The Modi lead Union Government during its second tenure revoked the special status accorded to the State of Jammu and Kashmir under Article 370 of The Constitution of India, vide. the Constitution (Application to Jammu and Kashmir) Order, 2019 issued by the President of India on 5th August 2019 and 6th August 2019. Followed by the said Presidential order(s), another act, namely “Jammu and Kashmir Reorganization Act, 2019” was passed by both houses of the Parliament and got assent from the President on 9th August 2019. This act reorganized the existing State of Jammu and Kashmir into two Union territories, namely (a) Union territory of Jammu and Kashmir, and (b) Union territory of Ladakh.
Many journalists, writers, bloggers and political experts refer to the aforementioned Presidential order(s) as an amendment of Article 370, repeal of Article 370, abrogation of Article 370, etc. However, for this Article let us refer to it as the Presidential Order(s), given the legal appropriateness.
Chronology of legal events relevant to the subject under discussion:
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15 Aug 1947 |
India attains Independence |
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26 Oct 1947(1) |
The instrument of accession signed by Maharaja Hari Singh, ruler of the princely state of Jammu and Kashmir, under the provisions of the Indian Independence Act 1947, acceding to the Dominion of India. |
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26 Jan 1950(2) |
The Constitution of India is adopted Article, with Article 370 described as a “temporary provision”. |
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26 Jan 1950(3) |
The Constitutional Order (CO) 10 issued providing for special provisions for State of Jammu and Kashmir inter alia providing for > Giving effect to special status to State of Jammu and Kashmir > Limited the powers of the Union (Dominion) to subjects listed in the first schedule of the order. > All references to “Rajpramukh” shall be construed as references to the “Sadar-i-Riyasat of Jammu and Kashmir” (As per Art.366 (21b) of the Indian Constitution (as it existed in 1950) Rajpramukh means, in relation to the State of Jammu and Kashmir ………., the person who for the time being is recognized by the President as the Maharaja of that State) |
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14 May 1954(4) |
The Constitutional Order 48 issued superseding Constitutional Order 10, for State of Jammu and Kashmir (hereinafter referred to as CO48) inter alia providing for > Added Article 35A to The Constitution of India, empowering the Jammu and Kashmir state’s legislature to define “permanent residents” of the state and provide special rights and privileges to those permanent residents. > Modified All references to “Sadar-i-Riyasat of Jammu and Kashmir” to be construed as references to the “Governor of Jammu and Kashmir” > Article 356 (power to impose presidential rule in case of failure of constitutional machinery in State) extended to the State of Jammu and Kashmir, subject to Constitution of Jammu and Kashmir |
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25 Jan 1957 |
The Constituent Assembly of Jammu and Kashmir was dissolved, without recommending the abrogation of Article 370. |
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26 Jan 1957(5) |
The Constitution of Jammu and Kashmir as empowered under Article 370, came into force. |
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20 Jun 2018 |
Governor’s rule imposed in the state of Jammu and Kashmir under Article 92 of the Constitution of Jammu and Kashmir |
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21 Nov 2018 |
Governor dissolved the 87-member legislative assembly |
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20 Dec 2018 |
President’s rule imposed in the State of Jammu and Kashmir, on the recommendation of the Governor of the State of Jammu and Kashmir under Article 356 of the Indian Constitution, since the Constitution of Jammu and Kashmir had no provision for extension of Governor’s rule) |
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03 Jul 2019 |
Union Cabinet extends the imposition of President’s by 6 months |
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05 Aug 2019(6) |
The Constitution (Application to Jammu and Kashmir) Order, No. 272, issued superseding the CO No. 48 [The Constitution (Application to Jammu and Kashmir) Order, 1954], for State of Jammu and Kashmir (hereinafter referred to as CO272). > The President, in concurrence with the Government of State of Jammu and Kashmir, through Governor of Jammu and Kashmir, revoked special status accorded to State of Jammu and Kashmir and made applicable all the provisions of the Indian Constitution, as amended from time to time, shall apply in relation to the State of Jammu and Kashmir > Amended Article 367 of the Constitution of India to the effect that all references to the Government of the said State shall be construed as including references to the Governor of Jammu and Kashmir acting on the advice of his Council of Ministers > In the proviso to Article 370(3) of the Constitution of India, the expression “Constituent Assembly of the State referred to in clause (2)” shall read “Legislative Assembly of the State” |
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06 Aug 2019(7) |
The Constitution (Application to Jammu and Kashmir) Order No. 273 issued declaring that as from the 6th August 2019, all clauses of the Article 370 shall cease to be operative (hereinafter referred to as CO273). |
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09 Aug 2019(8) |
The Jammu and Kashmir Reorganisation Act, 2019 (hereinafter referred to as J&KRA) passed. Reorganized the existing State of Jammu and Kashmir into two Union territories, namely (a) Union territory of Jammu and Kashmir, and (b) Union territory of Ladakh |
Legal status of State of Jammu and Kashmir before the Presidential order(s) 272 & 273.
Let’s first have a verbatim look at Article 370 of Constitution of India (hereinafter referred to as Article 370).
- Temporary provisions with respect to the State of Jammu and Kashmir.
(1) Notwithstanding anything in this Constitution-
(a) the provisions of Article 238 shall not apply in relation to the State of Jammu and Kashmir;
(b) the power of Parliament to make laws for the said State shall be limited to
(i) those matters in the Union List and the Concurrent List which, in consultation with the Government of the State, are declared by the President to correspond to matters specified in the Instrument of Accession governing the accession of the State to the Dominion of India as the matters with respect to which the Dominion Legislature may make laws for that State; and
(ii) such other matters in the said Lists as, with the concurrence of the Government of the State, the President may by order specify Explanation: For the purposes of this Article, the Government of the State means the person for the time being recognised by the President as the Maharaja of Jammu and Kashmir acting on the advice of the Council of Ministers for the time being in office under the Maharajas Proclamation dated the fifth day of March, 1948 ;
(c) the provisions of Article 1 and of this Article shall apply in relation to that State;
(d) such of the other provisions of this Constitution shall apply in relation to that State subject to such exceptions and modifications as the President may by order specify:
Provided that no such order which relates to the matters specified in the Instrument of accession of the state referred to in paragraph (i) of sub-clause (b) shall be issued except in consultation with the Government of the State:
Provided further that no such order which relates to matters other than those referred to in the last preceding proviso shall be issued except with the concurrence of that Government.
(2) if the concurrence of the Government of the state referred to in paragraph (ii) of sub-clause (b) of clause (1) or in the second proviso to sub-clause (d) of that clause be given before the Constituent Assembly for the purpose of framing the constitution of the state is convened, it shall be placed before such assembly for such decision as it may take thereon.
(3) Notwithstanding anything in the foregoing provisions of this Article, the President may, by public notification, declare that this Article shall cease to be operative or shall be operative only with such exceptions and modifications and form such dated as he may specify.
Provided that recommendation of the Constituent Assembly of the State referred to in clause (2) shall be necessary before the President issues such a notification.
Article 370 clause (1) starts with the non-obstante clause, which confers its supremacy over the rest of the articles of The Constitution of India. Sub-clause (d) provides unfettered and unlimited powers to The President, to extend any other provision or exception, by simply issuing a Presidential order. However, this legal position has been made “subject to” the two provisos under sub-clause (d). The first proviso makes it mandatory that for matters specified in Instruments of accession the same shall be done in consultation with the Government of the State. The second proviso makes it mandatory that for all other matters the concurrence of the State Government is necessary. Clause (3) confers power on the President to declare that provision of this article ceases to operate, or have a limited operation, provided it has the recommendation of the Constituent Assembly of the State of Jammu and Kashmir.
Article 370 granted the state of Jammu and Kashmir a special status within the Indian Union. Under Article 370 clause (1)(b), the Union Government could only make laws for the state, in consultation with the Government of the State only on limited matters of Defence, Foreign Affairs, and Communications as specified in the Instrument of Accession. On any other matter the Union Government could only make laws vide a Presidential Order, with the concurrence of the Government of the State.
Article 370 clause (1)(d) stipulated that other constitutional provisions may be applied to the state from time to time, “subject to such modifications or exceptions” made by the president of India, also through a presidential order, as long as they do not fall within the matters referred to above and with the concurrence of the state government
Article 370 clause (3), confers power on The President of India to amend or repeal Article 370 itself through a notification (declaring that this Article “shall cease to be operative or shall be operative only with such exceptions and modifications”), provided that “the recommendation of the Constituent Assembly of the State” is given before the President issues such a notification.
On account of this status, the State of Jammu and Kashmir enacted its Constitution, which was formally adopted by a Constituent Assembly on 17th November 1956, and entered into force on 26th January 1957.
Steps that were taken by the Government.
On 5th August 2019, the president of India issued the Constitution (Application to Jammu and Kashmir) Order, 2019, C.O. 272, under Article 370 clause (1). Since the Union Government could not directly rely on Article 370 clause (3) to abrogate other Articles, it sought to use its powers under Article 370 clause (1) to amend Article 367 of Constitution of India (hereinafter referred to as Article 367), the interpretation clause of the Constitution, so that references to “Government of the State [Jammu and Kashmir]” in Article 370 would be construed as the Governor of Jammu and Kashmir, and the expression “Constituent Assembly of the State [Jammu and Kashmir] referred to in Article 370 clause (2)” shall read “Legislative Assembly of the State”.
On the same day, the Rajya Sabha passed a Statutory Resolution recommending that the President of India abrogate most of Article 370 pursuant to Article 370 clause (3). The next day, on August 6, the President implemented the resolution and revoked Jammu and Kashmir’s special status through Presidential Order C.O. 273(7), which stated that, as of 6th August 2019, “all clauses of the said Article 370 shall cease to be operative, and that all the provisions of this Constitution, as amended from time to time, without any modifications or exceptions, shall apply to the State of Jammu and Kashmir.”
Case of the government
Due to the Presidential orders and amendments from time to time, the Ruler of the State of Jammu and Kashmir (Rajpramukh) was equated to Sadar-i-Riyasat. The Sadar-i-Riyasat was equated to the Governor of the State of Jammu and Kashmir vide The Constitution orders 10 and 48, and the “Constituent assembly” State of Jammu and Kashmir is to be read as the “Legislative Assembly” of State of Jammu and Kashmir (as amended Article 367 by CO272), therefore, consultation with the constituent assembly means the consultation with Legislative Assembly. Therefore, this not the first time such a power was exercised by the President of India.
Because the legislative assembly of State of Jammu and Kashmir was dissolved, the Governor has assumed on itself all/any functions of the Government of State of Jammu and Kashmir, the consultation with the Governor is deemed to be consultation with the Government of State of Jammu and Kashmir. Its recommendation to bring about the changes in Article 370 to make the entire Constitution of India applicable to the State of Jammu and Kashmir as the consent of the Government of State of Jammu and Kashmir.
As a result, the union government, by exercising its power under Article 370 clause (1), modified Article 367. The President of India under the power of Article 370 clause (3) passed an order to cease the operation of Article 370 from in the State of Jammu and Kashmir and complied with requirements of the proviso as per the modified Article 367.
By exercising its powers under Article 3 clause (a) of the Constitution of India (Part 1), for the reorganization of the State and its bifurcation into two union territories, the requirements of Article 3 are also satisfied, for altering shape/boundary of the state, for seeking views of the state assembly, by seeking views of the Governor of State of Jammu and Kashmir, who in turn, represented the view of the Government of the then State of Jammu and Kashmir.
Contrary/Opposition views
The case against the said action of the Union Government involves a multi-facet challenge, namely:
The CO272 is ultra vires Article 370, whereby clause (4) was Article 367, after the dissolution of Constituent Assembly. The instrument of accession particularly and expressly stated non-acceptance of any future Constitution of India. The contents of Article 370 were meant to operationalize the instrument of accession within the constitutional framework of the Constitution of India and believed to be operative during the lifetime of the Constituent Assembly. Non-acceptance of any future Indian constitution was a condition precedent for the accession of the State of Jammu and Kashmir into Dominion of India. Therefore, Article 370 cannot be amended, repealed or de-operationalized by the Union Government unilaterally, in absence of Constituent Assembly, even under plenary powers of Article 368 of the Constitution of India. The President is conferred with the power to apply other provisions of the constitution with exceptions and modifications. However, the power to apply “such other provisions” with exception and modification, excludes Article 1 and Article 370 of the Constitution of India by implication. Clause 2(d) of the CO272 violates this expressly by modifying Article 370 (3) proviso.
Furthermore, based on the doctrine of colorable legislation (which fundamentally says that one cannot do indirectly what one cannot do directly) it is argued that when the President is expressly barred to make any exception or modification to Article 1 and Article 370, under Article 370 clause (1) subclause (c) read with subclause (d). Therefore, any modifications, under Article 370 clause (1), applied to Article 367, whatsoever, cannot be read back into Article 370 and thereby alter its interpretation given the modified Article 367.
It should also be noted that the Powers of the Governor during the emergency (Article 92 of The Constitution of Jammu and Kashmir, hereinafter referred to as Article 92) is limited to carrying out of the day-to-day and necessary function of the Government and is not meant to make policy decisions, which can wait for the election of the legislative assembly, including the power to express views on behalf of the State Legislature. The powers delegated to the Governor under Article 92 are subject to clause (4), which states that such act of the Governor shall cease to have an effect on the expiry of 2 years, unless sooner repealed or re-enacted by the legislature. This indicates that such an act of the Governor is temporary and must be ratified by the State Legislature to attain permanency. Therefore, when the Governor makes such orders, acts or expresses its views on behalf of State Legislature, which are irreversible, it renders Article 92 clause (4) infructuous and therefore, are unconstitutional.
Similarly, the President’s rule under Article 356 of the Constitution of India, the Parliament of India acting on behalf of the State Legislature is limited to carrying out of the day-to-day and necessary function of the Government and cannot take-up any/all matters under state list despite the absence of any compelling circumstances. When the Parliament makes such resolutions, orders or acts on behalf of State Legislature, which is irreversible, it renders Article 356 clause (4) infructuous and therefore, such action is unconstitutional.
Interestingly, the Governor is an appointee of the Union Government, and therefore, a representative of the Union. The Governor lacks the capacity/power of consultation between Union and State government and express its view, on behalf of the State Legislature, when the State Legislature is non-existent, defunct or not in operation for any reason whatsoever, and by doing so, the entire purpose of “consultation with the Governor, working under the aid and advise of the legislative assembly” stands vitiated. Such an act of the Governor is against the letter and spirit of the Instrument of Accession, the federal structure of the Constitution of India and the relationship between the Union and the States.
Another view is that the text in Article 370 title with the word “temporary” was meant to indicate its temporary nature until the Constituent Assembly frames the Constitution for the State of Jammu and Kashmir. The said Constituent Assembly was dissolved on 25th January 1957. As a result, Article 370 clause (3) became defunct/non-operational on 26th January 1957 as the Constituent Assembly before its dissolution did not express any views on Article 370, hence the same had now become a permanent feature
Status of the Challenge in The Supreme Court
Several writ petitions have been filed in the Hon’ble Supreme Court of India, challenging the CO272, CO273 and J&KRA. The petition in W.P. (C) 1368/19 titled as People’s Union For Civil Liberties & Anr v. Union Of India, tagged along with W.P.(C) 1099/19 titled as Dr. Shah Faesal & Ors v. Union Of India raised the contention that the present matter needs to be referred to a larger Bench as there were contrary opinions by two different Constitution Benches on the interpretation of Article 370 of the Constitution. It was contended that in the case of Prem Nath Kaul v. State of Jammu and Kashmir, AIR 1959 SC 749, after considering the various issues, held that Article 370 was temporary, but the subsequent judgment of Sampat Prakash v. State of Jammu and Kashmir, AIR 1970 SC 1118, reversed the aforesaid position, recognizing Article 370 as a permanent provision giving perennial power to the President to regulate the relationship between the Union and the State. Therefore, this conflict needs reconsideration by a larger Bench. The Apex court vide an order dated 2nd March 2020 in the aforesaid matters, held that there is no conflict between the judgments in the Prem Nath Kaul case (supra) and the Sampat Prakash case (supra) since the Apex Court in the Prem Nath Kaul case (supra) had to determine the legislative competence of the Yuvaraj, in passing a particular enactment, the court did not discuss the continuation or cessation of the operation of Article 370 after the dissolution of the Constituent Assembly of the State of Jammu and Kashmir, a contention which was specifically made before and refuted by, the Apex Court in the case of Prem Nath Kaul case (supra). Hence, the plea to refer the present matter to a larger Bench on this ground was rejected.
Multiple petitions, have been filed on multiple questions of law before the Supreme Court, each such question may require separate and special handling, and the same shall be heard and decided by the Apex Court in due course.
Author’s view on the subject matter
The court would decide the matter in time to come, however, purely for the academic purposes, let me try to put down thoughts and views on the various questions of law as per my understanding of the law.
Question of law: Whether the nature of Article 370 is temporary or is permanent.
Author’s View: The headline text of Article 370 is “Temporary provisions with respect to the State of Jammu and Kashmir”. Also, subsection (3) expressly states that “President may, by notification, declare that this Article shall cease to be operative”, thereby affirms that framers of the constitution intended this Article to be in operation for a limited period. However, such limited period was not prescribed within the Article, possibly because it was not practically foreseeable for the framers of the constitution. This also confirms that the President does have the power under Article 370 (3) to de-operationalize Article 370, subject to conditions laid down in the proviso. It should also be noted in the case of Sampat Prakash v. State of Jammu and Kashmir (supra) after considering the various issues, it was held in Para 7 that :
“There are, however, much stronger reasons for holding that the provisions of this article continued in force and remained effective even after the Constituent Assembly of the State had passed the Constitution of the State. The most important provision in this connection is that contained in clause (3) of the article which lays down that this article shall of the article shall cease to be operative or shall be operative only with such exceptions and modifications and from such date as the President may specify by public notification, provided that the recommendation of the Constituent Assembly of the State referred to in clause (2) shall be necessary before the President issues such a notification………………………….”
This view has been further affirmed recently by the Supreme Court of India in the case of State Bank of India v. Santosh Gupta and Anr, (2017) 2 SCC 538 and held that
………… however, much stronger reasons for holding that the provisions. of this article continued in force and remained effective even after the Constituent Assembly of the State had passed the Constitution of the State. The most important provision in this connection is that contained in clause (3) of the article which lays down that this article shall cease to be operative or shall be operative only with such exceptions and modifications and from, such date as the President may specify by public notification, provided that the recommendation of the Constituent Assembly of the State referred to in clause (2) shall be necessary before the President issues such a notification. This clause clearly envisages that the article will continue to be operative and can cease to be operative only if, on the recommendation of the Constituent Assembly of the State, the President makes a direction to that effect. … … …
Hence it can now be inferred that Article 370 was a “temporary provision” as intended by the framers of the constitution, however, the Constituent Assembly of the State of Jammu and Kashmir dissolved itself on 25th January 1957, therefore, the Article 370 clause (3) proviso has become defunct making the power under Article 370 clause (3) non-exercisable and thus, have acquired a permanent feature of the Indian constitution.
The CO272, by amending Article 367, has attempted to remove this impediment and to operationalize the proviso to Article 370 clause (3) by altering the expression “Constituent Assembly of the State” to “Legislative Assembly of the State”.
Question of law: Whether President has the power to amend, repeal or modify any Article of the Constitution, while exercising power under Article 370 clause (1)(d), including Article 370 of Constitution of India.
Author’s View: Article 370 clause (1)(c) of Constitution of India states that Article 1 and this Article 370 shall apply to the state (of Jammu and Kashmir) and Article 370 clause (1)(d) states that “other provisions of this Constitution”, which may be subjected to “exceptions and modification” by the President. The word “other” here indicates Articles other than the ones mentioned in the previous sub-clause, that is, Article 1 and Article 370. Therefore, when the President modifies any “other” Article while exercising its power under Article 370 clause (1)(d) in any manner and to any extent whatsoever, the said modification cannot result into a different interpretation of Article 370 by re-interpretation, given such modification. Such reading-back of modification into the Article 370 would amount to a modification of the Article 370 itself, which is barred by implication under Article 370 clause (1) subclause (c) read with subclause (d).
Question of law: Whether the Governor, in absence of the state assembly, under Article 92 of Constitution of Jammu and Kashmir or the Parliament exercising functions of the State, under Article 356 clause (1)(a), can legally resolve, legislate or express its view or consult on behalf of the State Legislature of State of Jammu and Kashmir for any policy matter relating to the state, particularly when such “resolution” or “legislation” or “views” or “consultation” are irreversible.
Author’s View: Article 92 clause (4) states that any laws made by the Governor under Article 92 clause (1)(a) of The Constitution of Jammu and Kashmir cease to have effect after two years unless sooner repealed or re-enacted by an Act of the State Legislature. This indicates that any/all laws made by the Governor under 92 clause (1)(a) are temporary and have a limited lifespan unless ratified by the State Legislative Assembly. Similarly, under Article 356 clause (4) of the Constitution of India, any laws made by the Parliament under Article 356 clause (1)(a) ceases to have effect after six months, and maybe extend by further six months, if approved by both houses of Parliament, but not beyond 3 years. This as well expressly states that any/all laws made by the Parliament under Article 356 clause (1)(a) are temporary unless repealed or ratified by the Legislative Assembly of the corresponding State before expiry. Therefore, any policy decisions which is irreversible must and ought to be outside the powers of the Parliament, unless the circumstances warrant such a law on grounds of urgency and cannot wait for Legislative Assembly to become operational. The onus to establish such urgency would lie on Governor of erstwhile State of Jammu and Kashmir and/or the Parliament given the then prevailing circumstances. If the power under aforementioned Articles of the two constitutions is exercised to make such irreversible orders, resolutions and legislations casually, then it will render Article 92 clause (4) and Article 356 clause (4) infructuous and a dead letter. Such exercise of power is ultra-vires and amounts to fraud on the constitution.
Question of law: Whether the Jammu and Kashmir Reorganisation Act, 2019 is unconstitutional as it has not satisfied the requirements of Article 3 of the Constitution of India.
Author’s View: The Article 3 of the Constitution of India was made applicable to the State of Jammu and Kashmir vide CO48 along with a proviso that “Provided further that no Bill providing for increasing or diminishing the area of the State of Jammu and Kashmir or altering the name or boundary of that State shall be introduced in Parliament without the consent of the Legislature of that State.”. Therefore, we go back to the previous question, that, whether in absence of the state legislature, Parliament can express views or give consent while functioning/acting on behalf of State Legislature, which is irreversible. This question was concluded in negative, therefore, the law made under the exercise of such power is also illegal and should be void ab-initio.
Question of law: Whether it is operationally possible/practicable to set aside the CO272 and CO273, which in-turn result into setting aside of the J&KRA as well and bring the erstwhile State of Jammu and Kashmir into the status-quo-ante state.
Author’s View: As an outcome of questions of law above, the CO272, CO273 and the J&KRA would be liable for setting aside. Such setting aside will not just void these orders and the legislation, but will bring all subsequent actions of the Parliament and the executives, under judicial scrutiny, made with respect to the erstwhile State of Jammu and Kashmir, either in pursuance of CO272, CO273, J&KRA or any other action thereunder (for example people kept in detention under preventive detention law).
Such relief would mean that the State of Jammu and Kashmir, will be restored with its special status as before 5th August 2019, this would leave the State as well as the nation in a state of chaos.
The Apex court may exercise its powers under Article 142 to make appropriate orders to minimize the litigation flood in view of setting aside of CO272, CO273, the J&KRA and any other incidental or connected matters.
Irrespective of the approach adopted by the Supreme Court to handle the chaos and soften the blow, the Election Commission would be required to conduct the fresh legislative elections at the earliest possible timeframe. With that, the State of Jammu and Kashmir will spring back to life.
Author
Neeraj Sharma (Advocate)
Disclaimer: The views and opinions expressed in this article are those of the author alone and do not necessarily reflect the official position of Vedya Partners.
References:
1: http://jklaw.nic.in/instrument_of_accession_of_jammu_and_kashmir_state.pdf
2: https://dl.wdl.org/2672/service/2672.pdf
3: http://www.jeywin.com/wp-content/uploads/2009/12/Constitution-of-India-Constitution-Order-10.pdf
4: http://jklaw.nic.in/constitution_jk.pdf
5: http://jklaw.nic.in/pdf/CONSTITUTION%20.pdf
6: http://egazette.nic.in/WriteReadData/2019/210049.pdf
7: http://egazette.nic.in/WriteReadData/2019/210243.pdf
8: http://egazette.nic.in/WriteReadData/2019/210407.pdf
ABOUT THE AUTHOR
Neeraj Sharma
Neeraj is an associate at Vedya Partners, he is a Civil Litigation Lawyer, who regularly appears before various forums in Delhi ranging from the the Hon’ble High Court of Delhi, Sessions and District Courts, TDSAT and NCDRC. Neeraj decided to make shift into the Legal Profession, leaving behind a successful career of over 18 years with several Fortune 500 Companies as an Senior IT Engineer. His passion and commitment to law is evident by his hard work.
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