Tuesday, August 26

My witness is the empty sky

The State Human Rights Commission
Madhya Pradesh


Ref: The reply of Director, Culture Shri Pawan Shrivastava, dated 22.04.08 forwarded to Commission vide letter of Secretary, Culture, dated 28.06.08 served on us on 14.07.08 by the Commission.

Respected Sir,

In response to our complaint Director, Culture has filed his reply before Commission and the same has been reiterated by the Secretary, Culture. The perusal of the reply reveals that deliberate incorrect statements have been made and therefore, it has necessitated the complainant to file this explanation / counter to bring correct facts on record for kind consideration by this Hon’ble Commission, as under:-
1) That the facts stated in para 1 are deliberately distorted to dispute the locus of complainant. It is most humbly submitted that the contract was awarded by the Directorate to firm M/s PA Systems and Shri Prashant Agnihotri, an electrical contractor, is the proprietor of the said firm. Ms Shehla Masood has been authorized by way of duly executed power of attorney to transact on behalf of and work for the said firm and since inception she has been representing the firm by virtue of authority given to her and recognized by the Directorate till date. Authorities at no point of time raised any objection regarding the validity of authority given to Ms. Shehla Masood and therefore, the objection raised in para 1 is of no consequence and deserves to be rejected.
2) In response to para 2 it is most humbly submitted that before the year 2006 no system of public tender was adopted and followed in the Directorate and the work was awarded on the basis of arbitrary pick and chose without there being any eligibility or selection. The complainant for the first time noticed this high handed pattern of working and persuaded the authorities to invite tenders through public notice and select contractors for fixed duration as per the eligibility fixed and notified. Large number of letters were sent to all concerned higher authorities for this legitimate request and ultimately it is because of complainant’s persuasion the system of public tender was adopted in the year 2006. In the year 2006 our firm stood lowest and therefore, was selected for one year. As per the terms and conditions the Directorate was bound in law to give work to us in all the functions / programmes organized by it or organized under its supervision or management through out the state. The commitment was faithfully honored till Shri Pawan Shrivastava the present Director, joined but soon after his joining the scenario changed and the terms of the contract were flagrantly violated and large number of programmes were diverted to contractors / parties of his choice ignoring the obligation of Directorate to award work to the selected contractor i.e. M/s PA System. A list of programmes / functions diverted to unauthorized contractors after joining of Mr. Shrivastava is being enclosed as in Attachment -7 for kind perusal by Hon’ble Commission and the same would show that deliberately complainant was victimized by diverting the work to unauthorized contractors without there being any legal or justified reason for the same.
3) No tenders were called In spite of written request from us to the Director/ Secretary/PS/ Minister. It is complainant who has been requesting for the tenders because for last 40 years transparent process of public tender was being followed by the Department of Culture and its Academies. The representations made by complainant in this regard are being enclosed as Attachment -2.
4) In reply to para 4, it is incorrect to say that the payments were done on time. After Mr. Pawan Shrivastava joined, our payments are still pending without any reason but due to his deliberate victimizing attitude towards us, as complainant is not ready to succumb to unjust and illegal practice of commission to the extent of 30% of our bill amount. Deliberately for no reason Shri Shrivastava has been creating hurdles in the work, mentally harassing, calling up on mobile and asking / coercing complainant to withdraw her applications pending under the RTI Act for related information blackmailing complainant saying that “Agar RTI ke letter wapas nahi loge to bhaiaya dekhlo age kaam kaise karoogee”. Shri Shrivastava also says “Ye sab kaam ladkiyon ke bas ke nahin hai .. aaap kahen aur kaaam kare. Ye sab kaam choro.” Shri Shrivastrava blacklisted complainant without any justified or legal reason and without giving any opportunity of explanation in complete violation of principles of natural justice. These were some of the tactics he applied for not letting complainant work and also for not releasing the due payment of the work completed. It is complainant’s constitutional right to work and get the payments for the work done as per the terms of bill raised or at least within the reasonable time. There are still bills pending of the year 2006/2007 and some of the instances are being quoted as under:-
i) Bill no 307 of Rajya Mahotsav 2006 dated 24/11/06 of amount Rs 12, 50,583 were given. Rs 4, 97,370 were released. Due payment of Rs 7, 53,213 is due.
ii) Bill no 320 Khajuraho investors meet dated 26/2/2007 is still pending. The amount of the bill was Rs 1, 44,160. Received payment is Rs 30,000/- Due is Rs 1, 14,705.
iii) Bill No. 311 Tansen Samaroh dated 27.11.06 pertaining to Ustad Allauddin Khan Sangeet Evam Kala Academy is still pending and amount of Rs. 359351/- is still due and outstanding. Kindly refer Attachment - 4-(3). These payments were not released as the department said it will be done after some time/ in the coming financial year. The work orders can be checked from the department. The items used at the time of the function are also duly signed by the officer incharge. The bills have the sign and seal of the authority that were approved at the site and accordingly the bills were produced. Attachments. Till date our pending amount of Rs 7, 53,213 and Rs 1, 44,160 is due of the year 2006/2007 work. Mr. Pande the lekha adhikari was the incharge of the rajya mahotsav and Khajuraho investors meet in 2006.
Complainant met Mr. Shrivastava on this issue to remind for payments and briefed him about the last year delay and even asked to check the official record to confirm. Shri Shrivastava directed his junior officers. Mr. Chaturvedi and Mr Jha to put up the files before him and having received file, complainant was called on mobile by Mr. Shrivastava for the payment issue. On meeting Mr. Pawan Shrivastava said “Purana mamla hai … mehnat karni padegee tumhe. Dekh lo agar teyaar ho to? On being asked the intention he told”tum samajdar ho dekh lo” On the second meeting on this same issue he said ”Is saaal ka naya Blue colour Mont Blanc Pen dekha hai tumne? Us se sign karunga…. System to follow karo Shehla kaam ho jaega pareshaan mat ho.”

More than 16 months have passed but our payments are still stuck up ever since he has joined. Reason complainant refused to be party to his corrupt practices and secondly did not succumb to his pressures and tactics.
My payments after he joined are also not cleared till date.
My part payments after he joined in Feb. 2007 are still pending.
- Bhojpur mahotsav bill no 319 of amount Rs 1,50,705 dated 26/2/3007
- Betwa mahotsav bill no 419 of Rs 2,65,272 dated 12/6/2007 is still not cleared
- The works were given from the cultural secretariat as we were the official L 1 Tender party for the year.
The complainant has been facing problems because huge amount has been blocked. It is distressing us, work and business. Complainant is unable to cope with the present situation of business because of continuous illegal demands made and victimization done by Shri Pawan Shrivastava. Shri Pawan Shrivastava wants to exploit from our situation and has been harassing us and violating our fundamental rights
Reference Attachment 4(1) Reminders of the same were sent from31/1/2007 till 1/4/2008- to Shri Pawan Shrivastava/Secretary./PS Cultural
Attachment 4 (2) letter to Director/ Shri Pawan Shrivastava ustad alluding khan sangeet evam kala academy for the Tansen Samaroh.
Attachment 4 (3): Bills of all the 5 events along with the signature of the officer incharge at the time of the function to confirm that the items were used.

5. The allegations contained in Paras 5 to 9 of reply are incorrect and denied. It is incorrect that after assumption of charge by Shri Shrivastava, complainant repeatedly met him and applied pressure that the different academies working under the Directorate are not getting the work done through M/s P.A. Systems, a firm approved by the Directorate. The correct factual situation is complainant was called in the C.M. House to discuss the arrangements regarding Kavi Goshthi scheduled to be organized in C.M. House. Shri Shrivastava was also present being the Director but having no experience of event management remained silent spectator and could not contribute in the discussion. Thereafter Shri Shrivastava himself used to call complainant to seek opinion and advises in regard to management of culture programmes / events. Thus the allegation of frequent meeting by complainant is absolutely false. It is very strange that a senior officer like Director Culture has made false accusation of application of pressure by complainant. It is beyond common prudence how come requesting for rightful claim could be termed to be applying pressure that to by a person who is responsible to redress the complaint/grievance. It is relevant to mention that complainant has been making complaint regarding diversion of work to unauthorized agencies by academies of Cultural Directorate and in past also various complaints / letters were given to previous Director Shri Pankaj Rag and these letters are annexed as Attachment - 5. It is also relevant to mention that in Para no. 8 & 9 of reply itself Shri Shrivastav has stated that he gave corrective orders and started giving work to the approved firm. This clearly shows that complaints were correct and raising lawful grievance, by no stretch of logic or argument can be termed to be applying pressure. In the concerned year as many as 73 programmes were organized directly by Directorate or its associated academies etc. and out of these 73 the approved firm was hardly given few programmes in complete violation of terms of tender. The complainant is annexing the list of programmes organized in the year by the Directorate and its academies as Attachment - 6.1,2,3 Despite complaint most of the important programmes/works were assigned to unauthorized private parties by Shri Shrivastava and some of the examples are as under :-
i) Anushruti in Dhar organized on 30th April
ii) Kavi Sammelan in Burhanpur on 4th May
iii) Anushruti in Katni on 30th May
iv) Anushruti in Morena on 30th June
v) Kishore Kumar’s programme in Khandwa on 4th & 5th August
vi) Anushruti in Bharat Bhawan Bhopal on 21st August
vii) Sharma Bandhu’s programmes in CM House Bhopal on 4th Sept.
From the aforesaid, it would be clear to this Hon’ble Commission that deliberately major programmes were given to unauthorized and unapproved agencies by the Director or at least by his consent causing huge and irreparable loss and damage to our firm because having entered into contract with the Directorate the firm kept all its resources reserved for the functions of Directorate and its Secretaries and did not entertain any major assignment. Barring Sahitya Academy no academy of the Directorate gave any work to the firm and despite complaint no concrete action was taken by Shri Shrivastava and his act of overlooking virtually promoted and encourage assignment of work to unapproved agencies. It is incorrect that all the payments were used to be made through cheque after assumption of Office by Shri Shrivastava. The complainant gave information to the Director with specific names regarding illegal and unjust demands but no action was taken and as a result the exploitation and victimization continued. Thus from the aforesaid, it would be apparent to this Hon’ble Commission that Shri Shrivastava deliberately violated and flouted the contract of complainant firm and diverted major assignment to unapproved agencies and also failed to take any appropriate action against erring officials despite specific complaints and thereby was instrumental in patronizing the erring officials working illegally and in clear violation of terms of contract. The Directorate being part of State Govt. is bound in law to honour its contractual commitments in letter and spirit but in case of complainant the Directorate has deliberately violated the contract time and again though the complaint firm was always ready, willing, prepared and capable of doing the work. Kindly obtain a list of programmes organized in a year and work given to complainant out of those programmes before blacklisting.
6. That the adverse allegations contained in para no. 10 of reply are incorrect and denied. The correct factual situation is that on 16th August a very small Mushaira was organized in the Governor House. It was a personal programme of Hon’ble Governor which was attended by only 12 persons including Hon’ble Governor. The staff of Governor house and culture department was also present. The firm was given the work of audio arrangement and appropriate arrangement was accordingly made. The arrangement made was checked before the commencement of the programme in the presence of Director Shri Shrivastava and the trial check was successful. Just before the end of programme a very minor technical snag developed in one of the mike. Immediately Shri Shrivastava present the programme was asked if need is felt mike / system can be changed just in two minutes. Since the snag was very minor and programme was just about to be completed Shri Shrivastava did not prefer to allow change of one of the mike. To avoid any interruption the mike was immediately disconnected and programme continued with the other available mikes working properly. The programme went on peacefully without any complaint from any of the guest or from the Hon’ble Governor or Staff of Governor house. It is relevant to mention that the very next day another programme was organized in the Governor house and complainant firm was given the arrangement by the Staff of the Governor House considering good past performance. The Governor house in the same month issued letter of extension for sound work for the next period. The copy of Letter issued by Governor House for sound arrangement for programme of 22.9.2007 is annexed as Attachment- 7 (1 -2.) The firm also did another function in the Governor house on 30th Sept.2007 and the letter of appreciation issued for the same is annexed as Attachment - 8. Thus from the aforesaid it would be apparent to this Hon’ble Court that the allegations made regarding poor arrangement of programme held on 16.8.2007 are incorrect, baseless and have been cooked up to justify and support the illegal and arbitrary action of the Directorate. It is incorrect that the audio system was defective from the inception and the amplification was bad. It is further incorrect that to defect the voice of Hon’ble Governor got distorted when he was delivering the speech. It is incorrect that Director present in the programme repeatedly asked to rectify the defect so that programme could be completed gracefully. It is further incorrect that the Director asked firm to replace the defect parts/components but the firm showing unnecessary adamancy did not change the parts of the equipment and as a result the whole programme was spoiled. As submitted above before the start of function itself trial check was done as a routine in the presence of Director Shri Shrivastava and there was no defect and after his complete satisfaction only he cleared the arrangement. It is important to mention that even till date complainant firm is getting work of supply of sound system to the Governor House. And the record of the firm has been extremely good, spotless and unblemished although and all the departments have appreciated the work time and again.
7) That in reply to para no. 11 & 12 of reply submitted by Shri Shrivastav it is most humbly submitted that the adverse allegations made are incorrect. It is incorrect that Ms. Shehla Masood had admitted the failure of arrangement in the complaint made. It is further incorrect that M/s P.A. Systems was asked to submit explanation and the same was not submitted and therefore the firm has been blacklisted. Before passing the order of blacklisting no opportunity of hearing or explanation proposing blacklisting was given and the blacklisting has been order in complete violation of principles of Natural Justice with a view to victimize the complainant. The action taken is wholly illegal, unjust and improper. The blacklisting has been done to settle the personal grudge and score of Shri Shrivastava and the same amount to high handed exercise of powers because complainant Shehla Masood became eye sore because she being lady is doing the business with competitive efficiency and resisting all throughout to succumb to illegal demands and pressures. Due to aforesaid via media of blacklist has been resorting to get rid off complainant. Only after receiving the letter of blacklisting, the complainant received information of the action and reasons for the same. Immediately reply was sent to place the correct facts on record though the complainant was aware that the same will not be given any attention or consideration. Deliberately vague assertions have been made to hide and suppressed that no prior notice was given to the complainant before taking extreme penal action. If Directorate had issued / given any notice before blacklisting the same and proof its service ought to have been placed before this Hon’ble Commission and non filing / production of these relevant documents leads to only one conclusion that the allegations are incorrect, baseless and false. Against the illegal action complaints were made to the Hon’ble Minister and Higher Authorities annexed as Attachment - 9. The concerned minister having noticed genuineness of the complaint Shri Shrivastava was called and directions were given to rectify the mistake. Complainant sent letter dt. 16.11.2007, annexed as Attachment - 10. for recall of illegal order and for release of illegally withheld payment. Shri Shrivastava bent upon to harass and victimize us did not pay any heed to the advises given and continued with his illegal pursuit. The vested motive of Shri Shrivastava is too apparent as he has been giving work to M/s Bijlee Bhawan a firm who has been working for the Department for last 40 years, without any tender.
The fresh tenders were deliberately delayed for six months and in the meanwhile the work was allotted by arbitrary pick and choose to firms/agencies as per the choice of the Director. The work of Madhya Pradesh Utsav held in December 2007 was given without selection or tender and during entire Utsav the arrangement was extremely poor and defective. M/s Bijlee Bhawan not only failed to provide proper sound system but at the same time acting illegally ofloaded the work to M/s Durgesh Sounds of Indore.ignoring the conditions NO 15 of the tender. photographs in proof whereof are being attached as Condition 15 of the tender clearly stated that no work will be subleted. The norms were flouted openly. Tender form conditions are in the Attachment - 11. The above described national programmes were completely spoiled by the extremely poor sound system deployed and the same was duly highlighted in the press and electronic media. Some of the news reports are being attached as Attachment - 12. Shri Shrivastav’s obstinacy and personal interest prevailed over the honor of the State and no action has been taken against the concerned agency / contractor. The complainant sent written complaints to the Higher Authorities for illegal, arbitrary and malafide actions taken by Shri Shrivastava but the same remain unattended. It is important to note that Shri Shrivastava is a Public Servant and is bound to act as per the procedure prescribed in law and in the interest of State. Shri Shrivastava cannot be allowed or permitted to work for his personal likes and dislikes that too spoiling the image, esteem, prestige and reputation of State at the National level. The motivated, legal, arbitrary and discriminatory actions taken by Shri Shrivastava clearly shows that he has no commitment for the interest of State and his individual interest are paramount to him and which raises serious doubt about his integrity towards his duties and official obligation.
8) That in reply to para no. 13 it is most humbly submitted that the tender for the year 2008 was public after inordinate delay of more than 6 months and the same was published in Dainik Bhaskar of 21.12.2007 and tender forms were not supplied till 26.12.2007. As a result a complaint was to be made Director cc to Minister and Secretary annexed as Attachment - 13. Similar complaint was made to Hon’ble Chief Secretary, Principal Secretary (Home) and Secretary of Culture for not taking appropriate action and the same is annexed as Attachment -14. because complainant was being denied lawful right of participation in the tender. With great difficulty complaint could get the tender document and on examination noticed that there are various deliberate material mistakes and accordingly the same was pointed out / informed to the Director. The action taken by complainant further aggrieved the Director and he cross all limits of decency and official decorum phoned to undersigned on 4.12.2008 at 2.43 hours on mobile and gave clear threats to withdraw the applications submitted in the Department under the R.T.I. Act. The complainant was warned to withdraw application before submitting the tender. Immediately the matter was reported to the D.G.P. as the FIR of the complainant was not being lodged. The relevant documents are being as annexed as Attachment –(15) 1and2 .
Shri Shrivastava continued with his legal acts of giving threats and warning over phone and these telephonic conversations have been recorded and can be placed as and when directed. In the aforesaid hostile background the tenders were opened and two firms namely Nanu Video and Vision Force were disqualified in the presence of committee members and the bidders as they could not fulfill the conditions. Complaints tender was cleared in technical bid and financial bid was also opened on 31.12.2007 in the Cultural Secretariat at 9’0 clock and the complainant was declared lowest. Acting illegally and arbitrarily the tender of disqualified firm M/s Nanu Video was accepted and the complainant received the said information after about 20 days. It is relevant to mention that Condition No. 13, 16, 27, 38 to 41 and 44 were not fulfilled and complied with by M/s Nanu Video and therefore it was declared disqualified at 8.00 PM on 31.12.2007 in the presence of all the bidders and committee members. Written complaints for disqualification of firms with unfulfilled conditions were accepted by the committee. Bids of disqualified firms were not unwrapped from the envelopes. It was informed to the Secretary Cultural as well. The relevant documents are being as annexed as Attachment –(16) 16-1,2,3,4,5 .Awarding contract to a disqualified bidder is purely illegal and amounts to fraud on powers. The complaints regarding illegalities committed during the process of tender were made to the Hon’ble Minister and Secretary but except bald enquiry nothing yielded. The Director and his subordinates acting with purpose have manipulated the process of tendering and whereby denied contract to the lowest bidder i.e. complainant. The entire tender proceedings, objections filed, declarations etc may be summoned to cross check and verify the correct facts. In fact complainant being most eligible was legally entitled for award of contract but the same has been denied by illegal and arbitrary manipulation amounting to fraud and forgery.
9) That the contents of para no. 14 of the reply are misconceived. The Director has failed to see and appreciate that the complaint is of non payment of balance amount Rajya Mahotsav 2006. The bill no. 307 dt. 24.11.2006 was for Rs. 12,50,583/- and only meager sum of Rs. 4,97,370/- was released and an amount of Rs. 7,53,213/- was illegally and unjustifiably withheld and the same is still due and outstanding. All the bills submitted were duly supported by the letters of officer incharge issued after due and proper check of items used in the function. The bills are completely in order and there is no discrepancy in the items, rates or amount claimed. The unjust withholding of substantial amount of bills clearly shows personal prejudice of the Director and the same was with the sole purpose to harm and harass the complainant. The ill-will of Shri Shrivastava is apparent from the reply itself because despite having complete record with him, he could afford to feigned ignorance about admitted non payment of huge amount of Rs. 7,53,213/- by filing evasive reply. The entire record could be summoned to ascertain the correct factual situation to confirm the authenticity of the reply to the Hon’ble commission.
10) That the contents of para 15 to 18 of the reply are incorrect and denied. Deliberately incorrect and evasive averments have been made to misrepresent before Hon’ble Commission. The correct factual situation is that no work order was directly given to the complainant by any of the Collectorate. All the work orders were given by the Department / Directorate of Culture and therefore, the concerned department / Directorate is responsible for the payment and cannot shift the liability taking recourse to their internal arrangement. Signatures of the officer incharge of the function form the secretariat has duly signed the papers after installing of sound in every programme. The bills are raised to the department and accordingly the payments are released by the Department only. Shri Shrivastava having complete knowledge of the system of functioning has made deliberate incorrect statement to avoid the liability and misguide this Hon’ble Commission. It is incorrect to suggest that the bills of Betwa Utsav and Bhojpujr Utsav were wrongly presented to the Directorate.It is further incorrect that the Director in order to help complainant firm sent immediate letters to the concerned collectors. In the reply deliberate details of correspondence has not been mentioned. Bill No. 319 of Bhojpur Mahotsav of Rs. 1,50,705/- was sent to Director on 26.02.07 and Bill No. 419 of Betwa Mahotsav for Rs. 2 65 272/- was sent to Director on 12.06.07 and despite lapse of more than 17 months the payment has not been made despite repeated reminders and complaints to the higher authorities. The Director has categorically told complainant that the payment will only be made provided complaints made are withdrawn. The Director has repeatedly phoned complainant on her mobile to warn and give threats. In November 2007 the Director has specifically warned that if the compliant made in RTI is not taken back, we cannot work. The conversation has been duly recorded and can be produced as and when directed. Various complaints were made narrating the aforesaid facts and same as annexed as Attachment – same as 4,5,9,13,14,15. The complainant was given work as the approved contractor of Directorate by the Directorate and therefore the release of payment is also the responsibility of the Directorate and the same cannot be avoided or passed on to an agency with which the complainant has no privacy of contract. The complainant has been pursuing for payment for last 18 months and the letters / complaints sent in that regard are attached as Attachment -4.
11) That the contents of para 19 are incorrect and denied. It is incorrect that before black listing all the works were given to the complainant. The complainant has already clarified the correct factual situation in the preceding paras and crave leave to refer the same. It is relevant to mention that the function organized in the CM house was done by the M/s Bijli Bhawan before black listing of complainant. Similarly various programmes in various districts were given to different venders ignoring the approved contractor.
12) That the contents of para 20 are incorret and denied. Following bills are lying due and outstanding-
i. “Bill no 307 dated 24/11/06 of amount Rs 12, 50,583 was given. Rs 4,97,370 were released and a sum of Rs. 7, 53,213 is still due and outstanding.
ii. Bill no 320 dated 26/2/2007 is still pending. The amount of the bill was Rs 1, 44,160. Received payment is Rs 30,000/- Due is Rs 1, 14,705.
iii. Payment of the Ustad Alluding Khan Sangeet Evam Kala Academy for the Tansen Samaroh Bill No 311 Dated 27/11/2006 is pending for the balance amount of Rs 3,68,000 as we received an amount of Rs 70,000 from the Academy.
iv. Bhojpur Mahotsav bill no 319 of amount Rs 1,50,705 dated 26/2/3007 is still due and outstanding
v. Betwa Mahotsav bill no 419 of Rs 2,65,272 dated 12/6/2007 is still due and outstanding.

From the aforesaid, it would be clear that wrong and incorrect statement had been made that no payment is due and outstanding. The Directorate be directed to place the complete record of payment of bills. All the bills were submitted after due and proper verification as per the rates approved and there was no deficiency or short fall despite no short or deficiency payments are not being made only because of personal bias and grudge of the Director as he has been clearly telling and warning that “jab tak complaints waps nahin loge payment nahin milega”. The complainant is suffering continuous extreme loss and difficulty due to deliberate non payment of due bills. The calculated delay has been done so that the complainant could be pressurized to succumb to illegal wants of Director or other functionaries like Shri Pandey lekha adhikari and Mr Jha asst Secretary. From the aforesaid it would be apparent that how systematic victimization is being done to punish and to teach a lesson to the complainant for raising her voice against injustice and illegalities and for not succumbing to the ulterior intentions of concerned functionaries. It is relevant to mention that in past too Shri Shrivastava has exhibited the same arbitrary, victimizing attitude and conduct in performance of his duties and with his subordinates and which could be duly got verified by the Hon’ble Commission.
From the aforesaid, it would be apparent to this Hon’ble Commission that the reply filed is incorrect and full of misrepresentation and therefore, the same deserves to be rejected and appropriate orders be issued for immediate redressal of grievance of the complainant and for severely punishing the guilty so that in future, the high placed officers may not abuse their office and authority for their personal whims, likes and dislikes and gains, and to deny the legitimates claims and rights of eligible claimants.

Yours faithfully,

Anticipating Justice

Shehla Masood

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