry of Corporate Affairs regarding this insertion, it appears that that this provision is an attempt to codify the principles laid down in the judgment of the Bombay High Court in the case of Messer Holdings Limited v. Shyam Madanmohan Ruia and Others, [2010] 104 SCL 293 (Bom). The Court held that it is open to shareholders to enter into consensual agreements in relation to the specific shares held by them, provided such agreements are not in conflict with the articles of association of the company, the Companies Act, 1956, and its rules. Such agreements can be enforced like any other agreement and does not impede the free transferability of shares.

The Companies Act, 2013 has also recognised the position that a share is the property of the shareholder. The shareholder is free to transfer his or her property, provided that it is not in conflict with the articles of the company and other provisions of company law.

Let us now focus on a few common transfer restrictions.

Lock-in period

By a specifying a period during which a party is prohibited from transferring or selling its shares in the company, a shareholder is ‘locked in’ to the company. This restriction can apply to one, some, or all the shareholders of in the company.

There is no specified time period applicable to all transactions. Parties determine the time period for the lock-in depending on commercial considerations such as the nature of the business. Sometimes, the time period may differ among shareholders.

The Indian party in our earlier example may feel that five years is sufficient time to absorb all the foreign investor’s know how and then run the business independently. In such a case, the Indian party would probably be content with a lock-in period of five years applicable to the foreign investor.

Right of first refusal

Sometimes, a shareholder who intends to sell its shares to a third party can only do so after first offering them to the other shareholders and only if they refuse to purchase these shares. The price at which the shares are sold to the third party must be equal to or higher than the price at which they were offered to the other shareholders. This gives the other shareholders in the company a right of first refusal, that is, a right to purchase shares which helps consolidate their own shareholding in the company and also prevent the entry of an undesirable purchaser.

Tag along right

A right is some times granted to a minority shareholder to require the majority shareholder to sell its shares along with those of the majority shareholder, to the same third party. This gives a minority shareholder, the right to exit the company if it does not want to continue in the company with a new majority shareholder.

Drag along right

While a tag along right is granted to a minority shareholder, a drag along right is typically granted to a majority shareholder. A majority shareholder will have the right, while selling its own shares, to require the minority shareholder to sell its shares as well. The majority shareholder can thus drag the minority shareholder along while making a sale.

This right is important from the perspective of a new investor. Consider the case of an investor who is about to purchase 95 per cent of the shares of a company from one party in which another party holds the remaining five per cent shares. Since a new investor would prefer to own all the shares and take full control of the company, the majority shareholder would prefer to exercise a drag along right and force the minority shareholder to sell its five per cent to the same new investor.

The key point to remember while drafting any of these clauses is that your clients (whether a majority or minority shareholder) would like to maximise their investment while exiting the company. Therefore, determining the price at which shares are sold is critical.

Say for instance, your client has a drag along right. While drafting this clause, it may be best to lay down certain principles as to how the share price will be determined to ensure that there is no dispute at a later stage. Generally, the minority shareholder sells his or her shares at the same or higher price than that which is offered by the third party for the shares of the majority shareholder.

Always be very clear while drafting these clauses. You should choose your words and terms carefully and ensure there is no ambiguity while interpreting the nature of the restriction. Remember that these clauses are primarily contractual in nature and will always change depending upon the nature of the transaction. Never cut and paste a clause from another agreement without applying your mind to the facts of your transaction. In short, put in time and effort in understanding the transaction and only then draft a clause to suit the requirements of your client.

(Deepa Mookerjee is part of the faculty on myLaw.net.)

Categories
Human Rights

Four women lawyers help Bastar’s imprisoned adivasis access justice in a broken system

Manish_goodhumanrightslawyeringConflict zones, as this column has pointed out earlier, are particularly difficult places for human rights lawyers to work. In the Bastar region in southern Chhattisgarh, years of the Maoist insurgency and the counter-operation by the Indian state have created a battle zone where even normal life is subject to the oversight of security forces. In Jagdalpur, I was advised not to step out after sunset as I could be picked up by the CRPF.

Paradoxically, for the wide publicity it gets, there is little in-depth information or reportage about Bastar. The legal issues that affect the region have not been understood or documented in detail.

It is in this situation that a group of committed human rights lawyers has been quietly working towards documenting the plight of undertrials in Bastar and providing them with legal aid at the trial courts. The Jagdalpur Legal Aid Group (or “JagLAG” as they call themselves), is an all-women team of lawyers based out of Jagdalpur, the headquarters of Bastar district, where they are fighting state apathy, disempowerment, and patriarchy while helping the predominantly adivasi population secure access to justice.

Earlier this year, I interacted with the group at their office in Jagdalpur and visited the courts and the jail there. JagLAG is unique in that its members are all graduates from major law universities and have chosen to litigate at the trial courts in Bastar over other, more lucrative, options. Shalini Gera, 44, is the oldest member of the group and a graduate from Delhi University, and had previously been working with senior advocate Sudha Bharadwaj in Bilaspur. The others, Guneet Kaur, Isha Khandelwal, and Parijatha Bhardwaj, are recent graduates from Indian and foreign universities. For all of them, JagLAG was the first experience at practising law at the trial courts. In an unfamiliar location, theirs has been a trial by fire of sorts.

Early days of gathering data

Chattisgarh's Bastar district

Chattisgarh’s Bastar district

JagLAG had its genesis in conversations that took place in Mumbai and Delhi among lawyers and activists around the possibility of a systematic legal intervention in Bastar. Major human rights abuses, such as the Soni Sori case, had come to light from the region. The intervention aimed at documenting human rights issues from the ground and providing legal aid to undertrials and adivasis who had been framed as “Naxals”. As a result of these conversations, a few advocates committed themselves to providing funding and mentorship for the group, with the aim of supporting an effort at ensuring access to justice in this region.

The Bastar region, where the group works, is comprised of five districts – Bastar, Dantewara, Kanker, Sukma, and Bijapur. JagLAG, being the first such intervention in the area, has had to learn the ropes from scratch. They spoke to local lawyers to get a sense of the courts and the cases being handled, and used empirical data obtained through the Right to Information Act to substantiate the anecdotes.

The RTI applications about court and prison statistics revealed a complete breakdown of the criminal justice system in Bastar. The jails were severely overcrowded. While  the average occupancy in jails across the country is 112%, the corresponding figures ranged from 255% at the Jagdalpur Central Jail to an astounding 428% at the Kanker District Jail. Most of the prisoners were illiterate adivasi men between the ages of 18 and 30 and an overwhelming majority were undertrials.

Overcrowding-in-Bastar-jails-(2012) (1)

An analysis of the case disposal statistics between 2005 and 2012 revealed that two-thirds of undertrials in Jagdalpur had to spend between two and five years in prison before receiving bail, while on an average, across the country, 75 per cent of undertrials spend less than a year in prison before receiving bail. An astounding 96 per cent of the cases between 2005 and 2012 ended in acquittal, indicating that in most cases, the police had mostly framed innocent adivasis and there was no evidence to indicate any actual links with the Maoists.

ChattisgarhJails_Undertrials_Bail

Trademark Naxalite cases

Following up, JagLAG began to track the cases of those who had been incarcerated the longest, to identify the blocks in the system. As they interacted with more prisoners and went through their files, patterns began to emerge. Most of them had been incarcerated in what Shalini described as “trademark Naxalite cases” – allegations of being involved in Maoist activities or conspiracy – including charges under Sections 302 or 307 and 149 of the Indian Penal Code, along with Sections 25 and 26 of the Arms Act, 1959 and Sections 3 and 4 of the Explosives Act, 1884. In addition, provisions of the Unlawful Activities Prevention Act, 1967 and the Chhattisgarh Special Public Security Act, 2005 are also invoked. Many of the prisoners who had been in jail for a long time had not even applied for bail, due to a combination of circumstances.

Bringing in families to file for bail

Local lawyers are reluctant to file for bail, given that the sections involved are non-bailable and the charges are grave, making it rather difficult to obtain bail from a trial court. In addition, the prisoners are usually residents of remote villages and given the long distances and poor transportation facilities in the region, it is difficult for their families to visit the jail or the lawyers. As families was unable to take an active role in the case, the local lawyers lose interest and the cases – and the undertrials involved –  would languish for years.

The Jagdalpur Legal Aid Group - (from left to right) Guneet Kaur, Isha Khandelwal, Shalini Gera, and Parijatha Bhardwaj

The Jagdalpur Legal Aid Group – (from left to right) Guneet Kaur, Isha Khandelwal, Shalini Gera, and Parijatha Bhardwaj

The group began their legal aid work by filing bail applications on behalf of these undertrials. This intervention, including working with the lawyers currently representing the undertrial prisoners and persuading them to file for bail and bringing the families back on board, was a learning experience. They visited the families in their villages rather than rely on them – mostly poor, illiterate adivasis – to make the long and expensive commute all the way to Jagdalpur. However, local security concerns and the looming threat of police action have forced them to restrict field visits in favour of courtwork. They also provide support to fact-finding investigations into grave human rights violations, such as the PUDR investigation into the Sarkeguda extra-judicial killings of 2012, and represent victims of custodial torture, violence, and death at enquiries before the sub-judicial magistrate. Incidentally, on the day of my visit, Guneet and Shalini had just arrived after a day’s trip to Dantewara, to record the affidavits of villagers in a case of extra-judicial execution.

Problems with data and procedure

From the beginning, JagLAG faced several challenges in their work. The initial set of RTI applications revealed that data was recorded in different ways in different places. For instance, while the jail records were referenced by crime numbers, the court records used case numbers, and matching the two took some effort. Many of the long-pending cases that they took up already had lawyers, and much time was spent in tracking down people and their cases, as well as persuading the current set of lawyers to file applications or hand over the cases.

Local procedural requirements also made simple processes, like the filing of a bail application, extremely onerous. The criminal court rules of practice in Chhattisgarh require that while applying for bail, an affidavit had to be filed by a person other than the accused, who was conversant with the facts of the case. Usually, this was a close relative who resides far away from the court and the lawyer. The bail application cannot be filed until such a person has been located and the affidavit filed. JagLAG therefore had to re-calibrate its strategy and adopt more realistic goals about the number of cases they planned to take up. At present, they have taken two cases to the High Court and have handled several more at the various trial courts.

The group’s successes have also exposed the rot within the system. One of their early achievements was securing bail for two undertrials who had been incarcerated for six years, without their names even appearing on the chargesheet. Shockingly, the bail was only granted on a surety of Rs. 10,000 which resulted in the individuals concerned remaining in jail for another ten months while they contacted relatives and raised the money. An application filed under Section 440 of the Code of Criminal Procedure, to reduce the bond amount, remains pending before the court. In another case, they managed to get bail for three arrested persons at the remand stage itself – something that, despite being permitted under law, was almost impossible to do in Bastar.

Threats to their safety

The Sukma court, deserted on a weekday.

The Sukma court, deserted on a weekday.

The rigidly binary nature of public discourse in conflict areas means that anyone who does not espouse the State’s views is seen as siding with the opposition. In Bastar, this has meant that the members of JagLAG have been branded as “Naxalite supporters” or “sympathisers” by the administration and the police, for trying to higlight human rights abuses by the State. Consequently, they work under a constant cloud of threats to their safety, and hostility from the courts. Working as ‘outsiders’ in Bastar has not been easy: they have also faced hostility from fellow lawyers, who view them suspiciously because of their model of human rights lawyering, where they blend activism with court work, and also see JagLAG as competition because do not charge for their services. Isha says, “People keep attributing ulterior motives to us all the time. It’s difficult to explain the concept to them.” In addition, they began work with no contacts or local networks, and have had to build these up from scratch. However, being outsiders with no familial or other investments in the area has also enabled them to take more aggresive stances against the State which local lawyers would have been reluctant to do. As a group, JagLAG is always conscious about the danger of their advocacy work appropriating the agency of the adivasi communities they are representing as lawyers. Says Guneet, “It’s something that goes on all the time in my head – in our role as civil society here, we shouldn’t make decisions [on behalf of the adivasis] that aren’t ours to make.”

The challenges of patriarchy

Being women in a partiarchal, all-male structure – there are almost no women among court staff and at the Bar in Jagdalpur – means that they are at the receiving end of condecension and a patronising attitude from lawyers and judges alike. Parijatha says, “We have inexperience going against us, but this gets compounded by the fact that we’re women.” Over the last couple of years, they have managed to negotiate an uneasy space for themselves, while in the process breaking stereotypes about how women are expected to work and behave in public spaces. Guneet, Isha, and Parijatha have recently featured in Forbes India‘s “30 under 30” list for their efforts.

Sustainability          

JagLAG is supported, financially and professionally, by a number of lawyers around the country, and they are grateful for the mentorship that has helped them work in a very difficult location with very little experience. All four of them have found the work to be an enriching process. Says Guneet, “There were times we would call [the senior lawyers] up at night with minute legal queries and they were always very encouraging and helpful.”

The group has not fully considered its future, given that their experiences have been different from what they had originally planned. However, they are optimistic that they will be able to sustain themselves and include more local lawyers in the process. Shalini concludes, “The key to replicating and making this sort of initiative sustainable in other places is to involve local people as a core part of the work. That is something that we look forward to doing in the future.”

(Manish is a 2013 graduate of NLSIU, Bangalore and works on issues of access to justice. He is currently based in Ahmedabad.)