With over a billion people in India under the threat of virus SARS- CoV-2 (COVID- 19 disease), Hydroxychloroquine (HCQ) emerged as an elixir of life but the question still remains as to the whether this elixir stands the test of Article 21 of the Constitution of India in view of Right to dignified life and Health being a Fundamental Right?

Through this note, by analysing the nature of untested hydroxychloroquine (HCQ) drug and the recent conduct of Indian Council of Medical Research (ICMR), in recommending high doses of the same, as a preventive measure against Covid-19 (without any substantial evidence for effectiveness of the same), the author intends to establish that the concerned authorities by exposing the general population to the adverse effects of the said drug, have violated the Right to Health and thereby Right to Dignified life under Art. 21 of the Constitution of India.

Soon after the President of United States touted the malaria drugs as potentially the biggest changers in the history of medicine'[i]and when the Indian Council for Medical Research (ICMR) recommended hydroxychloroquine (HCQ) as a preventive medication for high- risk population and asymptomatic health workers,[ii]this has led to massive hoarding of this HCQ drug and shortage for the prescribed users throughout the country, as a result the central government of India in exercise of its powers under Section 26B of the Drugs and Cosmetic Act, 1940, had to declare the Hydroxychloroquine (HCQ) as schedule H1 drug (which cannot be sold over counter).[iii]

The drug has gained attention in spite of the fact that the World Health Organization has itself stated that there is no definite evidence that the HCQ drug works.[iv]Even the U.S Food and Drugs Adminstration (FDA), the body concerned with licensing medicines in America has allowed for only emergency use' of this drug against Covid- 19 that too only a limited number of hospitals.[v]

It is feared that in a largely uncultivated population as in India, the recommendation of the ICMR with regard to the preventive (prophylactic) use of the HCQ drug, will create an overly optimistic perception about the effectiveness of a drug, which still lacks clinical trials and has serious side effects. That on 18 April 2020, even the ICMR has admitted that the healthcare workers in India, who have self medicated themselves with the HCQ drug have demonstrated side-effects like nausea, abdominal pain and hypoglycemia and other, and that the ICMR has launched a study on the side effects of the HCQ.[vi]

-That isn't the exposure to the general population of the country to a non- clinically tested drug as HCQ with adverse side effects for the treatment of Covid- 19, is a clear violation of Right to Health, more so right to proper and correct Heath Care, within the contours of Right to life under Article 21 of the Constitution of India?

Constitutional Safeguards:

Article 21 of the constitution guarantees protection of life and personal liberty to every citizen. The Hon'ble Supreme Court of India, has in Bandhua Mukti Morcha v. Union of India[vii] has held that the right to live with human dignity as enshrined in Art. 21 (Maneka Gandhi v. Union of Indiam[viii]), derives from directive principles of state policy and therefore include protection of health. Moreover, the Hon'ble Supreme Court in the landmark judgment of State of Punjab & Ors. v. Mohinder Singh Chawalam[ix]has held the right to health is integral to right to life. Further the Hon'ble Court in Paramanda Katara v. Union of India,[x]mhas clearly stated that preservation of life is of utmost importance, because if one life is lost it is beyond the capacity of man to resurrect the same. Hence, it is clear that Right to life and Health are in alienable rights, which cannot be bargained at any cost.

Regulatory frame work for clinical trials:

Presently, there exists an extensive set of both rules and regulation for clinical trials in India, ranging from Drug and Cosmetics Act 1940, ICMR Ethics Guidelines 2006, Indian Good Clinical Practice Guideline 2001, Medical Council of India Act- 1956, Central Council for Indian Medicine Act 1970, Guidelines for exchange of Biological Material and to Right to Information Act 2005.

But the regulatory framework with regard to clinical trials[xi] with which we are more concerned is dealt in Drug and Cosmetic Act 1940, Drug and Cosmetic Rules 1945 and the New Drugs and Clinical Rules, 2019[xii](New Rules) and the ICMR ethical Guidelines 2006.

Further, the Central Drug Standard Control Organization (CDSCO) headed by drug controller general of India (DCGI) is a national regulatory authority- assuring safe, efficacious and quality drugs in India; while the ICMR remains the apex body responsible for all the medical research and its ancillary functions.[xiii]

Under the new rules, 2019 it is still debatable as to whether Hydroxychloroquine (HCQ) would fall under the category of new drug' (includes those already approved drugs posing new claims) or an orphan drug' (i.e. drug for treatment of a condition not affecting more than 5 lakh people in India),[xiv]but considering the fact that there exists no substantial law on orphan drug', the HCQ might be proceeded as a new drug'.

In brief, the process for clinical trial would first require filling of an application (as per form CT-04) seeking permission for the trial,[xv] which is to be decided by the DCIG within a maximum span of 30 days (depending on the indigenous nature of the drug), further if the same is not decided within the said period, the application would stand automatically approved.[xvi]Furthermore, all clinical trials are mandatorily required to be registered with the Ethics Committee,[xvii]where the nature of research proposal is subject to extensive review depending on the nature of risk involved.[xviii]

Moreover, the Clinical Trial Registry of India', which is a free online portal open to public inspection, requires all clinical trial to be prospectively registered on a mandatory basis since June 2009.[xix]It is important to note that the participants to the clinical trial, on whom the drug is to be tested are required to give their informed consent to such trials, and also all the adverse affects during the trial (i.e. death, disability, patient hospitalisation- out patient trial, prolongation of hospitalization- inpatient trial, birth defects and other medical occurrences) have to be duly reported to the concerned department, which would compensate accordingly.[xx]Hence, there is a full proof system in place to check the efficiency of any medicine in India, which can be speeded up considering the nature of calamity.

With regard to Covid-19 disease, recently the Drug controller (DCGI) has permitted clinical trial of convalescent plasma in the already treated patients of Covid-19, it is claimed that the anti bodies are said to develop in recovered patients against the dreaded virus, research on which will help in controlling the said disease.[xxi]It is important to mention here that ICMR till date does not intend to go for a clinical trial for the hydroxychloroquine (HCQ) drug.

Questions And Contradictions-An Uneasy Path:

Recently, in a video published by ANI[xxii], Chief epidemiologist of the Indian Council of Medical Research (ICMR), Raman Ganagakhedkar, stating that there exist little evidence as to efficiency of the drug and further stated that the drug was only recommended as a preventive /prophylactic, that too only for the doctors and contacts of lab confirmed cases.[xxiii]As per Priyanka Pulla, a science writer, the statement of the ICMR chief is contradictory to the government's suggestion in its Revised Guidelines on clinical Management of Covid-19',[xxiv]March 31, 2020 which suggest administration of the hydroxychloroquine as a treatment to Covid- 19 patients in Intensive Care Units (ICU's).[xxv]

Further, as per Pulla, though the statement of the ICMR chief with regard to the lack of data on efficiency of hydroxychloroquine is correct but there exist even less evidence to support the fact that hydroxychloroquine can be used as an prophylactic, as there exist no completed study on humans with regard to the same.[xxvi]Moreover, the empirical data available until now from the ongoing vivo trial across the globe to establish the effectiveness of hydroxychloroquine in treating Covid- 19 has shown conflicting results.[xxvii]

It is further important to note that prior to the aforementioned announcement (dated 18 April 2020), of the ICMR with regard to launching of a study on the side effects of hydroxychloroquine, there existed no evidence to the fact that ICMR was conducting either a randomized trial or an observation study, this is evident from the fact that The Clinical Trial Registry of India' on which the drug controller general of India requires trial to be registered prospectively, shows no Indian study of HCQ as a COVID – 19 prophylaxis being registered.[xxviii]

• So it seems rather difficult to understand as to why the ICMR recommend hydroxychloroquine (HCQ) even as prophylactic drug for doctors and household contact persons of proved cases, being fully aware of the lack of evidence with regard to its effectiveness even as a prophylactic and its side-effects?
  
  On the other end, Gangakhedkar (ICMR, Chief) in a recent press conference dated April 18, 2020, has claimed that an observational study with 480 patients, expected to go on for about eight weeks, further added that the said study was not a clinical trial in the light of dearth of enough evidence for the said trial.[xxix]
  
  As per Priyanka Pulla, these statements seem illogical, she draws a strict contradiction to the said statement of Gangakhedkar, with his own statement in another press conference dated April 1, 2020, where Gangakhedkar claimed that as a part of demonstration study hydroxychloroquine was already being administered to the healthcare workers, while in April 18, 2020 press conference he mentioned about the study in future tense, suggesting to the fact that the study has not yet been commenced.[xxx]
   
• Pulla, strongly questions the fact as to whether the study of HCQ drug has begun or not, and if not, what has been the reason for such a delay, considering the fact that numerous healthcare workers across the country are already self- medicating themselves with HCQ?
   
• Further Pulla, also questions the nature of study adopted, as to why did the authorities decided to go for an observational study rather than a well organized randomized control study (RCT) / clinical trial, being absolutely aware of the fact that only RCT could give convincing results?

As according to her, the observational study will give no information on the causation and they would not be able to prove as to whether hydroxychloroquine is helpful in preventing the disease or not. Moreover, she further adds that Gangakhedkar's statement seems more bizzare, when he cries for lack of adequate evidence for randomized trial, as lack of evidence is a perfect scenario for randomized control test.

If you want to prove a point, you should do a well-designed randomized control study. Any other design will not give you convincing proof and you are back to square one.' said Urmila Thatte, (a clinical pharmacologist and bioethicist at the Seth GS Medical College and KEM Hospital, Mumbai).

More so, as mentioned that when the ICMR can seek permission from the drug controller for the clinical trial of Covid-19 plasma in recovered patients[xxxi], then why similar clinical trial cannot be conducted with regard to the hydroxychloroquine drug, and also why the authorities would want to waste their time and money on a study which is of a proven poor quality, considering the fact that the axis of hydroxychloroquine self- medication is continuously lying on the throats of our healthcare workers?

Ensuring Transparency:
In the light of the above development, the question of transparency would genuinely crop up, as it is the need of the hour that authorities should be made accountable for their actions. Under the National Ethical Guidelines of the Indian Council of Medical Research and Right to Information Act 2005 (RTI Act), there is a strong system in force to ensure a fine balance between transparency and right to privacy of the patients. The RTI Act, normally does not warrant/ support the disclosure of personal health information to any third party, exception being larger public interest', interpretation of which still remains a matter of controversy.[xxxii]The word larger public interest' has been wrongfully interpreted by both ends to serve their own interest from time to time.

Though the compulsory registration of any clinical trials with the the Clinical Trial Registry of India' (i.e. open to public inspection) has been a welcome step towards greater transparency, [xxxiii] Central Information commission (CIC) with a decision to an RTI application continues to maintain that though transparency in bioresearch/ clinical trial is important but it may not be divulged in public domain as it includes confidential information concerning numerous strategies of substantial nature, scientific data along with patient related information.[xxxiv]Hence, the transparency in spite of a well-established mechanism is opaque.

The Only Proven Effect:
The only fact which is well established with regard to hydroxychloroquine (HCQ) is its side effects, while it cannot be denied that hydroxychloroquine (HCQ) apart from being used as an anti- malaria drug, is also successfully being used by people suffering with systematic lupus and rheumatoid arthritis but even in their case all prescribed doses of HCQ are customized according to the measurement of individual, based on his/ her liver & kidney function test and since HCQ as a side effect affects retina, visual test are also important, [xxxv] hence there is no uniform dose suitable to all. The massive hoarding of HCQ drug has severely affected such prescribed users since the non availability of the same in the market is creating a havoc on them and also violating their Right to Health.

As per the press release of American Association of Poison Control Centers on Hydroxychloroquine has a variety of following side effects:[xxxvi]

Genetic predisposition: Individuals who have inherited G6PD deficiency may have a serious reaction to hydroxychloroquine. It should be used with extreme caution in people with prolonged QT syndrome or who are on medications for heart rhythm problems as the addition of chloroquine/hydroxychloroquine can increase the risk for fatal dysrhythmia. Azithromycin, which has been suggested by some to be used in combination with hydroxychloroquine for the treatment of COVID, may also cause prolonged QT syndrome increasing the risks of this problem.

Adverse effects for the general population: Some patients taking hydroxychloroquine may experience nausea, vomiting and/or diarrhea. They may also experience headache and dizziness. Irritability, tremor and even changes in mood have been reported.

Most of the symptoms will resolve when the drug is discontinued . However, symptoms of adverse drug effects may be difficult to differentiate from symptoms of the virus itself. Hydroxychloroquine may interfere with drugs used for the treatment of diabetes and produce a drop in blood sugar causing symptoms. People with type I or type II diabetes should be aware of this possibility.

As with any drug, allergic reactions may occur. These medications have a narrow therapeutic window meaning that accidental ingestion of amounts that exceed recommended dosing can be extremely dangerous with toxicity including coma, seizures, cardiac dysrhythmias, low potassium levels, cardiac arrest and death. Even a single pill can be potentially life threatening to a child.'

It is pertinent to mention that as per the above press release some of the adverse side effects are such, which are difficult to be distinguished from symptoms of virus (including Covid-19) itself. Hence, on many occasions it would be difficult to ascertain as to whether the death of the deceased was the result of virus or was a reaction to hydroxychloroquine.

Furthermore, As per Art Krieg, (a former practicing rheumatologist and the founder of Checkmate Pharmaceuticals, a US-based firm that studies cancer immunotherapies),Hydroxychloroquine (HCQ) is associated with impaired production of interferon-alpha molecules[xxxvii], production of which is necessary for the strength of our immune system, as result of blockage in production, our body's defence system to fight against virus such as Covid- 19 weakens, though it may work for those sicker patients having overzealous immune system.[xxxviii]

Since the efficiency of the drug against Covid- 19 is not yet established except for the fact that it can weaken our defense system to fight diseases, hence Krieg in his words said - I would not take HCQ myself to prevent Covid-19 nor would I recommend it to any friends.[xxxix]

In India, the doctors are concerned with the recommendation of the ICMR who has recommended a high dose of 400mg twice a day on the first day causing doctors to avoid the drugs because of the fear of arrhythmia, a heart aliment.[xl]Some of the testimonies are as follows [xli]

My family has a history of heart ailments. HCQ is not suitable for people with heart issues, and thus I am avoiding the drug intake for the time being, as I do not have direct exposure to positive [coronavirus] cases,' (said Dr. Rajeev Ranjan, Senior Resident, Laboratory Medicine at the All India Institute of Medical Sciences in New Delhi).

It is well known that hydroxychloroquine has known side effects, which can put people with heart conditions at an added risk. While the side effects are known, we still do not have any clarity on its effectiveness in treating COVID-19. Thus, considering its profile, many medical professionals in our community are conscious and rethinking HCQ intake, '(Dr. Harjit Singh Bhatti, president of the Progressive Medicos and Scientists Forum, told Anadolu Agency).

Medicine that can affect people with cardiac irregularities should only be taken by recommended people, (said Luv Aggarwal, Joint Secretary of the Ministry of Health and Family Welfare, in a daily press briefing).

Hydroxychloroquine and Self –Medication:
Meanwhile, the time bomb of self- medication (SM) of hydroxychloroquine (HCQ) among the healthcare worker and other contact persons, continue to tick at an unpredictable pace, needless to mention that soon after the ICMR recommendation on usage of HCQ in early this April, the panicked general public swept the pharmacy stores across the country off the drug, hence the problem is far greater than perceived, which not only threatens the healthcare workers but also the public at large. In a recent 2019 study on the prevalence of self –medication (SM) to treat self-diagnosed symptoms without legitimate prescription, India's standing has emerged significantly high.[xlii]

In other words, the Indian population is more susceptible to self –medicating themselves in order treat self- diagnosed symptoms of any disease without actually consulting a health care professional. In Assam, soon after the ICMR recommendation of HCQ regime, a doctor of Guwahati's Pratiksha Hospital died after taking the HCQ drug as per the directions, raising a serious question on the reliability of this untested drug.[xliii] This issue is further complicated at hands the respective state governments, who are cheerful of their sufficient HCQ stock and some of whom are considering the distribution of the same as prophylactic/ preventive drug. The example of the same being Maharashtra, where the government is considering distribution of HCQ tablets as a preventive measure openly in Dharavi, Mumbai.[xliv]While the health care workers in Rajasthan and Bihar were given the drug without screening for the risk factors as claimed by concerned officials.[xlv]

Though some states like Karnataka have behaved rather responsibly by screening the receivers with electrocardiogram (ECG) to monitor their heart rates.[xlvi]While the state of Telangana has emerged as a true vigilante by saying no' to self- medication and by enlightening people about the side effect of the drug, moreover the concerned local department of the state has been taking strict measures including instructing the pharmacist not to sell HCQ tablets to any one without genuine prescription.[xlvii]Hence the authorities should have acted more diligently before jumping to any recommendations as such and thereby putting the lives of a billion people at stake.

Conclusion:
In the light of the above analysis it can be well concluded that the Right to Health, more so Right to proper correct Health care, as originating from Right to life under Article 21 of the Constitution may have been violated, as the Indian Council for Medical Research (ICMR) through its recommendations, has exposed the entire nation (especially the health care workers, contacts of the lab- confirmed cases) to the adverse side effects of non-clinically tested hydroxychloroquine (HCQ) drug, a drug the effectiveness of which till date stands to question.

That by virtue of the said act the entire nation has been converted into a testing lab/ clinic, where the individuals are merely non- consenting human specimen, hence the ICMR has not only denied the basic right to health but also denied right to dignified life under Article 21 of the constitution. Hence the violation to Art. 21 of the constitution is manifest in nature.

It is also feared that if thousands of health care workers in lieu of the ICMR recommendation start self- medicating the HCQ drug, there would be a massive pool of diseased health care workers. The storm of COVID- 19 may not last long but if strict responsible measures are not adopted by the concerned authorities, a storm infested with the side- effects of HCQ drug may follow, which may not then find any health care worker to deal with.

End-Notes:

1. Melissa Healy, Malaria Drugs fail to help coronavirus patients in controlled studies, Los Angeles Times,Apr. 17, 2020, available at: https://www.latimes.com/science/story/2020-04-17/malaria-drugs-fails-to-help-coronavirus-patients-in-controlled-studies , (Last Modified April 19, 2020).
2. ET Online, Coronavirus: ICMR recommends hydroxychloroquine for high- risk population, Economic TimesMar. 23, 2020, available at: https://economictimes.indiatimes.com/industry/healthcare/biotech/pharmaceuticals/indias-covid-task-force-recommends-hydroxychloroquine-for-high-risk-patients-with-strict-riders/articleshow/74774540.cms?from=mdr , (Last Modified April 19, 2020).
3. Divya Rajagopla, Hydroxychloroquine becomes a Schedule H1 drug as hoarding leads to shortage, Economic times, Mar.27,2020, available at: https://economictimes.indiatimes.com/industry/healthcare/biotech/pharmaceuticals/hydroxychloroquine-becomes-a-schedule-h1-drug-as-hoarding-leads-to-shortage/articleshow/74842650.cms?from=mdr (Last Modified April 19, 2020).
4. Jack Goodman and Christopher Giles, Coronavirus and chloroquine: Is there evidence it works?, BBC News, April 6, 2020, available at: https://www.bbc.com/news/51980731, (Last Modified April 19, 2020).
5. Ibid.
6. Outlook India, COVID-19: ICMR launches study on side effects of hydroxychloroquine, Outlook, Apr.18, 2020 https://www.outlookindia.com/newsscroll/covid19-icmr-launches-study-on-side-effects-of-hydroxychloroquine/1807105 (Last Modified April 19, 2020).
7. AIR 1984 SC 802.
8. 1978 SC 597.
9. (1997) 2 SCC 83.
10. AIR 1989 SC 2039.
11. clinical Trial in relation to new drug or investigational new drug means, any systematic study of such new drug or investigational new drug in human subjects to generate data for discovering or verifying its- i). Clinical or ii) pharmacological, including pharmacodynamics, pharmacokinetics or iii.) Adverse effects, with objective of determining the safety, efficiency or tolerance of such new drug or investigational new drug.
12. Rule 97(Rule 122DAA): New Drugs and Clinical Rules, 2019 supersede existing Part XA and Schedule Y of the Drug and Cosmetic Rules 1945.
13. Gogtay, Ravi and Thatte, Regulatory Requirements For Clinical Trials In India: What Academicians Need To Know, Indian Journal Of Anasthesia, Mar. 2017, available at: https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5372399/ (Last Modified on April 20, 2020).
14. Rule 2, New Drugs and Clinical Trial Rules , 2019.
15. Rule 21, New Drugs and Clinical Trial Rules , 2019.
16. Rule 23, New Drugs and Clinical Trial Rules , 2019.
17. Rule 7, New Drugs and Clinical Trial Rules , 2019.
18. Supra N. 13.
19. Ibid.
20. Ibid.
21. Press Trust of India, Drug Controller General permits Clinical trial of convalescent plasma in Covid-19 patients IndiaToday, April 18, 2020, available at:https://www.indiatoday.in/india/story/drug-controller-general-permits-clinical-trial-convalescent-plasma-covid19-patients-1668416-2020-04-18(Last Modified on April 21, 2020).
22. ANI News, Never recommended Hydroxychloroquine to general public: ICMR, ANI News, Apr.11, 2020, available athttps://www.youtube.com/watch?v=15ZTu4Ag9SE, (Last Modified April 19, 2020).
23. Priyanka Pulla , Why India's stated policy on Hydroxychloroquine makes no sense, The Wire,Apr. 14, 2020, available at: https://science.thewire.in/health/covid-19-indian-council-of-medical-research-raman-gangakhedkar-hydroxychloroquine-prophylaxis-clinical-equipoise/ (Last Modified April 19, 2020).
24. Revised Guidelines on Clinical Manangement of COVID-19, Government of India, Ministry of Health & Family Welfare, April.14, 2020, available at: https://www.mohfw.gov.in/pdf/RevisedNationalClinicalManagementGuidelineforCOVID1931032020.pdf , (Last Modified April 19, 2020).
25. Supra n. 23
26. Ibid
27. Kome Gbinige, Kerstin Frie, Should Chloroquine and Hydroxychloroquine Be Used to Treat COVID-19? A Rapid Review, U.S. National Libraray of Medicine, Apr. 7, 2020, available at: https://pubmed.ncbi.nlm.nih.gov/32265182/ , (Last Modified April 19, 2020).
28. Supra n. 23
29. Priyanka Pulla, ICMR's Latest Clarification on its Hydroxychoroquine Policy is Just Baffling, The Wire, April 19, 2020, available at: https://science.thewire.in/health/covid-19-hydroxychloroquine-policy-raman-gangakhedkar-icmr-observational-study/ (Last Modified on April, 20, 2020).
30. Ibid
31. Supra n 21
32. N.N. Mishra, Lisa S.Parker, V.L Nimgaonkar, S.N. Deshpande ,  Privacy and the Right to Information Act 2005, Indian Journal Of Medical Ethics, 2008, available at: http://ijme.in/articles/privacy-and-the-right-to-information-act-2005/?galley=html (Last modified on 21-04-2020).
33. Supra n. 23
34. Suja Nair Shirodkar, CIC expmts clinical trial related information from disclosure under RTI Act, RTI Today, June 16, 2011, available at: http://www.nishithdesai.com/fileadmin/user_upload/pdfs/CIC_exempts_clinical_trial_related_information_from_disclosure_under_RTI_Act.pdfhttp://www.nishithdesai.com/fileadmin/user_upload/pdfs/CIC_exempts_clinical_trial_related_information_from_disclosure_under_RTI_Act.pdf (Last Modified on April 21, 2020).
35. Hydroxychloroquine, Versus Arthritis, available athttps://www.versusarthritis.org/aboutarthritis/treatments/drugs/hydroxychloroquine/, (Last Modified April 19, 2020).
36. American Association of Poison Control Centers on Hydroxychloroquine Side Effects, American Association of Poison Control Centers, Mar.25, 2020, available at: https://piper.filecamp.com/uniq/Klk1IGw3Mzt29mhN.pdf (Last Modified April 19, 2020).
37. Karim Sacre, Lindsey A Criswell and Joseph M McCune, Hydroxychloroquine is associated with impaired interferon-alpha and tumor necrosis factor- alpha production by plasmacytoid dendritic cells in systemic lupus ,erythematosus ,U.S. National Libraray of Medicine, Jun. 27, 2012, available at: https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3446541/(Last Modified April 19, 2020).
38. Priyanaka Pulla, Does a Pandemic Justify Using Hydroxychloroquine to Beat the Coronavirus? The Wire, Apr.7,2020, available at:https://science.thewire.in/health/coronavirus-covid-19-hydroxychloroquine-icmr-guidelines-long-qt-syndrome/ (Last Modified April 19, 2020).
39. Cheena Kapoor, India: Doctors concerned over drug to treat corona virus, Anadolu agency, Apr. 10, 2020, available at: https://www.aa.com.tr/en/asia-pacific/india-doctors-concerned-over-drug-to-treat-coronavirus/1799330 (Last Modified on 21-04-2020).
40. Ibid.
41. Rashid , Chhabra , Kashyap, Undela, Gudi , Prevalence and Predictors of Self- Medication Practices in India: A Systematic Literature Review and Meta- Analysis, US National Library of Medicine, Nov. 21, 2019, available at: https://www.ncbi.nlm.nih.gov/pubmed/31763976 (Last Modified on 21-04-2020).
42. Hemanta Kumar Nath, Coronavirus in India: Guwahati doctor dies after allegedly taking hydrochloroquine, India Today, Mar. 30, 2020, available at:https://www.indiatoday.in/india/story/coronavirus-in-india-guwahati-doctor-dies-after-allegedly-taking-hydroxychloroquine-1661535-2020-03-30(Last Modified on April 21, 2020).
43. ET online, Maharashtra government may hand out HCQ tablets in slums to curb Covid spread, The Economic Times, Apr. 13, 2020, available at: https://economictimes.indiatimes.com/news/politics-and-nation/maharashtra-government-may-hand-out-anti-malaria-drug-in-slums/articleshow/75117043.cms (Last Modified on April 21, 2020).
44. Supra n. 38.
45. Ibid.
46. M. Sai Gopal, Telangana says no' to self- medication, Telangana Today, Apr. 21, 2020, available at: https://telanganatoday.com/telangana-says-no-to-self-medication (Last Modified on April 21, 2020).