In modern times, Peoples' Security
and Progress are sought to be secured through codified laws and scheme of
Justice is thus introduced to secure that Security and Progress. The whole
scheme of Justice it appears in its most common acceptation implies the giving
of every man his due.
The expression
“Rule of Law” may have varied dimensions, and the most apt explanation to this
expression appears to be, “The People have an absolute / unqualified right to
be Ruled / governed/ regulated by Law, and not by individual whims and
fancies”. This is also in fact and precisely the mandate of Article 14 of our
Constitution, which among other things, guarantee equal protection of laws to
all the persons. And therefore, whenever the laws of the land are not adhered
to, causing prejudice or any loss to any person, he can claim that his fundamental
right recognized under Article 14 stands abridged.
The next legal
query may arise, what is meant by Law. And, we may look at the definition of
“Law” provided under the General Clauses Act, 1897.
3(29) "Indian law" shall
mean any Act, ordinance, regulation, rule, order, bye-law or other instrument
which before the commencement of the Constitution had the force of law in any
Province of India or part thereof, or thereafter has the force of law in any
Part A State or Part C State or part thereof, but does not include any Act of
Parliament of the United Kingdom or any Order in Council, rule or other
instrument made under such Act ;
3(50) "Regulation" shall
mean a Regulation made by the President under article 240 of the Constitution
and shall include a regulation made by the President under article 243 thereof
and a Regulation made by the Central Government under the Government of India
Act, 1870 , or the Government of India Act, 1915 , or the Government of India
Act, 1935 ;
3(51) "rule" shall mean a
rule made in exercise of a power conferred by any enactment, and shall include
a regulation made as a rule under any enactment;Rule of law, simply, would mean,
right to be Ruled by Laws of the land, and not by personal wishes of the
person, who is to administer the Law.
Before adverting
to Rule of law in detail, let us briefly look into the primitive stage of human
civilization, when codified laws were not in existent. In order to appreciate
the point of view advanced hereinafter, it is imperative to appreciate the
historical relationship between State & Citizens and fundamental importance
of State – Citizen relationship. And, it is necessary to trace the evolution
and development of law, the emergence of concept of democracy, and trace the
origin of today's concept of Citizens & the State.
There
were ancient times immemorial when man were sovereign and with passage of
centuries together, from aristocracy, the cherished concept of democracy
evolved, wherein all man voluntarily decided to surrender their own sovereignty
to State sovereignty; and now we are a land governed by rules & laws and by
Judicial pronouncements and scheme of Justice by open courts was introduced for
enforcement of these rules & laws and Judicial pronouncements.
At
the advent of Human Civilization, ‘Men’ were Sovereign in their own, in the
sense that, they were free and were not subject to or bound by any law. Then,
men were Ruled by their own conscience and not by codified laws and were even
free to the extent of inflicting violence at their will & strength, i.e.
Might is right was the scene. Men were guided by own conscience and greed. An
action not emanating from reason and the freedom to do as one pleases.
Great
Philosopher Thomas Hobbes (1588- 1671) says that prior to concept of Statehood,
the man lived in chaotic conditions of constant fear. The life in the state of
nature was solitary, poor nasty, brutish and short.
For
getting self protection and avoiding misery and pain, man voluntarily entered
into a contract and surrendered their part of freedom to some might authority,
who could protect their lives and property, which emerged later on as the ruler
and which ultimately culminated into the shape of the State.
With
the great passage of time and centuries together, codified laws evolved and
were introduced in human life. Men came together, they voluntarily surrendered
their individual sovereignty to State sovereignty, and opted to subject
themselves to laws of the land, however, they were promised, in return, the
governance by codified laws. The governance by codified laws purported to
promise the safety of their life & their property and also sought to
guarantee the general dignity inherent in human person alonwith guarantee that
he will not be discriminated. This is how the ancient Social contract between
Men & State came into being.
The
conception of democracy is a sentiment which desires the well being of all men.
Laws were made so that the stronger might not in all things have his way. A law
is something which must have a moral basis, so that there is a inner compelling
force for every citizen to obey. The law is reason free from passion. Law is
Summing up in legislative form of the moral judgment that the community has
already reached.
Among
various definitions of State given by Scholars of law and by Philosophers, this
appears hereinafter to be more satisfactory and convincing. It is by professor
Goodhart. He defines State in terms of its purpose. He states that the purpose
of society which we call a State is to maintain peace and order within a
demarcated territory. THE MINIMUM AND ESSENTIAL PURPOSE OF THE STATE IS TO MAKE
LIFE POSSIBLE.
A
Sovereign State is one which is subordinate to no one and is supreme over the
territory under its control. The word State connotes all three organs, namely-
The Legislature, The Executive Government and The Judiciary.
Hugo
Grotius (1583-1645) is regarded as the father of philosophical jurisprudence.
He said- it is the first duty of the Sovereign State to safeguard the citizen
because State was given power only for that purpose.
Jeremy
Bentham (1748-1832) heralded a new era in the history of legal thought in
England. He is considered to be the founder of positivism (codification of
laws). He advocated that the law should be made exclusively by legislation
which was suppose to remove inroads upon individual's freedom and provide him
opportunities for development of the self. The proper end of every law is the
promotion of the greatest happiness of the greatest number of people. According
to Bentham, the task of governments is to promote, in general, the happiness in
the society.
Main
thrust of the legal brains emphasizing on codification of laws, has been
firstly, as a means of attainment of human perfection and secondly to secure
liberty to individuals in the society. They all considered liberty as the first
pre-requisite for the development of human personality. In their view, a State
is like a family to which the interests of its members are always dear at
heart, like a family which would not be happy if its members are in difficulty,
want or trouble, like a family which would not interfere unnecessarily with the
free choice of its members.
And
therefore, in the backdrop of ancient social contract, every Society &
every Individual Citizen has certain basic assumptions to take it for granted
from the State that-
(i) His Life & Property will be protected and
his liberty will be secured;
(ii) He can appropriate for his own use what he has
created by his own labour and what he has acquired under the existing economic
order;
(iii) That others will act with due care and will
not cast upon him an unreasonable risk of injury;
(iv) That others will not commit any intentional
aggression upon him;
(v) That people with whom he deals will carry out
their undertakings and will act in good faith;
(vi) That he will have security as a job holder;
(vii) That State will bear the risk of unforeseen
misfortune;
(viii) That State will bear the burden of supporting
him when he becomes aged;
Our Democratic
India is founded on Written Constitution and founding fathers and mothers
established in the Constitution- both the ideals and the institutions &
processes for achieving them.
In our vast,
beautiful, geographical landscape of Independent INDIA, i.e. Bhaarat, the
Constitution of INDIA, which came into existence on 26th January 1950, is the
supreme & fundamental governing volume. It is nearly self contained as to
broad principles of governance. It is mammoth, defining every bit of governance
for the very accomplishment of security of life and of property to all Indians
residing wherever in any corner of the world territory.
This epic
governing volume makes a categorical announcement in the introductory passage
that people of INDIA are the architect of this volume. The announcement assumes
significance because by this announcement, the framers of our Constitution
propose to acknowledge and give tribute to selfless sacrifice of every men
& women who devoted their only life for the independence of INDIA.
The origin &
the authority of the Indian legislatures, of the Indian govt, of the Indian
judiciary and of the Indian bureaucracy flow from this peoples' governing
volume. Every injunction of this governing volume represents the wishes and
ambitions of our countless freedom fighters; and Indian law makers, Indian
government, and the Indian judges discharge their responsibilities within four
corners of injunctions in this governing volume. These State organs, while in
every exercise of their discretionary powers, take inspiration and guidance
from this governing volume.
And therefore,
every bit of word, whether by guidance or by mandatory injunction, contained in
this governing volume, can safely be taken as, will bring prosperity to people
of India when adhered to it, in letter and spirit. The spirited adherence to
the words of this governing volume is the first promise all men at State organs
make to the people of India.
In India, the
contemporary democratic set up and functional relationship between the State
organs comprising the Legislature i.e. The MPs & MLAs, The Executives i.e.
Govt which acts as an Agent between the People and its Representatives, and the
Judiciary, the watch dog of the Rights of the People, is such that the People
choose their Representatives and authorize them to make laws and authorize them
to institute Government for administration of the Country.
And therefore
the Representatives in turn make laws for the welfare of the people and appoint
agent in the name of Govt. to implement the laws made by them. The role of the
Judiciary is to ensure that the laws made by the Legislatures are implemented
by the Govt. in letter and spirit.
Attributes of
law
Introducing a
law is a basic incident of a democracy.
Laws are made
and passed by Elected Representatives / Legislatures which represents wishes of
the people; and the govt who acts on behalf of legislatures voluntarily takes
oath and undertakes to fulfill the wishes of people as they administer laws and
perhaps this is the premise why ministers and bureaucrats including the Judges
are called Public Servants and Legislatures are not deemed as Public Servant
ordinarily, except in cases of Corruption. Also, the Govts, ordinarily, are not
a law making body but a law enforcing body. They are entitled to make laws only
to the extent to further the objectives of laws made by our Legislatures.
A law or rule is a common sense which is
binding on you to obey. A law is a social necessity prevailing over your own
interest. A Legal right is an advantage, interest or benefit conferred upon a
person by law and enforceable by means of legal proceedings in competent court
of jurisdiction. All laws are enacted in the backdrop of immense expediency.
A law is something which must have a moral
basis, so that there is a inner compelling force for every citizen to obey. Law
is Summing up in legislative form of the moral judgment that the community has
already reached. Ordinarily whilst law provides a remedy to prevailing
conditions but the remedy so employed get its sanctity if it is founded on
principle of equity and conscience.
Laws were and are made so that the
stronger might not in all things have his way. Laws are to be enforced simply
because they are made and unnecessary laws are traps for extorting money.
Law has reached
its finest moments when it has freed man from the unlimited discretion of some
ruler. (Douglas J. – United States versus Wunderlich – (1951) 342 US 98)
Objectives of any government in
power is to Spread development widely and in particular to the rural areas and
to the socially and economically backward classes with a view to reaching all
needed persons in the country and providing them reasonable opportunities of
livelihood. Giving security of life to its citizens is the first charge.
Purpose of law
Law is meant to
serve the living. Its functional fulfillment, as social engineering, depends on
its sensitized response to the situation. AIR 1977 SC 965.
In such a toxic cloud
that darkened ‘rule of law’, there was a ray of light when Hon’ble Sri Mahadev
Waman Rao Deo (M W Deo) authored an innovative and historic order on 17th December
1987 as the District Judge of District Court of Bhopal in case of Union of India vs Union Carbide
Corporation. His historic pronouncement is this: “The ghastly
tragedy took a toll of more than 2700 lives and manifold more were injured.
Some of them were permanently disabled and as much unable to work. In some
cases the bread-winner was lost and in others, limbs rendered helpless to win
bread. These and number of other cases certainly need payment of money as
interim relief which can bring them an assured sum of money to keep their heart
and soul together and to provide health care. The need for immediate relief to
the gas victims is so obvious nothing more is need to be said.” As civilization
grows with scientific development, circumstances come into being which were
never contemplated before. Law also must grow to meet the problems raised by
such challenges in general including hazards of industrialization in
particular….. I therefore hold that in a tort action the civil court has
jurisdiction to grant interim compensation. So law will not stand still. It
will act in aid of justice to distressed gas victims to move ahead towards
amelioration. Law activates the court and the court orders that the defendant
UCC will deposit in this court a sum of ‘three thousand five hundred million
rupees for payment of substantial interim compensation and welfare measures for
gas victims”. (His portrait and these excerpts rightly adore the walls of
library at National Judicial Academy, Bhopal.) He should have been at the apex
court to do justice to victims of Bhopal. Nevertheless he has set the ball of
‘law’ rolling which reached its pinnacle of settlement and establishment of
principle of absolute liability, the implementation of which is awaited
eternally. Toxic genocide is certainly a tragedy but lax and inept rule is
more.
Elements of good
law
Whereas Law is a
Dharma in the Indian context. Every law, as far as possible, must have a certain
degree to its application, must provoke intelligent proposition in the minds of
the reader.
The word “Law”
in the expression “Procedure established by law” in Article 21 has been
interpreted to mean in Maneka Gandhi’s case, that the law must be right, just
and fair, and not arbitrary, oppressive or fanciful. AIR 1978 SC 1675 (Sunil
Batra)
It is
commonplace that the law, to be a valid law, must satisfy two things – (a) that
the Legislature has competence to make it; (b) that it does not take away or
abridges any of the fundamental rights enumerated in part III of the
Constitution. AIR 1960 SC 1080.
The law is to
play its allotted role of serving the needs of the Society. It must reflect
ideas and ideologies of that society. It must keep time with the heartbeats of
the society, and the need and the aspirations of the people. AIR 1986 SC 1571.
1.
Before
criminalization of human conduct, the legislature is expected to convince
itself that –
a)
It
is absolutely necessary to create an offence;
b)
The
behaviour in question is sufficiently serious to warrant intervention by the
criminal law;
c)
(Whether)
The mischief could be dealt with under existing legislation or by using other
remedies;
d)
The
proposed offence is enforceable in practice;
e)
The
proposed offence is tightly drawn and legally sound; and
f)
The
proposed penalty is commensurate with the seriousness of the offence.
Lord
Williams of Mostyn, the then Minister of State at the Home office, UK, stated
in 1999 in writing on the floor of the House.
The
rule of law is a implied limitation on the power of Parliament to legislate –
(2011) 9 SCC 1 – Para 212
What is the
reverse of “Rule of Law”
To illustrate I
would borrow the wisdom of Dr Upendra Baxi, one of the finest Indian Legal
mind.
(1) As an
Authority of Public Power, I have this and that power. I exercise it in this or
that manner because I so wish. The only good reason which I exercise my power
this or that manner is that I wish to exercise it in this or that manner.
(2) As an
Authority of Public Power- I may so act as to favour some and disfavour others;
(3) As an
Authority of Public Power- I may so act as to give an impression that I am
acting within my powers but in reality I may be acting outside it;
(4) As an
Authority of Public Power- I may decide by myself what your rights and
liabilities are without giving you any chance to be heard, Or I may make your
opportunity to be heard a meaningless ritual;
(5) As an
Authority of Public Power- I may decide but declines to let you know the
reasons or grounds of my decisions or provide reasons without being reasonable;
(6) As an
Authority of Public Power- I may use my power to help you only if I am
gratified in cash or in kind;
(7) As an
Authority of Public Power- I may choose to use my power only after a good deal
of delay and inconvenience to people;
(8) As an
Authority of Public Power- I may just refuse to exercise the powers I have
regardless of my legal obligation to act and regardless of social impact of my
inaction;
In modern
democracies, wide powers vest with Legislators, Judges and with Administrators,
with Govt, and with Bureaucrats. Each group, if it so wishes, may act quite
fancy, in any or all the ways thus far specified hereinbefore.
Rule of Law as a basic feature of our Constitution
AIR 2014 SC 2175
Para 5: Rule
of law is the basic feature of the Constitution. There was a time when REX was
LEX. We now seek to say LEX is REX. It is axiomatic that no authority is above
law and no man is above law. Article 13(2) of the Constitution provides that no
law can be enacted which runs contrary to the fundamental rights guaranteed
under Part III of the Constitution. The object of such a provision is to ensure
that instruments emanating from any source of law, permanent or temporary,
legislative or judicial or any other source, pay homage to the constitutional
provisions relating to fundamental rights. Thus, the main objective of Article
13 is to secure the paramountcy of the Constitution especially with regard to
fundamental rights.
Para 6: The
aforesaid provision is in consonance with the legal principle of "Rule of
Law" and they remind us of the famous words of the English jurist, Henry
de Bracton "The King is under no man but under God and the Law". No
one is above law. The dictum "Be you ever so high, the law is above
you" is applicable to all, irrespective of his status, religion, caste,
creed, sex or culture. The Constitution is the supreme law. All the
institutions, be it legislature, executive or judiciary, being created under the
Constitution, cannot ignore it.
The exercise of powers by an authority cannot be unguided or
unbridled as the Constitution prescribes the limitations for each and every
authority and therefore, no one, howsoever high he may be, has a right to
exercise the power beyond the purpose for which the same has been conferred on
him. Thus, the powers have to be exercised within the framework of the
Constitution and legislative provisions, otherwise it would be an exercise of
power in violation of the basic features of the Constitution i.e. Part III
dealing with the fundamental rights which also prescribes the limitations.
Para 7: Article
14 of the Constitution provides for equality of opportunity. It forms the
cornerstone of our Constitution.
In I.R. Coelho (dead) by L.Rs. V/s. State of Tamil Nadu, AIR
2007 SC 861, the doctrine of basic features has been explained by this Court as
under:
"The doctrine of basic
structure contemplates that there are certain parts or aspects of the
Constitution including Article 15, Article 21 read with Articles 14 and 19
which constitute the core values which if allowed to be abrogated would change
completely the nature of the Constitution. Exclusion of fundamental rights
would result in nullification of the basic structure doctrine, the object of
which is to protect basic features of the Constitution as indicated by the
synoptic view of the rights in Part III."
In Som Raj &Ors. V/s. State of Haryana &Ors., AIR
1990 SC 1176, this Court held as under:
"The absence of arbitrary power is the first postulate
of rule of law upon which our whole constitutional edifice is based. In a
system governed by Rule of Law, discretion when conferred upon an executive
authority must be confined within clearly defined limits. The rules provide the
guidance for exercise of the discretion in making appointment from out of
selection lists which was prepared on the basis of the performance and position
obtained at the selection. The appointing authority is to make appointment in
the order of gradation, subject to any other relevant rules like, rotation or
reservation, if any, or any other valid and binding rules or instructions
having force of law. If the discretion is exercised without any principle or
without any rule, it is a situation amounting to the antithesis of Rule of Law.
Discretion means sound discretion guided by law or governed by known principles
of rules, not by whim or fancy or caprice of the authority."
Implementing the
“Rule of Law”
Laws are not
passed merely for being passed but for being implemented. The mere fact that an
objective has been embodied in the Constitution or a law itself indicates that
the Constituent Assembly and the relevant legislature wanted it to be achieved.
The order embodied in the Constitution and various laws framed under it is the
concern of every citizen as a breakdown of that order shell jeopardize our
existence as a free and cohesive society and this injure every citizen. This
stake in the order is sufficient to provide standing to a citizen to draw the
attention of Courts to developments that endanger that order.
All Statutes or
Laws so made and passed by Legislatures is to remedy the ill that has plagued
the society. All Statutes comes into being with some policy and objective to be
achieved. Every statutory provision in a Statute comes into being after due
deliberation and every letter of the law is employed with great caution and
care and with some purpose. It is settled that Legislation, both Statutory and
Constitutional, are enacted from experience of evil.
Words and
Provisions found in the Constitution of India or in the enacted laws are no
trivial. They are found for their notoriety and expediency, to regulate human
behavior and promote society welfare. And no separate set of reasons needed to
seek spirited observance of the law, for its mere presence in the books of law
calls for forceful observance of it.
It may be beyond
one’s wisdom to anticipate nor it is necessary for one to outline the
consequences that may occasion due to patent violation of a statutory
provision, for the consequences have already been deliberated at the time of
passing of the statutory provision. It is suffice if one merely seeks the bare
observance of the letter of the law and the spirit inherent in the letter of
the law. As everyone says that we live in a Rule of Law society. What we really
mean by Rule of Law is that the Law which is established must be observed in
all the circumstances except in cases where the Law itself is absurd and or
arbitrary. Every letter of the Law must be observed with due respect, unless
the same is declared by the competent court of Jurisdiction as manifestly
arbitrary and or absurd.
It is of first
importance to the Govts and its various instrumentalities to implement and
administer the Laws so made by the Parliament and the State Legislatures. It is
even not open to the Supreme Court and the High Courts to act or give judgments
in deviation from established laws. However, the bare act of State or its
instrumentality in contravention of established laws frustrates the foundation
of Rule of Law society.
Moreover, in my
firm view, every Public Servant invariably speak letter of the law meaning that
as soon as he assumes charge of that designated public office, he deemed to
have said & promised all what is written on the statutes. Like for example,
Instead of stating the letter of the law, Can I have the liberty of stating-
“The Chief Justice of Bombay High Court has promised and emphatically said,
“Tell us if you face any misbehavior or any difficulty in getting Justice at
Lower Courts or Tribunal, I have, under Article 227 of Constitution of India,
unqualified Power of superintendence over all courts and tribunals throughout
the territories in relation to which I exercises jurisdiction. I will do the needful.”
The Chief Justice further exhorts and reiterates that Section 14 of General
Clauses Act 1897 empowers me to exercise my powers from time to time as
occasions requires.
I would also
like to say that the failure of the Public officials or their illegal acts of
omissions and negligence should actually be read as their positive decision
Like for eg., the govt. has decided that children should continue to beg;
people may continue to live on footpath; the corrupts should continue to have
all substantial legal protection against prosecution for corruption.
This Hon'ble
Court may appreciate that, while presiding & dwelling upon and adjudicating
a case before it, the injunctions and mandate embodied in the Constitution of
India is of first importance to them, for Judges themselves owe their origin,
derive their authority and discharge their powers and responsibilities within
ambit of this Constitution. The injunctions & mandate incorporated in the
laws & legislation made and passed by competent Parliament and State
Legislature, the off-spring of Constitution itself, therefore becomes of
immediate importance to the Judges while presiding & dwelling upon and
adjudicating a case before it, for it entails the cherished Rule of law
society. It may deserve mention Constitution.
There cannot be
blind adherence to the letter of the law
To lose our
country to a scrupulous adherence to a written law, would be to lose the law,
absurdly sacrificing the ends to the means. No law is an end in itself. The
curtailment of liberty for reasons of State security or national economic
discipline, has to be administered under strict constitutional restrictions. Thomas
Jeffereson. (2007) 10 SCC 190.
In the
case of Vishnu Agarwal versus State of U.P. (AIR 2011 SC 1232), the Apex Court
observed to say that –
Para 8: In
our opinion, Section 362 cannot be considered in a rigid and over technical
manner to defeat the ends of justice. As Brahaspati has observed :
"Kevalam Shastram Ashritya Na Kartavyo Vinirnayah
Yuktiheeney Vichare tu Dharmahaani Prajayate"
which means:
"The Court should not give its decision based only on
the letter of the law. For if the decision is wholly unreasonable, injustice
will follow."
In Raghubir Saran versus State of Bihar– “The Courts exist
not only for securing obedience to law of the land but also for securing ends
of justice in its widest sense. All Courts, including the HC can exercise such
powers as the law of the land confers upon them as well as such inherent powers
to do justice as are preserved expressly or are not taken away by a Statute. It
is necessary to remember that courts are established to do justice.
Every practice of court must find its ultimate justification
in the interest of justice. Every Court possesses the power to do justice.
Absence of conferment of powers on subordinate courts does not change this
basic and fundamental principle which is inbuilt in every civilized system of
law. The primary duty of the court is to see that truth is arrived at.
In The State of Uttar Pradesh Vs. Mohammad Nooh [1958 SCR
595] Vivian Bose, J. said that justice should be done in a common sense point
of view stating: "I see no reason why any narrow or ultra technical
restrictions should be placed on them. Justice should, in my opinion be
administered in our courts in a common sense liberal way and be broad based on human values rather than on narrow and restricted considerations
hedged round with hair-splitting technicalities...."
Enforceability is the essence of
any law in the absence of which that law becomes optional to observe A Law
never inspires confidence unless the procedure for its administration is
inspiring and fair.
Rule of Law
Rule
of Law – (2011) 9 SCC 1.
Rule
of law – country leading to anarchy – (2011) 6 SCC 189 – Paras 30 to 33;
Importance
of – Rule of law – (2011) 9 SCC 1 – Paras 211 to 222
Sovereignty
and Power – what is – (2011) 4 SCC 36
Indian
Politicians – little regard for – rule of law – (2011) 1 SCC 577 – Paras 35,
36, 50 to 54.
Political
agenda of Political party cannot be subversive of rule of law – (2011) 8 SCC
737 – Para 35
Political
class – rule of law – no respect for – (2011) 1 SCC 577 – Para 56
Law has to
promote justice – (1994) Supp (3) SCC 198
Constitutionality
of law and hardship – (2007) 10 SCC 306
In many
respects, we now live in a society that is only formally democratic, as the
great mass of citizens has minimal say on the major public issues of the day,
and such issues are scarcely debated at all in any meaningful sense in the
electoral arena and where life decisions are taken in closed chambers of
Ministers & Bureaucrats.
"To oppose
or challenge the illegal acts & omissions of government does not mean you
are against the country or the people that the government supposedly
represents. Such opposition should be called what it really is: democracy, or
democratic dissent, or having a critical perspective about what our leaders are
doing. Either we have the right to democratic dissent and criticism of these
acts & omissions or we all lie down and let the leader do what is best,
while we follow uncritically, and obey whatever he commands. That's just what
the Germans did with Hitler, and look where he got them.
Sandeep Jalan
Advocate
https://www.vakeelkanumber.com/
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