THE IMPLICATIONS OF DESIGNATING JUS POST BELLUM AS A CUSTOMARY PRINCIPLE OF INTERNATIONAL LAW

AUTHOR – KRISHNA ANAND IYER, STUDENT AT SCHOOL OF LAW, CHRIST (DEEMED-TO-BE) UNIVERSITY

BEST CITATION – KRISHNA ANAND IYER, THE IMPLICATIONS OF DESIGNATING JUS POST BELLUM AS A CUSTOMARY PRINCIPLE OF INTERNATIONAL LAW, INDIAN JOURNAL OF LEGAL REVIEW (IJLR), 6 (3) OF 2026, PG. 378-392, APIS – 3920 – 0001 & ISSN – 2583-2344.

ABSTRACT

The principle of jus post bellum in international law is one of the three laws of war, which outlines post-war conduct, which is primarily reconstruction and restoration to status quo. Under the purview of the laws of war, the principles of jus ad bellum, or lawful justification for war, and jus in bello, or the lawful conduct to be followed in war, take precedence over jus post bellum, primarily because jus post bellum lacks the obligatory power that comes with customary laws, unlike the other two. The aim of this paper is to explore the applicability of the principle and an in-depth analysis of the direct consequence if the principle also becomes a principle of customary international law.

2. Keywords

“Jus post bellum”, “laws of war in customary law”, “obligations essential for post-conflict reconstruction”, “international humanitarian law”, “customary international law”

SOCIAL STIGMA AND DISCRIMINATION UNDER JUVENILE JUSTICE

AUTHOR – MEGHANA R, STUDENT AT SCHOOL OF LAW, CHRIST (DEEMED TO BE UNIVERSITY)

BEST CITATION – MEGHANA R, SOCIAL STIGMA AND DISCRIMINATION UNDER JUVENILE JUSTICE, INDIAN JOURNAL OF LEGAL REVIEW (IJLR), 6 (3) OF 2026, PG. 368-377, APIS – 3920 – 0001 & ISSN – 2583-2344.

Abstract

Juveniles in conflict with law in India still suffer from extreme discrimination and stigma, posing barriers to their rehabilitation and social reintegration. In spite of a progressive legislative paradigm under the Juvenile Justice (Care and Protection of Children) Act, 2015 (“JJ Act, 2015”), public perception too goes against the reformist purpose of the legislation. The present study critically analyzes how stigma thwarts the ends of the Act based on doctrinal research approaches, case law, government reports, and cross-border comparative international paradigms. The article shows how confidentiality violations, poor aftercare, and deep-rooted bias among stakeholders lead to continued marginalization of children, negating the promise of a “fresh start” under statute. Case analysis of Sheela Barse v. Union of India, (1986) 3 SCC 596, Salil Bali v. Union of India, (2013) 7 SCC 705, and Subramanian Swamy v. Raju, (2014) 8 SCC 390 depicts judicial anxiety about discrimination by society and the need for change at the earliest. The approach used is doctrinal analysis, along with qualitative examination of the court rulings with emphasis on failure in enforcement and implementation. The author concludes that without real change in institutional practice and attitudes among the community, the objectives of the Juvenile Justice model—rehabilitation, reintegration, and safeguarding children’s rights—will never be achieved.

Keywords: juvenile justice, stigma, discrimination, rehabilitation, rights of children

LEGAL CHALLENGES OF INTERNATIONAL SURROGACY: A PRIVATE INTERNATIONAL LAW PERSPECTIVE

AUTHOR – RUBAN G, STUDENT AT VINAYAKA MISSION’S LAW SCHOOL, CHENNAI

BEST CITATION – RUBAN G, LEGAL CHALLENGES OF INTERNATIONAL SURROGACY: A PRIVATE INTERNATIONAL LAW PERSPECTIVE, INDIAN JOURNAL OF LEGAL REVIEW (IJLR), 6 (3) OF 2026, PG. 362-367, APIS – 3920 – 0001 & ISSN – 2583-2344.

Abstract: –

Significant developments have taken place in assisted reproductive technology, which has led to an increase in cross-border surrogacy. The issue of international surrogacy has raised various complex issues in the area of private international law. International surrogacy arrangements involve various international parties such as intended parents and surrogate mothers, and children born out of such surrogacy arrangements. International surrogacy arrangements have raised various conflicts with regard to jurisdiction, recognition of parentage, and determination of the nationality of the child. The absence of an international regulatory framework has led to inconsistent approaches by different countries in dealing with surrogacy arrangements. Therefore, there is an element of uncertainty for all the parties involved in such arrangements.^[1]

In the past, India has become one of the popular destinations for international surrogacy arrangements due to low medical costs and availability of specialized medical services. However, there have been concerns with regard to commercialization of surrogacy arrangements and exploitation of surrogate mothers. The enactment of the Surrogacy (Regulation) Act, 2021 is an attempt by India to deal with the issue of surrogacy by regulating commercial surrogacy and allowing altruistic surrogacy under certain circumstances.^[2]

Judicial decisions have also contributed to the development of the legal framework governing surrogacy. In Baby Manji Yamada v. Union of India, the Supreme Court of India addressed issues concerning guardianship and the legal status of a child born through international surrogacy, highlighting the challenges arising from cross-border reproductive arrangements.^[3]

This paper analyses the legal issues surrounding international surrogacy from the perspective of private international law, particularly focusing on jurisdictional conflicts, determination of parentage, and recognition of foreign decisions.

Keywords: Private International Law, International Surrogacy, Cross-Border Surrogacy, Jurisdictional Conflicts, Parentage Determination, Citizenship of Surrogate Child, Surrogacy (Regulation) Act, 2021.

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[1] Scott B. Rae, Ethical Issues in International Surrogacy, 38 J. Med. & Phil. 248, 248–63 (2013), available at
https://www.jstor.org/stable/10.1093/jmp/jht016  

[2] Surrogacy (Regulation) Act, 2021, No. 47 of 2021, India Code, https://www.indiacode.nic.in/handle/123456789/17102

[3] Baby Manji Yamada v. Union of India, (2008) 13 S.C.C. 518 (India), https://indiankanoon.org/doc/854968/.

REGULATING SYNTHETIC VOICE IMPERSONATION IN COURTS: A COMPREHENSIVE RESEARCH PAPER WITH INDIAN LEGAL FRAMEWORK

AUTHOR – MANAN JHAMB, STUDENT AT CHANDIGARH UNIVERSITY

BEST CITATION – MANAN JHAMB, REGULATING SYNTHETIC VOICE IMPERSONATION IN COURTS: A COMPREHENSIVE RESEARCH PAPER WITH INDIAN LEGAL FRAMEWORK, INDIAN JOURNAL OF LEGAL REVIEW (IJLR), 6 (3) OF 2026, PG. 352-361, APIS – 3920 – 0001 & ISSN – 2583-2344. DOI – https://doi.org/10.65393/UOUQ6138

I. UNDERSTANDING THE TOPIC: EXPLAINING

Concept: Synthetic Voice Impersonation

Artificial Voice Impersonation is when systems or people are deceived into thinking that an artificially created voice — produced by AI and Deepfake technology — is a genuine individual’s voice. In literature the fake voice creation process is called synthetic voice cloning or voice synthesis; AI algorithms are trained on a set of previously recorded voices to create vocalizations that mimic the tone of the training sample. The hyper-realism of these artificially created audio reproductions makes them nearly indistinguishable from actual human voices; thus, there are problems associated with deception and digital consent.^[1] There is documented evidence of the use of fabricated/impersonated synthetic voice in committing crimes and fabricating evidence.
Thus, there is a very serious problem for Courts of Law — in which the presentation of fabricated audio recordings can be used as “evidence” to support claims of confessions from defendants or statements from witnesses or victims; therefore, the reliability of the trial being fair cannot be ensured and the integrity of the evidence has been questioned.^[2]

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[1] Kumar, R. (2025). Synthetic voice impersonation technology and the “Liars Dividend”: Regulatory gaps and comparative legal safeguards. Asian Journal of Law and Technology, 11(2), 177–210

[2] Kothari, V., & Tibrewala, A. (2024). Synthetic voice impersonation as a threat to judicial integrity and fair trial rights. Journal of Digital Forensics, Security and Law, 19(4), 87–109.

SEDITION REIMAGINED UNDER THE BHARATIYA NYAYA SANHITA: REFORM OR MERE REPACKAGING?

AUTHOR – VAISHNAVI SRIVASTAVA* & DR. SUKRITI YADAV**

* STUDENT AT AMITY UNIVERSITY LUCKNOW CAMPUS

* ASSIST. PROFESSOR GRADE 1 AT AMITY UNIVERSITY LUCKNOW CAMPUS

BEST CITATION – VAISHNAVI SRIVASTAVA & DR. SUKRITI YADAV, SEDITION REIMAGINED UNDER THE BHARATIYA NYAYA SANHITA: REFORM OR MERE REPACKAGING?, INDIAN JOURNAL OF LEGAL REVIEW (IJLR), 6 (3) OF 2026, PG. 340-351, APIS – 3920 – 0001 & ISSN – 2583-2344.

Abstract

In India sedition laws have always been a matter of controversy, largely due to their colonial origins and misuse against political dissent. Section 124A of the Indian Penal Code (IPC), introduced by the British in 1870, criminalized speech or expression that brought “disaffection” against the government. Over the years, this provision was widely criticized for curbing free speech and being misapplied against journalists, activists, and citizens who merely questioned those in power. The Supreme Court, while upholding its constitutionality in Kedarnath Singh v. State of Bihar (1962), limited its application to acts inciting violence or public disorder. Yet, its misuse persisted.

With the introduction of the Bharatiya Nyaya Sanhita (BNS), 2023, the government repealed Section 124A, signaling the apparent end of sedition law. However, its replacement, Section 152 of the BNS, has raised concerns of being “old wine in a new bottle.” This section penalizes acts that endanger the sovereignty, unity, and integrity of India, including subversive speech. Critics argue that the language remains vague, retaining potential for misuse similar to the colonial law. While the government claims it provides stronger safeguards and focuses on threats to national security, skeptics fear it could still target dissent under the guise of protecting integrity.

Thus, while the terminology has shifted, the essence of sedition survives. Unless clearly distinguished from legitimate criticism of the government, the BNS risks continuing the legacy of colonial suppression, making the promise of reform appear cosmetic rather than substantive.

Keywords: Sedition, BNS 2023, Free Speech, National Security, Legal Reform

THE “MISUSE” NARRATIVE VS. SUBSTANTIVE JUSTICE: DECONSTRUCTING SECTION 498A

AUTHOR – RASHMI MALL* & DR. SHAIWALINI SINGH**

* LL.M (CRIMINAL LAW) STUDENT AT AMITY LAW SCHOOL LUCKNOW, AMITY UNIVERSITY UTTAR PRADESH, LUCKNOW CAMPUS

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

BEST CITATION – RASHMI MALL & DR. SHAIWALINI SINGH, THE “MISUSE” NARRATIVE VS. SUBSTANTIVE JUSTICE: DECONSTRUCTING SECTION 498A, INDIAN JOURNAL OF LEGAL REVIEW (IJLR), 6 (3) OF 2026, PG. 335-339, APIS – 3920 – 0001 & ISSN – 2583-2344. DOI – https://doi.org/10.65393/ZSSE9826

ABSTRACT

This research paper investigates the prevailing tension between the legislative intent of Section 498A of the Indian Penal Code 1860 (now Sections 85 and 86 of the Bharatiya Nyaya Sanhita 2023) and the judicial discourse surrounding its purported misuse. Introduced as a response to the alarming rise in dowry-related violence in the 1980s, Section 498A provided a critical legal framework for criminalizing domestic cruelty. However, over the decades, a narrative has emerged bolstered by landmark Supreme Court judgments that characterizes the law as a tool for ‘legal terrorism’ and personal vendetta. This paper deconstructs this narrative through a doctrinal analysis of case law, statistical trends from the National Crime Records Bureau (NCRB), and sociological data from the National Family Health Survey (NFHS-5). It argues that the low conviction rates often cited as proof of misuse are more accurately understood as a failure of the justice delivery system, stemming from police-mediated settlements, hostile witnesses, and patriarchal societal pressures. Furthermore, the paper analyses the procedural shifts introduced by the Bharatiya Nagarik Suraksha Sanhita 2023, particularly the codification of preliminary inquiries and the institutionalization of cooling-off periods. The research concludes that while safeguards against arbitrary arrest are necessary, the current judicial and legislative trajectory risks trivializing domestic violence and undermining the substantive justice that the law was designed to provide.

Keywords: Section 498A, Domestic Violence, Misuse Narrative, Bharatiya Nyaya Sanhita (BNS), Substantive Justice.

THE INDIAN SUPREME COURT’S RIGHTS-BASED APPROACH TO BAIL WITH REFERENCE TO ARTICLE 21 AND 22

AUTHOR – TARANNYA P, STUDENT AT SCHOOL OF LAW, CHRIST (DEEMED TO BE UNIVERSITY)

BEST CITATION – TARANNYA P, THE INDIAN SUPREME COURT’S RIGHTS-BASED APPROACH TO BAIL WITH REFERENCE TO ARTICLE 21 AND 22, INDIAN JOURNAL OF LEGAL REVIEW (IJLR), 6 (3) OF 2026, PG. 323-334, APIS – 3920 – 0001 & ISSN – 2583-2344.

ABSTRACT

The rights-based approach to bail adopted by the Indian Supreme Court, grounded in Articles 21 and 22 of the Constitution, signifies a constitutional shift in the interpretation of criminal law and procedural practices. Article 21 asserts that “no person shall be deprived of his life or personal liberty except according to the procedure established by law,” while Article 22 enumerates specific procedural protections in instances of preventive detention and arrest. By interpreting these articles in conjunction, the Supreme Court has delineated bail jurisprudence in such a way that prioritizes liberty as the presumptive standard and classifies detention as a carefully restricted exception. Traditionally, bail was analyzed through a limited perspective defined by the Code of Criminal Procedure, focusing on procedural details and the seriousness of the crime. Nevertheless, the Supreme Court has gradually transformed this perspective toward a model that is more aligned with constitutional rights. Bail is now regarded not merely as a judicial prerogative but is instead understood as fundamentally associated with the right to liberty enshrined in Article 21. The Court has consistently emphasized that excessive pre-trial incarceration, particularly when applied without proper justification, undermines the presumption of innocence and effectively penalizes individuals prior to the establishment of guilt. In this context, bail jurisprudence has emerged as a vital protection against the potential abuse of state authority.

The Court has also pointed out that bail decisions should be informed by the virtues of reasonableness, fairness, and proportionality. Decisions to grant bail should be based upon reasonable grounds and should not be arbitrary, taking into account the competing interests of upholding the liberty of the accused as much as upholding the administration of justice. Factors such as the gravity of the offense for which the accused is charged, potential disruption of witnesses or evidence, chance of offending again, and risk of non-compliance with bail are all important parameters; but these are subject to the presumption of liberty enshrined in the Constitution. Recent pronouncements of the Supreme Court highlight that bail cannot be denied merely by taking into consideration the gravity of the alleged offense. Instead, the focus should be kept on assessing whether continued detention is necessary and justified for achieving legitimate government goals.

The aim of the principle is to prevent the criminal justice process from becoming punishment per se, thus ensuring that individuals are not treated merely as objects of state power but rather are treated with dignity and humanity as citizens secured by the constitution. This right- based approach to bail has wider systemic implications. Prioritizing bail in appropriate cases allows the Court to confront perennial problems like jail congestion, of which undertrial prisoners account for a significant proportion of jail inmates. It enhances access to justice by securing judicial relief to marginalized and vulnerable sections of society that often lie at risk of arbitrary detention. It again instils in the criminal justice system the culture of accountability by subjecting judicial discretion to constitutional scrutiny and reminding the judiciary of its role of upholder of basic rights.

Overall, the Supreme Court’s evolving bail jurisprudence is reflective of a deeper constitutional philosophy that treats liberty as an article of justice itself and not as a statutory privilege of the state. Through the application of Article 21 as well as Article 22 to the calculus of bail decisions, the Court has emphasized that the criminal justice machinery must operate in conformity with the virtues of fairness, dignity, and proportionality. That development points toward a justice system that is more humane, transparent, and constitutionally compliant in every sense of the term, and in which the concern is less punishment-oriented and more focused upon the protection of individuals’ inalienable right of being free even while awaiting trial.

Keywords: Indian Supreme Court, Rights-Based Approach, Bail Jurisprudence, Article 21, Right to Life, Personal Liberty, Constitutional Law, Criminal Justice, Presumption of Innocence, Pre-Trial Detention

ANALYSIS OF FORENSIC FINGERPRINTING IN CRIMINAL INVESTIGATION: PRIVACY CONCERNS AND LEGAL SAFEGUARDS IN INDIA

AUTHOR – BHUVANESH M* & SUGITH KUMAR RG**

* STUDENT AT SCHOOL OF EXCELLENCE IN LAW, TNDALU

** PROFESSOR AT SCHOOL OF EXCELLENCE IN LAW, TNDALU

BEST CITATION – BHUVANESH M & SUGITH KUMAR RG, ANALYSIS OF FORENSIC FINGERPRINTING IN CRIMINAL INVESTIGATION: PRIVACY CONCERNS AND LEGAL SAFEGUARDS IN INDIA, INDIAN JOURNAL OF LEGAL REVIEW (IJLR), 6 (3) OF 2026, PG. 3110-322, APIS – 3920 – 0001 & ISSN – 2583-2344.

ABSTRACT:

The forensic fingerprint has for long been considered as one of the most reliable scientific methods of personal identification in criminal investigations. Fingerprint evidence in India has been used extensively for identifying and connecting the suspects to the crime scenes, and record keeping of a criminal. But the digitisation of forensic systems and creation of biometric databases has widened the scope of digitisation and storage of fingerprints by Law Enforcement Agencies. While these developments are aimed at simplifying investigations, they are not devoid of constitutional challenges in the areas of privacy, personal liberty and protection of biometric data. With the Indian Supreme Court recognising the right to privacy as a fundamental right in Justice K. S. Puttaswamy (Retd.) v. Union of India, the issue of biometric data collection and storage warrants a closer legal attention.

The current research paper focuses on the doctrinal analysis over the existent legal framework on forensic fingerprinting of the Indian subject. The research paper has considered the main provisions of Criminal Procedure (Identification) Act, 2022 and the related constitutional jurisprudence, which has been taken into account by the courts. The study reveals that forensic fingerprint is a scientific procedure that has evolved over time and has become an instrument of criminal investigation. The existing legal framework particularly in the context of biometric data and this paper finds that there is no comprehensive safeguard over the biometric data in terms of data retention, oversight and proportionality. The study suggests that a rights-based regulatory framework over biometric data must be elaborated, which ensures the balance between criminal investigation, personal liberty, dignity and privacy.

Keywords: Forensic fingerprinting, Personal Liberty and Dignity- Constitutional Safeguards- Biometric Evidence Regulation- Privacy Jurisprudence in India- Law Enforcement Surveillance

NDPS ACT:  A CRITICAL LEGAL ANALYSIS OF INDIA’S DRUG CONTROL FRAMEWORK

AUTHOR – RIDHI N, STUDENT AT SCHOOL OF LAW, CHRIST (DEEMED TO BE UNIVERSITY)

BEST CITATION – RIDHI N, NDPS ACT:  A CRITICAL LEGAL ANALYSIS OF INDIA’S DRUG CONTROL FRAMEWORK, INDIAN JOURNAL OF LEGAL REVIEW (IJLR), 6 (3) OF 2026, PG. 302-309, APIS – 3920 – 0001 & ISSN – 2583-2344.

ABSTRACT:

Indian law to stop drug trafficking and control using drugs in Indian is the Narcotic Drugs and Psychotropic Substances Act, 1985 or “NDPS Act”. This Act which was made as a result of India honouring its commitments under the 1961 Single Convention on Narcotic Drugs is a crime and ban on use of drugs. While the main goal of the NDPS Act is to stop illegal trafficking and protect the health of the general public, the law has been criticized many times due to its strict rules, inflexibility and lack of attention to harm reduction and rehabilitation.

The main question in this research is whether the country’s existing drug control measure, the NDPS Act, is a just and right way to strike an adequate balance between the interest of the State to control the drug and the liberty of the individual. The following are the specific objectives of this enterprise: (1) to trace the development of the NDPS Act over the years and examine its scope and framework; (2) to subject to critique the functioning of the said Act from the point of view of the legislative provisions, judicial interpretation and execution by law enforcing agencies; and (3) to determine greatly effective the NDPS Act as dissimilar to the international drug control mechanisms and to recommend different ways in which the NDPS Act could be corrected. In order to perform the aforesaid objectives of the research, an elaborate appreciation of primary data (statutes, case law and government reports) and secondary literature (academic writing, policy papers and comparative legal studies) has been made. The process adopted is doctrinal in nature.

Even though the NDPS Act established a robust legal framework that criminalized and punished drug related offences. The excessive importance placed on punishments meant that the implementing law caused many other more serious harms. For example, overcrowding prisons, violations of due process and the stigmatising practices which Durbanize drug users. A major correction to this legislation must include classifying traffickers and users within the law. The use of methodologies that focus on human health such as decriminalizing private use. and robust safeguards within the system to prevent police excesses are essential in the law of tomorrow. India thus has to move from absolute punitiveness towards equilibrium punitiveness which would inline the ideal benchmark International best practice and the rights guaranteed by its constitution.

KEYWORDS: NDPS Act, 1985, Drug Control Policy, Judicial Interpretation, Rehabilitation and Public Health, Comparative Drug Policy

ORGANISED CRIME: ANALYSING INDIA’S UNIFORM APPROACH UNDER SECTION 111 OF THE BNS — A COMPARISON WITH THE U.S. “RICO” MODEL

AUTHOR – SAMARTH R, STUDENT AT SCHOOL OF LAW, CHRIST (DEEMED TO BE UNIVERSITY)

BEST CITATION – SAMARTH R, ORGANISED CRIME: ANALYSING INDIA’S UNIFORM APPROACH UNDER SECTION 111 OF THE BNS — A COMPARISON WITH THE U.S. “RICO” MODEL, INDIAN JOURNAL OF LEGAL REVIEW (IJLR), 6 (3) OF 2026, PG. 288-301, APIS – 3920 – 0001 & ISSN – 2583-2344.

ABSTRACT

The recent addition of Section 111 of the Bhartiya Nyaya Sanhita, 2023 (hereinafter ‘BNS’), constitutes India’s first parliament-enacted provision against ‘Organised Crime’ at the national level.^[1] The deliberate structural similarities between Section 111 and the multi-statutory framework of state legislations — including the Maharashtra Control of Organised Crime Act, 1999 (hereinafter ‘MCOCA’),^[2] the Karnataka Control of Organised Crime Act, 2000 (hereinafter ‘KCOCA’),^[3] and the Gujarat Control of Terrorism and Organised Crime Act, 2015 (hereinafter ‘GUJCTOC’)^[4] — reflect a conscious legislative policy favouring a uniform national approach to dismantling organised crime syndicates. On the other side of the globe, the United States of America has its federal counterpart, the Racketeer Influenced and Corrupt Organisations Act (hereinafter ‘RICO’) under Title IX of the Organised Crime Control Act of 1970,^[5][6] which is widely recognised for its landmark prosecutions against the American Mafia and for its subsequently expansive scope in restraining diverse forms of organised crime. The present comparative study aims to analyse the legislative intent, constitutionality, and evolved definitional scope of Section 111 of the BNS through a socio-legal lens — drawing on doctrinal scholarship, constitutional provisions, and judicial precedents — while benchmarking its substantive intricacies against the principles of RICO jurisprudence. By engaging with the Global Organised Crime Index and contextualising its statistical methodology within the American and distinctively Indian milieus, this paper seeks to answer the supervening question: ‘Has India, in its control of organised crime, transitioned from a fragmented legal framework to a uniform one comparable to the core principles of American RICO jurisprudence, and is such a transition the correct step toward curbing organised crime?’

Keywords: Jurisprudential Analysis, Organised Crime, Prosecutorial Efficacy, RICO Act, Section 111 — Bhartiya Nyaya Sanhita, Constitutional Validity.

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[1]Bhartiya Nyaya Sanhita, No. 45 of 2023, § 111 (India).

[2]Maharashtra Control of Organised Crime Act, No. XII of 1999 (Maharashtra, India) [hereinafter MCOCA].

[3]Karnataka Control of Organised Crime Act, No. 10 of 2000 (Karnataka, India) [hereinafter KCOCA].

[4]Gujarat Control of Terrorism and Organised Crime Act, No. 35 of 2019 (Gujarat, India) [hereinafter GUJCTOC].

[5]Racketeer Influenced and Corrupt Organisations Act, 18 U.S.C. §§ 1961–1968 (1970) [hereinafter RICO].

[6]Organised Crime Control Act of 1970, Pub. L. No. 91-452, 84 Stat. 922 (1970).