A live-in relationship is a living arrangement between two people who do not want to marry but want to live together.”“In the recent decade, India has seen a significant shift in how the current generation views their relationships.”“Today many couples live together before their marriage for various reasons, such as checking whether they are compatible with each other or not.”“We have seen cases where couples seek divorce after getting married because they were not aware of certain things about one another or could not live together.[i]With society loosening up about pre-marital sex and live-in relationships, the stigma that once surrounded couples in live-in relationships has begun to dissipate.”“Today's generation is torn between two crucial terms: marriage and living together, sometimes known as cohabitation.”“Rather than getting married, more couples are opting for cohabitation, commonly known as a live-in relationship.”“The younger generation in India has decided to accept the practice of live-in relationships as a result of the acceptance and adoption of several western traditions.”“A variety of factors have led to the slow acceptance of such cohabitation in society.”“These factors are as follows:

·       Education and awareness.

·       Introduction of globalization.

·       The right to freedom and privacy.

There is no explicit legislation in India that regulates cohabitationrelationships.”“In a number of judgments, however, the Hon'ble Supreme Court has used the opportunity to clarify the nature and scope of connections.”“According to the Indian Court's established legal definition, a live-in relationship is an arrangement in which an unmarried couple lives together in a long-term relationship that resembles marriage.[ii]

Current Status of Cohabitation in India

In India, there is no specific law that governs cohabitation.”“Despite the lack of legislation addressing cohabitation, the sections of the Protection of Women from Domestic Violence Act of 2005, which protect all women in domestic partnerships, including cohabiting women, are praiseworthy.” “The Protection of Women from Domestic Violence Act of 2005 defines a domestic relationship as one in which two persons lived or are living together or shared a household under a number of circumstances, including marriage, consanguinity, a connection that resembles marriage, and so on.” “The inclusion of partnerships that are similar to or in the nature of marriage allows women who are cohabiting or living with their partners to seek remedy under the Protection of Women from Domestic Violence Act, 2005.”“Women in these types of relationships are especially vulnerable and exploited, both physically and mentally.” “To safeguard the safety of couples that join cohabitation, it is critical for the country's legislators to adopt separate laws that governs these partnerships by defining the partners' rights, responsibilities, and remedies.”“However, this would go against one of the primary reasons why the younger generation favours cohabitation or live-in relationships to marriage.”“The lack of any legal or societal formalities or requirements is the cause for this.Couples in cohabitation are free to initiate or end their relationship whenever they want, with no duties to complete throughout either process.”“As a result, enacting legislation would not only ensure rights but also impose obligations on partners. Despite the apparent lack of legislation on cohabitation, Indian courts have expressed sympathy with the new notion through their judgements, through various judgments that ambiguously identify the rights of cohabiting couples.

Not all live-in relationships are lawfully deemed to be marriage-like, and specific criteria must be met for cohabitation to be considered a marriage-like relationship.

In D. Velusamy v. D. Patchaiammal[iii], the Hon'ble Supreme Court declared that in order for a relationship to be in the nature of marriage under Section 2(f) of the Protection of Women from Domestic Violence Act, 2005, it must meet certain basic conditions.”“Couples must live together and not only spend weekends together or have a one-night stand to be considered in a domestic relationship.”“The Supreme Court also ruled that a connection formed solely for the sake of financial support, sexual pleasure, or assistance does not qualify as a domestic relationship.”“In this case, the Court laid down following conditions from which someone can determine that if a relationship resembles marriage:

a)     In front of society, the couple must act as husband and wife.

b)     They must be legally able to marry.

c)     The cohabitation must be voluntary, and the couple must show themselves to society as a married couple.

d)     To enter into a lawful marriage, the partners must be competent.

Under Personal Laws, couples in a live-in relationship are not automatically awarded inherited rights to their partners' property.”“The Hon'ble Supreme Court, on the other hand, ruled that people who have been cohabiting for a reasonable amount of time are entitled to inherit property from their partner.”“Despite its ambiguity, the ruling sets a precedent for future instances involving inheritance between partners in a live-in relationship.[iv]

Protection of Women & their Maintenance

In Virendra Chanmuniya v. Chanmuniya Kumar[v], the Hon'ble Supreme Court declared that unmarried women cohabiting with their partners or in a cohabitationrelationship have the same rights and remedies that were previously only available to married women.”“However, the recognition indicated above is insufficient to tackle the challenges that develop in live-in relationships.”“The Supreme Court accorded live relationships legal status, although this status does not address issues such as the legality of children born from such relationships, the entitlement to maintenance, alimony, and inheritance, among others.

Because women in live-in relationships have no legal recourse, Indian courts have expanded the definition of maintenance under the Criminal Procedure Code.”“Hence, Section 125 was enacted to offer lady partners in or out of marriage a legal right to support.”“The court recently ordered a sum of 40 lakhs as maintenance to women in live-in relationships in the case of Ajay Bhardwaj v. Jyotsana[vi].”“The court also cited the Malimath Committee's 'Reforms in the Criminal Justice System' report from 2003, which proposed that the word 'wife' in section 125 CrPC be modified to include a woman who has lived with a man like his wife for a significant period of time.”“The court also cited the Malimath Committee's 'Reforms in the Criminal Justice System' report from 2003, which proposed that the word 'wife' in section 125 CrPC be modified to include a woman who has lived with a man like his wife for a significant period of time.”“In the case of Abhijit Bhikaseth Auti v. State of Maharashtra and others[vii], the court affirmed the National Commission for Women's recommendation to the Ministry of Women and Child Development that women can claim maintenance under Section 125 CrPC, 1973.

Until recently, only a legally married wife was entitled to maintenance.”“In the case of Sumitra Devi v. Bhikan Choudhary[viii], however, it was decided that marriage might be implied for the purposes of giving support to a man and a woman who had been cohabiting for a long period.”“The Supreme Court's judgement did not apply to all live-in partnerships.”“The prevention of domestic violence between partners is another facet of cohabitation.” “Couples who are cohabiting as well as those who are legally married are treated equally here.”“The Domestic Violence Act of 2005, which was passed in 2006, gave all people in domestic partnerships equal status.”“Domestic relationships are defined as a relationship in which two individuals lived or are living together or shared a household under a variety of circumstances such as marriage, consanguinity, relationship resembling marriage, and so on, according to Section 2(f) of the act.”“The Act aims to give wives, as well as women in live-in relationships who share the household, access to remedies.”“A live-in relationship cannot be ended in any formal way.”“The law specifies the grounds for entering into a live-in relationship by "chosen or circumstance," however there is still some ambiguity when it comes to exiting a live-in relationship.

Status of Children born from the Cohabitation

Only a child born in a recognized marriage is regarded a legitimate child, according to Section 112 of the Evidence Act, making children born in live-in relationships illegitimate.”“In Tulsa v. Durghatiya[ix], the Supreme Court ruled that children born out of live-in partnerships are no longer regarded illegitimate in the eyes of the law.”“Nonetheless, in Dimple Gupta v. Rajiv Gupta[x], the court held in favour of the above-mentioned perspective that children from live-in partnerships have a right to support.

The Supreme Court ruled that a newborn born within a live-in relationship is only entitled to a part of the parent's self-acquired property and cannot claim inheritance in Hindu ancestral coparcenary’s property.”“In accordance with provision of Section 16 of the Hindu Marriage Act, illegitimate offspring must be considered as legitimate for all practical reasons, including succession to their parents' property.”“They cannot, however, succeed to the properties of any other connection using this rule, which is limited to the attributes of the parents in its application.”“Finally, couples in live-in relationships are unable to adopt children. There is no legal basis for them to do so.”“However, the central adoption resource authority has made it illegal for couples to adopt a child while still living together.


So far, the laws and rules governing live-in relationships have proven to be vague and imprecise.”“This necessitates quick changes to India's cohabitation rules.”“Though in certain areas, cohabitation is recognized the same as marriage, in other cases, partners who choose to cohabit do not receive the same privileges as married couples.”“Reforms must be implemented not just in the country's laws, but also in society as a whole.”“Live-in relationships are still considered immoral and unacceptable by a huge majority of the country's population.

It is also clear that, despite the fact that there are no specific laws governing live-in relationships, the country's courts have shown support for them and established guidelines to manage them.”“However, as previously noted, these judgments and rules are insufficient for live-in partners to build a compelling case in a court of law and go to great measures to prove cohabitation to the court.”“The need for a strict rule controlling live-in partnerships is urgent, as it will safeguard not only the people involved in the relationship, but also the children born out of it, who will be future citizens of the country.

To determine the rights and responsibilities of both cohabiting parties, strict norms must be established.”“Given the similarities in the nature of both partnerships, it is impossible to treat cohabitation and marriage as the same and award both relationships the same legal status.”“However, because cohabitation is in the nature of marriage, it must be treated similarly to marriages.”“Partners who are not married but live together and act as though they are married must be granted the same legal status as married couples.

Though cohabitation is simple to begin because of the independence and freedom it provides, there are some limitations and drawbacks, and a legislation is needed to solve these inconsistencies.

This Blog is written by Arryan Mohanty2nd year student from Symbiosis Law School, Nagpur

[ii]Shweta Gupta, Issues & Challenges involved in Live-in Relationships in India, Women and the law in India with special reference to live in relationships, Shodhganga,

[iii] 2010 AIR SCW 6731

[iv] Vidhyadhari v. Sukhrana Bai, (2008) 2 SCC 238

[v](2011) 1 SCC 141

[vi]2016 SCC P&H 9707

[vii] 2009 CriLJ. 889

[viii] AIR 1985 SC 765

[ix]2008 AIR SCW 1148

[x](2007) AIR SC 1139

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It has been seen often that countries wage war when all the diplomatic channels fail, and there is no other option to protect self-interest other than engaging in a conflict.

After the devastating effect of World War 2, governments have realised the disastrous economic implications that took place impacting the parties involved and the whole world. When the soldiers fail to protect their country, then the innocent civilians bear the consequences in the form of food crisis, rape, and forced migration, to name a few.

Mass Genocide and wiping out of community is another aspect of war leading to large scale humanitarian crisis. Same situation occurs in Ukraine failing the basic purpose of United Nations to maintain international peace and security.

Division in Europe

Involvement of Geopolitics and Trade

Western hypocrisy and division among European countries are one of the key reasons resulting in a humanitarian crisis. It is to be noted that Russia is the third-largest supplier of Natural Gas and Europe consumes 75% of it. Moreover, Europe purchases 48% of crude oil from Russia. Thus, any sanctions on Russia hurt Europe too which could ultimately cripple its energy supplies.[1]

In 2008, Germany blocked the entry of Ukraine in NATO considering its trade relations with Russia; while other members of NATO supported the resolution. Ukraine's repeated efforts to join NATO have been failed due to some way or the other.

Western Hypocrisy- Money over Principles

Today Western countries talk about sanctions, about western solidarity. But are they walking the talk? The US imports 16% of its uranium from Russia, but their sanction does not touch Uranium, imposing a sanction on Uranium will cost US 1 billion dollar.[2] US still imports fertilizers, potash, diamond, phosphate and urea because it has been listed as vital products. As far as Russian oil is concerned during the Ukraine war, the US bought 100,000 barrels a day, which is 43% jump.[3]

Carrot of NATO

The mistake that the Ukrainians have made is that they let their soil used for all kinds of geopolitical experimentation with the Western countries due to the bait of NATO. Reports of Ukraine joining NATO have rattled Russia, which took it as a serious provocation by the west to its borders.

Humanitarian Crisis and War Crime

Bucha Killings

Bucha is a city in Ukraine which was under Russian control and then later taken back by Ukrainians. Reports have been surfaced of mass grave, people with tied hands and women being brutally raped. These incidents pave the way for the international community to suspend Russia from the United Nations Human Rights Council.

Moreover, many Ukrainians have fled to neighbouring countries to protect their lives. Almost 3.7 million refugees have fled Ukraine since the escalation of conflict on 24th Feb. Among them, 374,059 have been displaced to Moldova.[4]

United Nations High Commissioner for Refugees came into action and declared Ukraine a Level 3 emergency. They are working on the ground to provide humanitarian assistance.

Global Economic Impact

This conflict has appended commodity markets from oil to gas and wheat, leading to the prospects of an increase in inflationary pressure on countries trying to revive their economic growth after the pandemic. Crude oil prices continue to rise and oil companies like shell and BP are winding up their operations in Russia.

It is to be noted that Russia is the world’s third largest oil producer and second most influential member of the OPEC, plus alliance behind Saudi Arabia.

Sanctions imposed by the United States and other western countries on Russia particularly banning some Russian banks from the swift global financial payment system is expected to make it more cumbersome for many companies to do any kind of business with Russia. Europe suffers the most due to sanctions because of its huge energy purchases.

As sanction cripple Russian economy, the Russian President decided to sell Natural gas and oil with its own currency. It has also started selling crude oil at discounted rates to India to fuel his economy.

Today, the entire world is interconnected and disruption of anything from anywhere leads to disruption of the entire supply chain. Also, the transportation of oil supply and gas pipelines impact Europe as it depends on almost one-fourth of its needs. Ukraine is also a big producer of wheat, sunflower and rare earth minerals; all these situations are extremely complex for the world economy which is resulting in increased inflationary pressures.

BRICS payment system

Western sanctions have led BRICS countries to give a thought on payment mechanism. Russia emphasizes other countries to use Chinese currency Yuan for payment to its oil and gas sectors. Russia is in talks with India and China to find ways to challenge the US dollar in the future. Today, the world is moving from unipolar to multipolar, where the power has distributed among several states rather than being dominated by one.

Resolution: Condemnation or Arbitration

As the war continue for over 50 days, cold war politics is also making a comeback, there are two clear power blocks on one side we have the anti-Russia camp led by the United States aided by the collective might of NATO supported by a host of democratic countries together they are painting this war as a fight between autocracy and democracy. Whereas, the pro-Russia camp Belarus, Armenia, central Asian republics also Syria, North Korea and Cuba some sworn enemy of the US. All these countries blame western hegemony and NATO expansionism for this crisis.

However, there are countries which are in neither camp and there are many such who don’t want to take sides in this war, but they’re under immense pressure to do so. On top of this pressure list is India, which share ties with both camps.

The world is trying hard to pressure India to condemn the Russian invasion of Ukraine. But, so far, it’s been firm in exercising its strategic autonomy on at least three occasions. India has abstained from voting on resolutions condemning Russia; first at United Nations Security Council, UN general Assembly and again at UN human rights council. On every occasion, India called for an immediate ceasefire, stressed on peaceful co-existence and urged for diplomatic talks.

National Interest

Undoubtedly, India’s national interest also lies with Russia as Russia is its biggest defence partner and time-tested strategic ally. But unintendedly, India’s abstentions have upset the west the most, as they say, India has chosen the aggressors’ side. New Delhi says it has only acted in National Interest as its priority was to evacuate its citizens 20,000 of them from Ukraine, mostly students, and the speed at which this crisis unfolded made evacuation an enormous challenge. It could not risk the safety of its citizens, it needed security assurances from both sides to evacuate its people.

Evacuation plan worked only because India kept its lines of communication with Russia open.

India has two hostile nuclear-armed neighbours. If India sides with the US, then it will push Russia further into China’s embrace and that’s the last thing we want.

Russia-Ukraine direct talks

It took a campaign led by western countries into play; one to condemn Russia and then suspend it from various international organisations. Such actions will only drift away from the main purpose of the Ukrainian President to hold direct talks of President Vladimir Putin.

Suppose for a moment India agrees to condemn Russia. What difference will it make? Europe has been condemning Russia has the war stopped. America has been threatening Russia has the war stopped.

Voting against Russia will not stop the war, but arbitration and mediation will. Today, India is sitting on the fence and has the privilege of creating an atmosphere to mediate with both the parties.

Authorized by

Shashwat Raj, student at Asian Law College, Noida

[1] US Energy Information Administration [Dec 13, 2021]

[2]Justice Calma, The US can’t seem to quit Russian Uranium The Verge [Mar 31, 2022]



In India it is believed that our society is male dominating society and over the years every socialist or individual is stressing over a point that women are victimised by man. They are treated bad, they don’t get equal opportunities, etc. But why is everybody forgetting that there are two sides of a coin. In our country if one person does any wrong than the all the people of his class or community will be predicted wrong. If a man with bad intentions does something wrong to a woman, then all the men are considered as wrong. This is an overall faith in our country that man can never be manhandled on the grounds that he is the centre of the general public. Because of blameworthy picture of man in the public arena everybody trusts a lady regardless on the off chance that she lies. The most famous strategy for male exploitation is honeycomb trap technique. In this technique a lady blames a man under misleading claim for assault, endowment that they can bring in cash out of it. It is what is going on in which somebody is fooled into unethical or unlawful sexual way of behaving can be openly uncovered.

Uplifting one part of the society do not mean rejecting others. Our society is so focused on upliftment of women that we have rejected the male citizens.People doesn’t realize that not even fingers in their hands are all same.  We have generalized them by “All men are same.”


We are so focused on uplifting women that we neglected other genders in the society. Law should be made for all citizens regardless what is their gender. Empowerment is needed but it should not be at the cost of anybody’s suppression. Law makers of our country made laws for protection of rights of women in the society. But as every coin has two sides and every action taken has both positive and negative results here also these laws are protecting women but they are also victimising men in some cases.

In the present times where the social media s faster than news itself, many cases came in spotlight through out the years where women falsely accuse men for their benefits or even revenge. These laws are an easy way for some people to get their way. This is the sad reality where many women are suffering from abuse daily in their family for one reason or other, there are others who are just using these allegations and laws as a way to make some quick cash. India has a male dominating society. In India every year hundreds of women get either raped or molested or victimised in one or the other manner. This everyone knows and what shameful is no one is doing anything to protect them. But a there is one more side to this which no one really talks about which is “male victimisation or male abuse”.


The term Gender Neutral means the view where the arrangements, language, and other social establishments ought to abstain from recognizing jobs as indicated by individuals' sex or orientation, to keep away from segregation emerging from the feeling that there are social jobs for which one orientation is more fit than another. All sexual orientations ought to be regarded. The bill was presented in 2012 and they suspended it in 2013 when it was accounted for by the Ministry of Home Affairs in a PIL that main a man can be a violator and not a casualty. The Indian Constitution under Article 14[1] and 15[2] discussions about correspondence.

The following provision in IPC[3] suggests gender inequality:

1.     Section 304B[4] and Section 498A[5]

The term 'Dowery Death' flashes off clear minds in one's mind of a lady being provoked and pestered for cash lastly, hanged to death inside the four dividers of her home. Women's activists have us accept that each unnatural or troublesome passing of a wedded Indian lady is settlement demise. Not just that, the women's activist poetic exaggeration on "lady killing" and "settlement badgering" makes it seem as though Indian men have an uncanny penchant to submit viciousness on their spouses for cash and property.[6]

2.     Section 375[7]

As per S. 375 of the IPC, you must take care of business to formally assault, and a lady to authoritatively get assaulted! The segment doesn't perceive men as assault casualties. India's enemy of homosexuality regulation, Section 377, is the main retreat for male casualties of sexual offenses. Notwithstanding, the law is loaded with difficulties. Indeed, even in situations where a male casualty is attacked by a male assailant, it isn't really considered as assault. The law frames no contrast among consensual and non-consensual sex between male grown-ups. Besides, assuming a female is the culprit, the casualty is passed on with no choice to look for equity!

It is intriguing to take note of that in the Criminal Law (Amendment) Ordinance, 2013, the violations of assault and inappropriate behaviour were sexually unbiased. The expression "assault" was eliminated and was subbed with "rape". Be that as it may, solid protests were raised by ladies' gatherings and the Act wound up making the offenses of assault and lewd behaviour orientation explicit. There are different recommendations advanced by women's activists on the side of this respect, for example, men not being as powerless, them continuously needing sex, ladies' ineptitude to assault men, men not being also impacted by assault, et cetera.

3.     Section 497[8] and Section 498[9]

Section 497 of the IPC says, "Whoever has sex with an individual who is and whom he knows or has motivation to accept to be the spouse of another man, without the assent or conspiracy of that man, such sex not measuring the offense of assault, is at legitimate fault for the offense of infidelity and will be rebuffed with detainment of one or the other depiction for a term which might stretch out to 5 years, or with fine, or with both. In such case, the spouse will not be culpable as an abettor."

In Sowmatri Vishnu v. Union of India[10], Sowmatri, whose darling was arraigned for infidelity, battled that the law was orientation one-sided. Regardless of being an equivalent party in the offense, the lady was a 'casualty'- she was absolved from discipline, as a kid would be, recommending that the lady submitting infidelity is unequipped for judicious idea and subsequently has no organization. This view is re-asserted by the following code in series, Section 498.[11]

Section-498 of the IPC Says Enticing or taking away or detaining with criminal intent a married woman. "Whoever takes or captivates any lady who is and whom he knows or has motivations to accept to be the spouse of some other man, from that man, or from any individual having the consideration of her for the benefit of that man, with purpose that she might have illegal intercourse with any individual or covers or confines with that aim any such lady, will be rebuffed with detainment of one or the other depiction for a term which might stretch out to two years, or with fine, or with both".

Some other provisions which suggest gender biasness are as follows:

1.     Under the Hindu Succession Act of 1956, assuming the expired has no will, the life partner, mother and kids acquire the property having a place with the perished. The dad is possibly entitled in the event that the expired doesn't have a mate, mother or kids.

2.     Under the Hindu Adoption and Maintenance Act of 1956, it is the guardians' liability to a young lady youngster's support till she chooses to accommodate herself or gets hitched.

3.     Under the Special Marriage Act, only the wife can claim permanent alimony and maintenance.


In our country despite being so much development the thinking and understanding of citizens have stopped somewhere. In today’s time where there are so many moments for equality, environment and so many crises we are facing, we have stopped recognising the pain of others especially men. Yes, they are species of privilegefrom the ancient times but we have generalised them in a way that we refuse that they can be victims too. According to a report by ministry of women and child welfare among 53.22% children abused in India in year 2007 52.94% are boys. But no one talks about it, everyone is forgetting that not all women are victim. Somewhere as a society we have forgotten that equality goes both ways. In today’s time if a man slaps a woman, he is called abuser but if a woman slaps men she is brave. We as a society have a common mindset which forces us to believe that women are equals to victim. And yes, it is true but somewhere in some cases women are the abuser and men are the victims.

If a man told you that he is been raped or beaten by his wife or eve teased by someone. What will be your reaction? It is something to think about.

On one hand these laws are relief for many in need but on the other hand they can also ruin life of an innocent men.


The 5-judge bench on account of Joseph Shine v. Association of India[12] held segment 497 illegal. It was held by the Supreme Court that this part is inconsistent in nature, disregards article 14 and 15 of the constitution and segregate people. The court likewise held that:

Spouse isn't the expert of wife. Ladies’ ought to be treated with correspondence alongside men, and antiquated thoughts of man being culprit and lady being casualty never again hold great"

Our expectation here is tolerating the way that there can be wrongdoings against men, that men likewise endure, and that ladies can be culprits too. There have been missions and developments overall for the reason for men. Global Men's Day is commended on November 19 consistently, from 2007, because of International Women's Day. We, as a society, truly need to install Gender-Sensitivity among ourselves, foster a sensation of regard and warmth towards the other gender, and comprehend that to elevate one segment; we don't need to persecute the other.

Legitimately, we really want to guarantee that impartial language is utilized in our regulations, and both the genders are similarly safeguarded. Regulations ought not be founded on the assumption that only one of the genders is the culprit, and the other, a hapless casualty.

If we truly have any desire to lay out an orientation just society, we really want to perceive LGBT freedoms also, on the grounds that that will guarantee both lawful equity, and cultural incorporation, everything being equal.

Ultimately, we should really try to understand that wrongdoing has no orientation, and everybody ought to be deflected from carrying out it. It incurs incalculable sufferings upon the person in question, and he merits equity.


After the Nirbhaya case[13], another hint of something to look forward to arose, with the interest for sexually unbiased regulations, yet this trust was run on account of "Rishi Malhotra v. Union of India[14]." However, the Law Commission exhorted that we supplant the words that accentuate a particular orientation with the word human, which covers the two sexual orientations. Thus, it is important that we eliminate regulations that separate among people. Everybody, whether she is a lady or a man, is qualified for similar regard, in this way regulations will be something very similar. We need to remember that crime has no gender.

This blog is authorized by Poorva student of Banasthali Vidyapith.

[1]The State shall not deny to any person equality before the law or the equal protection of the laws within the territory of India.

[2]secures the citizens from every sort of discrimination by the State, on the grounds of religion, race, caste, sex or place of birth or any of them.


[4]Dowery death

[5] Cruelty against women

[7] Rape

[8] Adultery

[9] Detaining with criminal intent a married woman

[10]AIR 1985 SC 1618

[12](2019) 3 SCC 39.

[13](2017) 6 SCC 1

[14]19 July 2019

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