DR.

RAM MANOHAR LOHIA NATIONAL LAW

UNIVERSITY

HUMAN RIGHTS LAW

Right Against Torture: Testing Indian Law and

Approach of Indian Judiciary on Global Standards

Submitted
Submitted by:

to:

Ms. Aparna Singh

Pajapati

Richa

Asst. Prof.
Sem

Roll No. 104 X

Faculty of Law
(Hons.)

B.A., LL.B.

TABLE OF CONTENTS
1.
2.
3.
4.
5.
6.

INRTODUCTION
INTERNATIONAL DOCUMENTS PROTECTING RIGHTS AGAINST TORTURE
CASES OF TORTURE AND THE LAW IN INDIA
JUDICIARY ON TORTURE
CONCLUSION
REFERENCES
INTRODUCTION

Torture has been used in most countries from time immemorial. Its concept is based on two fundamental
facts. First, that we all have imaginations, and secondly, that our bodies are susceptible to pain. In other
words we can envisage whats likely to happen, and we dont like getting hurt. Torture is unfortunately an
increasing problem throughout the world and, according to Amnesty International; governmentsanctioned torture is verified in more than 100 countries. Torture is known to have long term physical and
psychological effects on the victims. Torture is often used to punish, to obtain information or a
confession, to take revenge on a person or persons or create terror and fear within a population. Some of
the most common methods of physical torture include beating, electric shocks, stretching, submersion,
suffocation, burns, rape and sexual assault. Torture is a serious violation of human rights and is strictly
prohibited by international law. International law prohibits torture and other forms of inhuman and
degrading treatment, which cannot be accepted under any circumstances. Torture continues to be
practiced in a majority of countries round the world. A 2001 report by Amnesty International highlighted
the use of torture by 140 states between 1997 and 2001, and found that every year thousands of
perpetrators, beat, rape, and electrocute other human beings. Torture has been used in most countries from
time immemorial. Its concept is based on two fundamental facts. First, that we all have imaginations, and
secondly, that our bodies are susceptible to pain. In other words we can envisage whats likely to happen,
and we dont like getting hurt.
2

Torture" has not been defined in Constitution or in other penal laws. 'Torture' of a human being
by another human being is essentially an instrument to impose the will of the 'strong' over the 'weak' by
suffering. The word torture today has become synonymous with the darker side of human civilisation.
"Torture is a wound in the soul so painful that sometimes

you can almost touch it, but it is also so

intangible that there is no way to heal it. Torture is anguish squeezing in your chest, cold as ice and
heavy as a stone paralyzing as sleep and dark as the abyss.1

INTERNATIONAL DOCUMENTS PROTECTING RIGHT AGAINST TORTURE

Article 5 of the UDHR, 1948 proclaims that No one shall be subjected to torture, or to cruel, inhuman
or degrading treatment or punishment. Following the spirit of Universal Declaration, India proclaimed
its faith in fundamental freedoms in the Indian Constitution which provides for life and dignity and
honour as incorporated in the preamble and in the chapter on Fundamental Rights. The Constitution has
entrusted the work of protecting fundamental freedoms to Indian Judiciary. Therefore, the judiciary has
the prime obligation to be utmost careful and to resist even the slightest intrusion into its domain in
safeguarding the human dignity which our founding fathers have so passionately granted to us.
Article 5 of UDHR incorporated the right to protection against torture and the same has been sought to be
achieved through Declaration of Fifth United Nations Congress held in 1975.

International Covenant on Civil and Political Rights (ICCPR)

Article 7 of the ICCPR provides that no one shall be subjected to torture or cruel, inhuman or degrading
treatment or punishment. In particular, no one shall be subjected without his free consent to medical or
scientific experiment.
1 Sunil Batra v. Delhi Administration [AIR (1978) SC 1575]
3

The first sentence of Article 7 of ICCPR reproduces Article 5 of UDHR. Article 7 cannot be derogated
from in any circumstances not even during public emergency. This section shows the concern of the
international community to defend and preserve the physical and moral integrity of human beings. The
purpose of this article is to protect the integrity and dignity of the individuals. It is the responsibility of
the Human Rights Committee under Article 40(4) of ICCPR for implementation of these rights. The
Human Rights Committee adopted in 1982, general comments on Article 7 of the Covenant, after
examining reports submitted by State parties. Committee observed that even in situations of public
emergency as envisaged in Article 4(1) of the Covenant, this provision is non- derogable. The Committee
though said that Article 7 has a wide scope of application, it refrained from defining or providing clear
criteria for application of this section.
Particular forms of punishments and practices which have attracted the attention of Committee members
have been certain interrogation methods, the evidential use of illegally obtained information, virginity
testing of immigrants, treatment of so-called blanket people in Northern Ireland, stoning, flogging,
whipping, 30-40 years rigorous imprisonment, loss of nationality, and deprivation of civil and political
rights for extended periods.
The Human Rights Committee has expanded the meaning of torture by including corporal punishment
including excessive chastisement as an educational or disciplinary method. Article 7 clearly protects not
only persons arrested or imprisoned, but also pupils and patients in educational and medical
institutions.
Article 10(1) of the Covenant lay down that All persons deprived of their liberty shall be treated
with humanity and with respect for the inherent dignity of the human person.

United Nations Instrument Dealing With Torture

The process of legal codification against torture eventually culminated in The Convention Against
Torture and Other Cruel Inhuman or Degrading Treatment (CAT) (resolution 39/46), which was
adopted by the UN General Assembly on Dec 10th, 1984.The objective of this Convention is to prevent
acts of torture and other acts prohibited under this convention. Article 1 of the Convention defines
torture:
any act by which severe pain or suffering, whether physical or mental, is intentionally inflicted on a
person for such purposes as obtaining from him or a third person information or a confession, punishing
him for an act he or a third person has committed or is suspected of having committed, or intimidating or
coercing him or a third person, or for any reason based on discrimination of any kind, when such pain or
suffering is inflicted by or at the instigation of or with the consent or acquiescence of a public official or
other person acting in an official capacity. It does not include pain or suffering arising only from,
inherent in or incidental to lawful sanctions.2
Significant features of the Convention:
The convention requires state parties to take effective measures to prevent acts of torture in any territory
under their jurisdiction. Article 2 of the Convention says that torture cannot be justified even during war
or public emergency.
Article 3 of the Convention forbids State parties to expel, or extradite a person to another State where
there are substantial grounds for believing that he would be in danger of being subjected to torture. The
Convention also requires States to ensure that all acts of torture, attempts to commit torture or
participation in torture are offence punishable under criminal law of their states (provided in Art 4 of the
Convention). It also provides for prosecution or extradition of persons alleged to have committed acts of
torture.

2 Article 1, The Convention Against Torture and Other Cruel Inhuman or Degrading
Treatment
5

Article 4 requires States to ensure that all acts of torture are criminal offenses, subject to
appropriate penalties given their grave nature. State parties are also required to apply similar criminal
penalties to attempts to commit and complicity or participation in torture

European Convention
Article 3 European Convention which deals with torture says, No one shall be subjected to torture or
to inhuman or degrading treatment or punishment. This provision cannot be derogated under Article
15(2).
Torture- The European Commission has defined torture to mean, inhuman treatment having a
purpose such as obtain information or confession, or infliction of punishment and it is generally an
aggravated form of inhuman treatment. By inhuman treatment, Committee said it is a deliberate
treatment which causes severe suffering- mental or physical, which in the particular situation is
unjustified.3
Degrading Treatment- The Commission considered degrading treatment as: treatment or
punishment of an individual is degrading if it grossly humiliates him before others or drives him to act
against his will or conscience. This definition was followed and expanded later by the Commission in
East African Asians v. Uniked Kingdom (4430/70, E.,H.R.R 76) where it said that degrading treatment
was a conduct of certain level of severity which lowers victim in rank, position, reputation or character
whether in his own or eyes of others. These definitions have been explained by the Court in Tyrer case, in
which Court observed that the first element of serious humiliation was whether the conduct was
3 Infra at 7
6

degrading. In Campbell and Cosans, the Court observed that a threat directed to an exceptionally
insensitive person may have no significant effect on him but nevertheless be incontrovertibly degrading;
and conversely an exceptionally sensitive person might be deeply affected by a threat that could be
described as degrading only by ordinary and unusual meaning of the word.4

African [Banjul] Charter on Human and Peoples' Rights, adopted June 27, 1981
Article 5- Every individual shall have the right to the respect of the dignity inherent in a human being and
to the recognition of his legal status. All forms of exploitation and degradation of man particularly
slavery, slave trade, torture, cruel, inhuman or degrading punishment and treatment shall be prohibited.

American Convention on Human Rights:

Article 5 of the Convention provides that every person has the right to have his physical, mental, and
moral integrity respected.5 It says that no one shall be subjected to torture or to cruel, inhuman, or
degrading punishment or treatment. All persons deprived of their liberty shall be treated with respect for
the inherent dignity of the human person.6

4 Oxford, Handbook of Human Rights and Criminal Justice in India, 2nd ed, Pg 77
5 Article 5(1), American Convention on Human Rights
6 Article 5(2), American Convention on Human Rights
7

CASES OF TORTURE AND THE LAW IN INDIA

India has signed but not ratified the UN Convention against Torture (CAT). There has been a continuous
effort of the National Human Rights Commission (NHRC) to pursue the Government of India to ratify the
Convention against Torture so that a new domestic legislation thereafter can be brought into place. But
the effort has gone till date without success. 7 Indias refusal to ratify the UN Convention against Torture
was primarily based on the contention that its laws were adequate enough to deal with crimes committed
by the representatives of the State. Section 330 and 331 of the Indian Penal Code have been enacted to
punish those who voluntarily cause hurt or grievous hurt with an object to coerce the sufferer to confess
to his guilt or give information respecting the commission of a crime or a misconduct, or to restore
property or satisfy any claim or demand respecting thereto. Though the sections are generally worded, the
provisions are mostly brought into requisition against police personnel acting in furtherance of obtaining
confession through un-moded methods. Indeed, the police personnel in an attempt to win the tributes of
superior officers or to avoid censure for slackness to discover the culprit(s) / solve the case get tempted to
extort involuntary confession. Another driving force in this context may be the assumption that the law
would not admit in evidence anything said to the police, unless, it is substantially corroborated by the
discovery of the fact in consequence of confession / information (Section 27 Indian Evidence Act). The
ambit of these sections is wide enough as to extend to all policemen then present, but, who do nothing to
prevent torture and either stand unconcerned or withdraw from the scene for fear of getting themselves
implicated therein. 8
The official machinery for the protection of human rights in this country was set in motion by the
then Presidents assent to the Protection of Human Rights Act 1993 which came in to force on September
7 Vidya Vikram, Indias Response Against The Act Of Torture, 22 July 2010, available at <
https://indialawyers.wordpress.com/2010/07/22/india%E2%80%99s-response-against-theact-of-torture/>
8 Dr. Krishan Vij, Dr. Dasari Harish, Dr. Amandeep Singh, Torture and the Law: an Indian
Perspective
8

28, 1993. Section 3 of the Act provides for the setting up of the National Human Rights Commission
(NHRC) and Section 21 for the setting up of various State Commissions (SHRCs). The Act also provides
for the designation of certain courts of Session in each state as Human Rights Courts, by the state in
consultation with the Chief Justice of its High Court. All these Commissions were given the powers of
civil courts vide Section 13(1), with the power to summon any person to give evidence relating to the
matter under consideration (Sec. 13(2)), failing which they could be punished under Sections 176
(omission to furnish information) &177 (giving false information) of the IPC. Section 18 provides for
interim relief (monetary compensation) to the victim, which could be recovered by the State from the
accused officials. However, despite such elaborate Acts and Articles in place, along with the requisite
machinery, the mind-set of the average policeman continues to exist in a medieval time warp and torture
by the custodians of the law continues unabated against those very persons, safe-guarding of whose rights
and liberty, is their legal duty.
Apart from the police, there are several other governmental authorities like Directorate of
Revenue Intelligence, Directorate of Enforcement, Intelligence agencies like the Intelligence Bureau (IB),
Central Bureau of Investigation (CBI), CIA, etc., which have the power to detain a person and to
interrogate him. There are instances of torture and death in custody of these authorities as well. For
example, the Apex Court took suo moto notice of the death of Sawinder Singh Grover 9 during his custody
with the Directorate of Enforcement and after getting an enquiry conducted by the Additional District
Judge, directed the CBI to lodge a FIR and initiate criminal proceedings against all persons named in the
report. Directorate of Enforcement was also directed to pay a sum of Rs.2 lakh to the widow of the
deceased by way of ex gratia payment at the interim stage.10
Article 7 of the ICCPR is reflected in Article 21 of the Indian Constitution which is a nonderogable right. In tune with international human rights instruments against torture, the Constitution also
9 Smt Grover Vs Directorate of Enforcement, 1994 SCC (Cri) 1464; 1995
10 Ibid.
9

emphasizes respect and honour of human dignity and fundamental rights. Torture has not been defined in
the Constitution or in other penal laws. Article 21 of Constitution only provides no person shall be
deprived of his life or personal liberty except according to procedure established by law. Life or personal
liberty has been held to include the right to live with human dignity and includes within its ambit a
personal guarantee against torture or to cruel, inhuman or degrading treatment or punishment can move to
the higher courts for judicial remedies under Article 32 & 226 for deprivation of Fundamental Rights.
Article 22 guarantees protection against arrest and detention in certain cases and declares that no person
who is arrested shall be detained in custody without being informed about the grounds of such arrest and
cannot be denied to consult and defend him by legal practitioner of his choice. A22 directs that person
arrested and detained in custody shall be produced before nearest Magistrate within 24 hrs of such
arrest.11
Article 4 of CAT, requires States to ensure that all acts of torture are criminal offenses, subject to
appropriate penalties given their grave nature. State parties are also required to apply similar criminal
penalties to attempts to commit and complicity or participation in torture. But we do not have any
legislation criminalising the acts of torture specifically, although the appropriate provisions of the Indian
Penal Code are applied in the instances of torture.
NHRCs guidelines and Instructions on Torture
The NHRC, soon after its establishment, identified custodial deaths and rapes as a priority area of
concern and issued instructions to all states and union territories to report any instance of custodial rape or
death within 24 hrs of its occurrence. It also asked for reporting judicial as well as custodial deaths.
NHRC later held that all postmortem examinations done in respect of deaths in police custody and in jails
should be video-taped and sent to the commission along with postmortem report.12
11 Supra note at 3
12 Supra note at 8
10

The Indian Government has finally initiated steps to have a law to check torture by making it a
punishable offence. While the signatories to the UN Convention were only obliged to amend prevailing
laws to make torture a punishable offence, the Indian Government has decided to go the full hog and
bring in a new law providing for stricter punishment for those involved in incidents of torture.
The Prevention of Torture Bill, 2008, drafted by government includes torture by Government
servants, including police officials, within the ambit of punishable offences. Under the proposed law,
public servants and others responsible for causing grievous hurt or danger to life, limb or health of any
person would be liable for being punished for torture. Incidentally, the draft legislation also makes
inflicting mental torture a punishable offence. Public servants torturing anybody for the purpose of
extracting information or extra-judicial confession from any accused would be punished under the
proposed law.
Critique of the Prevention of Torture Bill, 2008:
The Bill falls short of expectations on several counts. The Bill contains only three operative
paragraphs relating to (i) the definition of torture, (ii) punishment for those who torture, and (iii)
limitations for cognisance of offences. It excludes many of the key provisions of the UNCAT. The Bill
also falls short of the obligations that States Parties to the UNCAT must undertake; they also fall short of
existing national standards on administration of the criminal justice system. The ACHR organised the
National Conference on the Prevention of Torture Bill, 2008 on 24 and 25 June 2009 to highlight and
debate its shortcomings.

THE JUDICIARY ON RIGHT AGAINST TORTURE

The State is under an obligation for protecting the human rights of its citizens as well as to protect the
society at large, and is authorised to do so. To protect the citizens from any possible abuse of this
authority, they are given certain basic privileges recognised by the Constitution of India as Rights.
11

Elevation of such claims to the status of Rights, gives the citizens the capacity to evoke the power of the
Judiciary to protect themselves against violation of such rights, as well as to seek redressal for their
restitution.13
A land mark judgement by Justice V.R. Krishna Iyer enumerated basic human rights of the
prisoners.14 Mr. Sunil Batra had written a letter from Tihar Jail, Delhi to the Supreme Court providing
information about the torture and inhuman conditions of the prison. This case recognized the various
rights of prisoners in the most comprehensive manner. The judgement held that: No prisoner can be
personally subjected to deprivation not necessitated by the fact of incarceration and the sentence of the
court. All other freedoms belong to him to read and write, to exercise and recreation, to meditation and
chant, to comforts like protection from extreme cold and heat, to freedom from indignities such as
compulsory nudity, forced sodomy and other such unbearable vulgarity, to movement within the prison
campus subject to requirements of discipline and security, to the minimal joys of self-expression, to
acquire skills and techniques. A corollary of this ruling is the Right to Basic Minimum Needs necessary
for the healthy maintenance of the body and development of the human mind. This umbrella of rights
would include: Right to proper Accommodation, Hygienic living conditions, Wholesome diet, Clothing,
Bedding, timely Medical Services, Rehabilitative and Treatment programmes. The Supreme Court did not
find itself handicapped by absence of specific provisions against torture in the Constitution and gathered
support from Article 14 & 19 in holding against the permissibility of torture vis--vis persons suspected
and accused of crime.

13 Nidhi Beniwal, Role of Judiciary on Protecting Rights of Prisoners

14 Sunil Batra v. Delhi Administration [AIR (1978) SC 1575]
12

In Nandini Satpati v. P.L Dani15, the Court held that not only physical threats or violence but
psychological torture, atmospheric pressure, environmental coercion, tiring interrogation by police are
violation of law.
In Raghbir Singhv. State of Haryana16 , where the violence employed by the police to extract a
confession resulted in death of a person suspected of theft, the court observed that the lives and liberty of
citizens are at peril when the guardians of law stab human rights to death. Vulnerability of human rights
assumes a traumatic, torturesome poignancy, the violent violence is perpetrated by the police arm of the
State whose function is to protect the citizen and not to commit gruesome offences against them. The
court awarded life sentence to the police officer responsible for the death of the suspect in police lock up.
Khatri v. State of Bihar (AIR 1981 SC 928)/ Bhagalpur Blinding case, was an example of cruel
and inhuman treatment to the prisoners which are insolating the spirit of Constitution and human value as
well as Article 21. Supreme Court in this case tackled the blinding of under-trial prisoners by the police
by piercing their eyeballs with needle and pouring acid in them. This case shows the pattern of torture, the
sanction of torture by state and local judicial authorities, the routine concealment of torture.
Formidable problem in an alleged case of police torture is to establish the guilt of the perpetrators
of violence. The wrongdoers may either be able to escape conviction due to lack of required degree of
proof or maybe found guilty of lesser offence than the one warranted by the actual facts. This is primarily
due to the situation that the warranted by the actual facts. This is primarily due to the situation that the
offenders are the comrades and colleagues of the prosecutors and the complete lack of neutral witness.
State of U.P v. Ram Sagar Yadav17, is a case indicative of extreme limits to which police violence
and highhandedness may extend. The victim made a complaint against a policeman who demanded bribe
15 AIR 1978 SC 1025
16 1980 ( 3) SCC 70
17 1985 (1) SCC 552
13

from him. He was arrested for his audacity and shortly afterwards while in custody was found in a
serious condition with 19 injuries on his body eventually causing his death. The Supreme Court while
affirming the punishment of 7years rigorous punishment for culpable homicide not amounting to murder
under Sec 304, expressed his regret that the trial judge did not find policeman guilty of murder as
indicated by the facts.
In D.K Basu v. State of West Bengal18, the Court laid down 11 guidelines (procedural measures) to
be followed while, during and after arrest of person till he is in the custody of police. This case came up
before the Court through a petition under art 32 of the Constitution by an NGO. The Executive Chairman
of this NGO had written to Chief Justice of India drawing his attention to news items published in a
newspaper, regarding deaths in police lock up and in jail in the State of West Bengal. Here the Court
observed that Custodial Torture is a naked violation of human dignity and degrading which destroys
individual personality. It is a calculated assault on human dignity and whenever human dignity is
wounded the Civilization takes a step backward.
However mere formulation of guidelines and safeguards would not be sufficient, therefore
Supreme Court in D.K Basu case warned that:
Failure to comply with the requirements mentioned shall apart from rendering the concerned
official liable for departmental action liable to be punished for contempt of Court may be instituted in
any High Court of the country, having territorial jurisdiction over the matter.
In Joginder Kumar v. State of U.P19 Joginder Kumar was called to the police station in connection
with a case. Thereafter, his whereabouts became unknown to his family members. His family members
filed a writ of habeas corpus before the Supreme Court, pursuant to which he was produced before the
court.
18 AIR 1997 SC 610
19 1994 (4) SCC 260,
14

The UN Convention against Torture provides for redress and compensation to the tortured
victim. Article 14 of the convention categorically emphasizes that every State party to the Convention
must ensure that the tortured victim is provided fair & adequate compensation and rehabilitation. If death
results in the event of torture, the family is to be provided with compensation. In Nelabati Behara v. State
of Orissa20; the principle of state liability and the need for state to make reparations for such liability was
recognized. It was highlighted that court under Art 32 and 226 of the Constitution has wide amplitude to
provide any remedy under Public Law for any contravention of Fundamental Rights.

CONCLUSION
The Honble Supreme Court laid down in DK Basus case the guidelines to be followed in all cases of
arrest or detention to combat the evil of custodial crime and bring transparency and accountability therein.
However most of the recommendations made by the Honble courts or the various NGOs from time to
time are only observed more in the breach and not adhered to. Though most of the rules and instructions
regarding the prohibition of torture are incorporated in the curriculum of training of the police force, the
basic mind-set has not changed. Hence the need of the hour is to put in serious thinking and concerted

20 1993 (2) SCC 746

15

efforts by all concernedthe State, the voluntary organizations, the society, etc so as to bring in the
needed change in the attitude of the custodians of law.
However, despite such elaborate Acts and Articles and Judgments in place, along with the requisite
machinery, the mind-set of the average policeman continues to exist in a medieval time warp and torture
by the custodians of the law continues unabated against those very persons, safe-guarding of whose rights
and liberty, is their legal duty.
It is for the implementing and supervising authority to ensure that these guidelines are strictly complied
with. Parliament should seriously consider the recommendation made by 113th Law Commission Report
and as suggested, amend the Indian Evidence Act so as to transfer the onus of proof of innocence on the
police in cases where evidence shows that an arrestee suffered an injury during police custody. This
provision is likely to instil some fear in the minds of police officials who tend to take law in their own
hands.

REFERENCES
Statutes and International Documents:
1
2
3
4
5

The Indian Penal Code

The Code of Criminal Procedure
African Charter on Human and Peoples Rights
American Convention on Human Rights
Convention against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment

(CAT)
European Convention for the Prevention of Torture and Inhuman or Degrading Treatment
16

7
8

International Covenant on Civil and Political Rights

UDHR 1948

Books and Articles:

1
2

Oxford, Handbook of Human Rights and Criminal Justice in India, 2nd ed.
Suhas Chakma, Lessons Learned from the ACHRs National Campaign for Prevention of

Torture in India
Dr. Krishan Vij, Dr. Dasari Harish, Dr. Amandeep Singh, Torture and the Law: an Indian
Perspective

Web Pages:
1
2
3

http://www.academia.edu/2207092/Human_Rights_violation_in_Custodial_Torture
http://medind.nic.in/jal/t07/i4/jalt07i4p125.pdf
https://www.fidh.org/International-Federation-for-Human-Rights/asia/india/16548-india-arbitrary-

4
5

arrest-judicial-harassment-and-ill-treatment-against-mr
http://www.nimhans.kar.nic.in/prison/chapter_10-r_he_prisoners.pdf
https://indialawyers.wordpress.com/2010/07/22/india%E2%80%99s-response-against-the-act-of-

torture/
http://www.legalservicesindia.com/article/article/role-of-judiciary-in-protecting-the-rights-of-

prisoners-1616-1.html
7 https://www.icrc.org/eng/resources/documents/misc/57jpg5.htm
8 http://www.ohchr.org/EN/ProfessionalInterest/Pages/CAT.aspx
9 http://www.hrw.org/news/2003/03/11/legal-prohibition-against-torture
10 http://phrtoolkits.org/toolkits/istanbul-protocol-model-medical-curriculum/module-111
12
13
14

international-legal-standards-overview/torture/prohibition-of-torture-in-international-law/
http://www.ijrcenter.org/thematic-research-guides/torture/
http://nhrc.nic.in/PoliceCases.htm
http://shodhganga.inflibnet.ac.in/bitstream/10603/8112/16/16_chapter%207.pdf
https://www.fas.org/sgp/crs/intel/RL32438.pdf

17