'Sedition is overt behaviour that aims toward revolt against the existing
order through speech and organisation. Sedition frequently involves the
violation of a constitution as well as the instigation of rebellion against
established authorities. Any disturbance that isn't directly and overtly violent
against the law is considered sedition. Seditious language is seditious libel. A
seditionist is someone who participates in or advances sedition.'
No matter what you think about it, this definition of sedition that I discovered
elsewhere seems rather dangerous. Everyone will agree, after knowing what
sedition is, that it poses a severe danger to national security and creates
resentment among the public toward their own elected government.
To put a stop to it, the government must intervene. It must take prompt action
to put a stop to these thieves. So that our nation may grow without any
interference from our administrations, the culprits should be captured as soon
as feasible and prosecuted by the law.
There is an issue. Every story has two sides, and just like sedition in India,
which is distinctly neither black nor white, 356 sedition-related incidents were
registered between 2015 and 2020. However, just 12 of those held throughout the
course of seven sedition trials over the course of these six years were
Law of Sedition
On July 15, Chief Justice N.V. Ramana expressed concern over the "colonial-era"
sedition statute's continued existence. He said that sedition was like giving a
carpenter a saw and telling him to cut a piece of wood, and then telling him to
clear the forest. His comments and a series of recent judgements by the top
court have sparked a contentious debate over how frequently state agencies (mis)apply
The Indian Constitution states in Article 19(1)(a) that everyone has the freedom
to express their opinions. However, the freedom of speech and expression is
subject to some reasonable restrictions under Article 19, therefore this right
is not unrestricted.
However, under section 124-A of the Indian Penal Code, 1860, actions that are
considered disrespectful to the Indian government and that can be carried out by
words, signs, or other means of communication are punishable. Speech that is
considered to be antagonistic to or dangerous to the state is illegal under the
crime of sedition. The protection afforded by Section 124A is fairly wide and
does not include any criticism made of any particular administrative decisions
or policies in good faith. It includes activities that defame the government.
History of Law Of Sedition
Meaning of Sedition under Section 124-A IPC
- "Action or speech that leads to revolt against the authority of the
state" is what is meant by sedition. The IPC's Section 124A, which addresses
the Law of Sedition, is viewed as a reasonable restriction on the right to
free expression. It was initially exhibited in 1870 and Thomas Macaulay
- The section was first included to address the growth of Wahabi activity
between 1863 and 1870. The colonial authorities faced a difficulty as a
result of these actions.
- Indian nationalist leaders were involved in some of the most well-known
sedition cases of the late 19th and early 20th centuries.
- The earliest of these was Jogendra Chandra Bose's trial in 1891. He
served as the newspaper Bangobasi's editor. He published a piece denouncing
the Age of Consent Bill for endangering the faith and its coercive treatment
of Native Americans.
- In 1897, Bal Gangadhar Tilak's articles in Kesari were the subject of
- The other well-known case included Mahatma Gandhi's 1922 sedition trial.
Sedition, according to Gandhi, is "the prince among the political sections
of the IPC meant to destroy the freedom of the citizen."
Meaning of Sedition under Section 124A of IPC, 1860 "Whoever, by words, either
spoken or written, or by signs, or by visible representation, or otherwise,
brings or attempts to bring into hatred or contempt, or excites or attempts to
excite disaffection towards the Government shall be punishable with Life
Sedition in Other Laws
What constitutes "sedition" is hotly contested in India. The following elements
must be present for an act to be classified as "seditious" under the Indian
- Any words, whether spoken or written, or any signs, such as placards or
posters (visible representation)
- Must foster animosity, contempt, and disillusionment toward the Indian
- Must lead to "imminent violence" or general unrest.
The following actions have been deemed to be "seditious" in accordance with
the Court's interpretation of Section 124-A of the Indian Penal Code, 1860 like
raising of anti-government chants by organisations, such as "Khalistan Zindabad."
It was believed that raising slogans by one or two people casually wasn't
For a speech to be deemed seditious, it must encourage violence or other forms
of public disorder. It has been further interpreted in subsequent decisions to
encompass "incitement of imminent violence." any written material that
encourages violence and disturbance in the public.
Disloyality in Action
Disloyalty in action has been referred to as "sedition." The goal of the
sedition laws is to sow dissatisfaction and rebellion, to incite hostility to
the government, and to defame the legal system. Sedition is a crime against
society since it includes any actions that defy the authority of the state,
incite civil war, or otherwise foster unrest in the community.
Punishment Under Section 124-A
Section 124-A of the IPC lists the following penalties: � It is a non-bailable
Available Defences to a person charged with Sedition
- A fine may be levied to any sentence of imprisonment ranging from three
years to life.
- The offender is ineligible for any government employment after being
convicted of this crime.
To get the exemption from Criminal Liability, the following are the defences:
That he did not make the sign or representation or not speak or write the words,
or not do any act in question. He did not attempt into the contempt or attempt
disaffection. Such disaffection should not be towards the Government.
Sedition and Article 19(1)(a) of Indian Constitution
Free expression is accepted by everybody as a fundamental human right and has
grown in importance on a global scale.
Various rights are protected in India under Part-III and Article 19 of the
Indian Constitution. The freedom of a person to communicate ideas and
information both inside and outside of India means that the aforementioned right
is not geographically limited. The courts have been given the power to protect
and uphold a citizen's rights. Although "freedom of speech and expression" is
protected by Article 19(1)(a), it is restricted by the provision in Article
19(2) that outlines the circumstances in which this right may be restricted by
In Niharendu Dutt's Case
 prosecution for sedition, the Federal Court
determined to interpret Section 124A of the IPC in conformity with British Law.
It had determined that a need under Section 124A was the potential to disturb
the peace. The Privy Council believes that section 124A does not need the
incitement of violence or a tendency to disturb the peace.
In Tara Singh v. State
, the legitimacy of Section 124A of the IPC was
immediately contested. This provision was declared unlawful by the East Punjab
High Court because it constrained the plaintiff's freedom of speech and
expression. The Constitution (First Amendment) Act of 1951 altered the First
Amendment's guarantees of free speech and expression in two ways. By introducing
further justifications, it significantly increased the scope for free expression
limits; the restriction imposed on Article 19(1)(a) must be fair.
This raises the issue of whether Section 124A of the IPC conflicts with Article
19(1)(a). The justifications listed below support this: In that it breaches
Article 19(1)(a), which protects the right to free expression, and is not
covered by the qualifier "for the sake of public order," Section 124A of the IPC
is extra vires of the constitution.
Section 124A is not unconstitutional since the phrase "in the interests of
public order" has a wider connotation and shouldn't be confined to just one
aspect of public order. Section 124A IPC is both partially invalid and partially
In Indramani Singh v. State of Manipur
, In contrast to the restriction
placed on the freedom of speech and expression protected by Article 19(2), it
was determined that Section 124A, which aims to put limits on igniting just
disaffection, is extra vires. Article 19(1)(a) of the Constitution was deemed to
be extra vires by the Allahabad High Court in 1959.
Sedition and Indian Freedom Struggle
Mahatma Gandhi was accused of seditious activity. Because he had written three
"politically sensitive" articles in his weekly journal Young India, which was
published from 1919 till 1932, Gandhiji was put in prison on the grounds of
sedition. He was sentenced to six years in jail. He was accused of trying to
incite resistance to the British government, interfering with loyalties, and
shaking manes. He authored the opening chapter of his autobiography.
The Story of my Experiments with Truth, while he was incarcerated and it was
about the Satyagraha movement in South Africa. After two years, due to
appendicitis, he was granted release. Bal Gangadhar Tilak was ultimately found
guilty as a result. Bal Gangadhar Tilak was twice charged with sedition due to
First, he was charged with sedition in 1897 for allegedly inciting violence that
resulted in the deaths of two British policemen. In 1898, he was given bail
while on trial.
Second, he supported the Indian revolutionaries and issued an editorial urging
swift Swaraj, or self-rule, in his periodical "Kesari." He was sentenced to
sedition for his conduct and held in Mandalay, Burma, from 1908 until 1914.
Constitutionality of Law of Sedition In India
The following are some laws which cover Sedition law:
Disaffection and the State
- The Unlawful Activities (Prevention) Act (Section 2(o) (iii)).
- The Code of Criminal Procedure, 1973 (Section 95)
- Indian Penal Code, 1860 (Section 124A)
- The Seditious Meetings Act, (1911)
Dissatisfaction and therefore the State In Srinagar, the Committee for the
Discharge of a Prisoner hosted a lecture with the theme "Azadi, the single Way."
The issue started when Arundhati Roy, Syed Ali Shah Geelani, Varavara Rao, and
other speakers at the Seminar were accused of seditious activity. The Central
Government reportedly opposed starting legal procedures in this issue, according
to the media. However, there have been allegations of lawsuits being filed in
Delhi, the capital of India. intimidation about the lawsuits being brought
against Roy, Geelani, and other seminar speakers in various regions of the
Queen Empress v Jogendra Chunder Bose (1891) 
Sedition Trial of Lokmanya Tilak (1897) 
- Jugendra Bose criticised the Age of Consent Act of 1891 in a piece of
- His critique was seen as disrespect for the government.
- However, once he was granted bail, the matter was subsequently
Sedition Trial of Lokmanya Tilak (1908)
- The celebration reports, together with an 1894 study by Professor R. P.
Karkaria on the Maratha monarch Shivaji, were published by Bal Gangadhar
Tilak. In 1894, Karkaria delivered his paper to the Royal Asiatic Society of
Bombay. The yearly Shivaji Coronation ceremony was made possible by this
publication. Tilak afterwards made the reports of the festivities public.
- These festivities were described as "Shivaji's Utterances" by Tilak in
his newspapers, Kesari and Mahratta.
- Justice Arthur Strachey presided over the proceedings.
- This sedition trial is infamous in history because it involved an
attempt to incite animosity against the government and was classified as
seditious under Section 124A. The interpretation of Section 124A was thus
- Tilak received a harsh 18-month jail term as punishment.
Mohandas Karamchand Gandhi's Sedition Trial (1922)
- On May 12 and June 9, 1908, respectively, Tilak wrote two pieces in
Kesari, headlined "The Country's Misfortune" and "These Remedies aren't
- In accordance with the recently created Section 124A, he received a 6
year jail term in Burma (Now, Myanmar).
Post-Independence �Supreme Court Decisions
Brij Bhushan and Another v. The State of Delhi
- Due to his articles in his daily, "Young India," Mahatma Gandhi was
sentenced to six years in prison.
- "Bringing or trying to stir disaffection towards His Majesty's
Government constituted by law in British India" was the allegation levied
- Section 124A was described by Mahatma Gandhi as "Prince among the
political parts of the Indian law code meant to restrict the citizen's
(1950) and Romesh
Thappar v. The State of Madras
- The Supreme Court ruled that it was unconstitutional for a statute to
limit speech if it may disrupt public order.
- The "First Constitution Amendment," which replaced "undermining the
protection of the State" with "in the interest of public order," was
inspired by the court's ruling.
The Punjab High Court had declared Section 124A invalid in 1951. The
Allahabad High Court made a similar decision in 1959 and came to the same
conclusion that it violated the fundamental right to free expression.
Kedar Nath Singh vs State of Bihar (1962) 
P. Alavi vs State of Kerala (1982) 
- In this case, the constitutionality of Section 124A was put to the test.
- A Forward Bloc member was accused of sedition after making a speech.
- The Supreme Court held:
- It is seditious to say or write anything that implies "subverting the
govt. by violent means," including the idea of "revolution."
- Sedition is considered to be a failed attempt with incitement.
- Creating chaos in public was seditious.
- There was no "unreasonable difference" made between criticising the
government's actions and criticising the government as a whole.
Balwant Singh vs State of Punjab (1995) 
- The Supreme Court ruled that using slogans or denigrating the government
or judicial system does not constitute sedition.
Sanskar Marathe v. State of Maharashtra (2015)
- Balwant Singh who was the Director of Public Instructions (DPI) in Punjab,
Chandigarh among other two, was speculated to have shouted pro-Khalistan slogans
on the day of former PM Indira Gandhi's assassination.
- The apex court held that unless there's public disorder merely
sloganeering can't attract punishment under Section 124A.
Rajat Sharma v. Union of India Case (2021)
- In this instance, the Bombay High Court established instructions that
police officers must abide by before bringing a sedition prosecution against
- These recommendations involve a critical analysis of the seditious
content. The police must assess if the statements and acts led to
dissatisfaction and treason against the government before coming to a
- According to the court's decision in this instance, rejecting the
government's policies and ideologies does not constitute sedition.
Therefore, it is not possible to use the Sedition clause to calm the unrest
(criminalizing the critics).
Improvement or change through legal means in opposition to governmental measures
is not viewed as seditious behaviour.
Strong language that conveys resistance to governmental regulations and deters
behaviour that may otherwise result in violent acts that disrupt public order.
To make sure that these actions are corrected legally without inciting animosity
or disloyalty that can lead to disturbance in the public square or the use of
force, or to better the situation of the people.
National Crime Records Bureau (NCRB) 
The National Crime Records Bureau (NCRB) reports that between 2015 and 2020, 356
instances of sedition under Section 124A of the IPC were reported, and 548
persons were detained.
Between 2015 and 2020, 356 sedition-related cases were reported. However, just
12 of those detained in seven sedition trials throughout this six-year period
were found guilty.
There were 73 sedition-related cases across the nation in 2020, 93 in 2019, 70
in 2018, 51 in 2017, 35 in 2016, and 30 in 2015.
In 2020, 3.3% in 2019, 15.4% in 2018, 16.7% in 2017, 33.3% in 2016, and 3.3% in
2019 were the conviction rates for sedition cases.
In 2020, 44 people in total were detained for violating the legislation on
dissent, as opposed to 99 in 2019, 56 in 2018, 228 in 2017, 48 in 2016, and 73
Out of 548 people, 290 between 2015 and 2020 belonged to the 18 to 30 year age
group, while the remainder are in the 30-35 age range.
Over the past three years that the NCRB has provided crime statistics
(2018-2020), Assam had the most sedition arrests, with 23 in 2018 and 2019, and
10 in 2020. The states with the most arrests made under Section 124A of the IPC
in 2018 were Andhra Pradesh (15), Madhya Pradesh (4), and Chhattisgarh (3); in
2019, Karnataka (18), Nagaland (11) and Uttar Pradesh (9) had the most; and in
2020, Uttar Pradesh (8), Nagaland (7), and Karnataka (6) had the most. In 2020,
Manipur had 15 sedition cases, more than Assam (12), Karnataka (8), or Uttar
Pradesh (7). (1).
Sedition Around The World
In the UK, the 1960s saw the end of the sedition statute, which was ultimately
repealed in 2009. Sedition committed by an alien (a resident who is not a
national of the country) is nonetheless illegal.
Some sedition laws in the USA have been revoked or declared to be unenforceable.
The courts provide free expression broad protection. The US Code's Sections 2381
through 2385 address treason, sedition, and subversive actions that call for the
overthrow of the government. To protect the right to free expression, however,
the legislation is rarely used.
In 2017, Singapore, which, like India, inherited colonial English law, abolished
its sedition statute, which had been put in place 83 years earlier to quell
local resistance to British colonial control. Key provisions of the Sedition
Act, according to the Home Ministry, have been out of date for a while in
contemporary Singapore, and prosecutions under the statute are extremely rare.
It claimed that a number of additional legislation can adequately solve the
problems covered by the sedition law. Over the years, Singapore has passed
additional legislation to address the problems addressed by the Act in a more
focused and calculated way.
The act of 'sedition' ceased to be a crime following the introduction of The
Crimes (Repeal of Seditious Offences) Amendment Bill in 2007 that came into
effect from January 1, 2008.
The Crime Act of 1920 was Australia's first comprehensive piece of law to
include a sedition offence. In 1984 and 1991, reviews were conducted on it. The
Anti-Terrorism Act (No 2) 2005's Schedule 7 underwent changes in 2005. The usage
of the term "sedition" to describe the offences stated in the 2005 amendment was
examined by the Australian Law Reform Commission (ALRC). The National Security
Amendment Act of 2010 adopted an ALRC proposal in 2010, changing the term
"sedition" to "urging violence offences." Scotland On March 28, 2011, the common
law offence of sedition was eliminated by Section 51 of the Criminal Justice and
Licensing Act, 2010.
Sedition was deemed "unconstitutional" in Indonesia in 2007, following the
directives of the Dutch colonisers.
Sedition laws were repealed in the Republic of Korea in 1988 as part of
political and legal changes.
A handful of journalists have previously been imprisoned under Ghana's Criminal
Libel and Seditious Laws, which were overwhelmingly abolished on July 27, 2001.
Following a unanimous majority in the House, the Criminal Code (Repeal of the
Criminal and Seditious Laws Amendment Bill) Act 2001 was repealed.
Sedition legislation controversies are not brand-new. Even Mahatma Gandhi
described Section 124A as a tactic used to restrict citizens' freedoms. The
application of the legislation by successive administrations against, among
others, political leaders, activists, and the media has been criticised as an
effort to stifle dissent. State and federal administrations have both exploited
Jibon Singha, the leader of the Kamtapur Liberation Organization, was recently
charged with sedition for referring to Mamata Banerjee as a "outsider" by the
West Bengal government. In another instance, the Lakshadweep government accused
filmmaker Aisha Sultana of violating the sedition act for her remark in which
she referred to Praful Patel, the UT's administrator, as a "bioweapon."
Government data shows that between 2014 and 2019, 326 sedition instances were
reported nationwide, however only six people were found guilty in these
proceedings. Journalist Kishorechandra Wangkhem of Manipur was similarly
detained on suspicion of sedition and later charged with the NSA, but the
Manipur High Court also granted him bail.
Reasons behind its Support
- The IPC's Section 124A is helpful in the struggle against terrorist,
separatist, and anti-national organisations.
- It also protects the elected government from attempts to overthrow it
via force or illegal means.
- If disrespecting the court results in criminal prosecution, then
disrespecting the government ought to do the same, as maintaining the
existence of the legal government is a requirement for the stability of the
- Maoist rebel groups successfully run a parallel government in a number
of states' various districts. These groups openly support a revolution to
overthrow the state legislature.
Therefore, repealing Section 124A just because it has been improperly used in
some well publicised cases would be a bad idea.
Reasons behind its Criticism
Poor implementation of court guidelines: The judiciary provided guidance to the
law enforcement agencies about its applicability each time a sedition case was
dismissed. However, the law enforcement organisations do not adhere to the
recommendations in text and spirit.
Supreme Court Intervention on validating its constitutionality
- Growing abuse of Sedition:
According to recent data, sedition charges under
Section 124A have surged by 160%. While the conviction rate decreased from 33.3%
in 2016 to 3.3% in 2019.
- Sedition has been outlawed in the UK:
Sedition was outlawed in the UK in 2010.
India, meanwhile, is still adhering to the British Empire's legal system.
Similar to this, the term "sedition" was deleted from references to "urging
violent crimes" in Australia after the Australian Law Reform Commission's (ALRC)
- Law Commission Recommendation:
The Law Commission of India questioned whether
Section 124A should be kept in place in 2018. Even the removal or revision of
Section 124A of the Indian Penal Code was urged.
- India signed the International Covenant on Civil and Political Rights (ICCPR)
in 1979, going against its international commitment.
- It lays out widely regarded norms for the defence of free speech. However,
abuse of the term "sedition" and arbitrary charging are in odds with India's
- There are sections in both the IPC and the Unlawful Activities Prevention Act
that make "disturbing the public order" or "overthrowing the government by
violence and criminal means" illegal. These are adequate to safeguard national
integrity. Section 124A is not specifically required.
The Indian Penal Code's Section 124-A has been suspended by the Supreme Court,
which also requested that neither the Central nor state governments file any
FIRs under this provision.
Governments should refrain from using the sedition clause until the Center's
review of the provision is complete, according to a bench led by Chief Justice
N.V. Ramana and composed of Justices Surya Kant and Hima Kohli. The apex court
has given the Central government permission to review and reevaluate the
provisions of Section 124A of the IPC, which makes sedition a crime.
"It will be prudent to wait to apply this legal provision until additional
review is complete. When the matter is being reviewed by the Center, we hope and
anticipate that the Central Government and States would refrain from filing any
FIRs, conducting further inquiries, or using coercive measures according to
Section 124A IPC "Ordered by the Supreme Court. According to the SC, if sedition
complaints are filed, the parties are free to appear in court and the judge is
required to quickly resolve the matter.
Expected Assumptions for its future
Many nations throughout the world, including Ireland, Australia, Canada, Ghana,
Nigeria, and Uganda, have recently modified or eliminated their laws on
sedition. Sedition has been outlawed even in the United Kingdom, where Indian
law was based, according to the Coroners and Justice Act of 2009.
It is crucial to educate the public, law enforcement, the executive branch, and
the lower judiciary about the modified section in order to combat these.
Several private member bills on sedition have been submitted in India, and the
bulk of them call for reform rather than repeal. While Section 124A of the IPC
was called out as being draconian and colonial in the private member bills put
forth by Shri D. Raja, Shri P. Karunakaran, and Shri Elamaram Kareem, other
bills, including those from Shri Shashi Tharoor, Shri Bhartruhari Mahtab, Shri
Saugata Roy, and Shri Baijayant Panda, propose reformation of the provision.
While some people may be excited by the potential elimination of sedition in the
nation, several private member bills have suggested modifying the restrictions
of Section 124A of the IPC. Even the Law Commission believes that sedition is
crucial for preserving national integrity in its comment document.
A few of the
changes may be:
- Adding explanation providing that acts expressing disapprobation of the
measures of the government or the administrative action of the government
would not amount to sedition
- Adding a clarification that sedition would apply only if it directly
results in incitement of violence and commission of an offence of certain
- Adding a clarification regarding the scope of "disaffection" under this
- Adding a clarification regarding legitimate protests.
- Adding procedural safeguards in Section 124A of the Code of Criminal
Procedure or through policy guidelines.
It might be claimed that despite Kedarnath v. State of Bihar
instructions, Section 124A of the IPC is still being misused by the police and
state agencies, making any reforms unlikely to be effective in practise. It may
also be argued that, in the absence of any institutional improvements, changing
the language of Section 124A alone would not significantly alter the current
situation. It is crucial to educate the public, law enforcement, the executive
branch, and the lower judiciary about the modified section in order to combat
these. Advocacy efforts are necessary to inform the many facets of society about
the significance of this provision in addition to the change.
The future of dissent and free expression in the nation may benefit from
repealing or amending the sedition statute. The legal reforms will have a
significant impact on whether a person feels comfortable voicing beliefs that
are opposed to those of the government. One can only hope that the alterations
safeguard the people's right to free expression and dissent while taking into
account the interests of the nation and security.
- To address the issue of misuse, the government must train law
enforcement officials. The enforcement agencies may get training on the
implementation of sedition laws and other criminal defamation laws, as well
as on when they do not apply.
- Parent-Child Relationship: The government must treat all of its citizens
as though they were its children. Parents don't readily abandon their
children despite the insults (sedition) they receive from youngsters
- The state should also acknowledge that prominent people will inevitably
- The government may pass the Protection of Speech and Reputation Bill,
2016, in amended form. The Private Member's Bill has certain crucial
- Determining the maximum claim amounts and prohibiting governmental
entities, municipal authorities, and other organisations from bringing libel and sedition
lawsuits (statutory functions).
- Imposing sanctions for less serious transgressions, such as apologies,
corrections, and retractions.
India is the largest democracy in the world and the right to free speech and
expression is an essential ingredient of democracy. Dissent is the lifeblood of
democracy. If the criticisms reach at the right time to the government, then it
can save a lot of resources, government machinery, etc. On the other hand, to
secure national integrity, divisive forces have to be kept in check. Preventing
wrongful enforcement and misuse alone can remove the majority of the criticism
against the Sedition. So the government must prioritize that.
- Ipleaders,'Law of Sedition In India'(Ipleaders, 14 February 2018)< https://blog.ipleaders.in/law-of-sedition/>
accessed 05 October 2022
- AIR 1939 Cal 703
- 1951 AIR 441, 1951 SCR 729
- 1955 CriLJ 184
- (1892) ILR 19 Cal 35
- (1898) ILR 20 All 55
- (1908) 10 BOMLR 848
- (1920) 22 BOMLR 368, 58 Ind Cas 915
- 1950 AIR 129, 1950 SCR 605
- 1950 AIR 124, 1950 SCR 594
- 1962 AIR 955, 1962 SCR Supl. (2) 769
- 1982 CriLJ 94
- 1976 AIR 230
- (2015) SCC BOM 587
- (2021) 5 SCC 585
- Marziya Sharif,'548 sedition related arrests since last six years: NCRB
data'(Siasat Daily, 10 May 2022 ) < https://www.siasat.com/548-sedition-related-arrests-since-last-six-years-ncrb-data-2324262/>
accessed 05 October 2022
- Praveen Shekhar, 'How various countries have junked sedition law' (India
Today, 11 May 2022) accessed 05 October 2022