lawyers in India

Exchange of organs or Exchange of Money? People do not give a damn to Religion

Written by:  Ashish Goel I am a first year student of National University of Juridical Sciences (NUJS), Salt Lake, Kolkata. I love my mom and dad very much and can do anything for them!
Constitutional Lawyers in India
Legal Service
  • Don't think of organ donations as giving up part of yourself to keep a total stranger alive. It's really a total stranger giving up almost all of themselves to keep part of you alive[1].

    In todays world, the scarcity of human organs cumulates in lethal cases, which could be saved otherwise. In other words lack of human organs causes preventable deaths. The deceased ones are either buried or cremated when their organs could be donated to the needy ones, the ones in the waiting lists to die. Christiaan Barnard[2] quotes "it is definitely better to transplant a heart than to bury it so it can be devoured by worms". But its not a childs game to make the organ transplantation successful. Organs cant be removed from a living body without a risky surgery. Organ transplants were a psychological as well as a surgical breakthrough, a step towards understanding the body by literally deconstructing it[3].

    Basically it means that the organ transplants were a surgical step put forward efficiently which includes the understanding of a body by removing the parts of one body to another. While a body might be more than the sum of its parts, transplants techniques proved that a single organ could be responsible for the disease in the whole. For making organ transplantation successful it should be kept in mind that the tissue of the donor matches to that of the recipient very closely[4].

    Even the concept that organ transplantation is a top-notch achievement in the medical world is somewhat faulty. Various diseases are cured by medical miracles and the persons illness gradually disappears, it does not apply in this risky transplantation.
    The words of Munson Ronald runs;
    "Because the recipient of the organ has to take anti-rejection drugs for the rest of his lives, always fearing an infection which will get past their now-suppressed immune system, transplants simply trade one acute illness for another chronic condition".[5]

    Thinking beyond the facade, we get to know that there are not only these complicated scientific reasons or say hindrances in the successful operation of the transplantation of organs, but also a plethora of ethical and moral objections on this transplantation of organs. For instance, there are people who argue that should one who has already received a transplant be allowed a second? Should alcoholics be given liver transplants? Are transplants really worth the tremendous costs? On the face of it, there seems to be a little reason to bother with these ethical debates, stating the fact that the transplantation is of course one of the greatest achievements that man had ever gripped, in the world of modern surgery. But these ethical objections as to whether these transplantations should be encouraged must be something to look into. Because right under the surface lurks a morass of ethical dilemmas and controversies which have threatened to demoralize the entire practice of transplanting organs. Time will decide whether there will be any resolutions to these ethical controversies as a large number of medical advances have been made in recent years, which will surely trample the ethics and moralities which seems to be a major obstacle in the implementation of this highly beneficial achievement.

    There are innumerable medical advancements which came out in the last few decades. Transplantation is one of the most important and successful medical breakthrough which mankind had not experienced before. Because of the vastness of the topic it is rather impossible to cover all the issues pertinent to it. The researcher escapes through tracing back into the history of organ transplantation of India, and explicitly mentioning the rules and regulations laid down by the Transplantation of Organs Act. This paper also briefly discusses the ethical problems relating to a new development in the procurement of human organs for transplantation. Lastly, the researcher gives a basic idea of the advantages and the shortcomings of transplantation.

    Replacement of diseased tissues or organs by healthy and compatible ones is called transplantation and is a technique used increasingly in surgery today. A milestone in organ transplantation was the first heart transplant performed in Cape Town, South Africa, in December 3, 1967 by the well known South African cardiac surgeon Dr. Christiaan Barnard. Medical scientists have devised surgical procedures by which certain organs like heart, lungs, liver and kidneys when they are irreversibly damaged by diseases can be replaced by healthy ones. The organs for replacements can either be taken from a healthy person who is willing to donate one of his paired organs like kidneys or from a dead body, i.e. cadaver. But if the body is dead for long, the organs also become dead and hence unfit for transplantation[6].

    So far India is concerned some opines that it has got a monolithic culture, Indian culture. But in fact it is a heterogeneous culture. The people of India vary in different forms e.g. Language, Habits, Food, and Dress etc. Even in the arena of music, in the north we have the so called Hindustani and in the south we have Karnataki. This can be seen in other fields also. But which does not vary is science. It can be said that science and technology is actually universal. The concept of taking an organ from one human being and using it for the treatment of another has been in the imagination of the human race since time immemorial. Today it is no longer just a question of donating ones organs for the benefit of the other person. Between the donor and the recipient lies a whole lot of commercial, political and simply ego satisfying problems.

    As discussed before transplantation is the replacement of a diseased organ with a healthy one. First of all it would be a better step to trace back into the history of the transplantation of human organs in India. In 1989, the organ trade was legal and widespread, and kidney was the only organ which was transplanted in India. Patients with heart and liver failure were joining the majority without any hope of transplantation. When the ministry of health was asked by the then prime minister of India, Shree Rajiv Gandhi, to work out on the problems which bars liver and heart transplants, the committee spot out two major problems.
    Firstly[7], the law which was prevailing in India does not give much importance to brain death[8], which in furtherance to that, the concept of brain death would not be acceptable to the Indian population at large. Mr. Bhattacharya in his article "Brain Death" clearly mentions;

    In India a person is called dead when the carotid pulsation is absent, there is no heart sound after listening it for 5 minutes, there is no respiratory effort, all the reflexes are lost and the pupils are widely dilated and fixed. In vast majority of the cases the heart and the lungs stop functioning first and death of the brain follows[9].

    Death in the Indian Penal Code was defined as death unless the contrary appears from the context or the permanent disappearance of all evidence of life at any time after live birth has taken place. Therefore it was not allowed to transplant organs that require a heart-beating, brain dead donor.

    On the other hand, the second major problem identified was that there was a trade in human organs. There was incessant repulsion in India at this exploitation of the grassroots by the so called bigwigs and also at the idea of the human organs being treated as commodities. The main objective of the committee was to legalise the concept of brain death, to disallow the sale of human organs and to thwart the abuse of law. Later, the Government of India established a committee under the chairmanship of Dr. L. M. Singhvi[10], to clarify the concept of brain death, which heavily includes the measures to be adopted to prevent the misuse of the concept of brain death as well as to find out the legal, medical, and social implications of the legislation to be enacted for the said purpose. The report of the Singhvi committee was submitted in June 1991, and after two years on May 5, 1993, the Transplantation of Human Organs Bill was submitted to the Rajya Sabha where it received unanimous approval. It received Presidential assent on the 8th of July 1994[11]. Indias first successful heart transplantation from an organ harvested from a brain dead donor was performed in the All India Institute of Medical Sciences (AIIMS) on August 3, 1994. This act provides certain rules and regulations as to when transplantation would be said to be legal. Without going in detail it will be better to mention the rules in the form of points. The following rules should be bore in mind when one talks about organ transplantation in India[12]:

    Authority for the removal of human organs: A minimum age limit has been provided who can grant authorization in writing before his or her death in front of two witnesses, one of whom must be a close relative.

    Registration of Hospitals: Basically it lays down the rules in which the hospitals carrying out organ transplantation must be registered by the appropriate authority.

    Punishments: The unauthorized removal of organs is considered to be illegal and is punishable with imprisonment which would not be less than five years and a fine of up to Rs.10, 000 would be imposed.

    Although the act has been in place for twelve years its effect on organ transplantation in India has been rather disappointing. Cadaver donations are still very rare because of lack of awareness among doctors as well as the individuals that brain death is a form of death. Again we face a dearth of transplant coordinators who are sufficiently trained to explain the benefits of the new life given to the recipients in a form of donation of organs from a brain dead cadaver.

    Lastly it is well known to every one that India has been facing major ethical problems since the primordial civilization. Relatives of the donors are worried day in and day out that the body may be mutilated, the funeral arrangements might be delayed and also think of the high costs which would incur after the brain death of the donor. In spite of all these problems it is somewhat wise to say that the Act has not fallen flat. It has allowed the start of heart, liver and lung transplantation programmes in the major cities of India such as Delhi, Chennai, Mumbai, Bangalore, to name a few. To protect the people waitlisted to die, what is solely needed is to improve public awareness about the benefits of organ donation.

    "On the face of it, there seems to be little reason to question the ethics behind transplanting organs. Apparently one of the greatest achievements of modern surgery, tens of thousands of people are given a new lease on life through the selfless altruism of others who choose to find hope in the midst of tragedy, literally giving of their own bodies in the effort to save others"[13].

    These ethical problems are spreading their roots but there is barely any resolutions observed hitherto which focuses on them. Mostly these ethical debates give rise to the twin questions of Procurement and the Allocation of organs. How do we procure organs, and how do we decide who will receive the transplants? The very fact that donors are screamingly less vis--vis the recipients hardly requires any proof. In other words the demand for organs drastically exceeds the supply. And this can be the sole reason why, unfortunately, more than 5,000 people die every next year while waiting for the transplantation of healthy organs. The distribution process mainly engages a lot of money in it, so to say. In a lay mans language, whoever is going to receive an organ transplant should pay for it in moneys worth irrespective of his financial soundness. Right from the outset, the poor ones are not wealthy enough to afford such huge amount of money, and do not dare to undergo the process of transplantation. If an organ is transplanted it should have some monetary value, bearing in mind the huge costs of the paraphernalias involved in its successful operation.

    But should the choice of who gets new organs also depend upon social worth? Simply put, should convicted felons receive organ transplants? Should alcoholics be denied transplantation of livers because they deserve what has happened to them? The answer lies itself in the question. The alcoholics deserve to what has happened to them. Almost 3 years back, it was revealed in Northern Ireland that a footballer[14] received a liver transplant after a long fight with his alcoholism. Doctors claimed that his liver has stopped functioning more than 80% and to keep him alive an instantaneous liver transplant is required, which was of course transplanted, because of the economic soundness of a footballer, which generally is a big barrier to transplant[15]. After a couple of months later, the same footballer took recourse to drinking, wisely predicting that he is not going to be affected the rest of his life since he has already got a healthy organ transplant and it would serve him until death. Now if this is the scenario, then it is very pathetic to say that liver transplants should not be any more allowed to the alcoholics.

    Coming back to the first debate as to whether the convicted felons should be gives transplants or not. This has been a subject of fierce debate since time immemorial. The question arises whether the criminals or the so called prisoners, especially who are awaiting capital punishment, are to receive the same level of what is called medical care vis--vis the people in general----which even does not exclude the donation of scarce organs for transplantation when required. People are still at loggerheads when it comes to the allocation of organs to the prisoners.

    The sole question arises is that prisoners are not a member of the society and they hardly deserve better medical care, including transplantation. It is an undisputable fact that these felons have committed heinous acts and have already taken away so much from the society through their crimes, but does it anyway justifies, why should the prisoners not be permitted to receive transplants. The doctors are duty bound or committed to provide the top-notch medical facilities to all human beings, irrespective of any personal opinions, debates, and ethical considerations. Take for instance; the doctors in the military are obligated to provide equal treatment to the prisoners, who might have been responsible for the serious wounds of the military soldiers, who in turn are still waiting for their medical treatment[16]. Unfortunately, if a prisoner is denied from receiving a transplant, and later on it is found that he is absolutely innocent and should not be put behind bars any more, the society as well as the State should be held responsible for his not receiving transplant, by virtue of his being innocent and not only this but the State can also be held liable for his preventable death, if any. So far as the society is concerned it is not an authority to judge, decide or table its decisions as to who is competent to get a transplant and who is not.

    "The arguments against providing quality medical care to prisoners may have a great deal of emotional appeal, but their logical and social basis is generally very poor. This is especially true because the health and welfare of prisoners are the responsibility of the state in a way unlike that of any other human beings - and a state presuming to keep people locked up as a matter of justice must also show justice towards them by meeting that responsibility adequately"[17].

    It can be well agreed without any disputes, that in all likelihood, a prisoner being a convicted felon should be moved further down in the waiting lists of candidates. But what cannot be easily digested is the unwise assumption that being a prisoner, an individual does not have any right to live, does not have the right to receive transplants and that he can be put to death any where inside the four corners of the prison, any time.

    Another problem is the procurement of organs for the simple reason that not every one agrees that the death has occurred. This is because of the lack of awareness among the individuals who consider brain death to be a scientific and medical jargon. No one wants to take organs from someone who is still breathing i.e. alive and this understanding totally misunderstand the concept of brain death, cumulating in various preventable deaths. And what about the question of consent? Pursuant to the Organ Transplantation act[18], in India consent is a major factor when you are talking about transplants. Organs can only be procured willfully, not force fully. The donor has to directly agree for transplantation in order for the organs to be removed. Shaun. D. Pattinsons interesting take on the ethical issues behind the procurement of organs becomes relevant at this point of time. He writes;

    "The dead body is regarded as sacred by many religions, cultures and individuals. Buying and selling organs is widely considered to be morally pernicious. Nascent technologies involving artificial organs, tissue engineering, and animal organs have practical limitations and evoke varying degrees of moral concern and condemnation. It is no exaggeration to say that the regulation and practice of transplantation is an ethical minefield[19]".

    Besides these dilemmas of moral concern of not donating organs because it is violating ones religious tenets, it will be better to explain all these in more of a legal as well as a moral concern. To put it simple, let us talk of consent which can be said as a Bible of Organ Transplantation. As said before, organs cannot be removed forcefully, but willfully. Now how to decide, that who can be competent enough to give his consent, if wanting to donate his or her organs. When we talk of adults, it is the individual himself who is supposed to give his or her concern. However in certain cases when the patient is unconscious, close relatives are asked to sign a consent form on behalf of the patient. But there is no such provision in law which allows the doctors to take consent of the close relatives, (in some cases when the patient has no knowledge of transplant whatsoever) for an organ transplant. In certain cases consent of relatives can be taken when the patient is incapacitated[20], such as a medically handicapped person, who is unable to make decisions for them. Generally children[21] also come within the category of incapacitated persons, for the simple reason that they are dependant on others, especially parents, for their well-being. The consent given by the relatives of a minor or an adult, who is mentally minor, should be subjected to public interest at large. There was a case[22] where a donor, who albeit adult, had a mental age of six, was chosen to donate a kidney to his ill brother. Considering the close relationship which existed between the two boys, the court came to a conclusion that the donation can be done as it would be in the donors best interests for his brothers life to be saved. Again lurks motley of ethical debates which says that sometimes it can be acceptable for a minor to be a donor, because there might be some sort of a generosity towards a brother or a sister and it may be named as a social duty. But the situation seems to be somewhat unclear with relatives other than siblings. Whether the same principle can be applied to a situation where the recipient is the cousin? It can be possible that the minor is as distressed by the illness of his cousin as he would be if it is his siblings. Nevertheless, a policy of limiting approved donation by minors to the immediate family has the attraction of certainty[23].

    On top of it, we should not forget that it has something to do with a persons life. We are talking about life and death. People who are suffering tremendously in the hospital beds hoping to get a transplant will have a terrific impact upon them when these ethical debates are discussed time and again. Although the afore-mentioned descriptions provide a detailed explanation of the ethical terrain of the current issue, it restricts us to make any sort of expeditious, restful and glaring decisions.

    Thanks to the donors, that a 12 year old boy still has his loving mother alive, that the father of the boy has still his wife alive, and of course it is also the mother and the wife, who fought back for her family, fought back to nurture her son, fought back to walk hand in hand with her husband in life. At the face of it the afore-mentioned words (surprisingly it is not a story) seems to be a bit emotional but it would be something more if any one of us is in the same position. You may not want to leave your organs to 'strangers' that's up to you, but please take a few moments to contemplate planning your own funeral at a very young stage of your life, writing goodbye letters to your beloved ones, sobbing as you hold your baby, knowing that without the amazing people who choose to let organs be used after their death, you will not live to see their next birthday.

    Sorry to say, but any one of us might need a transplant at any point of our life. Worse still, when it is not you who is about to die, but it is the one whom you believe to be a big deal more precious than your life, say your wife, daughter. Thousands of people die each year waiting for an organ to be transplanted because a transplantable organ is not salvaged and used[24]. Every human being has so much to do in his/her lives, be it personal or for others. Why not protect them and their willingness to do something when they are at stake? Why people boggle to donate his/her organs to save others and deliberately let his organs devoured by worms when his body his either buried or cremated?

    When the boons of organ transplantation are looked at, it is highly beneficial to both the parties. With respect to the donor, his family often finds that it helps them through their grieving process. They receive great comfort from being able to have something positive come from the death of a loved one. For recipients, organ transplants offer a second chance at life, enabling them and their families to maintain a more normal, higher quality of life. People should bore this in mind that by donating organs you utilizing your dead body by helping others in need. Something useful is coming out of your death. Our bodies are just like shells. The soul of our body has already left for good then what is the point in leaving your shell to rot when it could actually transform the lives of millions of people. One should encourage donation as an act of charity. Organ donation is the gift of an organ to help someone who needs a transplant. It is something good that can result from tragedy and a way for families to find comfort by helping others. However, it must be cleared that the organs are removed only after death and that people's wishes are respected. The question of whether one should will his or her bodily organs to be used as transplants or for research after death must be answered from deep within the conscience of the individual involved.

    Organ donation is an opportunity to donate life in the form of organs to the needy ones. Life has become impossible for them but this scenario can be completely changed when a dying person decides to donate his/her organs. Life after death is possible only by donating organs. One can live after his death; see his beloved ones, by organ donation. To put it shortly, organ donation is the truest gift of life. Therefore organ donation requires a timely decision at the right place, at the right time. Someone very rightly pointed out that blessed are those who give without remembering and take without forgetting.

    On the other hand, it involves a lot of complications, so to speak. Depression and anxiety faced by the living donors after organ donation is a common concern and often attributed to the healing process of surgery, renewed family demands and an attention shift from the donor onto the recipient. As with any transplant, there is also the risk that the recipient will have problems such as infection, rejection of the organ or even death. For a living donor, the news of such problems can be devastating. Living organ donors experience a vast array of emotions and psychological issues before and after donation. Some are minor while others can be major issues. Before donation, many donors have emotional ups and downs. Donors are focused upon relieving the pain and suffering the recipient experiences in everyday life. This can be very frustrating because the donor wants to help, yet they have little control in the whole process. Opposition from family members is very difficult for the Living Organ Donor. Some family members can oppose Living Organ Donation whether the donor is donating to another family member, friend, or stranger.

    Most donors state they feel tired and need frequent naps after donation. Of course donors who give kidneys or parts of other organs enjoy the benefits of a wonderfully altruistic act, but we should wonder whether that is enough to overcome the ages-old stricture on physicians to avoid harming patients unless it leads to sufficient benefit to them[25].

    Living donors feel frustrated after the donation of their organs because of several reasons. Some of them even hurt more when the recipients do not bother about them after the transplantation. They just use them and finally dump them. What Dr. Michelle Glasgow[26] says is quite incredible. He says;
    In the beginning they love you. They need you to do the transplant. Afterward, their attitude towards you is, we are done with you. Move on. We have more people. So if people have this kind of attitude then, sorry to say, every one would stop donating his/her organs which would result in numerous amounts of deaths. Most donors have no regrets, and many have only minimal pain. I'm in constant pain from the surgeries I've had. I can't even move around in bed," says Wood, 45, who now lives in Myrtle Beach, S.C. A doctor himself had enormous pain after his donation of one kidney to his brother. He says; "I volunteered to put my life on the line and I guess I've given up my good health for this and nobody seems to care,". "It's really hard not to cry[27]."

    As with any other operation there are also risks involved in donating an organ. People experience some pain and discomfort due to the donation. So far as the recipient is concerned, he has to take anti-rejection drugs the whole of his life and in sync, has to bear in mind that at any stage of his life, he can suffer from hidden diseases. And when we have a look on the reverse side of the coin, we get to know that, the dead body is regarded as sacred by many religions, cultures and individuals. Buying and selling organs is widely considered to be morally pernicious. Pattinson, very well puts it, "Nascent technologies involving artificial organs, tissue engineering and animal organs have practical limitations and evoke varying degrees of moral concern or condemnation. It is no exaggeration to say that the regulation and practice of transplantation is an ethical minefield". Most likely the donors also worry about the fact that whether after donatiuon of the body it will be properly utilized or simply dumped to rot in the garbage. In spite of all this it is an undisputable fact that organ transplantation is of course one of the greatest achievements in the world of modern surgery. So it will be better if one comes out of their imagination that by donating ones organs their God will turn eyes away from them. God has sent you in Earth so that you help your fellow beings when they are in deep trouble and not to leave them in the lurch. And this of course will be a continuous process to live and let live. I would end with the far sight of Wilson Mizner, which is very much relevant to this topic,
    Be nice to people on your way up;
    Because you will need them on your way down.

    The concept of taking an organ from one human being and using it for the treatment of another has been in the imagination of the human race since time immemorial. This brought in for the first time the ethical questions of transferring living tissue from one person to another and even today there are religious sects who refuse blood transfusion. Buying a few more years of life by going through the extreme rigorous of a transplant programme will appeal to a very few people, except in the young. If that is so then the priority lies elsewhere, in some other direction of science and it has to be researched and developed like a true independent society.The people of India are still carrying the tradition which our predecessors practiced. We take but never give.

    We have seen the laws regarding the transplantation of human organs and how it is applicable related to this. We have also seen that the shortage of human organs is causing preventable deaths and agonizing suffering. A number of ethical issues capable of addressing these shortages have been examined in detail. Lastly, a clear idea about the advantages and the disadvantages of transplantation has been explicitly elaborated.

    It is obvious that sufficient work is to be done if India is to look after its large pool of end organ failure patients awaiting death and to generate its need of organs for transplantation. All this activity should begin now to prepare a ground not awaiting legal sanction to this activity.
    Readers, if interested, may proceed towards the sources listed infra:
    Bhattacharya, Manoj, Brain Death, Papers on Proper Utilization of Donated Bodies, Second edition, Calcutta, Ganadarpan, (1998)
    Condon, Deborah, "1 in 4 not support liver op for alcoholics", available online at, last visited on 17.07.07

    "Ethics of Organ Transplants", available online at, last visited on 15.07.07

    Grace, Eric. S, "Biologically Unzipped, Promises and realities", Hyderabad, Universities press India limited, (1998)

    J. Amalorpavanathan, Transplantation of Human Organs Bill, Economic and Political weekly, 30(12), (1995)

    Mason, J K, R A Mc Call Smith, G T Lauris, "Law and Medical Ethics", United Kingdom, Butterworths, (2002)

    "Medical Care on Death Row: Should Condemned Prisoners Receive Organ Transplants?", available online at, last visited on 17.07.07

    Morgan, Derek, "Issues in Medical Law and Ethics", UK, Cavendish Publishing Limited, 2001,

    Munson, Ronald, "Raising the Dead: Organ Transplants, Ethics and Society", Oxford University Press, available online at,,last visited on 17.06.07

    Nundy, Samiran, A History of the Transplantation of Human Organs Act, 1994, of India, undated.

    Pace N, Sheila A. M. Mclean eds. "Ethics & the Law in Intensive Care", London, Oxford University Press (1996)

    Pattinson, Shaun, "Medical Law and Ethics", London, Sweet & Maxwell (2006)

    [1] The quotation has been taken from, last visited on 26.06.07
    [2] He is a South African cardiac surgeon, and is famous for performing the worlds first successful human to human heart transplant.
    [3]See Grace (1998 :56)
    [5]See, Munson, Ronald, "Raising the Dead: Organ Transplants, Ethics and Society", available online at, last visited on 20.06.07
    [6]See Amalorpavanathan (1995: 611)
    [7] See Nundy, undated.
    [8] It would be a futile attempt if the researcher tries to explain the term Brain Death separately as it is a very wide topic, having a lot of books against its name. However the researcher will definitely give an idea of what is Brain Death all about. Brain dead patients are considered to have irreversibly lost consciousness and the capacity to breathe unassisted. They have no discernable central nervous system activity. Even if such persons are ventilated there hearts will stop breathing within a few days.
    [9]See Bhattacharya (1998:3)
    [10]L. M. Singhvi is an eminent jurist, constitutional expert and writer from India.
    [11] Ibid.
    [12] Ibid.
    [13] See, "Ethics of Organ Transplants", available online at, last visited on 15.07.07
    [14]George Best, a former Manchester United and Northern Ireland footballer
    [15]For a provocative yet a persuasive analysis, see, Deborah Condon, "1 in 4 not support liver op for alcoholics", available online at, last visited on 17.07.07
    [16] See, "Medical Care on Death Row: Should Condemned Prisoners Receive Organ Transplants?" , available online at, last visited on 17.07.07
    [18] Supra note 7 at p. 5
    [19] See Pattinson (2006:419)
    [20] See Pace (1996:148)
    [21] Minor, i.e. below 18 years.
    [22] Strunk v. Strunk, 445 SW 2d 145 (Ky, 1969) as cited in Mason (2002:419)
    [23] Ibid. at p.431
    [24]See Morgan (2001:99)
    [25] The Dark Side of Organ Donation, available online at, last visited on
    [26] Ibid.
    [27] Ibid.

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