INTRODUCTION

INDIRECT TAXES

Indirect Taxes are the charges levied by the State on consumption, expenditure, privilege, or
right but not on income or property. Customs duties levied on imports, excise duties on
production, sales tax or value added tax (VAT) at some stage in production-distribution process,
are examples of indirect taxes because they are not levied directly on the income of the consumer
or earner. Also called consumption taxes, they are regressive measures because they are not
based on the ability to pay principle. Some of the indirect taxes are:

• Excise Duty

• Customs Duty

• Value Added Tax

• Central Sales Tax

• Service Tax

• Expenditure Tax

• Stamp duties

• Securities Transaction Tax

Various other taxes or rates are levied by the municipal authorities (e.g., on goods entering their
jurisdiction and on the annual value of property), by state governments (e.g., on motor vehicles
and amusements) and by the central government (e.g., on foreign travel and domestic air travel).

1
 Statement of Problem

Indirect taxes include a number of taxes such as Excise Duty, Customs Duty, Value Added Tax ,
Central Sales Tax, Service Tax, Expenditure Tax, Stamp duties, Securities Transaction Tax,
making it difficult to define all the goods on which indirect taxes are levied . Hence, to seek the
definition of goods which are included in indirect taxes, the provisions of the various acts which
together give shape to the concept of indirect taxes need to be studied.

2
 Research Objectives

 This research paper primarily investigates the dilemma regarding the scope of definition
of “goods” for the purposes of Indirect Taxes.

 Also, through this project I aim to present a detailed study of the definition
of “Goods” under the Sale of Goods Act, 1930.

3
 Research Questions

(1) Can the goods under Indirect Taxes be compartmentalized and given a restrictive
definition?

(2) What is the position of commodities such as Electricity, Lottery tickets and Software
programs with respect to Indirect taxes?

4
 I. A Brief Study of the various Taxes and Acts pertaining to Indirect
Taxes and definition of goods under the respective Acts

(1) Excise Duty: It is an indirect tax levied and collected on the goods manufactured in India.
Generally, manufacturer of goods is responsible to pay duty to the Government. This indirect
taxation is administered through an enactment of the Central Government viz., The Central Excise
Act, 1944 and connected Rules - which provide for levy, collection and connected procedures.
The rates at which the excise duty is to be collected are stipulated in the Central Excise Tariff Act,
1985. It is mandatory to pay duty on all goods manufactured, unless exempted. For example, duty
is not payable on the goods exported out of India. Similarly exemption from payment of duty is
available, based on conditions such as kind of raw materials used, value of turnover (clearances)
in a financial year, type of process employed etc.
The Central Excise Department spread over the entire country administers and collects the central
excise duty. The apex body that is responsible for the policy and formulation of connected rules is
the Central Board of Excise and Customs which functions under the control of the Union Finance
Ministry. There are about 60,000 staff and officers including 1500 officers in Group A level and
5,000 officers in Group B level in the Department.

 Definition of Goods under The Central Excise Act, 1944

Section 2(d) of Central Excise Act defines Excisable Goods as ‘Goods specified in the Schedule
to Central Excise Tariff Act, 1985 as being subject to a duty of excise and includes salt’.
‘Goods’ includes any article, material or substance which is capable of being bought and sold for
a consideration and such goods shall be deemed to be marketable.

Goods ‘excisable’ even if exempt from duty – 

“Excisable goods’ do not become non-excisable goods merely because they are exempt from duty
by an exemption notification” -. Wallace Flour Mills co. ltd v. CCE (1989) 186 ITR 440 (SC)

Goods not included in CETA are ‘non-excisable goods’ - Some goods like wheat, rice, cut
flowers, horses, soya beans etc. are not mentioned in Central Excise Tariff at all and hence they
are not ‘excisable goods’, though they may be ‘goods’. These are ‘non-excisable goods’.
Similarly, ‘waste and scrap’ will be ‘excisable goods’ only if specifically mentioned in CETA
- CCE v. Amol Decalite Ltd. 1999 (105) ELT 222 (CEGAT)

In Western India Ceramics P Ltd. v. CCE 1998(99) ELT 425 (CEGAT), it was held that broken
glazed tiles are not excisable as there is no specific entry (in Tariff) for it.

5
 Further, the ‘excisable goods’ are liable to duty only if they are ‘manufactured’ or ‘produced’.

Goods excisable even if duty is nil – If by virtue of an exemption notification, the rate of duty is
reduced to NIL, the goods specified in the tariff would still be regarded as excisable goods on
which NIL rate of duty was payable.

(2) Custom Duty: The Custom Duty in India is one of the most important tariffs. The custom duty
in India is regulated by the Customs Act of 1962. The main purpose of the custom duty in India
is the prevention of the illegal export and import of goods. The rates of the custom duty levied on
the imported and exported goods are assigned in the Custom Act, 1962.
The Acts under the custom duty in India:
• Foreign Trade (Exemption from application of Rules in certain cases) Order, 1993
• Customs Act, 1962
The Customs Act was formulated in 1962 to prevent illegal imports and exports of goods.
Besides, all imports are sought to be subject to a duty with a view to affording protection to
indigenous industries as well as to keep the imports to the minimum in the interests of securing
the exchange rate of Indian currency. Duties of customs are levied on goods imported or
exported from India at the rate specified under the customs Tariff Act, 1975 as amended from
time to time or any other law for the time being in force. For the purpose of exercising proper
surveillance over imports and exports, the Central Government has the power to notify the ports
and airports for the unloading of the imported goods and loading of the exported goods, the
places for clearance of goods imported or to be exported, the routes by which above goods may
pass by land or inland water into or out of Indian and the ports which alone shall be coastal
ports.. In order to give a broad guide as to classification of goods for the purpose of duty
liability, the central Board of Excises Customs (CBEC) brings out periodically a book called the
"Indian Customs Tariff Guide" which contains various tariff rulings issued by the CBEC. The
Act also contains detailed provisions for warehousing of the imported goods and manufacture of
goods is also possible in the warehouses. For a person who do not actually import or export
goods customs has relevance in so far as they bring any baggage from abroad.
Types of duties
Under the custom laws, the following are the various types of duties which are leviable:
• Basic Duty
• Additional Duty (Countervailing Duty) (CVD)
• Anti-dumping Duty
• Protective Duty
• Duty on Bounty Fed Articles
• Export Duty

 Goods covered under Customs The Customs Act, 1962:

As per Section 2 (22) of The Custom Act, 1962, "goods" includes-

6
 (a) Vessels, aircraft and vehicles;
(b) Stores;
(c) Baggage;
(d) Currency and negotiable instruments; and
(e) Any other kind of movable property.

(3) VALUE ADDED TAX (VAT): A value added tax (VAT) is a form of consumption tax. It is a
tax on the estimated market value added to a product or material at each stage of its manufacture
or distribution, ultimately passed on to the consumer. It differs from a sales tax, which is levied
only at the point of purchase. Value Added Tax is intended to be levied - or charged - whenever
there is some value addition to raw material. The taxpayers on the other hand, will get credit for
the amount of tax paid off at the stages of procurement. The value added tax system has proven
to be effective in avoiding problems that normally might arise out of the double taxation of
goods and services. The value added tax system is designed to address various problems
associated with the conventional sales tax system. In sales tax, there is no provision for input tax
credit, which means that the end consumer may pay tax on an input that has already been taxed
previously. This is known as cascading and leads to increases consumer tax and price levels,
which increases the rate of evasion and can be detrimental to economic growth. The value added
tax system deals with these problems quite efficiently. As VAT is imposed on value addition - at
every single stage - there is no incidence of cascading. In this way, the final consumers bear the
burden of paying value added tax. This system involves absolute transparency at every stage of
taxation, thereby making the tax system quite comprehensible and simple. In some countries like
India, the system of VAT has been designed to change the existing system of sales taxation.
Value added tax is different from the conventional system of sales tax, because VAT is charged
at every stage of value addition - whereas sales tax is imposed on final value of transaction only.
The value added tax system allows for input tax credit, or ITC, on the amount of tax levied at the
preceding stage of the value addition chain. The allowance for ITC is normally appropriated
from the value added tax liability imposed on the following stage of the sale of the product.

 Goods covered under VAT

All the goods including declared goods as mentioned in the Central Sales Tax Act, 1956 are
covered under VAT and will get the benefit of input tax credit.
Only few goods which has been kept outside VAT is liquor, lottery tickets, petrol, diesel,
aviation turbine fuel and other motor spirit since their prices are not fully market determined.
These will continue to be taxed under the Sales Tax Act or any other State Act or even by
making special provisions in the VAT Act itself, and with uniform floor rates decided by the
Empowered Committee.

7
(4) CENTRAL SALES TAX: Central Sales tax is generally payable on the sale of all goods by a
dealer in the course of inter-state trade or commerce or, outside a State. There can be an
interstate sale even if the buyer and the seller belong to the same state; even if the goods move
from one state to another as a result of a contract of sale; or, the goods are sold while they are in
transit by transfer of documents. Sales tax is payable to the sales tax authority in the state from
which the movement of goods commences. It is to be paid by every dealer on the sale of any
goods effected by him in the course of inter-state trade or commerce, notwithstanding that no
liability to tax on the sale of goods arises under the tax laws of the appropriate state.
The power to levy Sales tax
1. No state can levy sales tax on any sale or purchase where such sale or purchase takes place o
outside the state and o in the course of import of goods into or export of goods outside India.
2. Only the parliament can levy tax on inter-state sale or purchase of goods
Transactions not amounting to inter-state sales
Not all dispatches of goods from one state to another result in interstate sales rather the
movement must be on account of a covenant or incident of the contract of sales. There are some
instances wherein the goods are moved out of the selling state and yet they are not considered
interstate sales :-
• Intra-state sales
• Stock transfer from head office to branch & vice versa
• Import and Export sales or purchases
• Sale through commission agent / on account sales
• Delivery of Goods for executing works contract
Sales Tax ID number
A state sales tax ID number is basically a business version of your Social Security number under
which you collect and pay tax for any service or product you sell that qualifies for taxation in
your state. The state department of taxation provides sales tax ID numbers and it takes about a
month to get one. The rule of thumb for sales tax is that most services are exempt and most
products are taxable except for food and drugs. However, states have been gradually adding to
the list of services that are taxable for the last few years. Check with your state department of
taxation to determine if the product or service you sell is taxable in your state.
Exception in the sales taxes
• Sales to resellers such as wholesalers and retailers that have a valid state resale certificate.
• Sales to tax-exempt institutions such as schools or charities

 Definition of Goods under The Central Sales Tax Act, 1956

According to Section 2(d), “goods” includes all materials, articles, commodities and all other
kinds of movable property, but does not include newspapers, actionable claims, stocks, shares
and securities.

8
(5) SERVICE TAX: Tax on services has been in vogue in India since 1994 when it was
introduced for the first time. When it was introduced initially there were three services which
were liable but over the years various other services have been added and today more than a
hundred services are liable under service tax. The basket of services liable to service tax is only
expected to grow in the near future as the service sector’s contribution to the country’s GDP is
expected to increase even further though possibly most of the services which can be
comprehended are already being taxed. Here, a negative list would make more sense to avoid
uncertainty caused by frequent changes. One of the main reasons for the services to be taxed is
the fact that the manufacturing sector can be taxed only to a certain extent if we are to ensure the
competitiveness of our industry, since ours is no longer a closed economy, all activities are to
bear the burden. Services presently forming more than 55 % of the GDP are expected to reach
70% in the next decade, which should also bear the burden of tax. This tax would be subsumed
into the Goods and Service Tax which maybe in place in the next few years. Assessees should
note that in order to attract service tax, there should first of all be a service. The concept of
service though has not been defined for this purpose under law and one would have to refer the
meanings given by dictionary to understand the same.
Governing provisions
The provisions pertaining to service tax are given in Chapter V and VA of Finance Act 1994 as
amended from time to time. The Central Government has also been empowered to make rules to
carry out the provisions of this Chapter, through section 94 of this chapter. This comes along
with the power to grant exemptions from Service Tax u/s 93. The Government has consequently
notified various sets of rules FOR Service Tax. The service tax levy is attracted when a taxable
service is provided by a defined service provider to a defined service receiver. Unless a service
can be regarded as being taxable and being provided by a defined service provider to a defined
service receiver, it cannot be taxed. All the three conditions here should be met and even if one
of the conditions is not met, the activity in question cannot be taxed. The assessee may however
note here that the concept of service receiver now is only of academic interest as the scope of the
term is being widened to cover almost all service receivers in the last couple of years (the service
receiver can be any person in most of the services). Over the years, the number of services being
subject to service tax is also being increased by including all the concerned services in the
relevant section discussed above. The service tax levy does not extend to the state of Jammu and
Kashmir.
Payment of service tax
The service provider providing taxable services shall be required to pay service tax. However,
the service provider does not have to pay service tax until he collects the value of service, from
the service receiver towards the taxable services provided by virtue of Rule 6 of Service Tax
Rules 1994. Once the payments are received, the service tax shall be paid by the 5th of the month
following the month in which the sums are received towards such taxable service. However, in
respect of the amounts received in the month of March, the payment would have to be made by

9
the 31st of March and not by 5th of April. Where the payment is made electronically, the due
date is 6th of the following month instead of 5th .

(6) Expenditure Tax: Expenditure tax is levied under the Expenditure Tax Act, 1987 at the rate
of 10 percent on payments made to hotels toward room charges, food, beverages, and other
services. This tax is collected by hotels from their customers and deposited with the central
government. However, it is not applicable to hotels with room charges of less than Rs 1,200 per
day pr person.
(7) Stamp duties: Stamp duty is levied at various rates on documents, such as bills of exchange,
promissory notes, insurance policies, contracts affecting a transfer of shares, debentures, and
conveyances for the transfer of immovable property. Stamp duty on the transfer of shares and
conveyances of immovable property is normally payable by the purchaser. The rates are
prescribed by central government legislation, the Indian Stamp Act 1899, but rates on some
documents have been revised through state government legislation.

10
II. “Goods” under the Sale of Goods Act, 1930
Definition of “goods”

‘Goods’ is defined as per Section 2 (7) of the ‘Act’ as “Every kind of movable property other
than actionable claims and money; and includes stock and shares, growing crops, grass,
and things attached to or forming part of the land which are agreed to be severed before
sale or under the contract of sale.”

Definition of “Movable Property”

As per section 3(36) of the General Clauses Act 1897, “movable property” is defined as
“property of every description except immovable property.” Section 3(26) of the same Act reads
as, “Immovable property shall include land, benefits to arise out of land, and things attached to
the earth, or permanently fastened to anything attached to the earth.” Hence, a conjoint reading
of the two sections gives us a clear definition that anything that is attached to the land maybe
termed as “movable property”, provided that there is an element of severability involved.
[Pollock & Mulla, The Sale of Goods Act, 33 (Satish J Shah ed., 8th ed., 2011)] . The element of
severability is important while deciding on the nature of the property, and this element can be
established by ascertaining the nature of the property, intention of the parties and the terms of the
contract between them. [Id]. For instance, timber [Id. (defining timber as wood fit for building
and repairing houses)] falls under the ambit of “goods” as per S.2(7) [Sale of Goods Act, 1930]
because timber trees are severed from the land for the purpose of sale and hence they become a
commercial commodity.[ Kanakapalam Estate v. State of Kerela, (1989) 73 STC 336 ].  In the
case of Tata Consultancy Services v. State of Andhra Pradesh [ (2005) 1 SCC 308] it was held
that property as per Sale of Goods Act means general property over the goods and not merely a
specific property. The usage of the word ‘includes’ further expands the definition, as it includes
in the definition not only goods of the prescribed nature but it also imports those things that are
specifically provided by the interpretation clause.[Scientific Engg. House (P) Ltd. v. CIT, (1986)
1 SCC 11]

11
The following discussion primarily focuses on the point that whether certain types of
commodities can be included within the definition of “goods” or not.

Electricity as “goods”: Inclusion of intangible energy within the definition of

goods

Electricity does not come under the definition of “goods” as per English law[ Pollock & Mulla,
The Sale of Goods Act, 44 (Satish J Shah ed., 8th ed., 2011) ]. There have been judicial decisions
in England where electricity has been referred to as ‘thing’ and an ‘article’[Betnley Bros. v.
Metcalfe & Co., [1906] 2 K.B. 548, 552-553] and also as ‘tangible personal property’[ Re Social
Services tax Act, (1970) 74 W.W.R. 246 ], but there has been no judicial decision which includes
electricity within the definition of ‘goods’ for the purpose of Sale of Goods Act. [Benjamin’s
Sale  of Goods, 71 (M. Bridge et al. eds., 8th ed. 2010) ]. Moreover, the legal possession of
electrical energy is a challenging proposition as “it is capable of being kept or stored only by
changing the physical or chemical state of other property which is itself the subject of
possession.”[Id.]

In India however, the situation is quite different. In the Calcutta High Court case of Associated
Power Co. v. R.T. Roy [ AIR 1970 Cal 75] it was held that electricity comes under the ambit of
‘goods’ under the article 366 (12) of the Constitution as well as S. 2 (7) of the ‘Act’. This
proposition was affirmed in a Madras High Court case where the learned judge held that
electricity was under the definition of ‘goods’ since it is capable of delivery, and it does not
matter whether it is a tangible or intangible form of energy.[Kumbakonam Electric Supply
Corp Ltd. v. Joint Commercial Tax Officer , AIR 1964 Mad 477]. The Law Commission of
India in its 8th report proposed that electricity and water should be included in the definition of
‘goods’ under S. 2(7) of the ‘Act’ [ Law Commission of India, Eighth Report on the Sale of
Goods Act, 1930 (1958)]. Meanwhile, the Supreme Court while discussing about the definition
of ‘goods’ as mentioned in the Madhya Pradesh Sales Tax Act (2 of 1959), found that the
definition included all kinds of movable property[Supra note 13]. The court further held that:

12
“The term “movable property” when considered with reference to “goods” as defined for the
purposes of sales tax cannot be taken in a narrow sense and merely because electric energy is
not tangible or cannot be moved or touched like, for instance, a piece of wood or a book it
cannot cease to be movable property when it has all the attributes of such property……It can be
transmitted, transferred, delivered, stored, possessed etc., in the same way as any other movable
property.”[Commissioner of Sales Tax, Madhya Pradesh v. Madhya Pradesh Electricity
Board, AIR 1970 SC 732].

However, Pollock & Mulla, in their commentaries, have expressed their concerns over the
applicability of the ‘Act’ for electricity because, there is no contractual obligation on part of the
public authority to supply ‘electricity’, rather it is a statutory obligation on part of the authority
providing these ‘goods’. The supply of such commodities would not amount to a ‘sale’ for the
purposes of the ‘Act’. As a result, any breach or failure on part of the public body to supply
electricity would be dependent upon the terms of the statute governing the public body.

Thus, on one hand it can be said that ‘electricity’ comes under the definition of ‘goods’ however
the applicability of the ‘Act’ in case of sale of electricity is a dubious proposition.

Exclusion of Lottery tickets from the definition of “goods”

As per Black’s Law Dictionary, ‘lottery’ is defined as ‘a chance for a prize for a price’.[ Black’s
Law Dictionary 947 (6th ed. 1991)]. For the purposes of the ‘Act’ lottery tickets are clearly a
movable property, however it has been a matter of debate that whether they are an actionable
claim as defined under S.3 of Transfer of Property Act, 1882.

In the Supreme Court case of H. Anraj v. Government of T.N.[ (1986) 1 SCC 414] it was held
that a lottery ticket primarily involved two rights:

(1) the right to participate in the draw and

(2) the right to win the prize, depending on chance.

13
In that case it was held that the former right was a “transfer of a beneficial interest in movable
goods” and hence was a sale within the meaning of Art 366 (29-A)(d) of the Constitution
whereas the latter right was a chose in action and thus not “goods” for the purpose of levy of
sales tax.

However, the ruling of this decision was challenged in a later Supreme Court verdict of Sunrise
Associates v. Government of NCT of Delhi [(2006) 5 SCC 603]. It was held that sale of a lottery
ticket amount to a sale of an actionable claim. The conclusion of the Court was based on the
reasoning that there was no difference between right to win and right to participate in a lottery
draw, as no purchaser pays the consideration for a right to participate in the draw, instead he
pays it for the right to win.[ID] Thus, the classification by H. Anraj case (supra) of the right to
participate as right in praesenti and the right to win as a right in futuro, was incorrect as both
these rights are in futuro. As a result the earlier judgment was overruled to that extent and
“lottery tickets” were excluded from the definition of “goods”.

Conundrum surrounding Software programs

In the case of TCS v. State of Andhra Pradesh [ (2005) 1 SCC 308] the Supreme Court held that
a software program on a CD or a floppy drive would be a “good” for the purposes of levy of
sales tax.[Id] A software program is a collection of instructions or commands that are given to a
computer to perform a given task. The main area of debate is that “Do software programs – being
intellectual creations of human mind – be treated as “goods” for the purposes of the ‘Act’ or
not?”

One of the landmark cases in this regard was the case of St Albans City and District Council v.
International Computers Ltd. [(1995) FSR 686] where Sir Iain Glidewell observed that a
hardware device has no use of its own unless it is supplemented with a software and it was only
because of necessity that software was contained in a physical medium like a disk or a floppy
furthermore, in case the disk is sold and there is a defect with the program, then there would be
a prima facie liability against the disk manufacturer as well. Thus, he held that the tangible disk
and the software program both will be included within the definition of “goods”.

14
In the TCS case (supra) a special mention was given to ‘canned software’, where it was held by
the learned judge that once a software is uploaded on a medium like a CD or a floppy drive, it
ceases to be a work of intellectual creation. This is primarily because each of these mediums
becomes a marketable commodity in itself [See Advent Systems Ltd. v. Unisys Corpn , 925 F.
2d 670]. “Marketability” of a commodity was the determining factor whether it is a “good” or
not. It has also been held that “operational software” which was uploaded on a hard-disk does
not lose its character as a tangible good [Commnr. of Central Excise, Pondicherry  v. ACER
India Ltd., 2004 (8) SCALE 169].

It has also been a matter of debate as to inclusion of computer software within the definition of
“goods” as defined in section 2 of the Uniform Commercial Code, 1952. It is argued that since
“custom designed” computer software is a product of a labor intensive process and it must be
considered as a service rather than a good. However, sale of most of the software programs
resemble sales of any other consumer product available for consumption, and it is usually sold
through separate pre-existing packages. On the other hand contracts for providing data
processing services have been held to be contracts for services rather than contracts for “goods”.

With the help of the above discussion it is clear that despite of being an intangible commodity,
“computer software” can be included in the definition of “goods” for the purposes of the ‘Act’.

Exclusion of ‘Money’ from the definition

Money is specifically excluded from the definition of “goods” under S.2 (7) of the ‘Act’, because
it is the medium of exchange used at the time of sale of goods. Hence, money is not regarded as a
“chattel but as something ‘sui generis’”. However, a coin which was intended to be sold as an
item of curiosity will be said to be a “good”, as it was passed on as a commodity and not as a
currency [Moss v. Hancock, [1899] 2 Q.B. 111].

15
 Conclusion and Findings

Through the course of this project I have tried to identify some of the
major controversies surrounding certain commodities and their inclusion
in the definition of “goods” as per S.2 (7) of the Sale of Goods Act,
1930.

The discussion helped to prove that “electricity” (even being an

intangible good) comes under the ambit of goods, while on the same
hand lottery tickets (being movable goods per se) are excluded because
they are “actionable claims”. This helps us to show that being a movable
property in itself is not a conclusive proof of being a “good”. Also, the
debate on software programs elucidated the importance on
“marketability” aspect of “goods”.

Hence, it evident that due to rapid developments in science and

technology and constant evolvement of the economic structure, the
definition of goods for Indirect Taxes cannot be compartmentalized
into restrictive distinctions and the scope of definition of goods for
Indirect Taxes will expand over time.

References
16
 - TAXMANN’S Central Sales Tax Law and Practice by V. S. Datey, 14th
Edition
- http://www.lawctopus.com/academike/goods-under-the-sale-of-
goods-act-1930/
- https://www.taxmanagementindia.com/web/
View_discussions_detail.asp?ID=4096
- http://www.advocatekhoj.com/library/lawareas/vat/goods.php?
Title=VAT&STitle=Goods%20covered%20under%20VAT
- http://www.vscaglobal.com/images/images/INDIRECT
%20TAXES.pdf

Table of Contents
17
S. No. Topic Page No.
1. INTRODUCTION 1.
2. Statement of Problem 2.
3. Research Objectives 3.
4. Research Questions 4.
5. I. A Brief Study of the various Taxes and 5.
Acts pertaining to Indirect Taxes and
definition of goods under the respective
Acts
6. II. “Goods” under the Sale of Goods Act, 11.
1930

7. 16.
Conclusion and Findings
8. 17.
References

18
 PROJECT REPORT

ON

Defining Goods for Indirect Taxes

Submitted by: Under the Guidance Of:

Anam Ahmad Prof. Raveena Naz

B.A.LLB. (Hons.)

VIIth Semester

ACKNOWLEDGEMENT

19
I am highly indebted to Prof. Raveena Naz for her

invaluable guidance and constant encouragement.I am

obliged to her for giving me the opportunity for venturing

in the topic of my interest for the research.

20