Terrorism, Anti-Terrorist Laws, And Judicial Decisions-Niloufer Vishnu Bhagwat
It is difficult to find words to pay homage to so many of our colleagues who did not retreat from their professional duty, undeterred in the legal defence of citizens in an ‘Age of Terror ‘ worldwide, though aware that they lived in times, which would extract the ultimate in sacrifice, for voices raised for truth and justice. Ebru Timtik, our Turkish colleague , was one of the brave hearts and souls , whose memory we are here to honour ; to remind ourselves, that we carry the responsibility of moving wheels of justice forward , in difficult and dangerous times .
Before giving you an appraisal of Anti- Terrorist Laws, and judicial decisions from India , it is necessary to briefly reflect on the nature of ‘Terrorism ‘, and the role of covert agencies and military intelligence and agent provocateur organisations in terrorist acts against citizens, and the use of terror waged through hired saboteurs and mercenaries as an alternative to conventional warfare ; as no continent remains unaffected . Whereas innocent citizens are arrested under Anti-Terrorist Laws, covert agencies are initiating terror attacks across borders and within countries, with impunity.
Terrorism is the waging of a secret and cruel war, not against a conventional army; a terrorist attack or a terrorist war is waged against civilians, citizens and society of one’s own country, or citizens of another society, who are the real targets; with specified and secret objectives. To cause fear and apprehension ; to politically destabilize or implode a society from within for better political and economic control ; to manipulate a false political narrative advanced ; to justify a political course of action which would not be acceptable to democratic and constitutional functioning ; to fragment, divide and fracture a society as a diversion from real , social , political and economic issues.
It is necessary to recall ‘Operation Gladio, ‘ a coordination of terrorist activities by clandestine forces and intelligence agencies from the 1950s to the 1980s in Europe, directed against citizens, resorting to kidnappings , mass shootings and bombings ,and the use of political assassinations, among other acts of violence , to alter the composition and formation of governments in Europe.
In 1990 , Italian Prime Minister, Guilio Andreotti made a statement to the Italian parliament on these covert operations in which some of the world’s prominent intelligence agencies were involved . In November 1990, the European Parliament published a ‘Resolution on the Gladio Affair’, The Resolution disclosed :
“….in certain Member States military secret services or uncontrolled branches thereof were involved in serious cases of terrorism and crime as evidenced by , various judicial inquiries.”
“…these organisations operated and continue to operate completely outside the law since they are not subject to any parliamentary control …”
“…various Gladio organisations have at their disposal independent arsenals and military resources which give them an unknown strike potential, thereby jeopardizing the democratic structures of the countries in which they are operating …”
The resolution emphasized that European governments must : “Protest vigorously at the assumption by certain US military personnel at SHAPE( Supreme Headquarters Allied Powers Europe) and in NATO ( North Atlantic Treaty Organisation ) of the right to encourage establishment in Europe of a clandestine intelligence and operation network.”
The resolution recommended that all governments in Europe, “…dismantle all clandestine military and paramilitary networks.”
Significantly “NATO, the CIA and MI6 did not counter the findings of the Italian and EU Parliament “1.
Very recently, citizens lived through the terror of the ‘Lockdown’ and other measures imposed during the ‘Pandemic. ’Finally the International summits of experts, scientists and doctors convened in 2023 on Pandemic response by the European Parliament at Brussels 2 , concluded that the lockdown among other measures forcibly imposed , did nothing to reduce the impact of the Pandemic. Citizens, including doctors and lawyers, attempting to explain the real nature of and the science behind the Pandemic faced threats of arrest , some were arrested , and some doctors lost their licenses to practice .
A critical question which investigators of terrorist acts, including prosecutors, must raise in the context of all terrorist attacks is: Qui Bono? Who benefits ? The answer to this key question, supplies the lead .This applies equally to the recent terrorist attack in the Crocus hall in Krasnogorsk , Moscow Oblast , where approximately 137 Russian civilians , children, women and men were brutally murdered , and almost 200 were injured, as the entire concert hall was set on fire. Preceding the terrorist attack in Moscow, “the sentiment in Washington was that Russian civilians needed to feel the impact of the war.” This was evident from the discussion on the ‘impact of the war on the Russian Federation’, at the Centre for Strategic and International Studies. Emily Harding , a member of the US government and Arms industry funded CSIS, a former employee of the CIA, focused on how the civilian population of Russia could be made to feel the pain of war.Two weeks earlier, the government of the United States alerted its citizens , about a terrorist attack which was to take place in Moscow, at a public place .Fifty minutes after the attack, before investigations had began, Washington announced that ISIS/ISIL were the attackers and that Ukraine was not responsible . ISIS/ISIL/ Daesh/Jabhat ul Nusra , are mercenary terrorist organizations ,or foreign legions of US led NATO forces and their allies, recruited and trained for imperialist terrorist war and attacks on the people of West Asia , for pillaging of hydrocarbons, among other resources. Independently of NATO, these organisations have no strategic objectives whatsoever in the Russian Federation. Victoria Nuland, former Under Secretary of State for Political Affairs, observed : “there are nasty surprises ahead for President Putin.” From the nature of statements from Washington , it would prima facie appear , that the terrorist attack was prepared and planned by ‘Special Forces’, to bleed the civilian population of the Russian Federation ‘behind the frontlines” , for the Ukrainian and NATO defeat; irrespective of who pulled the trigger . A replay of the murderous attack on the civilian population of the former Soviet Union and occupied Europe , by the Nazi Army .
Against this backdrop , it is not our stand that terrorism does not exist, the real issue before us is , whether Anti-Terrorist Laws and the manner in which cases have been investigated , the laws enforced and interpreted , have fulfilled the objective of countering “terrorism” in our societies ; or whether these laws have been used to terrorise innocent citizens who belonged to the wrong ethnic , religious or political group, and have been unjustly and for political purposes, labelled as “ terrorist”. There is evidence that terrorist laws have been used against citizens supporting policies or advancing economic and political issues, interpreted as opposed to the dominant economic and political discourse of ‘neoliberal globalism’ and its policies , premised on the seizure of all public resources, by a miniscule fraction worldwide and indiscriminate privatisation of public assets and resources .
General Leonid Ivashov, Chief of Staff of the armed forces of the Russian Federation on 9/11, a former Vice President of the Russian Academy for geopolitical affairs, gave this analysis at the Axis of Peace 2005 Conference held in Europe, on the terrorist attacks of 9/11 in the United States of America:
“ … what is perceived as terrorism is an instrument of global and national political control “… and ” combines the use of terror by the state and non –state political structures… through peoples intimidation, psychological and social destabilization……and the creation of appropriate conditions for the manipulation of the countries’ policies and the behaviour of people ….at the same time … what is perceived as “ international terrorism in complicity with the media , becomes the manager of global processes … Generally secret services create , finance , control extremist organizations . Without the support of secret services such organizations cannot exist – let alone carry out operations of such magnitude inside countries so well protected….…The September 11 operation modified the course of events in the world … the use of the term “ international terrorism” by these forces has the following objectives “:
- Concealing the real objectives of the nature of forces deployed all over the world in the struggle for dominance and control ;
- Diverting peoples issues into a struggle of undefined goals against an invisible enemy – “terror’;
- Solving economic problems … using the war of terror as a pretext ;…..
“If we analyse what happened on September 11, 2001, we can arrive at the following conclusions :
- The organizers of the attack were the political and business circles interested in destabilizing the world order and who had the means necessary to finance the operation ;
- We have to look for the reasons of the attack in coincidence of the interests of big capital at global and transnational levels…… Unlike traditional wars, whose conception is determined by generals and politicians, the oligarchs and politicians submitted to the former, were the ones who did it this time. ” 3
This is one viewpoint. Our experience in South Asia is that whereas imperialism extensively funded and used cross border terrorism and other terrorist activities , using neighbouring countries as proxies , in an attempt to restructure societies and politics in countries of South Asia and for regime change in their global political interests; the local elite of the countries of South Asia while opposing cross border terrorism, are not above using the same ‘terrorism’ to pursue their own internal political policy agenda, for internal take over of resources and as a diversion from vital development and economic issues .
In a leading case colloquially known as the “ Salwa Judum “ case , Nalini Sundar Vs State of Chhatisgarh 4, decided by the Supreme Court of India on 5 July 2011 ; the Supreme Court disbanded the civilian vigilante organizations recruited in the Dantewada district of the Indian province of Chhatisgarh in the heart of Central India , under the provincial Chhattishgarh Police Act 2007 , to counter the insurgency of the tribal people , as constitutionally illegal ; attributing the conditions of unrest among the tribal or indigenous people , to the amoral economic policies of the state and the ” culture of unrestrained selfishness and greed spawned by modern neoliberal ideology “; and to the disproportionate action on the part of the State government, reducing the tribal people of the district to ‘sub-human existence’; and the dispossession of tribal land , to take over the resources of an entire region belonging to the Indigenous people , and the creation and arming of a civilian vigilante group for this purpose. A specially constituted subcommittee of the then Planning Commission of India (now substituted by the Niti Aayog), held the same view. A high level committee constituted by the Minister for Rural Development of the Union of India, named the companies involved in exacerbating the ‘extremist’ unrest, related to seizure of land and mineral resources of the indigenous people. Worldwide it is observed that among those frequently categorised as “terrorists”, are indigenous communities whose natural resources and habitat, including water resources, are targeted for takeover by companies. Those categorised as terrorists are also minority religious or ethnic groups in many countries in this age of ‘ neoliberal ’ economic policy; soft targets for anti-terrorist campaigns , to divert public attention from policies not in the interest of majority of citizens, with the support of corporate media groups orchestrating a shrill and manipulated “anti-terrorist’ campaign, to create and project an ‘ internal enemy’ ; in reality a phantom, to appease and politically control the majority while public resources are taken over. These are examples of the nature of internal terrorism, as distinguished from cross border terrorism.
Objectively more than one political party in the period of ‘ neoliberal globalization’ in many countries, have been involved in the political use and manipulation of “ terrorism” and arbitrary implementation of anti-terrorist laws, through Special Branches of Intelligence Agencies or through Anti-Terrorists Squad, often in cooperation with a consortium of the world’s most powerful intelligence agencies. A global pattern was established, to camouflage the seizure of surpluses of people and societies, and escalating capital flight to powerful global financial centres , by diverting attention to terrorism; though the impact of anti-terrorist laws under some governments have been more arbitrary, indiscriminate , draconian and wider, than under others, directly related to the degree of the political proximity of the government to special financial and corporate interests global and local .
The examples of the geopolitical use of terrorism in South Asia, would not be complete, without a reference to the use of a global international mercenary terrorist organization , the ‘al Qaeda’ and similar organizations, to defeat sovereign and democratic governments. The reference to terrorism would also not be complete without reference to the use of cross border terrorism in two provinces of India, in Kashmir and Punjab. People of these two provinces were the worst sufferers of these terrorist attacks. Tragically after the defeat of cross border terrorism in these two states ; this cross border ‘terrorism’ was turned around and used for partisan political gain in both these regions , a setback to the more important issues of development , of legitimate local grievances, and democratic and constitutional functioning .
Sustained and organised cross border terrorism in India began when India was broadly aligned with the anti –imperialist policies of the former Soviet Union. This cross border terrorism did not end because of the Terrorist and Disruptive Activities Act 1987, now repealed; or other Anti-Terrorist laws, such as the National Security Act 1980, or the earlier Unlawful Activities Prevention Act 1967, which are still enforced .Cross border terrorism in both provinces of Punjab and Kashmir, was reduced to a trickle , when the people of the two provinces were determined in their own interest along with provincial governments and local forces, to counter violent attacks on civilians and government personnel , carried out by mercenaries hired by a neighbouring state, and certain governments in North America and UK, to end the terrorist violence bleeding the people of the two regions.
A touchstone to investigate whether Anti-Terrorist laws in our countries are serving the objective and purpose for which these laws were enacted , is the background and character of those arrested and detained ; and the rate of conviction under these laws, as against the adverse impact of the existence of such laws and their chronic misuse, targeting specific sections of society; a form of “ state terror’ on socially and economically marginalized groups ; on religious and ethnic minorities ; and on those defending the socially and economically marginalised sections of society and religious and ethnic minorities ,against injustices, whether journalists, lawyers, academics, or social science researchers, among others.
There is however a difference between cross border terrorism and internal political terrorism. The latter are mainly fabricated or false flag operations, for internal political purposes. “Internal terrorism” is a highly exaggerated phenomena in countries of South Asia as distinguished from” cross border terrorism” which has extensive foreign financing. The recruits for cross border terrorism are mercenaries serving the geopolitical interests of Imperialist States , to fracture and reorder existing political states. The miniscule conviction rate of 3 percent of those arrested in India under the Unlawful Activities Prevention Act , 1967 and charged with internal terrorism and being members of unlawful terrorist or banned organisations, is evidence that internal terrorism has been politically magnified.
Justice Abhay Thipsay , a ‘ learned ‘Judge of the Mumbai High Court, observed in 2012 , that the nature of charges and arrests under the Unlawful Activities Prevention Act, should not be such as to make the task of working for democratic political change impossible. This observation was made while hearing a bail application on behalf of members and cultural activists of the ‘Kabir Kala Manch’ , a harmless scheduled caste and working class cultural group, focussing on issues of the marginalised; their real crime was writing and singing songs against poverty, inequality, gender injustice , environmental degradation , corruption and superstition . Undoubtedly, there are constitutionally enlightened rulings by a few courageous benches of different High Courts in India , including the Mumbai and Delhi High Court granting bail to those arrested under Anti-Terrorist Laws 5 , in prima facie cases of lack of evidence, where those charged had been languishing in jail , due to the draconian provisions of Section 43( D) 5 , of the Unlawful Activities Prevention Act ,1967, India’s ‘ umbrella anti-terrorist legislation ‘. UAPA as it is known, severely restricts the grant of bail if the Court on a perusal of the case diary or report made under section 173 of the Code of Criminal Procedure, is of the opinion that there are reasonable grounds for believing that the accusation against such person is prima facie true. “In simple language, this means that if on a bare , un-contradicted surface reading of the police’s version of events, the accusation appears to be true, the court is statutorily prohibited from granting bail.”6
The decisions granting bail under the Unlawful Activities Prevention Act are few and far between , and have not altered the overall judicial interpretation of this Act from the trial court to the Supreme Court in India , which is , that if charged with terrorism under this statute and other Anti-Terrorist Laws , unless acquitted , those charged shall be confined to jail custody until their trial concludes , years later , when the case is finally heard . Those charged have languished in jail, without bail, in some cases for more than 8 to 10 years, only to be acquitted. At the very minimum those charged under Anti-Terrorist Laws spend four years and more on an average, in jail , without bail, and without a trial.
In recent years the Supreme Court of India’s interpretation of the provisions of the Unlawful Activities Prevention Act, is even more oriented towards supporting the State, “adjusting to it and accommodating “state agencies 6, as against a person unjustly charged. In April 2019, in a leading case, National Investigating Agency vs Zaroor Ahmad Shah Watali 7, the Supreme Court of India, forbade courts from ascertaining whether those charged were guilty or not at the preliminary stage from the report and papers submitted by the prosecution. This is prima facie an unjust direction by the Supreme Court , prohibiting Courts from assessing the nature of evidence presented by the police and prosecution at an earlier stage when bail is being applied for by those charged, in particular in cases when there is really no prima facie evidence, or when the evidence procured by the prosecution is prima facie tainted and fabricated ; This results in years of incarceration in jail in high security cells , pending trial, for the innocent , as there is no provision for expeditious trial under the Unlawful Activities Prevention Act. The legal data indicates that 97 percent of those arrested under the Unlawful Activities Prevention Act are acquitted, as there is no evidence against them , as they are innocent; but not before they and their families are adversely impacted and some destroyed, by unjustified lengthy incarceration in prison without bail, which is now the primary objective of Anti-Terrorist Laws.
Significantly, there has been a worldwide orchestration of the threat of internal terrorism by governments facing serious financial and debt crisis; and in countries targeted by global corporations and investment companies in collaboration with local oligarchs, for pillaging of resources and outward financial flows and financial drainage, similar to the outflow during colonisation. Worldwide, democratic rights and civil liberties of citizens are adversely impacted. The covert assaults on the independence of the Judiciary is a matter of overwhelming concern in South Asia and in other countries .The Judiciary has been unable to roll back the widespread misuse of Anti-Terrorist laws, and the weakening of all institutions of the State for the protection of citizens .
Consequently those arrested under anti-terrorist laws in India are people participating in peaceful agitations ; the indigenous or “ first people” opposing unconstitutional takeover of their land and water rights ; scheduled castes opposing caste atrocities of the upper castes and classes; Muslim minorities derogatively referred to as “ Jehadis” or “ Mian”, scapegoated after declaration of the global “ war of terror” by Imperialist powers after 9/11, on countries inhabited by adherents of Islam , to seize hydrocarbon resources and other resources ; Christian minorities in resource rich tribal regions of India; journalists, professors , lawyers, academics, social scientists, a management expert ; member of the Legal Aid Committee of a High Court and a visiting Professor of Law ; a member of a state committee on health policy ; and even a 82 year old Christian priest, Father Stan Swamy, suffering from Parkinson, unable to drink from a glass without a sipper, who contracted Covid -19 while in jail custody; was denied medical bail by the Mumbai High Court, because he was arrested under an Anti-Terrorist Law, though medical bail is a legal right; and consequently died in custody. This case is referred to by sections of the media as “judicial murder”. The perceived crime of the priest was, that he had organised legal aid for the indigenous tribal people resisting land seizure by companies, in a natural resource rich province.
The Anti-Terrorist Laws now being enforced in India, are the National Security Act 1980 and more particularly the Prevention of Unlawful Activities Act 1967, among related legislation in the financial and monetary sphere. The enforcement of these acts proceed without a declaration of any ‘Emergency’, replicating conditions which are far more regressive than the previous constitutional emergency declared in 1975 for two years, after which a free and fair election was held in 1977. It is true that both these enactments were enacted when a different political party was in power in the Central Government and not the present government ; this does not absolve successive governments of different political parties and their alliance partners, who have used these laws, to restrict democratic debate , freedom of speech, to crush dissent , roll back political opposition to policies; and to curb the desire for federal autonomy in federal states of the Indian Union, in keeping with earlier autonomy constitutionally guaranteed, as in the case of Jammu and Kashmir and Ladakh; and in regions inhabited by Scheduled Indigenous tribes, for protection of scheduled tribes , as in the province of Manipur, where society has been fractured and there are conditions of serious civil strife , primarily related to the seizure of resources of the Indigenous tribes . These are not demands for secession from any region, but for federal autonomy, and the protection of the resources and habitat of Scheduled tribes constitutionally guaranteed, within the Union of India.
Democratic rights and civil liberties are not luxuries. Nor are they bestowed by benevolent rulers. These are rights we have fought for through centuries of political struggle and revolutions worldwide and in national liberation movements against imperial and colonial rule. Anti-Terrorist laws are against the spirit and substance of what we refer to as democracies and republics, now hollowed out by the misuse of such laws, with hundreds of thousands coerced and threatened with arrests. Aware of the demand from Indian citizens for the abolition of Anti-Terrorist laws in India, to circumvent this demand, terrorism as an offence has now been included in Section 113 of the new and amended Indian Penal Code, ( renamed Bharatiya Nyaya ( Second) Sanhita Code) , punishable by the death penalty or life imprisonment and without parole for terrorist acts , very widely defined and adopts the provisions of Section 15 of the Unlawful Activities Prevention Act . This provision is even more draconian and serves the same objective as Anti-Terrorist Laws. Whether guilty or not, the person arrested for committing a terrorist offence, will be incarcerated for years, until acquitted at trial. The arrest and incarceration is the punishment, without a trial.
Recently a disabled Professor of Delhi University Professor Saibaba charged under the Anti –Terrorist Unlawful Activities Prevention Act, was acquitted, after having spent almost 8 years in jail custody; despite the fact that his disability rendered him unfit to perform the most basic functions for himself in jail 8 . In another high profile case, known as the ‘Bhima-Koregaon case’ 9 , in a Pan India operation in 2018 , the police arrested 16 persons from different parts of India and charged them under the anti-terrorist Unlawful Activities Prevention Act. Among those arrested are lawyers, professors, social science researchers, journalists, a management expert, members of cultural troupes, and a priest. One third of those arrested are Senior Citizens, suffering from health disabilities, incarcerated in jail since 2018. . From 2022 onwards a few of those charged were released on bail by the Supreme Court , while others are still languishing in prison , for the offence of attending a political meeting known as the ‘ Elgar Parishad’, allegedly funded by an extremist terrorist organisation. The truth is and there is documentary evidence, that the convenors and organisers of this meeting , were a retired Judge of the Supreme Court and a retired Judge of the Mumbai High Court , who raised resources for the meeting, to protest against caste discrimination and atrocities , among related issues , to be discussed and condemned . Very few of those charged, had actually attended the meeting.These persons were framed as most of them had worked on various issues in their professional and academic capacity and as social activists and social science researchers; on the social and economic conditions of the Indigenous tribal people and the scheduled castes, who are at the bottom of the social and economic caste structure of society; the lawyers arrested had given legal aid to those castes and classes , among others , arrested under Anti-Terrorist Laws.
Louis the XIV, drowning in the megalomania of power, famously said: “I am the State “; ignoring millions who tilled the land , laboured and paid taxes, the real foundation of any State . What followed later, shook the foundations of monarchy, an absolutist political system crushing millions. Whether absolutist political systems are imposed through monarchy or an oligarchy of special financial and corporate interests, it makes no difference; both are antagonistic to democracy and to republics.
A company is a creation of legal fiction, intended to further the commercial concept of limited liability, while raising finance for commerce, trade and industry, for profits. The corporation or a company, banks and other financial entities, were never conceived of as instruments of political governance, which requires the nurturing of millions within a society. The focus of a company or financial entity is limited to profits and losses, other issues are peripheral to a company’s existence. An eminent Judge of the United States of America’s Supreme Court, Louis Brandeis , with extensive experience of corporate decision making and ‘Anti-Trust’ legal action, in a dissenting judgment, pronounced : “ Through size, corporations once merely an efficient tool employed by individuals in the conduct of private business, have become an institution which has brought such concentration of economic power, so that so called private corporations are sometimes able to dominate the state …..The changes thereby wrought …..are so fundamental and far-reaching as to lead scholars to compare the evolving Corporation system with the feudal system, and to lead other men with insight and experiences to assert that this material institution of civilized life is committing it to the rule of plutocracy….. there has occurred a marked concentration of individual wealth and the resulting disparity is a major cause of the existing Depression. Such is the Frankenstein monster which states have created by the corporations.” 10 (dissenting Judgment of Justice Brandeis in Louis K. Liggit Co. V Lee 288 U.S. 517, 1933). The Learned Judge with extraordinary legal insight perceptively observed as early as in the nineteen thirties : “ You can have either democracy in society , or individuals with unlimited wealth, not both.”
Political systems must be accountable and enhance civilization. No political system, however brutal and tyrannical , is eternal, despite attempts being made to render societies politically stagnant, by incarceration of political dissenters under Anti-Terror Laws and other similar statutes ; and the strategy to convert citizens through media conglomerates and tech companies into mere consumers of commodities, by technocratic or police states, controlled by absolutist corporate and financial entities.
We have lived through a very dark period. The tens of thousands opposing terrorism and war in Gaza worldwide , among other mass movements, may be the beginning of an understanding of the leading question of our times, raised by Academician of the Russian Federation , Andrey Fursov , to understand where political power really resides 11, in hollowed out democracies and republics. The answer to this question is critical to our understanding of the nature and functioning of our governments; and in whose interest policies are made and implemented, after the unlimited financing of the electoral process.
Yet, this is not the “Not the End of History.”
References:
- Ian Davis,” Operation Gladio – Hard Evidence of Government Sponsored False Flag Terrorism”, May 12 ,2018 , Iandavis.com
- Thomas O’ Reilly , “EU Parliament Covid Conference Slams Pandemic Response” , May 5, 2023 , The European Conservative
- General Leonid Ivashov ,” International terrorism does not exist: September 11 attacks were the result of a set up”, org/article133909.html;http://www.axisforpeace.net
- Nalini Sundar and Ors Vs State of Chhattisgarh , AIR 2011 Supreme Court 2839 ;
- (i) Ms Jyoti Babasaheb Chorge vs State of Maharashtra ,Criminal bail applications No.1020 of 2012 ;(ii)Asif Iqbal Tanha vs State of NCT of Delhi , Criminal Appeal 39 of 2021 , 15June 2021;(iii) Iqbal Ahmed Kabir Ahmed vs State of Maharashtra, Criminal Appeal No.355/2021 ,13 August 2021;
- Gautam Bhatia , “ Unsealed Covers : A Decade of The Constitution, The Courts and The State, ‘ HarperCollins Publishers ,2023 .
- National Investigating Agency Vs Zahoor Ahmad Shah Watali, AIR 2019 Supreme Court page 1734.
- .G.N.Saibaba vs State of Maharashtra, Bombay High Court, Nagpur Bench, Criminal Appeal Nos: 136 and 137 of 2017.
- Bhima Koregaon Case, Romila Thapar vs Union of India, 28 September 2018, AIR Supreme Court 4683.
- Louis K. Liggett Co. Vs Lee, 288 U.S. 517 (1933)
- Andrey Fursov,’ An Asymmetrical Answer to the British Empire’, New Paradigm Conference of the Schiller Institute, Frankfurt, Germany April 13-14, 2013.
