WHITE COLLAR CRIMES IN INDIA: AN OVERVIEW

Submission towards the fulfilment of assignment in Corporate and White Collar Crimes

SUBMITTED BY
VAIBHAV GADHVEER
SUBJECT: CORPORATE AND WHITE COLLAR CRIMES
R NUMBER: R6257
LL.M. (CRIMINAL & SECURITY LAW)
 TABLE OF CONTENT

Acknowledgement......................................................................................................................3

Introduction................................................................................................................................4

1. Definition........................................................................................................................5

2. Main Features..................................................................................................................5

White-Collar Crimes in India.....................................................................................................7

1. Business, Trade, Commerce and Industry.......................................................................7

2. Food and Drug Adulteration...........................................................................................9

3. Violations of Taxation Laws...........................................................................................9

3.1 Extent of the Problem...................................................................................................9

4. Corruption in Government and Politics........................................................................10

4.1 Corruption in Government.........................................................................................10

4.2 Political Corruption....................................................................................................11

White Collar Crime In Professions..........................................................................................12

1. White Collar Crimes in Legal Profession.....................................................................13

White Collar Distinguished From Traditional Law.................................................................14

Conclusion................................................................................................................................17

2
 ACKNOWLEDGEMENT

I would like to thank my teacher for allotting this challenging and interesting topic to me as
my project topic, and subsequently discussing and guiding us. This research work was indeed
a big learning experience.
I would further like to acknowledge the Library Staff at Apex University, Jaipur for their co-
operation and abundant resources which has so far backed every single proposition in this
work. The Info-tech facilities is further something that backed the research requisites of this
project and thereby something that I would like to recognize for the successful completion of
this work.
I would also like to show our profuse gratitude to our families for their valuable blessings and
to our friends for their pertinent encouragement, all of which has played an integral role in
the timely completion of this project.

3
 INTRODUCTION

“The practitioners of evil, hoarders, the profiteers, the black marketeers, and speculators are the worst enemy of

our society. They have to be dealt with sternly. However well placed important and influential they maybe, if we

acquiesce in wrongdoing, people will lose faith in us.”  - Dr. S. Radhakrishnan

White collar crime is the illegal activities of people and organizations whose acknowledged
purpose is profit through legitimate business enterprise. It is the crime committed by persons
of relatively high social or economic status in connection with their regular occupations.
White-collar crimes fall broadly into two categories: those illegal actions undertaken by
perpetrators to make money for themselves; and those illegal actions undertaken principally
to further the aims of their company or other organization. White collar crime involves illegal
business practices (embezzlement, price-fixing, bribery) with merchandise that is ordinarily
seen as a legitimate business product. 
These crimes are quite rampant in third world countries due to the economy, for instance, the
ease of doing business has taken a jump of almost 37 positions in the last two years (2018-
2020) in India which allows more investment and businesses to flow into the country but
exposes consumers and their rights and this has led to the rapid increase of cases over 80%
just in 2019.1 Edwin Sutherland stated that white crime could harm society more than other
normal offences mainly because of the financial losses that the public would incur in fact,
white-collar crimes can be traced back to the 15th century in the UK and later also in the US
during the civil war which allowed large monopolies to take over which led to the
enforcement of Anti-trust laws to protect the consumers and allow fair competition. 2 With the
world moving at a fast pace and the rate of development in technology and commerce it’s fair
to say that India is unable to deal with the increasing level of unprecedented growth which is
leading to white-collar crimes such as cybercrimes. This also means that crime can be
committed across any country’s border. Due to the ease of committing these crimes,
fraudsters have also become greedier and has also resulted in the lower average age of these
fraudsters and due to their ease of accessing and optimising technology the number of white-

1
Kaur, Bani Amrit. Opportunities for institutional investors in Indian REITs. Diss. Massachusetts Institute of
Technology, 2021.
2
Coffee Jr, John C. "Paradigms Lost: The Blurring of the Criminal and Civil Law Models--And What Can Be
Done About It." Yale LJ 101 (1991): 1875.

4
collar crimes is increasing and it also points out that the future of our country is turning
towards the dark side.
Related to the corporate sector, white collar crimes are defined as non-violent crimes,
generally committed by businessmen and government professionals. In simple words, crimes
committed by people who acquire important positions in a company are called white collar
crimes. 

1. Definition

Sutherland defined it as "a crime committed by a person of respectability and high social
status in the course of his occupation."3
As Sutherland saw it, the rich were engaged in a conspiracy to use their position for personal
gain without regard to the law.  Today, it is recognized that persons in all social classes can
commit white collar crimes, but the notion of getting away with disregard for the law still
exists in the justice system's tendency to treat these offences as civil rather than criminal
matters.4 

2. Main Features

Victims often suffer the effects of white-collar crime without ever meeting the perpetrators.
Goode calls this aspect of white-collar crime "diffuse victimization"5
Croall examined the characteristics of "white collar crime" and contended that the low
visibility of essential features often occurs under occupational cover. 6 It is in essence an
indirect form of theft. Perpetrators often rationalize that because it is indirect, it is victimless
and therefore "acceptable".
Defendants are at work at the scene while victims are present and unaware of offending. Box
pointed out that many fraud victims are not aware of being duped. 7 The low visibility is
combined with complexities. Levi argued that even juries necessarily found fraud trial
incomprehensible.8

3
Sutherland defined it as "a crime committed by a person of respectability and high social status in the course of
his occupation."
4
Id
5
Goode, Erich, and Nachman Ben-Yehuda. Moral panics: The social construction of deviance. John Wiley &
Sons, 2010.
6
Croall, Hazel. White collar crime. Buckingham: Open University Press, 1992.
7
Levi, Michael, and Andrew Pithouse. "The victims of fraud." Unravelling Criminal Justice. Palgrave
Macmillan, London, 1992. 229-246.
8
Id.

5
The diffusion of responsibility and elimination of blame for actions are lost in large corporate
structures. The diffuseness of white-collar crime may put us at greater risk for longer periods
of time than other crimes such as ordinary bank robbery.9
 

9
Green, Stuart P. Lying, cheating, and stealing: A moral theory of white-collar crime. Oxford University Press,
2006.

6
 WHITE-COLLAR CRIMES IN INDIA

White-collar crimes affected the nation and the society, which was not very much concerned
about, as people are not directly affected by the white-collar crimes which included, internet
hacking, defrauding of banks, printing of counterfeit notes. There is black money of
thousands of crores in circulation and criminals are merely escaping with a fine of few
thousand rupees for the offences running to several hundred crores. Only four per cent of the
white criminals got convicted at the Supreme Court.10

1. Business, Trade, Commerce and Industry

Sutherland emphasised the high degree of criminality among businessmen in contemporary

society and their immunity from criminal sanctions generally in the following words:
“The most powerful group in medieval society secured relative immunity from
punishment by ‘benefit of clergy’ and now the present most powerful group secures relative
immunity by benefit of business.”11
What Sutherland wrote about the American society is equally true of the conditions in India.
The Santhanam Committee gave a graphic account of the misdeeds of businessmen and
industrialists in the following words:
“Corruption can exist only if there is someone willing to corrupt and capable of
corrupting. We regret to say that both this willingness and capacity to corrupt is found in a
large measure in the industrial and commercial classes…….”12
It is these people who indulge in evasion and avoidance of taxes, accumulate large amounts
of unaccounted money by various methods such as obtaining licences, suppressing profits by
manipulation of accounts to avoid taxes… and under-valuation of transactions in immovable
property. It is they who have control over large funds and are in a position to spend
considerable sums of money on entertainment.
Possession of large amounts of unaccounted money by various persons including those
belonging to the industrial and commercial classes is a major impediment in the purification
of public life.13 If anti-corruption activities are to be successful it must be recognised that it is

10
Yang, Crystal S. "Free at last? Judicial discretion and racial disparities in federal sentencing." The Journal of
Legal Studies 44.1 (2015): 75-111.
11
Sutherland, White Collar Crime, (1961), p. 47 As cited by Siddiqui, Ahmed, Criminology- Problems and
Perspectives, p-391, (Lucknow: Eastern Law Company, 2001)
12
Anand, Atul. "DIMENSIONS OF WHITE-COLLAR CRIME IN INDIA: A LEGAL STUDY."

7
as important to fight these unscrupulous agencies of corruption as to eliminate corruption in
the public services. In fact, they go together.
Commenting on the extremely dishonest behaviour of Indian traders, it has rightly been
observed:
“Business communities in India of large and small merchants are basically a
dishonest bunch of crooks…… While it is true that the object of businessmen is to make
profit, there are degrees and degrees of making profit, and nowhere in the world do
businessmen get rich as quickly as they do in India….”14
Two instances of big-business criminality are provided by reports made by the commissions
dealing with the notorious Dalmia-Jain and Mundhra cases. The Vivian Bose Commission,
which inquired into the affairs of the Dalmia-Jain group of companies, the third biggest in the
country, held them responsible in different degrees for fraud, mismanagement, manipulation
of accounts, destruction of records, personal gain at the expense of the investing public,
avoidance of taxes and a number of other irregularities and violations of trust.15
Mr. M.C. Chagla, who probed into the working of the Mundhra concerns, had to make the
following observations about the business tycoon: Mundhra is a flamboyant personality and a
financial adventurer whose only ambition is to build up an industrial empire by dubious
means.” The reports of the Company Law Administration record about 124 prosecutions
against him and companies owned by him, out of which 113 ended in conviction during this
two-year period.16
Hoarding, profiteering and black marketing of essential commodities by traders in India has
become a chronic problem. Another white-collar crime which is quite prevalent among
businessmen is violation of the Foreign exchange Act and Imports and Exports Act.
According to Santhanam Committee Report, secret hoard of foreign exchange are built up
abroad by Indian businessmen through under-invoicing of exports and over-invoicing of
imports.17

13
Myrdal, Gunnar. "Corruption as a hindrance to modernization in South Asia." Political Corruption.
Routledge, 2017. 265-280.
14
Iyer, Gopalkrishnan R. "The impact of religion and reputation in the organization of Indian merchant
communities." Journal of Business & Industrial Marketing (1999).
15
Mishra, R., (2006). ‘Criminal Psychology’, Sunit Enterprises.
16
Ankit, Rakesh. "MC Chagla and the “Nationalist” Imaginations of a “Political Minority” in India, 1947–
67." Journal of Muslim Minority Affairs 41.3 (2021): 491-509.
17
Sawshilya, Archana. Ethics and Governance (ICFAI). Pearson Education India, 2012.

8
 2. Food and Drug Adulteration

This is easily the most atrocious crime committed by businessmen since it can cause
irreparable damage to the health or even lives of innocent citizens. In India, the problem is so
widespread that from 25 per cent to 70 per cent of most of the foodstuffs consumed in this
country are adulterated or contaminated. 18 The same is true of the production of spurious
drugs in the country.19 According to the Pharmaceutical Inquiry Committee, Government of
India, the spurious drugs trade flourishes in India to a colossal extent. 20 This is due to the
greed of the manufacturers, ignorance of the poor consumers who go in for cheap medicines
from unauthorised dealers and the shortage of genuine goods. Prosecutions under the
Prevention of Food Adulteration Act fail quite frequently because of defective reports of the
public analysts, or delay in the examination of samples or because he procedure prescribed by
the Act for taking samples is not followed.21

3. Violations of Taxation Laws

Some of the more important and frequent tax violations which occur in India are in the areas
of income tax, wealth tax, estate duty and sales tax. The loss resulting from the violations to
the State exchequer is tremendous. Apart from the financial implications of the problem,
there are other dimensions of the evil such as the corrupting influence of the tainted money
on governmental machinery and the consequent contempt. Disrespect and cynicism towards
law in general.22

3.1 Extent of the Problem

Probably the greatest menace caused by the failure to check tax evasion is the phenomenon of
black money which has serious repercussions on the economy of the country. The Wanchoo
Committee appointed by the Government of India in 1970 to make recommendations to
unearth black money and combat tax evasion identified the following direct effects of black

18
Singh, Anita, et al. "Risk assessment of heavy metal toxicity through contaminated vegetables from waste
water irrigated area of Varanasi, India." Tropical ecology 51.2 (2010): 375-387.
19
Id.
20
Rodrigues, Viola. "Need for a Separate Enactment to Curb White-Collar Crimes in India." LexForti Legal J. 1
(2019): 28.
21
Id.
22
Ananthanarayanan, Sriram. "New mechanisms of imperialism in India: The special economic
zones." Socialism and democracy 22.1 (2008): 35-60.

9
money economy in the country.23 There is loss of revenue to the State. This and the
immobility of investable funds contribute to the dearth for resources of national development.
It results in inequitable taxation; the honest taxpayer suffers in the process.
Since the unaccounted money cannot be declared or invested through lawful channels, a good
part of it is spent in lavish consumption and unproductive uses resulting in waste as well as in
inflation. The most disastrous aspect of the phenomenon of black money is that the general
moral fibre of the society as a whole is adversely affected.

4. Corruption in Government and Politics

Corruption is one of the most talked abut subjects today in the country since it is believed to
have penetrated into every sphere of government and political activity. Corruption of various
forms has always existed not only in India but also in countries which are materially and
politically more advanced.
In its wider sense, corruption includes all forms of dishonest gains in cash, kind or position
by persons in government and those associated with public and political affairs.

4.1 Corruption in Government

Various factors have been responsible for the widespread corruption among government
servants. While some factors are the same as in the case of white collar crimes in general,
there are some factors which have a special bearing on the problem of corruption among
government and other public servants. The two world wars gave vast powers to government
servants in matters relating to the grant of licences, permits and quotas.24
Some other factors which make public servants corrupt are connected with the economic
conditions of most of the government employees. In India, though the government services
have some special prestige, the salaries given to the employees, by and large, are quite low.
This factor in combination with some other factors like inflation contributes a great deal
towards corruption. The two government departments which have been traditionally
notorious for corruption in the country are those of police and public works.

23
Thavaraj, M. J. K. "Wooing Black Money: The Wanchoo Committee Way." Social Scientist (1972): 30-39.
24
Godwin, Kunda ‘Conference report on white collar crimes’.

10
4.2 Political Corruption

Corruption among ministers and other political personages is more dangerous than corruption
in the governmental machinery in terms of the enormity of the stakes involved in public life.
Corruption and indecency in political life informs all the sections of society since violations
are committed by those very persons who are expected to set the norms of social and political
conduct.
The more usual forms of political corruption in India are grafts, violation of election laws and
the abuse of official and political machinery because of the liaison of political forces with big
business.25 The well-known episodes known as Mundhra Sirajuddin Tul Mohan Ram in the
part affairs involving central Cabinet ministers and members of Parliament are typical
examples of political corruption.26

25
Olken, Benjamin A., and Rohini Pande. "Corruption in developing countries." Annu. Rev. Econ. 4.1 (2012):
479-509.
26
Patil, Harshad, and Shyamkarn Patil. "E-governance and white collar crime control." Proc. 6th Intl.
Conference on E-Governance. 2008.

11
 WHITE COLLAR CRIME IN PROFESSIONS

Among the many professions where opportunities for committing white-collar crimes are
abundant the professions which come readily to one’s mind are those of medicine and law.
The majority of the people belonging to the medical profession may not commit criminal or
unethical acts in the course of their profession but still the number of those who violate the
professional and legal norms is not significant.27 The most common instances are illegal
abortions, false medical certificates and unnecessary prolonged treatment in many cases.
Another widespread violation consists of prescribing medicines which one is not supposed to
having regard to his training or the system of medicine permitted to be followed by him.28
White-collar criminality among lawyers is believed to be fairly widespread. Though such
criminality is found to exist in many countries, the situation in India is further aggravated by
the fact that there are too many lawyers having regard to the work available to them with the
result that all sorts of unscrupulous practices have crept into the profession. It is not
surprising, therefore, that the image of a typical lawyer is far from being complimentary in
India.29 The usual legal and professional violations committed by the lawyers are: advising
organized criminals, aiding in preferring false claims and fabricating false evidence.30
The incidence of white-collar crime is fairly high among some other professionals also like
advertisements, property valuers, consulting and other engineers and contractors undertaking
construction and other kinds of work31.
With the increasing use of newly developed technologies in the various spheres of business,
commerce and industry, particularly the computers, the scope of white-collar crime is getting
wider; new crimes are emerging and the commission of certain kinds of pre-existing crimes is
being greatly facilitated.32

27
Jesilow, Paul D., Henry N. Pontell, and Gilbert Geis. "Medical criminals: Physicians and white-collar
offenses." Justice Quarterly 2.2 (1985): 149-165.
28
Id.
29
Reed, John P., and Robin S. Reed. "“Doctor, lawyer, Indian chief”: Old rhymes and new on white collar
crime." Australian & New Zealand Journal of Criminology 7.3 (1974): 145-156.
30
ID.
31
Geis, Gilbert, ed. White-collar criminal: the offender in business and the professions. transaction Publishers,
2006.
32
Bequai, August. White-collar crime: a 20th-century crisis. Lexington, Mass.: Lexington Books, 1978.

12
 1. White Collar Crimes in Legal Profession

The white-collar crimes became a phenomenon to be reckoned with industrial revolution.

Modern industrial capitalist economy which evolved with time became complex in nature as
it developed a growing commercial nexus among insurance, banking, stocks and related
corporate matters. This in turn, gave rise to critical legal intricacies relating to property rights
and other legal matters which paved the way for the birth of a new class of professionals of
advocates who in the name of providing justice started abetting in the wrong and thereby
pursued their own narrow interest.33 A large number of advocates evolved, who forget the
pious oath of serving the society and started looking for the legal loopholes and concentrated
mainly in helping out the rich entrepreneurs to grow richer. They made extensive study to try
out ways for maximum tax evasion for these rich corporate personalities as well as for
themselves. The white-collar crimes committed by these legal practitioners’ only confines in
sorting out illegal methods of tax-evasion. 34 There are very frequent instances of
unscrupulous and unethical practices like that of fabricating false evidence, engaging
professional witnesses, thereby violating ethical standards of legal profession and dilatory
tactics in collusion with the ministerial staff of the courts. The instances of white-collar
crimes committed in the Indian society by the lawyers, there lie the shameful illustrations of
Magistrates and judges involved in committing crimes. 35 They in the name of interpreting the
laws often act as the protective shield for the goons having or not-having any political colour
and allow them to go free whereas they should have been subjected to deterrence. It is the
most unfortunate situation at the same time devastating, because here the crimes are
committed by those individuals who are being given by the State the responsibility to ensure
justice.36

33
Supra note 30.
34
McBarnet, Doreen. "Whiter than white collar crime: tax, fraud insurance and the management of
stigma." British Journal of Sociology (1991): 323-344.
35
Id.
36
Ponnian, M. (2003). Criminology and Penology, Pioneer Books, Third edition.

13
 WHITE COLLAR DISTINGUISHED FROM TRADITIONAL LAW

It must be noted that white collar criminality has a close affinity to the attitudes and values of
culture in a particular society. This is evident from the fact that white collar criminals are
intelligent, stable, and successful and men of high social status as compared with the ordinary
criminals. They are foresighted persons belonging to the prestigious group of society. White
collar crimes which are committed in commercial world are indirect, anonymous, impersonal
and difficult to detect. As against this, ordinary criminals commit crime which are direct and
involve physical action, such as. Beating, removal of property or use of force, etc. which can
be easily be identified and detected. It is often said that ordinary crimes which are otherwise
called ‘blue collar crimes’ are more common with the under-privileged group while the
white-collar crime are committed by the privileged group who belong to the upper strata of
society.37 Edwin Sutherland, however, suggests that status alone is not determinant of white
collar or blue-collar crime.38 This is evident from the fact that even the most privileged and
prestige persons may commit heinous crime such as murder, rape or kidnapping for which
they can be severely punished, while on the other hand, most under-privileged people may be
involved in a white collar crime like tax evasion, corruption or misrepresentation which may
not be looked as serious offence. 39 This however, does not mean that white collar crimes are
petty offences because they do not carry severe punishment. Undouble, the penologist
hitherto confined their attention to prevention of ordinary crimes but the recent penal
programs sufficiently indicate emphasis has now shifted to suppression of white-collar
criminality with the equal vigour and strength. 40 The amendment s introduced in the Indian
Companies Act in 1988, Monopolies and Restrictive Trade Practices Act 1992, Insurance and
banking Laws, the appointment of Lokpal, Lokayukta and tightening of governmental control
over private business groups sufficiently reflect upon the government’s determination to
suppress white collar criminality in India.
There is much resemblance between white collar crime and blue collar crime, both owe their
origin to common Law and are adaptations of principles of theft, fraud etc. to modern socio-
economic institutions and in fact there is no basic difference between the two. The only
peculiarity of white collar crime is that it is committed by the persons of relatively high status

37
Braithwaite, John. "White collar crime." Annual review of sociology (1985): 1-25.
38
Supra Note 4.
39
Supra note 38.
40
Levi, Michael. Regulating fraud (routledge revivals): White-collar crime and the criminal process. Routledge,
2013.

14
of society. The criminal content in both the types is more or less common. 41 It must, however,
be noted that mens rea or guilty mind is an essential ingredient of every blue collar crime but
many statutes dealing with white collar crime do not require mens rea in strict sense of the
term. The doctrine of constructive mens rea.applies in such cases.42
It must be stated that besides being a social problem, white collar crime is also a legal
problem. As E H. Sutherland rightly puts it, no distinction in terms of social status,
occupational activity, attitude or gravity of consequences can separate white collar crime
from those of traditional crime. 43 The only distinguishing feature of this type of crime is the
temptation for considerable material gain with little or no loss of status. 44 This again, gives a
misleading impression that the executive and judicial authorities who are concerned with the
prevention of crime react favourably to the upper and middle class society and dispose of
white collar criminals with mere censure or admonition while other criminals are subjected to
severe penal sanctions under the law without being given any pre warning. But that the
reason for this soft attitude of law makers and prosecutors towards white collar criminals is
perhaps the latter's closer contacts with agencies of social control on account of their social
status and privileged position. More often than not, these criminals are friendly with the top-
ranking public officials. That apart, the impact of white-collar crime is so widely diffused in a
large number of people that it does not aggravate the feelings of one single individual.
Therefore, the public cry against white collar criminality is far less than for the predatory
crimes.
Commenting on the preponderance of white-collar crime in the modern time Edwin
Sutherland rightly comments that, "social disorganization on account of individualistic
policies and competitive economy are the root causes for this type of criminality". It is rather
a reflection on society's attitude towards different types of crimes and the accepted values of
its culture.45
The financial cost of white-collar crime is probably several times greater than that of all the,
crimes taken together. In a recent study it has been concluded the financial loss to society
from white collar crime is far greater than the financial loss from the predatory crimes
committed by persons of lower socio-economic status. 46 It has been further concluded that the
average loss per burglary is less than ten thousand rupees and a burglary which yields as
41
Surbhi, S. "Difference Between Blue Collar and White Collar." Key Diffrences 14 (2015).
42
Id.
43
Supra note 4.
44
Supra note 42.
45
Supra note 4.
46
Friedrichs, David O. Trusted criminals: White collar crime in contemporary society. Cengage Learning, 2009.

15
much as one lakh of rupees is exceedingly rare. On the other hand, there may be several
crores’ rupees embezzlement reported in one year.47 Notably, these embezzlements are
nothing as compared with the large-scale crimes committed by corporations, investment
trusts and public utility concerns. It can, therefore, be inferred that white collar criminals
violate trust and create distrust which lowers social morale and results into social
disorganization to a large extent while other crimes produce, relatively little effect on social
institutions.
By way of generalization, it may be stated that like other criminal behaviour, white collar
criminality can best be explained through the process of differential association. It is a
generic explanation for both white collar as also the blue collar criminality. Those who
become white collar criminals generally start their career in good neighbourhoods and good
homes, well-educated with some idealism and get into peculiar business situations in which
criminality is practically a routine way of life. Another explanation for white collar
criminality is to be found in the process of social disorganization in the community.

47
Konch, Karabi. Crime and Society. Notion Press, 2017.

16
 CONCLUSION

White collar crime is, therefore, a complex area to conceptualize. It remains on the side-lines
of criminology and poses analytical, definitional and research problems. Many of the issues
surrounding its definition and its relationship to other crimes remain unresolved and affect
estimates of its extent, explorations of its nature and impact and approaches to its analysis. It
asks major questions about the definition of crime, the role of class status and power in
criminalization and law enforcement and the scope of criminology. White collar crime is used
as an umbrella term encompassing both occupational and organizational crime. It is intended
to be inclusive, including activities of employees across the occupational hierarchy along
with many harmful and illegal activities that are not at present regulated by criminal law. This
avoids the narrowness of referring only to criminal law at the same time as avoiding the
subjectivity of ignoring law entirely. Adopting an inclusive definition of the subject means
that its scope is extremely broad, and that it includes activities ranging from the crimes of
individual employees and small businesses, through those of managers, executives and
owners of companies, to corporate crime and crimes of governments and states, such as war
crimes or the state-organized terrorism.

17