This article has been written by Oishika Banerji of Amity Law School, Kolkata. This article provides a detailed analysis of landmark sedition cases in India.
This article has been published by Abanti Bose.
Table of Contents
The most important thing to remember about sedition law is that this statute was enacted during a period when we were dominated by a foreign imperialist conquering force. The Britishers’ primary goal was to deny the inhabitants of this country their rights, especially the freedom to voice their opinions. Interestingly, whilst sedition was included in Lord Macaulay’s original draft of the Indian Penal Code, 1860 (IPC), it did not make it into the final version when it was passed in 1860. When Section 124A was amended in 1898, it changed the perception surrounding sedition. The first sentence defines the offence of sedition as inciting or attempting to incite emotions of dissatisfaction with the government. Sedition is still a rare crime when compared to other crimes (it accounts for less than 0.01 per cent of all IPC crimes). However, some areas of India are becoming sedition hotspots. With 37 sedition charges each, Assam and Jharkhand account for 32% of all sedition cases between 2014 and 2018. The authorities in Jharkhand have charged several categories of demonstrators with sedition. More than 3,000 people were charged with sedition in January last year, for opposing the Citizenship Amendment Act (CAA) in 2019 and more than 3,300 farmers were prosecuted with sedition in 2019 for protesting about land conflicts. The present article highlights the top 10 sedition cases majorly focusing on 2019-2021, that have attracted the attention of the nation as a whole.
Landmark sedition cases in India
The first lawsuit to address the legitimacy of Section 124A was Ram Nandan vs. State of Uttar Pradesh (1958). Section 124A of the IPC, according to the Allahabad High Court, was ultra vires in character and violated Article 19(1)(a) of the Constitution. The constitutional validity of Section 124-A was further challenged before a Supreme Court Constitution Bench in Kedar Nath Singh v. State of Bihar (1962), with the argument focused primarily on the fact that Section 124-A conflicted with Article 19(1)(a) of the Indian Constitution. The Supreme Court ruled that no crime of sedition is established under Section 124-A unless the remarks, said or written, have the potential to cause disruption or disturbance of public order through the use of violence, thereby overruling the decision of the Allahabad High Court. There is no offence unless the statements are likely to cause violence.
Following this decision, the Supreme Court ruled in 1995 in Balwant Singh And Anr vs State Of Punjab (1995) that merely raising slogans such as “Khalistan Zindabad,” “Raj Karega Khalsa,” and so on did not constitute sedition because there was no evidence or record that any violence occurred despite the slogans being raised in a public place. This legal stance has been reaffirmed several times, including in the cases of Bilal Ahmed Kaloo v. State of Andhra Pradesh (1997) and Common Cause v. Union of India (2018). In all of these cases, the Supreme Court instructed the courts to use caution while using sedition accusations. The courts were instructed to adhere to the principles set down in the Kedar Nath case. It was reiterated that sedition charges cannot be brought just for criticising the government or its policies.
Kishorechandra Wangkhemcha v. Union of India (2021) : sedition and its constitutionality
Senior Advocate Colin Gonalves had petitioned before the Supreme Court of India, arguing that the Apex Court’s judgment in Kedar Nath Singh v. State of Bihar (1962) should be reconsidered. In response, a three-judge bench of the Supreme Court, consisting of Justices UU Lalit, Indira Banerjee, and KM Joseph, issued a notice in a suit seeking to declare Section 124-A of the Indian Penal Code as unconstitutional and invalid. Three more petitions were marked to be considered alongside Kishorechandra Wangkhemkcha’s on July 16, 2021, by a three-judge bench comprising of CJI Ramana, Justice Bopanna, and Justice Roy. Retired Major General S.G. Vombatkere, Aamoda Broadcasting Company Pvt. Ltd., and Editors Guild of India, respectively, have filed challenges against Section 124A. The Editors Guild’s appeal also exposes how Section 124A is increasingly being used to intimidate journalists.
Facts of the case
Two journalists, namely, Kishorechandra Wangkhemcha, hailing from Manipur, and Kanhaiya Lal Shukla of Chattisgarh, have been charged with sedition over their posts and cartoons on social media sites. They have filed a writ petition contesting the constitutionality of Section 124A of the Indian Penal Code, 1860 which criminalises and punishes sedition. For comments and posts on Facebook, Kishorechandra Wangkhemcha had three FIRs filed against him under Section 124A. The remarks and postings chastised the Manipur government for handling a situation at Manipur University, referred to the Chief Minister of Manipur as an “agent of the Prime Minister,” and criticised lawmakers and their family members for making anti-Schedule Tribe sentiments. Kanhaiya Lal Shukla posted cartoons on Facebook that depicted fake encounters by the police.
The points laid down in the petition
- The petitioners argue that Section 124A violates Article 19(1)(a) of the Indian Constitution, which guarantees an individual the right to freedom of speech and expression. Section 124A, they claim, does not impose a reasonable restriction. As a result, it is exempt from the limitations on freedom of speech and expression imposed by Article 19(2).
- The petition further points out that the precedent set in Kedar Nath Singh v. State of Bihar (1962) is no longer valid. Because of the socio-economic circumstances in 1962, appropriate restrictions of the type outlined in Section 124A may have been warranted. Alternative laws involving safety, security, and public order have been established since then, rendering Section 124A obsolete.
- The petitioners further pointed out that the provision’s ambiguity allows for arbitrary implementation and abuse. This is incompatible with the freedoms provided by Article 19(1)(a).
Wangkhemkcha’s claims, in this case, have been supported by three intervention applications. The intervenors are third parties who want to be heard by the Court in the interest of justice but do not want to become parties to the case. They are:
- Mr Sashi Kumar, a distinguished journalist, is the first intervenor, arguing that the ambiguous language of Section 124A has been misapplied to label criticism against the administration as sedition. He claims that the goal of the sedition statute was not to penalise dissent, citing the Constituent Assembly and early Parliamentary Debates.
- The second intervenor, legal professor Dr Sanjay Jain, provided an overview of sedition legislation in different nations to assist the Court in analysing the statute in light of current events. He claims that since Section 124A was created by a colonial authority to suppress anti-colonial activities, it has to be revisited.
- The Foundation for Media Professionals, the third intervenor, raises similar arguments concerning the provision’s pre-constitutional character.
The Supreme Court will decide if Section 124A of the Indian Penal Code, 1860, which criminalises sedition, is unconstitutional, hence the matter is pending before the Apex Court.
Vinod Dua v. Union of India (2021)
Activities that are intended or have the potential to cause disruption or disturbance of public peace by resorting to violence, according to the Supreme Court of India, are to be criminalised. Based on the facts of this case, the Court concluded that the words used by Vinod Dua may best be described as expressions of disapproval of measures taken by the government and its officials for the current crisis to be resolved swiftly and efficiently. They were not created to incite others or demonstrate a proclivity for causing trouble or disturbing public peace through the use of violence.
Facts of the case
Mr Vinod Dua, in his YouTube programme The Vinod Dua Show, allegedly made unsubstantiated and odd charges on March 30, 2020, by saying the following facts at 5 minutes and 9 seconds of the video:
- Narendra Modi has utilised fatalities and terror incidents to obtain votes.
- He says that the government does not have adequate testing facilities and that he has made inaccurate comments concerning the availability of Personal Protective Kits (PPE) and that there is insufficient information on them at 5 minutes and 45 seconds into the video.
- He went on to say that shipments of ventilators and sanitisers were only prohibited on March 24, 2020.
Mr Vinod Dua, according to the F.I.R., generated terror among the population by making such false allegations. The FIR also stated that the programme would merely stir up public dissatisfaction, resulting in panic and individuals disobeying the lockdown to come out and stockpile supplies, which is completely unneeded. The rumours were distributed to induce fear or anxiety in the general public or any portion of the general public, to induce anybody to commit an offence against the state or public calm.
Supreme Court’s observations
The FIR filed against journalist Vinod Dua for his YouTube presentation about communal rioting in Delhi was dropped by a bench of Justices UU Lalit and Vineet Saran of the Supreme Court of India, on 3rd June 2021, who upheld citizens’ freedom to criticise the government in the present case of Vinod Dua v. Union of India (2021). The observations made by the Apex Court have been listed hereunder:
- A citizen has the right to criticise or comment on the actions of the government and its officials as long as he does not incite people to violence against the government established by law or with the intent of causing public disorder. Sections 124A and 505 of the IPC must be invoked only when the words or expressions have a pernicious tendency or intention of causing public disorder or disturbance of law and order.
- The assertions ascribed to Dua that the Prime Minister utilised fatalities and terror attacks to get votes, or that the Prime Minister won votes through acts of terrorism, were not stated during the talk show. There are no such claims in the real translation, and no objections were filed that the translated version was wrong in any manner. The petitioner did claim that India’s airstrikes on Balakot, Pathankot, and Pulwama were exploited as political events to attract votes, but no claims against the Prime Minister were made, as mentioned in the F.I.R.
- Migrant workers in large numbers were migrating back to their hometowns/villages as of March 30, 2020. Given the circumstances, there would be some concern regarding the shelter and food that would be supplied to them along the way. If Dua made certain remarks on his talk show on March 30, 2020, before the matter was taken up by the Supreme Court, he would be within his rights to claim that as a journalist, he was addressing subjects of major importance so that enough attention might be given to the current difficulties. The petitioner cannot be accused of propagating misleading information or rumours.
- The testing facilities to assess and monitor the spread and effect of the pandemic, at least in the early phases of the surge, were not precisely appropriate, given the magnitude of the country’s population. If the petitioner makes any comments concerning testing facilities, PPE Suits, N-95 masks, or ply masks in that light, the comments in the first two sections must be nothing more than an assessment of the circumstances at the time.
Rajat Sharma v. Union of India (2021) : Farooq Abdullah’s Article 370 comment
In an interview last year, Farooq Abdullah had remarked “whatever they are doing at LAC in Ladakh is all because of the abrogation of Article 370, which they never acknowledged,” I am hopeful that Article 370 would be reinstated in J&K with their help”. Abdullah had talked on “restoring Article 370” with “China’s support,” according to Rajat Sharma and Neh Srivastava’s petition. Abdullah previously stated in an interview with The Wire that the Kashmiri people do not feel or want to be Indian, and would rather be dominated by the Chinese. According to the petitioners, this saying amounted to a seditious act and therefore they had claimed punishment under Section 124-A of the India Penal Code, 1860 for Mr Abdullah. The petitioners further claimed that Abdullah was persuading people in Jammu and Kashmir “to join China” based on a comment made by BJP spokesperson Sambit Patra, who had said that “people in Jammu and Kashmir do not feel that they are Indians.”
Apex Court’s observation
The bench of Justices Sanjay Kishan Kaul and Hemant Gupta, of the Supreme Court of India while deciding on the present case of Rajat Sharma v. Union of India (2021) imposed a cost of Rs. 50,000 on petitioners for filing a “publicity interest litigation” seeking the initiation of proceedings against former J&K Chief Minister Farooq Abdullah for his “pro-China” comments regarding the abrogation of Article 370 of the Indian Constitution. The bench went ahead to observe that it is not possible to call, expressing a point of view that differs from a decision made by the Central Government, as seditious. There was nothing in the statement that the Apex Court considers insulting enough to justify a court’s proceedings to be initiated.
Toolkit case : State v. Disha A. Ravi (2021)
The arrest of climate activist Disha Ravi and the issuance of non-bailable warrants for two individuals in the Greta Thunberg toolkit case had sparked outrage across the country. The three activists were accused of working with a pro-Khalistani organisation to develop a toolkit to “defame India throughout the world on the matter of three agrarian legislation.” Many opponents have alleged that the toolkit, which was initially posted by Swedish teenage climate activist Greta Thunberg on February 4, 2021, is proof of the Khalistani conspiracy against India. The same day, Delhi Police filed an FIR against the toolkit’s designers, and Google was asked for the email addresses of people engaged in posting and modifying the document, which was hosted on google docs.
The applicant/accused allegedly started a WhatsApp group called “International Farmers Strike” and invited selected people to join. In addition, she erased the group conversation from her phone in an attempt to eliminate the vital evidence tying her to the toolkit. She also sought to keep her identity hidden so that no legal action could be taken against her, according to the prosecution evidence. She was also accused of using the backing of worldwide youth icon Ms Greta Thunberg to give separatist forces a global platform.
Opinion of the Delhi High Court and the Sessions Court
The issue before the Delhi High Court was whether the applicant/accused Disha was just engaged in peaceful dissent and protest against the agricultural acts, or whether she was truly engaged in seditious activity while demonstrating against the stated legislation?
- In each democratic nation, citizens are the conscience guards of the government. They cannot be imprisoned just because they disagree with the government’s policies. Differences of opinion, disagreement, divergence, dissent, and even disapprobation are recognised as appropriate means for infusing objectivity into governmental programmes.
- While elaborating on a healthy democracy, the Delhi High Court stated that an informed and assertive population, as opposed to an apathetic or meek public, is undeniably a hallmark of a healthy and vigorous democracy.
- During their social interaction, any individual with questionable qualifications may engage with a lot of others. People dealing with such people, whether ignorantly, innocently, or fully aware of their questionable qualifications, cannot be painted with the same colour as long as the engagement/interaction continues within the four corners of the law.
- The Sessions Court went on to say that the applicant/accused had already been interrogated in police custody for over 5 days and that restricting her liberty further based on a broad and sweeping charge would be neither rational nor legitimate. As a result, the Court concluded that the applicant accused deserved to be released on bail, subject to the posting of a personal bond of Rs 1 lakh with two sureties, subject to the following conditions:
- She must continue to cooperate with existing investigations and join them when summoned by the IO,
- She must not leave the country without the authorization of the Court,
- She must meticulously attend at each level of the proceedings before the Court is involved to avoid obstructing or delaying the proceedings.
Patricia Mukhim v. State of Meghalaya (2021)
In 2020, 25 unidentified boys assaulted children playing basketball in Block 4, Lawsohtun, with iron rods and sticks, prompting Patricia Mukhim to write on Facebook the following things:
- “Conrad Sangma, CM Meghalaya, what happened yesterday at Lawsohtun where some Non-Tribal youth playing Basketball were assaulted with lethal weapons and are now in Hospital, is unacceptable in a state with a Government and a functional Police Force.
- The fact that such assailants and troublemakers have never been apprehended and, if apprehended, never punished according to the law, which implies that Meghalaya has long been a failed state.
- We hope this isn’t another instance that gets lost in the shuffle. We want to see something done. There is no sense of community among criminal groups. They must be dealt with in accordance with the law. Why should our non-tribal brethren in their incite state continue to live in constant fear? Those who were born and raised in this state have the same right to name it Meghalaya as the indigenous tribes.”
Following this, the Headman and Secretary of Dorbar Shnong, Lawsohtun, Shillong, filed a complaint alleging that the Appellant’s Facebook comment incited communal hostility and might lead to a communal clash. The Appellant in return had filed a petition in the High Court of Meghalaya for quashing the FIR. The High Court, however, by its judgment dated 10.11.2020 dismissed the said petition.
Apex Court’s observations
The Supreme Court of India’s division bench comprising Justices L. Nageswara Rao and S. Ravindra Bhat has quashed the criminal case filed against Shillong Times Editor Patricia Mukhim under Sections 153 A, 500, and 505(1)(c) of the Indian Penal Code, 1860, stating that citizens’ free speech cannot be stifled by involving them in criminal cases unless such speech has the potential to affect public order. The observations of the Court have been listed hereunder:
- India is a multiethnic and cosmopolitan country. The Preamble’s promise of liberty is embodied in several clauses that spell out each citizen’s rights. When individuals travel, settle down, or carry on a career in an area where they find conditions suitable in the lawful exercise of such right, there may be resentments, especially if such citizens thrive, leading to enmity or potential violence. When victims express their dissatisfaction and speak up, especially when state officials turn a blind eye or drag their feet, such expressions of dissatisfaction are a scream for sorrow, for justice denied or postponed.
- The Court remarked that the appellant’s anguish was aimed towards the Chief Minister of Meghalaya, the Director-General of Police, and the Dorbar Shnong of the area’s indifference in not taking action against the perpetrators who assaulted the non-tribal teenagers after scrutinising the Facebook post. The appellant alluded to the 1979 attacks on non-tribals.
- The claim made by the Dorbar Shnong, Lawsohtun, that the appellant’s remark would provoke community animosity and may lead to a communal clash throughout the State is nothing more than a fabrication of the mind. The appellant’s passionate plea for the protection and equality of non-tribals residing in Meghalaya cannot be classified as hate speech by any stretch of the imagination. It was a demand for justice for law-abiding behaviour that every citizen has the right to expect and express.
Zakir Hussain v. UT of Ladakh (2021) : Galwan valley clashes
On the 18th of June, 2020, the J&K police filed an FIR against Zakir Hussain and his co-accused Nissar Ahman Khan in connection with a viral audio clip containing objectionable conversation demeaning the country’s armed forces, which occurred against the backdrop of clashes between the Indian Army and Chinese armed forces in the Galwan Valley of Ladakh. The chat was considered to be exceedingly offensive, including insulting comments about the Indian Army’s participation in the Chinese armed forces’ Galwan misadventure. The petitioner had argued before the J&K High Court that the police had no power to file an FIR since the law stated that the Court may only take notice of a complaint submitted by a District Magistrate under Section 196 of the Code of Criminal Procedure, 1973 (C.r.P.c), and no such complaint had been lodged in this case.
Observations of the Jammu and Kashmir High Court
Because of the complexities of the situation, the Court established two moot questions that were to be decided in this case:
- What is the actual import and extent of Sections 124-A, 153-A, 153-B, and 505(2) of IPC when seen through the lens of Article 19(1) of the Indian Constitution?
- Can an FIR be filed for the conduct of crimes under Sections 124A, 153A, 153B, 505(2), and 120-B of the Indian Penal Code (IPC) without the previous approval of the competent authorities, as required by Section 196 of the Code of Criminal Procedure, 1973?
The following opinions were made by the Hon’ble High Court in light of the present case:
- To prove an offence under Sections 124A, 153A, 153B, and 505(2) of the IPC, it was essential to show that the words, written or said, as well as signs or visible representations, had the tendency or intention of causing public commotion or disruption of public peace by incitement to offence.
- The provision of Section 196 of the Criminal Procedure Code, 1973 did not, in any way, control Section 154 of the Code of Criminal Procedure, 1973 in that the police were competent to file an FIR if information received by them, which reveals the commission of a cognizable offence, even if the information was not referable to Section 196.
- If there was no prior sanction by the Central Government, State Government, or District Magistrate, as the case may be, Section 196 CrPC would come into effect at the stage of taking cognizance by the Court, and the Court would have to refuse to take cognizance of the offence(s) referable to Section 196 CrPC.
- If a report relating to an offence(s) under Section 196 CrPC was presented to the Judicial Magistrate without first obtaining prior sanction from the competent authority, the Court should not take cognizance of it and should return it, to be presented only after first obtaining prior sanction from the competent authority.
- Only if the Court applied its attention to the final police report presented before it in accordance with Section 173 CrPC to proceed in the way permitted by law, it should not be regarded to have taken cognizance of the same.
- That the Magistrate, if the police report is found to violate Section 196 CrPC, should not keep the report and proceed with the case, but rather return it to the prosecution.
As a result, the petition was granted, and all criminal actions against the petitioner, including the contested FIR, were dismissed.
Rajina Parbin Sultana v. State of Assam (2021)
Ms Rajina Parbin Sultana, the petitioner, has been detained since May 16, 2021, under Sections 120B and 124A of the Indian Penal Code and Section 2 of the Prevention of Insult to National Honour Act, 1971. When a photo of her enjoying lunch at that dining table with several guests went popular on social media, the petitioner was accused of using the Indian National Flag as a table cover on the occasion of the Eid celebration. Several claims of wilfully dishonouring the Indian National Flag were made against the petitioner as a result of the occurrence. Five of the six accused people included in the FIR had already been freed on bail, according to the petitioner before the Gauhati High Court. The State, on the other hand, claimed that the accused-petitioner hosted a lunch on the 14th of May, 2021, in her home, during which the alleged offence occurred. It was argued that there was sufficient proof that the accused petitioner used a table cloth that looked like the Indian National Flag when welcoming visitors to her home for the Eid celebration.
Observations made by the Gauhati High Court
- The Court accepted the defence position and advised the petitioner to proceed with caution and care in the future. The Bench stated that the question of whether the accused-petitioner committed the offence under Section 2 of the Prevention of Insult to National Honour Act, 1971 in any public place or another place within public view by her action must be determined based on the materials gathered during the investigation and their admissibility during the trial. As a result, it did not appear to be an act with the intent of overthrowing the government by inciting scorn, hate, or disaffection against it.
- Given the accused petitioner’s detention since May 16, 2021, and the progress made in the investigation, the Court determined that further custodial detention of the accused-petitioner was not necessary for investigating the case and that her release on bail at this stage of the investigation would not be likely to cause any prejudicial effect in the subsequent investigation, provided she continues to extend her assistance and co-operation. As a result, the petitioner was ordered to be freed on bail after posting a Rs 20,000 bail bond.
Sikha Sarma v. State of Assam (2021)
An F.I.R. had been filed against the petitioner, alleging that her Facebook post from April 5, 2021, disrespected the nation’s martyrs. It was also said that the accused petitioner denigrated and disrespected the victims’ sacrifice by advising the ‘media’ not to engender public feelings in their favour and not to refer to them as ‘Swahids’ since they were paid for the services they provided to the country in her opinion. It was also said that the defamatory tweet sparked a public outcry on social media since the country was grieving the murder of 22 Jawans slain during an anti-naxal operation in Chattisgarh on March 3, 2021, which included two jawans from Assam.
The state believed that the accused not only disrespected the nation’s martyrs but also attempted to incite anti-social elements by claiming that the assassination of our soldier was not a crime. The accused attempted to incite hate against the government while doing its legal duties through the stated post. Furthermore, her comments stoked discontent with India’s leadership and had the potential to fuel terrorist and anti-national elements.
Mr A.M. Borah, the petitioner’s lawyer, maintained that the accused did nothing wrong when she posted the words on her Facebook account. She made no anti-national statements, nor did she make any statements that incited or sought to incite hostility, animosity, contempt, or disaffection toward the government. The petitioner claimed that the term “Swahid/martyr” is not defined in any law or by any government announcements and that the accused petitioner did not break the law by expressing her right to free expression in good faith.
The views of the Gauhati High Court
- The accused petitioner allegedly expressed her personal views on the use of the term ‘Swahid/martyr’ on a social networking platform in respect of 22 brave hearts/patriot soldiers, including two such soldiers from the state of Assam, who died in action or were killed on duty, eliciting widespread criticism. In this regard, the High Court, having considered the merits and drawbacks of the allegations and evidence gathered thus far by the investigating officer in the case, as well as the threat to the prisoners’ health posed by the second wave of novel COVID-19 pandemic, is of the considered opinion that further detention of the accused petitioner, who is a woman, may not be necessary for the interests of the ongoing investigation.
- The Court granted the petitioner’s bail plea and ordered the petitioner to be released on a bail of Rs.30,000 with one guarantee of the same amount.
Patit Paban Halder v. State of West Bengal (2019)
In this case, the police had obtained information about a conference being held in a village where seditious lectures were being delivered. A couple of members of the 30-40-person gathering had guns with them. When the police arrived on the scene, the individuals began running, and the accused-appellants were apprehended. They were found to own several seditious flyers and leaflets. A complaint was made against them, and charges were drafted against them under Sections 121 A, 122, and 124 A of the Indian Penal Code, 1860, Sections 25(a) and 35 of the Arms Act, 1959, and Sections 4 and 5 of the Explosive Substances Act, 1908.
Calcutta High Court’s observations
- The Court found that the prosecution had failed miserably to prove the accusations levelled against the appellants and that there was no evidence on the record linking the accused-appellant to the claimed offences. The prosecution case was found to be riddled with inconsistencies, and the appellants were given the benefit of the doubt.
- The Court also said that it is a common law that the prosecution had sole responsibility for proving a charge against an accused and that the prosecution was expected to present evidence that was coherent, compact, credible, and trustworthy enough to be incompatible with the accused’s innocence.
- The Court noted that the trial judge had failed to see the evidence in its appropriate context and had overlooked the crucial fact that there was no relationship between the appellants and the damning evidence offered by the prosecution. As a result, the appeal was granted, and the contested verdict was reversed.
The enactment of Section 124A of the Indian Penal Code, 1860 seeks to suppress and eliminate all last forms of resistance in society. Such a propensity runs counter to the intrinsic characteristics of democracy. The presence of such a provision in a progressive state like India appears to be redundant. The severity of the penalty makes the provision harsh. The continuation of such a clause chills freedom of speech and expression, which is supposedly a fundamental right guaranteed by Article 19(1)(a) of the Indian Constitution. There is a need for India to evolve and change its sedition laws to keep up with the changing needs of society.
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