Combating Stereotypes Concerning Persons with Disabilities

A Compendium of Disability Inclusive Terms

**Nayan Chandra Mishra and Aditya Singh Jethwant 

Context

Words have varied meanings and unique connotations, either evolved through rules of grammar, or extraneous factors including history, region, religion, and context. They have a substantial impact on an individual’s psychology and mindset, and over time, their usage assimilates into the vocabulary of contemporary society. Words can also nurture implicit bias and stereotypes, causing attitudinal barriers and fostering an environment that encourages discrimination against certain sets of population. With this idea  the Supreme Court of India (SC) has started a movement to transcend the shackles of archaic and derogatory terminologies/sentences used for disadvantaged groups, including persons with disabilities, women, and those from the LGBTIQA+ community, from the legal discourse and judicial findings and introduce words/phrases with neutral or positive connotation.

The SC in the Handbook on Combating Gender Stereotypes and Sensitisation Module for the Judiciary on LGBTIQA+ community succinctly reflected on why words/phrases/sentences matter and how they affect the contours of social justice and equality in the society. As the SC is in the process of compiling a similar handbook for disability inclusive terms for the judiciary, in the interim this compendium has collated discriminatory and insensitive terms used by the judiciary, along with their positive alternatives – in a quest to assimilate their usage. 

In a nation of diverse languages and slangs, where the heart of justice lies in lower and special courts, the usage of English terminology is not common. The SC’s previous handbooks have solely focussed on the English language. In comparison, the United Nations (UN) in its Disability-Inclusive Communications Guidelines has translated the disability inclusive terms in all of its 6 official languages. Therefore, this compendium strives to widen the ambit a little to cover stereotypical phrases in Hindi and encourage lower courts to foster what Articles 14 and 21 seeks to achieve in terms of positive equality, human dignity and mutual respect. The ultimate goal is to encourage the Hon’ble High Courts and lower courts to develop regional vocabularies/glossaries to combat stereotypes against persons with disabilities.   

Approach

The compendium has been compiled from relevant words, slangs, and phrases available online in the form of judgements, reports, and glossaries. It is divided into 4  parts: first 2 columns focus on derogatory words and reasons why they be removed, and the other 2 focus on their alternatives and the reasons to imbibe in the legal discourse.

The suggestions are primarily based on “person-first language” followed by most international organisations and treaties, including the UN Office at Geneva, and the World Health Organisation. People-first language emphasises the person and not the disability, asserting that individuals with disabilities are people first with equal rights and they should be treated as everyone else. It is also the language used in the UN Convention on the Rights of Persons with Disabilities. People-first language means using “person with a disability” and “people with disabilities”, and for specific disabilities, using “person with a spinal cord injury” or “person with cerebral palsy”. Similarly, using “wheelchair user” or “person who uses a wheelchair” instead of using “wheelchair bound”, since people are not bound or confined to their wheelchairs – they are merely a tool that enables the person to move and participate in society. Hence, wheelchairs are liberating, not confining. 

S. No.Terms to avoidWhy they should be avoidedDisability Inclusive TermsWhy they should be preferred
1.Lunatic, 
Mad,
Idiot,
Maniac,
Insane,
Deranged,
Hypersensitive
In a 6th century legal code compiled by the Emperor Justinian, “lunatic” shows up in a passage discussing the value of slaves. Over a period of time it became an impolite way of referring to a person’s mental and emotional condition and behaviour.Similarly, terms like idiot, maniac, insane etc. are used interchangeably for describing a person’s mental and emotional condition and behaviour.
EXAMPLE:13. Though a stand was taken since inception that Bhaurao was an idiot and may be lunatic at times, the suit itself would have been defective, if this stand was to be taken about his lunacy.” “14. He has admitted in his cross-examination that the accused Sitaram is a mad man therefore, his wife left him long back and now she is married with someone else. Though the first informant has admitted that the accused was a mentally deranged person but denied the suggestion of the defence that the F.I.R. was lodged by him with an ulterior motive…However, in the cross-examination, he has confirmed that Sitaram was an insane man since before the incident. Sometimes he used to hit the neighbours also in the heat of his madness…Further assertion of this witness is that villagers were always very cautious with him as every one knew that he was a deranged person. … but only because of his insanity, his wife left him and went to another place… Thus all the eyewitnesses are unanimous and agree that Sitaram accused is a mad person and he committed this offence in a fit of crazy insanity.26. If the deceased happened to be hypersensitive and his action of committing suicide is not ordinarily expected to induce a similarly circumstanced person to commit suicide then it may not safe to hold the accused guilty of abetment of suicide.”“The true facts…….that the first respondent had been a highly mentally deranged person and a man of paranoid schizophrenia and a chronic maniac of depression.” “27. His evidence clearly shows that the first plaintiff was behaving in an abnormal manner and he was taking his own excreta and he tried to attack him without any reason and he has stated that on examining the first plaintiff he found that the patient was not in a good mental condition and he issued Ex.A.8 certificate………he was suffering from schizophrenia and his behaviour was violent and used to get maniacal symptoms frequently.”
Persons with psycho-social disabilities‘Persons with psychosocial disabilities’ is used by international human rights agencies and representative organisations of persons with disabilities. It encompasses all “persons who, regardless of self-identification or diagnosis of a mental health condition, face restrictions in the exercise of their rights, and barriers to participation on the basis of an actual or perceived impairment”. This term reflects a social rather than a medical approach to mental health conditions, with a focus on the attitudinal and environmental barriers that restrict the equal participation of persons with psycho-social disabilities in society.  The phrase has not been yet used as an alternative in Indian courts. 
EXAMPLE ON USAGE FROM EUROPEAN COURTSThe applicant requested that the Court indicate general measures to the respondent State, specifically to carry out urgent reform with a view to ensuring that persons with psychosocial disabilities benefit from special protection under the law in line with the international standards.
2.The Disabled, 
The handicapped,
Confined to a Wheelchair,
Wheelchair- bound,
Crippled,
Deformed
People are not bound or confined to their wheelchairs because a wheelchair is a tool that liberates the person to get around and participate in society.Using “cripple”, “lame”, “deformed” or “deranged” to refer to a person, or as a metaphor, is offensive.
EXAMPLE:5. The present petition has been preferred by Mr. Saurabh Shukla who is suffering from Tetraplegia and paralysis below his chest due to a spinal cord injury which he had suffered in 2011. His physical condition is such that he is confined to a wheelchair and has limited use of his arms. Despite this injury, as recorded in the previous order, he is an investment banking professional, employed with a hedge fund and works from home.”“13. This Court……the petitioner indeed is a wheelchair bound person and has multiple orthopaedic issues which appear to limit the movements of the petitioner.”“11. This witness has also denied the suggestion that accused Pappu is disabled since birth, as his right leg is crippled.”
People/Persons with disabilitiesThe disability communityPerson with disabilityPeople with physical disabilitiesWalks with a caneUses leg bracesPerson who uses a wheelchairPerson with a mobility disabilityPerson with a mobility impairmentPerson using a mobility device People-first language emphasises the person, not the disability, by placing a reference to the person or group before the reference to the disability. EXAMPLE:59. For a person with a disability, the constitutionally guaranteed fundamental rights to equality, the six freedoms, and the right to life under Article 21 will ring hollow if they are not given this additional support that helps make these rights real and meaningful for them.”“59. For a person with a disability, the constitutionally guaranteed fundamental rights to equality, the six freedoms, and the right to life under Article 21 will ring hollow if they are not given this additional support that helps make these rights real and meaningful for them.
3.Differently- abled,
Specially- abled
These terms are euphemistic and can be considered patronising or offensive. Euphemisms are a denial of reality and a way to avoid talking about disabilities.
EXAMPLE:9. In the matters of providing relief to those who are differently abled, the approach and attitude of the executive must be liberal and relief-oriented and not obstructive or lethargic.”
Persons with disabilities“Persons with disabilities” is a neutral term, allowing the person, and not their disability, to be put first.
EXAMPLE:9. ….I make it clear that this will not stand in the way of the Commissioner for making any suitable recommendation to the KPSC, or the Government in order to protect the interest of persons with disabilities in the matter of their appearance in the selection process conducted by the KPSC.
4.Mental retardation,
Mentally challenged,
Mentally retarded,
Mentally ill,
Retard, 
Intellectually challenged
Slow learner, 
Special needs,
Special person,
Infirm
Negative connotations of these terms result in misunderstandings about the nature of the person’s disability/disorder. In a 2012 survey titled: “What’s in a name? Attitudes surrounding the use of the term ‘mental retardation’”, the majority of parents indicated that they would be upset if a physician used the term mental retardation.
EXAMPLE:“3. Facts of the case, in brief…..on 18-10-2017 at about 9 – 10 am, when she was in her house and her granddaughter (victim), aged about 32 years, who is deaf and dumb and also mentally retarded, was sleeping in a room…..“123. A perusal of the alleged Will…the said alleged Will that the school education of the petitioner was not much satisfactory and that she was a slow learner.”“42. It is pertinent to note that the petitioner also falls under the term “infirm” as according to the interpretation of the Coordinate Bench of this Court in Kewal Krishan Kumar case [Kewal Krishan Kumar v. Enforcement Directorate, 2023 SCC OnLine Del 1547] observing that infirmity takes place if the person is incapacitated in performing ordinary routine activities on a day-to-day basis. 43. Hence, the fact that the petitioner is unable to sit, bend forward, and not even able to lift any weight suggests the infirmity on the part of the petitioner to carry out day-to-day routine activities and non-following the advice and the specialised treatment may lead to neurological damage to the petitioner.”“1. It is submitted……the State is committed to impart education to the children with special needs. On the previous occasion, a statement was made that the State had already commenced the procedure for engaging 12,000 teachers out of which some shall be the teachers for children with special needs.
People/Persons/Children with intellectual disabilityLearning disabilityCognitive disabilityPerson with a learning / cognitive disabilityPersons with psycho-social disabilitiesPersons with intellectual disabilities is a technically correct and positive term. It is currently used by medical professionals and also national/foreign legislations
EXAMPLE:5. According to Adv. Sheji P. Abraham, who appears for the appellant, his client is a person with learning disability.”
5.The Blind,
Visually impaired
“Impaired” has a negative connotation as it reflects the assumed inability of a person to fully participate in the society.
EXAMPLE:44. Moreover, to give due affect…a Web Accessibility Compliant Cause List has been launched in this Court, which would help the visually impaired advocates, litigants and public at large to access the cause list seamlessly by using various accessibility text-to-speech software.”
Person/ [Designation] with visual disabilityPerson with low vision Visual impairmentSame as Sr. No. 2
EXAMPLE:17. That apart……..it is clear that the stipulation is not arduous, which a person with low vision cannot achieve.”
6.Deaf-mute,
The Deaf,
Deaf and dumb 
Deaf is an offensive term from the 18th-19th century; “mute” means silent and without voice. Both labels are technically inaccurate, since Deaf, Deaf-Blind, Deaf-Disabled, Hard of Hearing, mute and Late-Deafened people generally have functioning vocal chords.Aristotle pronounced people “deaf and dumb,” because he felt that if a person could not use their voice in the same way as ordinary people, then there was no way that they could develop cognitive abilities of learning and reasoned thinking. In later years, “dumb” came to mean “silent.”  This definition still persists.
EXAMPLE:“11. Overall, the prayer of the petitioners is that the deaf sports persons ought to be treated on par with para sportspersons. In principle, there can be no doubt and even the court confirms that deaf sport persons and para sport persons would have to be treated equally and neither category can be discriminated against the other.”“26. In the instant case, victim is deaf and dumb and her deposition ……………….. Thus, the victim was a rustic village girl who is not found to have studied such sign language taught in those special schools.”“7. Smt. Tripta Devi, mother of the prosecutrix, appeared as PW-12. Since she was deaf mute, the questions were put to her in writing in Hindi and she answered the same in writing.”
Person who is deaf or hard of hearingPerson/ [Designation] with hearing disability 
It is acceptable to refer to someone as a “person who is deaf or hard of hearing.” It is important to be as specific as possible. If someone uses any Sign Language, lip-reads, or uses other means to communicate, it must be stated specifically. If the kind of disability is difficult to identify, one can use person-first terms: “[Designation] with hearing disability”. Eg.: Sportsperson with hearing disability
EXAMPLE:4. He also stated that PW-3 is serving in Civil Hospital, Theog in the X-ray department and he (DW-1) used to work in the house of the complainant, who is hard of hearing since his birth.”
7.Multiple impairment,
Multiple disability
Using the phrase multiple impairment/disability reflects that a person is burdened with numerous disabilities of a physical nature.
EXAMPLE:14. We note that the Medical Boards have recorded the Locomotor Disability of the petitioner as 90% and also his case is not of a Multiple Disability. In other words, except Locomotor Disability there is no other disability.”
Persons with cross disability Cross DisabilityThough cross disability is an identity-first word, it is a neutral term in comparison to negative connotations attached to multiple impairments.  It means including all forms of disability, including but not limited to: acquired, congenital, intellectual, brain, neurologic, sensory, mobility, mental health, episodic, .
8.Dwarf,
Stunted  
Use of the word “dwarf” is considered acceptable when referring to the genetic condition, but it is often considered offensive when used in a non-medical sense.
EXAMPLE:62. From the witness box, he gave the description of the assailants as one was tall and another was dwarf and they were aged between 21 to 22 years.”“11. After carefully examining the orders Annexure-P/1 and Annexure P/11 and the petitioner who is present in person, who is stunted, it prima facie appears that petitioner is not leading a normal life.”
Person of short stature, Little person
“Little Person” or “person of short stature” are better suited
EXAMPLE:“Petitioner is stated to be a disabled person of short stature with very less power in his right hand.
9.Down Over the years “Down” has been given a negative connotation. 
EXAMPLE:3. As the child belongs to the category of down syndrome, she needs special training and treatment and consideration, is the statement.”
Person with Down SyndromePerson with Trisomy-21For specific disabilities, saying “person with a spinal cord injury” or “person with cerebral palsy” is respectful. However, person with down syndrome is acceptable as well. EXAMPLE:13. No doubt, a person with down syndrome may lead a normal life, but in the present case, when the victim is unable to take care of herself, there is every possibility that she will not be able to take care of the foetus.
10.Leper,
Leprosy patient
Same as Sr. No. 5
EXAMPLE:4. ….The respondents are directed to take further steps for allotment of the land for setting up the shelter-homes for the leper patients. 5. The policy for rehabilitation of the lepers has not been framed…”
Person affected by LeprosySame as Sr. No. 2
EXAMPLE:18.6. The awareness campaigns must include information that a person affected by leprosy is not required to be sent to any special clinic or hospital or sanatorium and should not be isolated from family members or the community.
11.Cerebral Palsy victim,
Victim of cerebral palsy 
Cerebral palsy does not make the person a “victim”. Persons with Cerebral Palsy exist on a spectrum and have the ability to exercise daily activities and lead a normal life. Associating them with victimhood is the first point of discrimination. EXAMPLE:58. The High Court appeared to be insensitive to the fact that as a victim of cerebral palsy, the appellant suffered from a slight speech disability which must have worsened on account of nervousness when asked to appear before the Court to answer questions.”Person with Cerebral Palsy Same as Sr. No. 2. EXAMPLE:3. From the pleadings it is seen that the petitioner is a person with cerebral palsy. Notwithstanding such disability, petitioner has overcome physical and mental barriers in his personal capacity and by virtue of his commitment and participation, he has become a leading disability rights activist of the country.
12.Suffering from, Sufferer,
Afflicted with,
Stricken with,
Affected with
Expressions such as “suffers from”, “afflicted with”, or “stricken with” are inappropriate. They suggest constant pain and powerlessness and carry the assumption that persons with disabilities have a poor quality of life. They should not be referred to as patients unless they are under medical care.
EXAMPLE:2. The petitioner sought general transfer on special grounds as he has been certified by competent authority to be suffering from hearing disability up to 60%. Hearing disability is included in the category of physical disability. It is a congenital disability suffered by the petitioner….”18.14. The Union and the State Governments must proactively plan and formulate a comprehensive community based rehabilitation scheme which shall cater to all basic facilities and needs of the leprosy affected persons and their families.
has [name of condition or impairment]
– person with ______  (insert the name of their condition if known  and with their consent to disclose it) (e.g. person with depression, person with bipolar disorder, etc)
Same as Sr. No. 2
EXAMPLE85. The Tribunal, in its judgement, couched the disability of the appellant in terms of ‘suffering’ and ‘disease’. Specifically, in its order dated 30 May 2018, the Tribunal, at para 5, noted: “The applicant is suffering with a disease called Writer’s Cramp.” In its order dated 7 August 2018, at para 7, the Tribunal refers to those “suffering” with disabilities. Even if the usage is unintentional, we cannot ignore its enduring impact in shaping the way the society views the disabled and the way they view themselves. Viewing disability as an affliction that causes suffering, or that views it as a God-given fate (whether a blessing or a curse) is rooted in the medical model of disability. Our discourse must be couched in terms that reflect the recognition of a human rights model to viewing disability. Insensitive language offends the human dignity of persons with disabilities.”
13.Epileptic AttackSame as Sr. No. 1
EXAMPLE:5. Later in the day accused threatened PW-1 and PW-8 that if they disclosed the incident to anyone he would kill PW-8 and Alina, hence PW-1 out of fear informed the doctor about Rizwan suffering an epileptic attack and having a fall and getting injured.”
Person with EpilepsyPerson with seizure disorder/ disabilityEpileptic episode or event  Same as Sr. No. 2
EXAMPLE:The appellant denied beating her at all or causing her death. He maintained that she could have found injury due to an epileptic episode.
14.VictimThe term “victim” should not be used unless strictly relevant. A victim is a person who has been harmed by a crime or has been subject to a human rights violation. Victims are often seen as vulnerable and helpless. This underlying perception must be taken into account when using this term in references to persons with disabilities.Has (description of disability) It is preferable to use neutral language when describing a person who has a disability, simply stating the facts about the nature of the disability. For example: “He has muscular dystrophy.”
15.SurvivorThe term “survivor” is sometimes applied to people who have recovered from or adjusted to a health condition. Some examples include “brain injury survivor” and “stroke survivor”. Some people also refer to a disability or health condition in terms of a “battle,” as in “to battle cancer.”Has (description of disability) Same as Sr.No. 14
16.Paraplegic,
Quadriplegic
Same as Sr. No. 2
EXAMPLE:7. Evidence of PW7 Dr.Sanjiv Desai shows that the deceased was made quadriplegic because of assault on him.”1. Because of the injuries suffered by her at the hands of the appellant-accused, on account of a frustrated love affair, the victim has become a paraplegic.
Person with ParaplegiaPerson with QuadriplegiaSame as Sr.No. 2
17.Hyperactive,
Hypersensitive
These terms reflect that the person is uncontrollable, resulting in misunderstandings about the nature of the person’s disability.
EXAMPLE:20. The Apex Court, in the afore-quoted judgement, also recognizes that a person who is depressed and suffering from mental health issues could be hypersensitive.”“5. …From the video footage, it is seen that the petitioner had not given just a tapping or patting, but she had given repeated beatings on the hyperactive child, who had speech delay problems. Surely the petitioner’s conduct cannot be appreciated and approved.”
Person with ADHD It is ideal to use the proper medical name of the condition, i.e., Attention Deficit Hyperactivity Disorder (ADHD) instead of stereotypical phrases.
EXAMPLE:16. However, Mr. Newell submits that the further evidence as to H’s need to be medicated, and having a history of not taking the medication, is of limited probative value and is unfairly prejudicial. This is because the jury may think a person with ADHD is more likely to act on impulses, including sexual ones, when there has been a failure to take medication. It is also possible that the jury might have inferred from the cross-examination that a person with ADHD can revert back to childlike behaviour without medication and is more prone to risk-taking.”
18.Autistic,
High-functioning autism
The terms have negative connotations that often result in misunderstandings about the nature of the person’s disability.
EXAMPLE:3. Further, learned advocate for the petitioner submitted that petitioner’s son named Varun, aged about 5 years and 6 months suffering from “High Functioning Autism” since he was 2 years and 6 months old as diagnosed by Fortis Hospital Mohali, Punjab.
Person with Autism Person on the Autism Spectrum Neuroatypical NeurodivergentEXAMPLE:“8. ..He submitted that, as far as the appointment of persons with disability is concerned, though persons with benchmark disabilities under categories a, b and c of Section 34 of the ‘PWD Act’ were available, when it came to the fourth category, namely, persons with autism, intellectual disability, etc., no one was identified and therefore, that it was left unfilled.”9. Dr. George Abraham added that, when the next round of selection happened, it was again found that persons with autism, intellectual disability, etc. were not available……applying the principle of interchangeability among the categories. ”
19.Senile,
Demented 
Same as Sr. No. 17
EXAMPLE:218.2. This form of euthanasia is that which most intimately concerns the medical profession. Selective non-treatment of the newborn or the doctor may be presented with demented and otherwise senilely incompetent patients.”
Person with Alzheimer’s diseasePerson who has DementiaSame as Sr.No. 2
20.StuttererSame as Sr. No. 17.
EXAMPLE:9. The medical examination has concluded that there is no doubt that the candidate is suffering from stuttering which is classified as a speech defect.”
Person with a speech impairment Person who has a speech disabilitySpeech disorder/ disability Communication disability  Same as Sr.No. 2
EXAMPLE:“The prosecution case in short is that after the marriage of the above said spouses, the accused persons have treated her with cruelty and harassment and that the petitioner used to beat their child, who has speech disability and that the accused persons have made her go without food for quite a few days.”“The law under the Evidence Act recognizes a witness with speech disability as a competent witness.”
HINDI TERMS
21.लंगड़ाअपंगThese words are archaic, offensive, and abusive and along with having a negative connotation . लोकोमोटर अक्षमता वाले व्यक्तिचलन-सम्बन्धी अक्षमताचलन अक्षम व्यक्ति“लोकोमोटर अक्षमता वाले व्यक्ति” is the hindi translation of the term persons with locomotor disabilities and “चलन अक्षमता व्यक्ति” is the translation of the term person with a mobility disability. This is a humane way of referring to a person’s disability. Another way could be to just refer to the disability by its name – for example, “चलन-सम्बन्धी अक्षमता”.  Moreover, It is always preferable to mention the exact medical term of a disability with a people-first approach to avoid misunderstandings as these terms do not reflect the true nature of the disability
22.मानसिक मंदता
मंदबुद्धि
पागल
मानसिक रोगी
दिमाग का संतुलन सही नहीं
हैमानसिक रूप से अविकसित
These words are offensive, abusive and have a negative connotation attached. The Uttar Pradesh State Commissioner for Persons with Disabilities has noted that words like बुद्धिदुर्बलता, मूर्खता, मन्दबुद्धि, क्षीण बुद्धि, मूढ़ और मंदमनस्कता are no longer in use to refer to a PWD in a respectful manner. [Percentage of Disability] बौद्धिक रूप से बाधित व्यक्तिबौद्धिक अक्षम व्यक्तिबौद्धिक अक्षमता Both the phrases have a positive connotation as opposed to the archaic terms.It is preferable to use a neutral and technical phrase/term to identify the form/type of disability of a person.
23.भैंगाकानाSame as Sr. No. 21दृष्टि बाधित दिव्यांग/ दृष्टि अक्षम व्यक्तिSame as Sr. No. 22
24.बहराबधिरSame as Sr. No. 21श्रवण बाधित/अक्षम व्यक्ति
25.कुबड़ाSame as Sr. No. 22वक्र, विनत, अस्थि बाधित व्यक्ति
26.चितकबराSame as Sr. No. 22Prefer to use a common medical term.
27.डिसऑर्डर से पीड़ितSame as Sr. No. 12[Name of Disability] बाधित/अक्षम व्यक्ति
28.मूक गूंगा/मूक बधिरSame as Sr. No. 6वाक् बाधित/अक्षम व्यक्ति
29.पीड़ितशिकारविपत्ति-ग्रस्तSame as Sr. No.14[Name of Disability] बाधित/अक्षम व्यक्तिSame as Sr. No.14
30.तोतलाSame as Sr. No. 20वाक् बाधित/अक्षम व्यक्ति
31.बौनाठिगनाSame as Sr. No. 22छोटे कद का व्यक्तिSame as Sr. No. 22

ADDITIONAL RESOURCES:

  1. People with disability vs persons with disabilities
  2. Psychological impact of using negative/archaic terms
  3. Mental health, human rights and legislation Guidance and Practice
  4.  Disability-Inclusive Communications Guidelines
  5. Law Related Stereotypes
  6. Myths About Hiring Persons with Disabilities
  7. Myths and Stereotypes About Mental Disabilities Greatest Barrier to Employment
  8. Violence and harassment against persons with disabilities in the world of work
  9. Attitudes of the Public in India towards People with Intellectual Disabilities

** Nayan Chandra Mishra is a Volunteer at Mission Accessibility and is a 3rd year law student at Dr. Ram Manohar Lohiya National Law University, Lucknow. Email id: punanayan@gmail.com 

**Aditya Singh Jethwant is a Student Fellow at Centre for Business and Financial Laws and is a 3rd year student at National Law University, Delhi. Email id: aditya.jethwant21@nludelhi.ac.in