Abstract

The rise of ride-hailing platforms such as Uber and Ola has created a significant challenge for Indian labor law. These platforms classify drivers as independent contractors, while exercising substantial control through algorithms, ratings, pricing, and account deactivation. This article critically examines the judicial and statutory developments concerning the classification of Uber and Ola drivers in India. It analyses traditional Indian tests of control and supervision, with particular focus on the 2024 Karnataka High Court ruling that treated Ola drivers as employees under the POSH Act. The article further evaluates the Code on Social Security, 2020 (enforced in 2025) and the 2026 Rules, which formally recognize “gig” and “platform” workers but deliberately keep them outside the traditional employer–employee relationship. By highlighting the tension between judicial findings of control and the limited statutory protection offered to platform workers, the study argues that the current framework provides recognition without adequate rights. It concludes with recommendations for greater legal coherence, including the possible introduction of an intermediate worker category, stronger regulation of algorithmic management, and effective grievance mechanisms against arbitrary deactivation.

Introduction of Uber and Ola

The Indian transportation landscape witnessed a seismic shift with the arrival of ride hailing platforms like Uber and Ola. Gone were the days of the hailing down auto-rickshaws on dusty streets or bargaining with taxi drivers. The Indian labor force, one of the largest in the world, is on the verge of witnessing a major overhaul in the laws that govern its relations with employers. The four labour codes, i.e., Code on Wages 2019 (hereafter referred to as ‘Wage Code’), Code on Social Security 2020 (hereafter referred to as ‘Social Security Code’), Occupational Safety, Health and Working Conditions Code 2020 (hereafter referred to as ‘Occupational Safety Code’) and Industrial Relations Code 2020 (hereafter referred to as ‘Industrial Relations Code’) All four await implementation as some states are yet to come up with relevant rules. These Codes amalgamate 29 of the 44 existing central labour law legislations and introduce some novel and important concepts in Indian labour law.

At present, the gig economy in India comprises about 8 million jobs, with the potential of generating 90 million jobs. It is estimated that over 4 million of these are held by drivers registered with just two cab aggregators, Ola and Uber, both of which have at least 2 million drivers each registered on their platforms.

Global Beginnings

Uber

Established in 2009 in San Francisco, Uber revolutionized on-demand ride-hailing with its app-based platform, connecting passengers with drivers through smartphones. Initially offering black car services, it expanded to various options including budget-friendly rides.It rapidly became a global phenomenon, facing legal challenges and regulatory roadblocks but pushing the boundaries of traditional taxi industries.!?]

Ola

Founded in 2010 in Bengaluru, India, Ola started as a platform for booking local taxis, aiming to bridge the gap between unorganized taxi stands and reliable, convenient cab services. Initially focused on premium cabs, it soon adapted to budget-friendly segments and app-based booking, directly competing with Uber’s entry in 2011.

Laws Applicable to Uber Drivers in India

At present, Uber is regulated under the laws applicable to cab aggregators. Regulations for this category have evolved as a consequence of a few offences committed by cab drivers and involving passengers. Thus, the focus of these provisions has been on ensuring the safety of passengers rather than promoting workers’ right. The Social Security Code envisages the constitution of six types of social security organisations: Board of Trustees of Employees Provident Fund (Central Board), Employees State Insurance Corporation (ESIC), National Social Security Board for Unorganized Workers (NSSBU), National Social Security Board for Gig and Platform Workers (NSSBGP), State Unorganised Workers’ Board and State Building Workers’ Welfare Boards. Of these, gig/platform workers are covered only by the ESIC and NSSBGP.

Significance of the Case Study / Literature Review

The case study of Uber and Ola in the Indian ride-hailing market holds significance for various stakeholders, including:

Businesses

• Understanding the dynamies of disruptive innovation: This research offers insights into how disruptive technologies like ride-hailing apps can reshape existing industries. Businesses can learn from the strategies and challenges faced by Uber and Ola to adapt and innovate in their own sectors.
• Market entry and competitive analysis: This research provides valuable insights into entering and competing in a rapidly evolving market with a strong local competitor. Businesses can learn from the successes and failures of Uber and Ola to develop effective market entry strategies and navigate competition.
• Balancing growth and profitability: This research explores the challenges of balancing aggressive growth strategies with achieving long-term profitability. Businesses can learn how to optimize pricing models, manage expenses, and invest in sustainable growth practices.
• Adapting to local regulations: This article highlights the importance of understanding and adapting to local regulations when entering new markets. Businesses can learn how to navigate complex regulatory frameworks and build positive relationships with local stakeholders.

Policymakers

• Creating a conducive environment for innovation: This research can inform policymakers on how to create a regulatory framework that fosters innovation in the transportation sector while ensuring consumer safety and fair competition.
• Balancing economic benefits with social concerns: This data highlights the need to address social concerns like driver welfare and environmental impact alongside promoting economic growth and convenience. Policymakers can learn how to design regulations that address these concerns effectively.

Consumers

• Understanding the ride-hailing market: This document provides consumers with insights into the factors that influence ride-hailing fares, service quality, and safety features.
• This can help them make informed choices when choosing a ride-hailing
• Holding companies accountable: This information provides highlights of the importance of holding ride-hailing companies accountable for their practices regarding driver treatment, data privacy, and fair pricing. This can empower consumers to advocate for the better services and transparency.

Research Methodology

This study aims to comprehensively analyze the strategies, challenges, and impact of Uber and Ola in the Indian ride-hailing market. This section will outline the chosen research methodology to ensure a thorough and objective investigation.

Research Design

This research employs a multi-methodological approach combining qualitative for a rich and nuanced understanding.

Qualitative Methods

Secondary Data Analysis: Extensive review of academic journals, industry reports, news articles, company websites, and government documents to assess industry trends, market data, and regulatory frameworks.

Limitations

• Limited access to confidential company data may restrict a deeper understanding of internal operations.
• Perceptions and experiences of individual participants may not represent the entire population.

Analytical Framework and Methods of Analysis

Doctrinal / Textual Analysis

Close reading of statutory definitions (“employee”, “gig worker”, “platform worker”, “employer”) and contractual clauses.

Case-Law Analysis

Application of the traditional Indian multi-factorial tests (control and supervision, integration, economic reality / organisation test) as developed in landmark Supreme Court decisions (Dharangadhara Chemical Works, Silver Jubilee Tailoring House, Hussainbhai, Balwant Rai Saluja, etc.). The Karnataka High Court’s reasoning is dissected to identify how these tests have been adapted (or stretched) to platform work.

Are Uber Drivers ‘Workers’?

The question whether Uber drivers should be considered ‘workers’ for the purposes of labour laws has posed a legal challenge for almost all the major economies of the world. Different jurisdictions have reacted differently to this issue, though Commonwealth countries seem to have put their weight behind the drivers.

Internal Analysis of Uber and Ola

Uber: A SWOT Analysis in the Indian Matrix

Internal Factors

External Factors

Ola: A SWOT Analysis in the Indian Matrix

Internal Factors

External Factors

Case Studies and Industry Examples

Case Study: Global Expansion Strategies of Uber and Ola

Uber and Ola are two major ride-hailing companies that used technology to make transportation easier. After becoming successful in their main markets, both companies tried to expand into other countries. However, their approaches were different. Uber expanded internationally very quickly, while Ola first focused on building a strong business in India.

Uber’s Global Expansion

Uber followed an aggressive global expansion strategy. It entered many countries quickly and used its technology, mobile app and strong brand to attract customers.

Uber had some early success in markets such as China and Southeast Asia. However, it also faced many problems. Different countries had different rules, cultures and customer expectations. Uber also faced strong local competitors and protests from drivers.

A major example was China, where Uber faced strong competition from Didi Chuxing, a company that understood the local market very well. Uber eventually left the Chinese market and combined its China business with Didi.

From this experience, Uber learned that entering a market quickly is not enough. A company must understand local customers, laws, culture and competitors. Later, Uber became more careful about international expansion and focused more on profitable markets and strategic partnerships.

Ola’s Expansion Strategy

Ola followed a different approach. Instead of expanding globally from the beginning, it first focused on becoming strong in the Indian market.

Ola understood the needs of Indian customers and offered different transportation options, including cars and auto-rickshaws. This helped Ola build a strong position in India and compete with companies such as Uber.

After becoming established in India, Ola started exploring international markets. However, its international expansion was more cautious. It faced challenges such as different regulations, customer preferences, competition and lower international brand recognition.

Ola’s experience shows that building a strong domestic business first can provide a good base for international expansion. But when entering another country, the company still needs to understand the local market and adapt its services.

Overall Comparison

The main difference between the two companies is their approach to expansion.

Uber expanded quickly and globally, using technology and its international brand. This helped it enter many markets, but it also created challenges related to regulations, culture and local competition.

Ola focused on India first and expanded internationally more carefully. It used its understanding of local customers as an important part of its strategy.

The experiences of companies such as Didi and Grab also show that local knowledge and partnerships can be very important when entering a new market.

Overall Lesson

The main lesson from Uber and Ola is that success in one country does not automatically mean success in another country. A company must understand the local market, customers, culture, government rules and competitors.

Therefore, successful global expansion requires more than technology and money. Companies need local knowledge, proper partnerships, cultural understanding and the ability to adapt their business strategy to each country.

Case Study: Ola Driver Status

Case Study: Uber BV v Aslam

A very important case in the discussion of gig workers is Uber BV v Aslam, decided by the UK Supreme Court in 2021. The basic question before the Court was simple: Were Uber drivers really independent contractors, or were they “workers” of Uber?

Uber argued that it was mainly a technology platform that connected passengers with drivers. According to Uber, the drivers were independent and were providing services directly to passengers. The drivers, however, argued that Uber controlled important parts of their work and that they should therefore receive legal protection as workers.

The Court looked at how the Uber system actually worked in real life rather than relying only on the wording of the contracts. It found that Uber had considerable control over the drivers. Uber decided the fares, set important terms and conditions, used a rating system to monitor drivers and could take action against drivers in certain situations. Uber also controlled several aspects of the relationship between drivers and passengers.

After considering these factors, the UK Supreme Court held that Uber drivers could be treated as “workers” under UK employment law. This gave them important rights, including protection relating to minimum wages and working hours.

One of the most important points from this case is that what a contract calls a person is not always the full picture. The Court was more interested in what was actually happening between Uber and its drivers. In simple terms, it looked at questions such as: Who controls the work? Who decides the important terms? And how dependent is the worker on the company?

At the same time, the judgment did not mean that every person working through a digital platform would automatically become a worker. This was clear from the later Deliveroo case, where the riders were treated as self-employed. One important factor was that Deliveroo riders could arrange for someone else to perform the delivery instead of doing it personally.

This shows that the legal status of gig workers depends on the actual facts and working conditions of each platform.

Relevance to India

This case is particularly relevant to India because companies such as Uber and Ola use a similar platform-based model. Drivers may have the freedom to choose when to work, but at the same time, the platform can influence important aspects of their work through fares, ratings, incentives, app-based monitoring and account restrictions.

Therefore, Uber v Aslam provides a useful example for understanding the changing relationship between platforms and workers. It shows that the question is not simply whether a driver is called an “independent contractor.” Instead, it is important to look at the real level of control, economic dependence and working relationship between the platform and the driver.

Legal Framework

Pre-Code Legal Position

Before the labour codes came into force, the legal status of Uber and Ola drivers in India was highly uncertain and largely unfavourable to workers.

• Platform companies classified drivers as independent contractors or “driver-partners” through subscription agreements.
• Very few cases directly examined Uber/Ola drivers. A Delhi High Court petition by Uber drivers was later withdrawn, leaving the issue unsettled.
• Regulatory focus was mainly on passenger safety, not worker rights.

Code on Social Security, 2020 (and 2026 Rules)

The Code on Social Security, 2020 (enforced from 21 November 2025) is the first central legislation that formally recognises gig and platform workers.

Key Definitions

• Gig Worker (Section 2(35)): A person who performs work outside the traditional employer–employee relationship.
• Platform Work (Section 2(60)): Work arranged through an online platform for payment.
• Platform Worker (Section 2(61)): A person engaged in platform work.
• Aggregator: Digital intermediary or marketplace connecting users with service providers (includes Uber, Ola, etc.).

Main Provisions for Platform Workers

• Central Government can frame social security schemes covering life & disability cover, accident insurance, health & maternity benefits, old-age protection, etc. (Section 114).
• Aggregators must contribute 1% to 2% of their annual turnover to a Social Security Fund (capped at 5% of the amount paid to gig/platform workers).
• Workers must be registered on a central portal.
• Eligibility under the 2026 Rules: Minimum 90 days with one aggregator or 120 days across multiple aggregators in the previous financial year.

Important Limitation

The Code deliberately keeps platform workers outside the traditional employer–employee relationship. Therefore, they do not automatically get rights under the Code on Wages, Industrial Relations Code, or Occupational Safety Code (minimum wage, job security, collective bargaining, etc.).

3. Aggregator Regulations (Motor Vehicles Law)

Uber and Ola are also regulated as transport aggregators under the Motor Vehicles Act, 1988 and related rules/guidelines.

• Central Government has issued Motor Vehicles Aggregator Guidelines (latest version 2025).
• States frame their own rules. In Karnataka (important jurisdiction for Ola/Uber cases), the Karnataka On-demand Transportation Technology Aggregators Rules, 2016 apply.
• Main requirements:
  • Licence from State Transport Authority
  • Minimum fleet size
  • GPS tracking and control room
  • Police verification of drivers
  • Safety devices (panic button, etc.)
  • Grievance redressal for passengers
  • Compliance with fare regulations

Judicial Analysis

Indian Precedents on Control and Supervision Tests

Indian courts have developed several tests over the years to decide whether a person is an employee or an independent contractor.

Main Tests Used by Indian Courts

• Control and Supervision Test: The most important test. The court looks at how much control the company has over the worker’s work — how the work is done, when it is done, and under what conditions.
• Economic Reality / Dependence Test: Whether the worker depends economically on the company for their livelihood.

Important Supreme Court Cases: Balwant Rai Saluja v. Air India (2014)

The Court made the test stricter. It said there must be absolute and effective control. Factors include: power to appoint, fix wages, dismiss, take disciplinary action, and continuous supervision.

These older cases were decided for traditional factories and companies. Applying them to app-based platforms like Uber and Ola is difficult because control is exercised through algorithms, ratings, and the app — not by a human supervisor.

Future Prospects

Predicting the future of any industry is inherently uncertain, but here are some potential scenarios for the future of ride-hailing in India, based on current trends and potential disruptions

Technological Advancements

• Autonomous vehicles (AVs): If AV technology becomes commercially viable, it could significantly disrupt the industry, potentially reducing driver costs and operating expenses for platforms. However, regulatory challenges and public acceptance need to be addressed.
• Electric vehicles (EVs): Transitioning to electric fleets will be crucial for environmental sustainability and compliance with stricter emission regulations. Battery technology advancements and charging infrastructure development will play key roles.
• Micro-mobility: Shared e-bikes, e-scooters, and other micro-mobility options could become increasingly popular in urban areas, offering short-distance, first-mile/last-mile solutions and integrating with ride-hailing platforms.
• Advanced data analytics: Leveraging data to personalize passenger experiences, predict demand, and optimize driver routes can further enhance efficiency and user satisfaction.
• Air-Taxi: An air taxi is a small, electric-powered, vertical takeoff and landing (eVTOL) aircraft intended for short-distance passenger transportation within urban areas , Unlike traditional helicopters, they aim to offer a quieter, more affordable, and environmentally friendly alternative They are still in the development and testing phase, but the vision is to offer on-demand air transportation similar to ride-hailing services, potentially revolutionizing urban mobility.

Key Characteristics of Air Taxis

• Electric-powered: They utilize electric motors, aiming to reduce noise pollution and contribute to sustainability compared to fuel-powered alternatives.
• Vertical takeoff and landing (eVTOL): Unlike airplanes requiring runways, they can take off and land vertically, enabling operations in urban environments without large infrastructure
• Short-distance: They are designed for short trips within cities, typically aiming for ranges of 50-100 kilometers.
• Autonomous operation: The ultimate goal is for many aerial vehicles to be autonomous, reducing pilot costs and potentially increasing safety.
• On-demand service: Similar to ride-hailing apps, users could book their “flight” via apps and be picked up or dropped off at designated locations.

Market Dynamics

• Consolidation: Increased competition could lead to mergers and acquisitions, resulting in fewer major players, potentially impacting driver and passenger options.
• Government regulations: Stringent regulations aimed at addressing concerns like driver welfare, data privacy, and traffic congestion could shape the industry’s future landscape.
• Growth of alternative modes: Public transport improvements, shared mobility options like carpooling, and cycling infrastructure could influence ride-hailing demand, especially for short trips.

Impact on Stakeholders

• Drivers: Their roles might evolve with AVs, requiring upskilling and potentially leading to job displacement. Platform policies on wages, benefits, and working conditions will remain
• Passengers: Safety, affordability, and convenience will continue to be key concerns. Personalized features, loyalty programs, and integration with other mobility options could enhance their experience.
• Platforms: Adapting to new technologies, regulations, and market dynamics will be crucial for their survival and growth. Collaboration and partnerships can play a significant role.

Possible Scenarios

• Sustainable and equitable model: Focus on EVs, micro-mobility, and driver welfare alongside technological advancements, leading to a greener and more socially responsible industry.
• Tech-driven dominance: AVs become mainstream, leading to platform consolidation and potentially impacting driver jobs. Ethical considerations and regulations become paramount.
• Multimodal ecosystem: Ride-hailing integrates with other transportation options like public transport and micro-mobility, creating a seamless urban mobility network.

Ultimately, the future of ride-hailing in India depends on various factors, including technological advancements, regulatory frameworks, market competition, and societal preferences. The industry needs to prioritize sustainability, ethical practices, and stakeholder well-being to ensure its long-term success and positive contribution to urban mobility.

Critical Evaluation / Discussion

The Central Tension: Judicial Findings vs Statutory Category

The most significant tension in the current legal landscape is the gap between judicial reasoning and the statutory design of the Code on Social Security, 2020.

On the basis of this control, the Court held that drivers qualify as “employees” under the POSH Act. This reasoning is consistent with the substance-over-form approach seen in Hussainbhai and in comparative jurisprudence such as Uber BV v. Aslam.

On the other hand, the Code on Social Security deliberately creates a separate legal category of “gig worker” and “platform worker” that exists outside the traditional employer–employee relationship.

2. Gaps in the Current Framework

Several important gaps remain:

Limited Scope of Judicial Recognition

The 2024 Karnataka ruling is confined to the POSH Act. It does not decide the broader question of whether drivers are “workmen” under the Industrial Relations Code or “employees” under other labour statutes. The stay granted by the Division Bench further reduces its immediate impact.

Absence of Intermediate Category

Unlike the United Kingdom, which created a “worker” status with limited but important rights (minimum wage and paid leave), India has not introduced any intermediate category between employee and independent contractor. Platform workers are left with either full employee status (which platforms strongly resist) or a weak statutory recognition with limited benefits.

3. Algorithmic Control as a New Form of Supervision

One of the most under-examined aspects in Indian judicial and legislative discourse is algorithmic management.

Platforms exercise control not through human supervisors but through:

• Dynamic pricing and surge algorithms
• Rating systems that directly affect access to work
• Automated allocation of rides
• Instant deactivation or temporary blocking of accounts
• Incentive and penalty structures

4. Weak Grievance and Appeal Mechanisms

A major practical problem for platform workers is the near-absence of effective grievance redressal, especially in cases of account deactivation or suspension.

• Platforms can unilaterally deactivate a driver’s account with little or no prior notice.
• Internal complaint mechanisms, where they exist, are often controlled by the platform itself and lack independence.

The Fate of Uber Drivers in India

So far, the legal status of Uber drivers as ‘workers’ has not been settled in India. A case was filed by a group of Uber drivers in the Delhi High Court to raise this issue. However, it was later withdrawn. If a similar case were to be brought before the courts again after the coming into force of the labour codes, it would be decided on the basis of precedents that deal with the factors that are integral to the concept of ‘worker’. The first judgement that needs to be considered in this regard is the 1978 judgement of the Supreme Court of India in Hussainbhai v Alath Factory. Delivered by a three-judge bench headed by Justice Krishna Iyer, it lay down the test for employer–worker relationships in the following words:

[w]here a worker or a group of workers labours to produce goods or services and these goods or services are for the business of another, that other is, in fact, the employer. He has economic control over the workers’ subsistence, skill and continued employment. If he, for any reason, chokes off, the worker is, virtually, laid off… If the livelihood of the workmen substantially depends on labour rendered to produce goods and services for the benefit and satisfaction of an enterprise, the absence of direct relationship or the presence of dubious intermediaries or the make-believe trappings of detachment from the management cannot snap the real-life bond.

The views expressed in the Hussainbhai judgement are very similar to the ones that have been upheld by the UKSC and the Supreme Court of Canada. The two-pronged test of ‘subordination’ and ‘dependency’ used to analyse the degree of control seems to run common across all three judgements. At the same time, these judgements take a broader approach in analysing the factors that contribute to the existence of the employeremployee relationship and do not limit themselves to such instances where direct and absolute control is apparent. However, the Indian judiciary seems to have deviated, although partly, from the line of reasoning followed in Hussainbhai.

In Balwant Rai Saluja v Air India Ltd., a judgement delivered in 2014 by another three-judge bench, the Supreme Court took a different approach.

It weighed the test of absolute and effective control against the test of sufficient control as the true measure for the employer-employee relationship and held in favour of the former. The court said that ‘to satisfy the test of employer-employee relationship…it must be shown that the employer exercises absolute and effective control over the said workers’. The specific factors through which an employer-employee relationship could be established, according to this judgement, depend upon the following: (i) power to appoint; (ii) power to determine wages; (iii) power to dismiss; (iv) power to take disciplinary action; (v) existence of continuous service; and (vi) power to control and supervise, in other words, ‘whether there exists complete control and supervision’.

Conclusion and Way Forward

Conclusion

The legal status of Uber and Ola drivers in India remains complex and unsettled. Traditional employment tests developed by the Supreme Court in cases such as Hussainbhai and Balwant Rai Saluja were designed for conventional workplaces. When applied to platform work, these tests face serious limitations because control is now exercised through algorithms, ratings, and digital systems rather than human supervisors.

The 2024 Karnataka High Court judgment in the Ola POSH case marked an important shift. By examining the real degree of control in the subscription agreement, the Court recognised that driver-subscribers can be treated as employees for the purposes of the POSH Act. Although the order was later stayed, it demonstrated that Indian courts are willing to look beyond contractual labels.

At the same time, the Code on Social Security, 2020 (enforced from November 2025) has taken a different path. It formally recognises “gig workers” and “platform workers” but deliberately places them outside the traditional employer–employee relationship. While this provides a limited social security framework through aggregator contributions, it does not grant core labour rights such as minimum wages, protection against arbitrary deactivation, or collective bargaining.

The result is a fragmented legal position. Drivers may receive limited recognition under one statute while remaining largely unprotected under others. Algorithmic control remains poorly understood in Indian labour jurisprudence, and effective grievance mechanisms against sudden account deactivation are almost non-existent.

Overall, India has moved from complete non-recognition of platform workers to partial and conditional recognition. However, recognition without adequate rights and enforcement mechanisms offers only incomplete protection.

Way Forward

To create a more coherent and fair legal framework, the following steps are necessary:

Clarify the Relationship between Judicial Findings and the Social Security Code

Courts and the legislature must address the inconsistency between findings of employee status (as seen in the POSH context) and the statutory creation of a separate non-employee category.

Consider an Intermediate “Worker” Category

India could usefully examine the United Kingdom model, which created a middle category of “worker” entitled to basic rights such as minimum wage and paid leave, without imposing the full range of employee obligations on platforms.

Strengthen Regulation of Algorithmic Management

Future legislation or judicial doctrine should explicitly recognized algorithmic control as a form of supervision. Transparency in ratings, deactivation decisions, and incentive structures is essential.

Create Effective Grievance and Appeal Mechanisms

Platform workers must have access to independent and time-bound procedures before their accounts are suspended or permanently deactivated. A fair hearing and reasoned decision should be made mandatory.

References

1. choubey, s. b. (2024). analying worker right of uber driver in india. national law school journal, 18.
2. Available at: https://repository.nls.ac.in/nlsj/vol17/iss1/5
3. https://repository.nls.ac.in
4. Surabhi, ‘Roll-out of labour codes unlikely before 2024 polls’ Financial Express (Delhi, 3 April 2023)
5. https://perma.cc/JJ7L-WR9M accessed 4 May 2023. It should be noted that, as on the date of the writing of this article, a few provisions of the Social Security Code relating to Employees’ Pension Scheme, 1995 have been brought into effect.
6. Ministry of Labour and Employment, ‘Gazette Notification bearing number CG-DL-E-03052023-245642’ The Gazette of India (Delhi, 3 May 2023) https://egazette.nic.in/WriteReadData/2023/245642.pdf accessed 4 May 2023