Author: PRASANNASRI26092001

GIAN KAUR VS STATE OF PUNJAB AIR 1996 SC 946

AUTHOR – T.CHARUMATHI, STUDENT AT SCHOOL OF EXCELLENCE IN LAW, TAMIL NADU DR. AMBEDKAR LAW UNIVERSITY

BEST CITATION – T.CHARUMATHI, GIAN KAUR VS STATE OF PUNJAB AIR 1996 SC 946, INDIAN JOURNAL OF LEGAL REVIEW (IJLR), 6 (4) OF 2026, PG. 420-425, APIS – 3920 – 0001 & ISSN – 2583-2344.

INTRODUCTION:

Article 21 of the Constitution of India provides that no person shall be deprived of his life and personal liberty except in accordance with a procedure established by law. The importance of this article has been reiterated by the judicial authorities of our country on many occasions and is widely regarded as one of the fundamental tenets of civilized society. Public policy prohibits the enactment of laws which deprive individuals of their life or liberty for arbitrary/irrational reasons, thereby contravening fundamental human rights. The necessity of Article 21 is fundamental to the principles of justice and rule of law and is such that it can be suspended even in cases of national emergencies. Bhagwati J., writing for the Court in Francis Coralie Mullin v. The Administrator, ^[1]also spoke about the significance of Article 21 as a constitutional principle integral to democratic governance. The article scope includes all cases where someone loses their life or freedom (regardless of the reason). Hence, what does this article actually advocate? What does this right to live mean? How does this right to die relate? If there is a connection between the two rights, why do we impose criminal punishment for attempted suicide? The right to live and the right to die are separate rights but somehow related. One permits and one prohibits. An analysis of Gian Kaur v. State of Punjab (an important case in relation to this subject) will elucidate the lines between the two rights.

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[1] AIR 1981 SC 746;

REGULATING MICRO INSURANCE FOR FINANCIAL INCLUSION: AN ANALYSIS OF LEGAL AND REGULATORY BARRIERS IN INDIA

AUTHOR – DIYA MITTAL* & DR. RENU MAHAJAN**

* STUDENT AT AMITY UNIVERSITY, NOIDA

** PROFESSOR AT AMITY UNIVERSITY, NOIDA

BEST CITATION – DIYA MITTAL & DR. RENU MAHAJAN, REGULATING MICRO INSURANCE FOR FINANCIAL INCLUSION: AN ANALYSIS OF LEGAL AND REGULATORY BARRIERS IN INDIA, INDIAN JOURNAL OF LEGAL REVIEW (IJLR), 6 (4) OF 2026, PG. 401-419, APIS – 3920 – 0001 & ISSN – 2583-2344.

Abstract

Micro-insurance has emerged as an important instrument of financial inclusion in India, particularly for low-income households, informal workers, small farmers, migrant labourers and other economically vulnerable groups who remain largely outside formal social security systems. It provides affordable risk protection against contingencies such as death, disability, illness, accidents and livelihood shocks, thereby reducing the possibility that sudden financial crises push vulnerable households deeper into poverty. This paper examines the legal and regulatory framework governing micro-insurance in India and critically analyses the barriers that hinder its effectiveness as a tool of inclusive development.

The study explores the statutory foundation of micro-insurance through the Insurance Act, 1938 and the Insurance Regulatory and Development Authority Act, 1999, and evaluates the role of the Insurance Regulatory and Development Authority of India (IRDAI) in shaping inclusive insurance governance. Particular attention is given to the IRDAI (Micro Insurance) Regulations, 2005 and 2015, including issues relating to product design, eligibility, distribution channels, disclosure norms and claims settlement procedures. The paper also analyses the contribution of government-supported schemes such as Pradhan Mantri Jeevan Jyoti Bima Yojana, Pradhan Mantri Suraksha Bima Yojana^[1], Ayushman Bharat and the wider financial inclusion framework created through Pradhan Mantri Jan Dhan Yojana.

The paper argues that despite the existence of an extensive legal and policy framework, micro-insurance in India continues to face significant structural and regulatory challenges. These include low awareness, weak consumer protection, mis-selling, infrastructural constraints, overlapping regulatory jurisdictions, claims-related difficulties and digital exclusion. It concludes that for micro-insurance to function as a meaningful instrument of financial inclusion, the legal regime must move beyond formal access and focus on substantive accessibility, accountability and equity. The paper ultimately positions micro-insurance not merely as a financial product, but as a critical mechanism of social protection and distributive justice in India.

Keywords: Micro-Insurance; Financial Inclusion; Insurance Regulation; IRDAI; Low-Income Policyholders; Consumer Protection; Social Security; Insurance Law; Inclusive Development; India

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[1] Pradhan Mantri Suraksha Bima Yojana, Ministry of Finance, Government of India, Operational Guidelines (2015).

FROM SILENCE TO RIGHTS:  RECOGNISING MENSTRUAL HEALTH AND HYGIENE WITHIN INDIA’S FUNDAMENTAL RIGHTS FRAMEWORK

AUTHOR – CHARUMATHI.T, STUDENT AT SCHOOL OF EXCELLENCE IN LAW, TAMIL NADU DR. AMBEDKAR LAW UNIVERSITY

BEST CITATION – CHARUMATHI.T, FROM SILENCE TO RIGHTS:  RECOGNISING MENSTRUAL HEALTH AND HYGIENE WITHIN INDIA’S FUNDAMENTAL RIGHTS FRAMEWORK, INDIAN JOURNAL OF LEGAL REVIEW (IJLR), 6 (4) OF 2026, PG. 387-400, APIS – 3920 – 0001 & ISSN – 2583-2344.

ABSTRACT:

In India, menstrual hygiene and health have transformed from being socially taboo to having become a constitutional issue of importance. The Supreme Court of India has determined that hygienic menstruation is part of the broad interpretation based on Article 21 that constitutes basic rights to equality, health, dignity, and life. Menstruation rights as basic human rights to the protection against discrimination to access products for menstruation, safe sanitation, and medical care are guaranteed by Articles 14, 15, and 21 of the Indian Constitution. This research uses a doctrinal approach to assess menstruation hygiene as part of the broader Indian framework of fundamental rights. This research considers the constitutional guarantees surrounding menstrual hygiene as well as the important court cases and the various government programs aimed at increasing awareness of menstruation, improving hygiene facilities in schools, and providing free sanitary napkins to those in need. Addressed here are the continuously evolving issues that obstruct the implementation of menstrual hygiene initiatives including, but not limited to, economic barriers, lack of awareness, social stigma as well as inadequate facilities in rural areas. Setting legal recognition of menstrual hygiene as a fundamental right has made an important move toward recognizing socio-economic status, but requires different enforcement mechanisms and policies, as well as a better public understanding of these issues, in order for menstruation health to be considered a basic human right. The research findings include adding additional provisions regarding menstrual hygiene into the constitution of a country relates to human dignity and gender justice; moving from going from no rights to have rights protects people from being denied the opportunity to have a menstrual cycle .

Keywords: Article 21, Gender Justice Human Dignity Menstrual Health Basic Human Rights Supreme Court of India and Constitutional Protection.

CORPORATE SOCІAL RESPONSІBІLІTY AND CORPORATE FІNANCІAL PERFORMANCE: A STUDY WІTH SPECІAL REFERENCE TO CORPORATE CRІMІNAL LІABІLІTY

AUTHOR – SAMIKSHA SINGH* & DR. JYOTSNA SINGH**

* STUDENT AT AMITY LAW SCHOOL LUCKNOW, AMITY UNIVERSITY UTTAR PRADESH LUCKNOW CAMPUS

** ASSISTANT PROFESSOR OF LAW AT AMITY LAW SCHOOL LUCKNOW, AMITY UNIVERSITY UTTAR PRADESH LUCKNOW CAMPUS

BEST CITATION – SAMIKSHA SINGH & DR. JYOTSNA SINGH, CORPORATE SOCІAL RESPONSІBІLІTY AND CORPORATE FІNANCІAL PERFORMANCE: A STUDY WІTH SPECІAL REFERENCE TO CORPORATE CRІMІNAL LІABІLІTY, INDIAN JOURNAL OF LEGAL REVIEW (IJLR), 6 (4) OF 2026, PG. 377-386, APIS – 3920 – 0001 & ISSN – 2583-2344.

Abstract

Corporate Social Responsibility (CSR) has emerged as an essential component of modern corporate governance. With growing societal expectations and legal obligations, corporations are increasingly required to balance profitability with ethical and social responsibilities. This research paper examines the relationship between Corporate Social Responsibility (CSR) and Corporate Financial Performance (CFP), while also analyzing the impact of corporate criminal liability on this relationship. The study explores whether socially responsible corporate behavior enhances financial performance and how legal accountability for corporate crimes influences CSR initiatives. The findings indicate that CSR can improve corporate reputation, investor confidence, and long-term profitability, while corporate criminal liability acts as a regulatory mechanism encouraging ethical conduct and responsible business practices.

Keywords: Corporate Social Responsibility, Corporate Financial Performance, Corporate Governance, Corporate Criminal Liability, Companies Act 2013.

ARTIFICIAL INTELLIGENCE IN MODERN CORPORATE LEGAL DISPUTES: APPLICATIONS, CHALLENGES AND THE PATH FORWARD

AUTHOR – AKSHAT SINGH* & DR. KAVYA CHANDEL**

* STUDENT AT AMITY LAW SCHOOL LUCKNOW, AMITY UNIVERSITY UTTAR PRADESH LUCKNOW CAMPUS

** ASSISTANT PROFESSOR OF LAW AT AMITY LAW SCHOOL LUCKNOW, AMITY UNIVERSITY UTTAR PRADESH LUCKNOW CAMPUS

BEST CITATION – AKSHAT SINGH* & DR. KAVYA CHANDEL, ARTIFICIAL INTELLIGENCE IN MODERN CORPORATE LEGAL DISPUTES: APPLICATIONS, CHALLENGES AND THE PATH FORWARD INDIAN JOURNAL OF LEGAL REVIEW (IJLR), 6 (4) OF 2026, PG. 370-376, APIS – 3920 – 0001 & ISSN – 2583-2344.

Abstract

The rapid integration of artificial intelligence into corporate legal practice constitutes one of the most consequential transformations in the administration of justice in recent decades. This paper offers a systematic examination of how AI driven technologies , including machine learning, natural language processing, predictive analytics, automated contract analysis, and online dispute resolution platforms  are reshaping the full spectrum of corporate legal activity, from transactional due diligence to high stakes commercial litigation and regulatory compliance management.

The study traces the historical trajectory of AI in law, from the rudimentary rule based expert systems of the late twentieth century to the sophisticated deep learning architectures that today predict judicial outcomes with statistically significant accuracy. It then examines five key application domains: AI assisted legal research and case law analysis; automated contract review and risk identification; predictive analytics and psychometric profiling in litigation strategy; AI powered mediation, arbitration, and online dispute resolution; and regulatory compliance monitoring. For each domain, the paper draws on empirical evidence and institutional case studies  including JPMorgan Chase’s Contract Intelligence (COiN) platform, Baker McKenzie’s deployment of Lex Machina, and eBay’s Modria powered dispute resolution system to assess where AI delivers genuine value and where deployment remains premature or ethically problematic.

A substantial portion of the paper interrogates the principal ethical and regulatory challenges attending AI integration: algorithmic bias arising from historically inequitable training data; the opacity of deep learning models and its incompatibility with professional transparency obligations; data confidentiality risks when privileged communications are processed at scale through third party infrastructure; and the unresolved questions of professional liability when AI influenced decisions produce harmful outcomes. The paper then conducts a comparative survey across the United States, the European Union, China, Australia, Sub-Saharan Africa, and India, revealing a wide spectrum of regulatory approaches from China’s ambitious judicial AI programme to the EU’s structured risk based AI Act governance framework.

CODIFYING CULPABILITY: THE TRANSITION FROM IPC 1860 TO BHARATIYA NYAYA SANHITA 2023 AND THE FUTURE OF THE ‘KNOWLEDGE’ REQUIREMENT

AUTHOR – APURVA SINGH* & DR RAJEEV KUMAR SINGH**

* LLM STUDENT AT AMITY LAW SCHOOL LUCKNOW, AMITY UNIVERSITY UTTAR PRADESH LUCKNOW CAMPUS

** ASSOCIATE PROFESSOR OF LAW AT AMITY LAW SCHOOL LUCKNOW, AMITY UNIVERSITY UTTAR PRADESH LUCKNOW CAMPUS

BEST CITATION – APURVA SINGH & DR RAJEEV KUMAR SINGH, CODIFYING CULPABILITY: THE TRANSITION FROM IPC 1860 TO BHARATIYA NYAYA SANHITA 2023 AND THE FUTURE OF THE ‘KNOWLEDGE’ REQUIREMENT, INDIAN JOURNAL OF LEGAL REVIEW (IJLR), 6 (4) OF 2026, PG. 361-369, APIS – 3920 – 0001 & ISSN – 2583-2344. DOI – https://doi.org/10.65393/IJLRV6I437

ABSTRACT

The adjudication of homicide under the Indian Penal Code, 1860 (IPC), necessitates a rigorous inquiry into the mental state of the accused, specifically distinguishing between “intention”

(dolus) and “knowledge” (scienter). While intention represents the volitional desire to cause a result, knowledge operates within the cognitive domain, signifying an awareness of consequences that are likely to occur. This dissertation examines knowledge as a distinct, independent basis for criminal liability, bridging the gap between the highest culpability of purposeful murder and the lower culpability of negligence. The study analyses the epistemic framework of liability by contrasting the statutory definitions of Culpable Homicide (Section 299) and Murder (Section 300). It explores the “fine but real” distinction in the probability of death foreseen by the offender, differentiating between acts “likely to cause death” (Section 299) and those so “imminently dangerous” that they must causing death in “all probability” (Section 300). Through an analysis of landmark judicial decisions, including State of Andhra Pradesh v. Rayavarapu Punnayya and State of Madhya Pradesh v. Ram Prasad, the research highlights how courts utilize the “degree of probability” test to determine whether an act escalates from culpable homicide to murder.

Furthermore, the dissertation investigates the complex boundary between “knowledge” and “rashness/negligence” (Section 304A). It critiques the judiciary’s evolving approach to “attributed knowledge” in cases of vehicular homicide involving intoxication, such as Alister Anthony Pareira v. State of Maharashtra, where courts impute knowledge to bridge the gap between objective negligence and subjective culpability. Contrastingly, the study notes the higher evidentiary threshold required in corporate and medical negligence cases, such as the Bhopal Gas Tragedy and Jacob Mathew, where “actual knowledge” remains a strict requirement.

BEYOND SECTION 25: TRADEMARK ENCROACHMENT, GENERICIDE, AND THE EFFICACY OF THE INDIAN GI ACT

AUTHOR – PRACHI SENGRIYA* & DR. KAVYA CHANDEL**

* STUDENT AT AMITY LAW SCHOOL LUCKNOW, AMITY UNIVERSITY UTTAR PRADESH LUCKNOW CAMPUS

** ASSISTANT PROFESSOR OF LAW AT AMITY LAW SCHOOL LUCKNOW, AMITY UNIVERSITY UTTAR PRADESH LUCKNOW CAMPUS

BEST CITATION – PRACHI SENGRIYA & DR. KAVYA CHANDEL, BEYOND SECTION 25: TRADEMARK ENCROACHMENT, GENERICIDE, AND THE EFFICACY OF THE INDIAN GI ACT, INDIAN JOURNAL OF LEGAL REVIEW (IJLR), 6 (4) OF 2026, PG. 348-360, APIS – 3920 – 0001 & ISSN – 2583-2344.

ABSTRACT

This paper examines the complex intersection and inherent doctrinal conflicts between trademark law and geographical indications (GIs), two intellectual property regimes that both serve as source identifiers but possess fundamentally opposing philosophical underpinnings. While trademarks function as private, highly alienable rights indicating a product’s commercial origin, GIs represent collective, inalienable public rights inherently tethered to a specific geographic region and its unique terroir. The research explores primary conflict scenarios, such as the clash between prior registered trademarks and subsequent GIs, contrasting the strict “first in time, first in right” (FITFIR) principle with the equitable doctrine of coexistence adopted by jurisdictions like India and the European Union. Additionally, it analyzes the statutory mechanisms designed to protect established GIs from bad-faith trademark encroachment and the superseding power of internationally well-known trademarks. 

Furthermore, the study highlights the critical global threats of genericness (“genericide”) and biopiracy, illustrating how the misappropriation of traditional knowledge and structural asymmetries in international IP law uniquely threaten developing nations, using prominent disputes over Basmati rice, Darjeeling tea, and Feta cheese as case studies. Finally, the paper concludes with a critical analysis of Section 25 of the Indian GI Act, arguing that while it establishes a foundational defensive shield against the corporatization of public geographical assets, its socio-economic effectiveness is severely undermined by deeply flawed statutory definitions of genericide, an absence of mandatory post-registration quality governance, and a severely eroded adjudicatory infrastructure following the abolition of the Intellectual Property Appellate Board (IPAB).

Keywords: Geographical Indications, Trademark Law, Genericide, Biopiracy, Indian GI Act.

THE THREE GENERATIONS OF INDIAN CYBER LAW: ANALYZING THE SHIFT FROM COMMERCE TO CRIME CONTROL TO RIGHTS-BASED GOVERNANCE

AUTHOR – AKSHITA TRIPATHI* & DR. KAVYA CHANDEL**

* STUDENT AT AMITY LAW SCHOOL LUCKNOW, AMITY UNIVERSITY UTTAR PRADESH LUCKNOW CAMPUS

** ASSISTANT PROFESSOR OF LAW AT AMITY LAW SCHOOL LUCKNOW, AMITY UNIVERSITY UTTAR PRADESH LUCKNOW CAMPUS

BEST CITATION – AKSHITA TRIPATHI & DR. KAVYA CHANDEL, THE THREE GENERATIONS OF INDIAN CYBER LAW: ANALYZING THE SHIFT FROM COMMERCE TO CRIME CONTROL TO RIGHTS-BASED GOVERNANCE, INDIAN JOURNAL OF LEGAL REVIEW (IJLR), 6 (4) OF 2026, PG. 333-347, APIS – 3920 – 0001 & ISSN – 2583-2344.

ABSTRACT

This paper provides a comprehensive chronological and thematic analysis of the evolution of India’s cyber legal framework, tracing its development from the unregulated early internet era of the 1990s to the complex data governance regimes of 2023. By examining legislative texts, judicial pronouncements, and institutional mechanisms, the study explores the trajectory of the Information Technology (IT) Act, 2000, and its subsequent regulatory amendments. The core argument posits that Indian cyber law has undergone a three-stage transition: beginning as a “first-generation” commerce-enabling framework primarily driven by the need to legitimize e-commerce, evolving into a “second-generation” crime-control and security-oriented regime following the 2008 amendments, and currently shifting towards a “third-generation” rights-based data governance architecture marked by the Digital Personal Data Protection Act (DPDPA) 2023. Key themes explored include the shifting paradigms of intermediary liability and “Safe Harbour” protections, the jurisprudential complexities of electronic evidence admissibility under Section 65B of the Indian Evidence Act, and the expansion of state surveillance and regulatory compliance mechanisms. Ultimately, this legal evolution reflects a broader global movement from “cyber-libertarianism” to “cyber-sovereignty,” highlighting India’s ongoing efforts to balance technological innovation, national security, and citizen rights in the digital age.

Keywords: Indian Cyber Law, Information Technology Act, 2000, Intermediary Liability, Data Governance, Cyber-Sovereignty

DIGITAL SEXUAL EXPLOITATION OF CHILDREN: ANALYSING POCSO PROVISIONS ON PORNOGRAPHY AND ONLINE ABUSE IN INDIA

AUTHOR – POONAM MISHRA* & DR. ROSHNI SRIVASTAVA**

* RESEARCH SCHOLAR, AMITY LAW SCHOOL, LUCKNOW, U.P

** ASSOCIATE PROFESSOR, AMITY LAW SCHOOL, LUCKNOW, U.P.

BEST CITATION – POONAM MISHRA & DR. ROSHNI SRIVASTAVA, DIGITAL SEXUAL EXPLOITATION OF CHILDREN: ANALYSING POCSO PROVISIONS ON PORNOGRAPHY AND ONLINE ABUSE IN INDIA, INDIAN JOURNAL OF LEGAL REVIEW (IJLR), 6 (4) OF 2026, PG. 324-332, APIS – 3920 – 0001 & ISSN – 2583-2344. DOI – https://doi.org/10.65393/IJLRV6I434

Abstract

The rapid expansion of digital technology has fundamentally transformed patterns of communication, access to information and social interaction in India. While these developments have created significant opportunities for learning and connectivity, they have also generated new risks for children in online environments. One of the most alarming consequences of this digital transformation is the growing prevalence of online child sexual exploitation, including online grooming, sextortion, live-streamed abuse and the circulation of child sexual abuse material (CSAM).^[1]

India’s primary legislative response to sexual offences against children is the Protection of Children from Sexual Offences Act, 2012 (POCSO), which includes specific provisions addressing the use of children for pornographic purposes under Sections 13–15.^[2] These provisions operate alongside Section 67B of the Information Technology Act, 2000, which criminalises the electronic publication, transmission and possession of sexually explicit material involving children.^[3]

Despite the existence of this statutory framework, doctrinal ambiguities and enforcement challenges persist. Judicial interpretation has historically varied regarding whether mere viewing or storage of CSAM constitutes a punishable offence. However, the Supreme Court has recently clarified that viewing, possessing and storing such material may attract criminal liability under both POCSO and the IT Act.^[4]

This paper critically analyses the legal framework governing online child sexual exploitation in India. By examining statutory provisions, judicial decisions and empirical data from the National Crime Records Bureau (NCRB), the study argues that although the legal regime has evolved significantly, implementation remains hindered by under-reporting, inadequate digital forensic capacity and limited institutional coordination. The paper concludes that stronger legislative clarity, enhanced investigative infrastructure and improved cooperation between law enforcement agencies and digital platforms are essential to effectively combat online child sexual exploitation.

Keywords: Child Sexual Abuse Material (CSAM); Online Grooming; Child Pornography; Digital Sexual Exploitation; POCSO Act; Information Technology Act; Cybercrime; Child Protection; Digital Evidence; Online Abuse.

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[1] UNICEF, Ending Online Child Sexual Exploitation (2022).

[2] Protection of Children from Sexual Offences Act 2012, ss 13–15.

[3] Information Technology Act 2000, s 67B.

[4] Just Rights for Children Alliance v S Harish (2024) SC.

LEGALITY OF NARCO ANALYSIS TEST IN INDIA-CONSTITUTIONAL AND JURISPRUDENTIAL PRESPECTIVE

AUTHOR – BHAVADHARANI.M* & MRS. HEMAVATHY**

* STUDENT AT SCHOOL OF EXCELLENCE IN LAW, THE TAMILNADU DR.AMBEDKAR LAW UNIVERSITY, CHENNAI

** PROFESSOR OF LAW AT SCHOOL OF EXCELLENCE IN LAW, THE TAMILNADU DR.AMBEDKAR LAW UNIVERSITY, CHENNAI

BEST CITATION – BHAVADHARANI.M & MRS. HEMAVATHY, LEGALITY OF NARCO ANALYSIS TEST IN INDIA-CONSTITUTIONAL AND JURISPRUDENTIAL PRESPECTIVE, INDIAN JOURNAL OF LEGAL REVIEW (IJLR), 6 (4) OF 2026, PG. 314-323, APIS – 3920 – 0001 & ISSN – 2583-2344.

ABSTRACT:

Narco-analysis, sometimes referred to as a “truth serum” test, uses medications to put suspects into a hypnotic condition in order to extract concealed information. It is a forensic instrument with stringent legal restrictions related to consent and constitutional rights in India. Barbiturates such as sodium pentothal (3 grams in 3000 ml distilled water, dosed by body weight at 4 ml/min) are used in narco-analysis to sedate a subject and lower inhibitions and willpower for truthful responses during questioning. The word comes from the Greek word “narko” (anesthesia), which produces a semi-conscious condition in which lying is challenging but not impossible.^[1] The constitutional validity and practical legality of narco-analysis tests in India are examined in this research. It charts the development from early court approval to the seminal ruling in Selvi v. State of Karnataka (2010)^[2], followed by recent rulings by the Supreme Court reiterating the illegality of involuntary narco testing. The study comes to the conclusion that forced administration of narco-analysis is unlawful and its evidentiary value is extremely restricted, even though volunteer narco-analysis under strict safeguards is not outright prohibited.

KEYWORS:Narco-Analysis, Truth serum test, Indian Constitution, Forensic instrument, Sodium pentothal, Anaesthesia.

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[1] NDTV, What Is a ‘Narco Test’: Explained (Nov. 16, 2022), https://www.ndtv.com/india-news/what-is-a-narco-test-explained-3529826. [last accessed Feb 02, 2026].

[2] Selvi v. State of Karnataka, (2010) 7 SCC 263.