MEMORIAL ON BEHALF OF PETITIONERS

MEMORIAL ON BEHALF OF PETITIONERS UILS, PUSSGRC MOOT MEMORIAL FOR 9TH SEMESTER ROLL NO. 1758 IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH CRWP. NO___ OF 2021 ORIGINAL WRIT JURISDICTION (Under Article 226 of the Constitution of India) IN THE MATTER OF: LALU PRASAD AND ORS. …………….………………PETITIONERS V. UNION TERRITORY OF CHANDIGARH AND ORS.……RESPONDENTS Memorial on behalf of PETITIONERS Page 1 of 21 MEMORIAL ON BEHALF OF PETITIONERS TABLE OF CONTENTS  List of Abbreviations………………...………………………………….2  Index of Authorities  Table of Cases…………………………………………………….…...4  Statutory Compilations…………………...…………………….….….5  E-Sources…………………………………….………………………..5  Statement of Facts…………………………………………...…………..6  Statement of Jurisdiction……………………………...………………...8  Statement of Issues………………………………………………………9  Summary of Arguments……….……………………...……………….10  Advanced Advanced…………………………………………………...11 1. WHETHER THE WRIT FILED IS MAINTAINABLE?...........................................................................11 2. WHETHER REMOVAL OF SOMEONE’S LIVELIHOOD IN THIS ARBITRARY MANNER VALID UNDER ARTICLE 19(1)(G) AND ARTICLE 21 OF INDIAN CONSTITUTION? ………….............................................................................................16 3. WHETHER THE VENDORS ARE ALLOTTED A SEPARATE PLACE FOR THE SALE?...............................................................20  Prayer…………………….…………………………………………….21 Page 2 of 21 MEMORIAL ON BEHALF OF PETITIONERS LIST OF ABBREVIATIONS Abbreviation Full Form All. Allahabad AIR All India Reporter Anr. Another Art. Article Bom. Bombay Cal. Calcutta Hon’ble Honourable ILR India Law Reports Ors. Others Q.B. Queen’s Bench Sec. Section SC Supreme Court SCC Supreme Court Cases SCR Supreme Court Reports U.O.I. Union of India u/s Under Section v. Versus & And Vol. Volume Page 3 of 21 MEMORIAL ON BEHALF OF PETITIONERS INDEX OF AUTHORITIES TABLE OF CASES  Haryana State Industrial Corporation v. Cork Mfg. Co., AIR 2008 SC 56  Pawan Kumar v. State of Haryana, (2003) 11 SCC 241  Carrington Investment Ltd. v. P.K. Prathapan, (2005) 1 SCC 212  Chunnilal Mehta v. Century Spinning & M Co. Ltd., AIR 1962 SC 1314  Sripur Paper Mills v. Commissioner of Wealth Tax, (1970) AIR 1520  Whirlpool Corporation v. Registrar of Trade Marks, AIR 1999 SC 22  Onkar Lal Bajaj v. Union of India, (2003) 2 SCC 673  Sarvepalli Ramaiah (D) Thr. Lrs. & ors. v/s District Collector Chittoor Dist. & Ors., Civil Appeal No. 7461 of 2009 SC  Surya Dev Rai vs Ram Chander Rai & Ors., (2003) 6 SCC 675  Maneka Gandhi v. Union of India, (1978) 2 S.C.R. 621  Harbans Lal v. Commissioner, A.I.R. 1994 S.C. 39  National Central Co-operative Bank v. Ajay Kumar, A.I.R. 1995 Raj. 15 35  Fateh Singh v. State of Rajasthan, (1968) S.C. [C.A. 1362/67 dt. 16.(J2.1968] 3  South Calcutta Hawkers, Association vs. Govt. of West Bengal, AIR 1997 Cal 234: (1997) 1 CALLT 453 HC  Olga Tellis & Ors vs. Bombay Municipal Council, 1985 SCC (3) 545  Bombay Hawkers Union v. Bombay Municipal Corporation & Others, 1985 AIR 1206: 1985 SCR Supl. (1) 849  Gainda Ram v. MCD, I.A. Nos. 1, 3 and 4 in I.A. No. 1 in I.A. No. 407 and I.A. Nos. 9 and 10 in I.A. No. 407 in W.P. (C) No. 1699 of 1987 Page 4 of 21 MEMORIAL ON BEHALF OF PETITIONERS STATUTORY COMPILATIONS  THE CONSTITUTION OF INDIA, 1950 E-SOURCES  india.gov.in  livelaw.in  scconline.com  thelawdictionary.org  indiankanoon.org  indialegallive.com  legalserviceindia.com Page 5 of 21 MEMORIAL ON BEHALF OF PETITIONERS STATEMENT OF FACTS 1. That sector 17 of Chandigarh is the GLORY OF city. Once it was, considered to be a “pedestrians’ paradise”. But with the passage of time, the area has been turned in to vendor’s zone. 2. That keeping in view the city beautiful image and the loss caused to the showroom owners, the Municipal Corporation and Chandigarh Police restored massive cleansing operation drive and stop allowing the single street vendor to carry out vending there. 3. That the Municipal Corporation noticed that around 600 street vendors selling belts, shoes, wallets, eatables were all over the place are operating here and have Encroached upon the open spaces at the plaza. 4. That in execution of the MC ORDERS, On September 2020, around at 6 pm in the evening, huge police force and corporation along with administration officials fortified the plaza, reached the spot with Police vehicles, corporation’s trucks, fire brigades, ambulances stationed around the plaza. 5. That seven drones also carried out aerial surveillance to keep a check on any kind of movement. With no vendors being allowed to even hover around the area, the corporation began with its beautification drive simultaneously. 6. That washing of the entire plaza was carried out by the officials and 1,000 plants and flower pots were placed to beautify the area. To keep 24X7 surveillance and a check on any kind of movement, as many as 24 CCTV cameras and three PTZ cameras were installed covering the entire plaza. They were made Wi-Fi-enabled and connected to Commissioner mobile phone. 7. That in oppression of the above said drive, the vendors moved the High Court of Punjab and Haryana against the Municipal Corporation and CHD Page 6 of 21 MEMORIAL ON BEHALF OF PETITIONERS Police. The street vendors Pleaded that they have been earning their livelihood since past 15 years from these vending zones of Sector 17. And till now, this arrangement has been undisturbed and not even interfered by the administration. This sudden drive has caused serious blow to their livelihood and eviction from our accustomed trading place without allocation of alternative suitable vending place is clear violation of our constitutional rights of articles 19(1) g and 21. 8. That the case is for hearing before Punjab and Haryana High Court. Page 7 of 21 MEMORIAL ON BEHALF OF PETITIONERS STATEMENT OF JURISDICTION Lalu Prasad and Ors. V. Union Territory of Chandigarh and Ors. The petitioners invoke the Jurisdiction of the Hon’ble High Court under Article 2261 of the Constitution of India, 1950. The present memorandum sets forth the facts, contentions and arguments in the present case. 1 Article 226 in The Constitution of India 1949: (1) Notwithstanding anything in Article 32 every High Court shall have powers, throughout the territories in relation to which it exercises jurisdiction, to issue to any person or authority, including in appropriate cases, any Government, within those territories’ directions, orders or writs, including writs in the nature of habeas corpus, mandamus, prohibitions, quo warranto and certiorari, or any of them, for the enforcement of any of the rights conferred by Part III and for any other purpose (2) The power conferred by clause (1) to issue directions, orders or writs to any Government, authority or person may also be exercised by any High Court exercising jurisdiction in relation to the territories within which the cause of action, wholly or in part, arises for the exercise of such power, notwithstanding that the seat of such Government or authority or the residence of such person is not within those territories (3) Where any party against whom an interim order, whether by way of injunction or stay or in any other manner, is made on, or in any proceedings relating to, a petition under clause (1), without (a) furnishing to such party copies of such petition and all documents in support of the plea for such interim order; and (b) giving such party an opportunity of being heard, makes an application to the High Court for the vacation of such order and furnishes a copy of such application to the party in whose favour such order has been made or the counsel of such party, the High Court shall dispose of the application within a period of two weeks from the date on which it is received or from the date on which the copy of such application is so furnished, whichever is later, or where the High Court is closed on the last day of that period, before the expiry of the next day afterwards on which the High Court is open; and if the application is not so disposed of, the interim order shall, on the expiry of that period, or, as the case may be, the expiry of the aid next day, stand vacated (4) The power conferred on a High Court by this article shall not be in derogation of the power conferred on the Supreme court by clause (2) of Article 32 Page 8 of 21 MEMORIAL ON BEHALF OF PETITIONERS ISSUES RAISED 1. WHETHER THE WRIT FILED IS MAINTAINABLE? 2. WHETHER REMOVAL OF SOMEONE’S LIVELIHOOD IN THIS ARBITRARY MANNER VALID UNDER ARTICLE 19(1)(G) AND ARTICLE 21 OF INDIAN CONSTITUTION? 3. WHETHER THE VENDORS ARE ALLOTTED A SEPARATE PLACE FOR THE SALE? Page 9 of 21 MEMORIAL ON BEHALF OF PETITIONERS SUMMARY OF ARGUMENTS 1. THE WRIT PETITION IS MAINTAINABLE It is most humbly submitted that the Writ Jurisdiction of High Court can be invoked under Article 226 of the Constitution for the violation of fundamental rights guaranteed under Part – III of the Constitution. In order to establish the maintainability of the plea, two conditions must be satisfied. Firstly, it must come under the jurisdiction of the Hon’ble High Court and secondly, there must be violation of fundamental rights. 2. WHETHER REMOVAL OF SOMEONE’S LIVELIHOOD IN THIS ARBITRARY MANNER VALID UNDER ARTICLE 19(1)(G) AND ARTICLE 21 OF INDIAN CONSTITUTION? Article 19(1)(g) of the Constitution guarantees to every citizen the right to practice any profession or to carry on any occupation, trade or business. Likewise, hawkers have the fundamental right to carry on trade or business of their choice. The right to life includes protection of means of livelihood. Forcible eviction of hawkers without prior notice is infringement of Article 21 of the Constitution. 3. WHETHER THE VENDORS ARE ALLOTTED A SEPARATE PLACE FOR THE SALE? The most important issue then arises that whether the vendors be allotted any other separate space after this eviction? It can be a kind of compensation for the loss they and their families be incurring. That separate place be genuine in the nature that, it must be highlighted by Government so people can buy from those and the vendors can earn reasonably as they were earning before. Page 10 of 21 MEMORIAL ON BEHALF OF PETITIONERS ARGUMENTS ADVANCED WHETHER THE WRIT FILED IS MAINTAINABLE? Jurisdiction of HC under Article 226 can always be invoked. I. It is humbly submitted before this Hon’ble Court that whenever a question of law of general public importance arises the jurisdiction can be invoked. The jurisdiction conferred under Art. 226 on the High Court are corrective one and not a restrictive one2. A duty is enjoined upon the High Court to exercise its power by setting right the illegality in the judgments is wellsettled that illegality must not be allowed to be perpetrated and failure by the High Court to interfere with the same would amount to allowing the illegality to be perpetuated3. It has been held in plethora of cases that when the question of law of general public importance arises, the jurisdiction of High Court can be invoked. In the present case, the issue involves matter of General Public Importance and hence, entitled to be maintainable. II. It is humbly submitted that the expression "substantial question of law"4 is not defined in any legislation. Nevertheless, it has acquired a definite connotation through various judicial pronouncements. A Constitution Bench of the Apex Court, while explaining the import of the said expression, observed that: “The proper test for determining whether a question of law raised in the case is substantial would, in our opinion, be whether it is of general public importance or whether it directly and substantially affects the rights of the parties and if so whether it is either an open question in the sense that it is not finally settled by this Court or 2 Haryana State Industrial Corporation v. Cork Mfg. Co., AIR 2008 SC 56 Pawan Kumar v. State of Haryana, (2003) 11 SCC 241 4 Carrington Investment Ltd. v. P.K. Prathapan, (2005) 1 SCC 212 3 Page 11 of 21 MEMORIAL ON BEHALF OF PETITIONERS by the Privy Council or by the Federal Court or is not free from difficulty or calls for discussion of alternative views.”5 III. In the present case, the question of law involved in appeal is of recurring nature which has been raised in plethora of cases. Hence, it is humbly submitted before this Hon’ble High Court of Punjab & Haryana that the matter involves substantial question of law and hence entitled to be maintainable. IV. The HC is not precluded from going into the question of facts under article 226, if it considers it necessary to do so. The Article 226 uses the wording “in any cause or matter”. This gives widest power to this court to deal with any cause or matter. It is plain that when the High Court reaches the conclusion that a person has been dealt with arbitrarily or that a court or tribunal has not given a fair deal to a litigant, then no technical hurdles of any kind like the finality of finding of facts, or otherwise can stand in the way of the exercise of this power. The existence of an alternative remedy is no bar to file petition I. It is humbly submitted before the Hon’ble Court that the remedy under Article 226 of the Constitution is discretionary remedy6. The Court is vested with power to entertain the petition where there occurs gross miscarriage of justice and effective remedy is not available. This rule of exhaustion of the statutory remedy is not rigid but somewhat flexible and it is primarily a matter of the discretion of the writ court. Reliance is placed upon the decision in the case of Whirlpool’s Corp. v. Registrar of Trade 5 6 Chunnilal Mehta v. Century Spinning & M Co. Ltd., AIR 1962 SC 1314 Sripur Paper Mills v. Commissioner of Wealth Tax, (1970) AIR 1520 Page 12 of 21 MEMORIAL ON BEHALF OF PETITIONERS Marks7, in which it was held by the Apex Court that the jurisdiction of the High Court in entertaining a writ petition under article 226 of the Constitution would not be affected although there exist alternative statutory remedies. II. It is submitted that a writ petition is maintainable when the Lis involves a public law character and when the forum chosen by the parties would not be in apposition to grant appropriate relief8. Question as to when discretionary jurisdiction is to be exercised or refused has to be determined having regard to the facts and circumstances of each case. No hard and fast rule can be laid down in this regard9. The Fundamental Rights provided in the Indian Constitution are guaranteed against any executive and legislative actions. Any executive or legislative action, which infringes upon the Fundamental Rights of any person or any group of persons, can be declared as void by the Courts under Article 14 of the Constitution. In Sarvepalli Ramaiah (D) Thr. Lrs. & ors. v/s District Collector Chittoor Dist. & Ors.10, the Supreme Court held that – A decision is vitiated by irrationality if the decision is so outrageous, that it is in defiance of all logic; when no person acting reasonably could possibly have taken the decision, having regard to the materials on record. The Supreme Court in Surya Dev Rai vs Ram Chander Rai & Ors.11, concluded that under Article 226 of the Constitution, writ is issued for correcting gross errors of jurisdiction, i.e., when a subordinate court is found to have acted: I. without jurisdiction, by assuming jurisdiction where there exists none, or 7 Whirlpool Corporation v. Registrar of Trade Marks, AIR 1999 SC 22 M.P. Jain, Indian Constitutional Law, 415(7th Ed., 2014) 9 Onkar Lal Bajaj v. Union of India, (2003) 2 SCC 673 10 CIVIL APPEAL NO. 7461 OF 2009 SC 11 (2003) 6 SCC 675 8 Page 13 of 21 MEMORIAL ON BEHALF OF PETITIONERS II. in excess of its jurisdiction – by overstepping or crossing the limits of jurisdiction, or III. acting in flagrant disregard of law or the rules of procedure or acting in violation of principles of natural justice where there is no procedure specified, and thereby occasioning failure of justice. It is humbly submitted that this Writ Petition is filed seeking issuance of writ of Prohibition to the Municipal Authorities of the Chandigarh Administration to stop evicting the vendors from the public premises in this arbitrary way and let them continue their profession under Article 19(1)(g) of the Indian Constitution. The present petition is maintainable under Article 226 on the grounds given below: The fundamental rights of the petitioners have been violated, including Right to Life under Article 21 of the Indian Constitution. Article 14 says about the equality before the law and equal protection of law; Article 21 talks about the protection of life and personal liberty. Article 21 was defined in the case of Maneka Gandhi v. Union of India12. In this case, it was held that law and procedure which is followed should be just, fair and reasonable kind. If the order is passed by the authority without providing the reasonable opportunity of being heard to the person affected by it adversely will be invalid and must be set aside as in the cases of Harbans Lal v. Commissioner13, National Central Co-operative Bank v. Ajay Kumar14 and Fateh Singh v. State of Rajasthan15. The principles of natural justice have also been violated. Rule of Audi Alteram Partem is the primary notion of the principle of natural justice. Both the parties 12 (1978) 2 S.C.R. 621 A.I.R. 1994 S.C. 39 14 A.I.R. 1995 Raj. 15 35 15 (1968) S.C. [C.A. 1362/67 dt. 16.(J2.1968] 3 13 Page 14 of 21 MEMORIAL ON BEHALF OF PETITIONERS should get an opportunity of fair hearing and justice. This maxim also ensures that fair hearing and justice will be done towards both the parties, both the parties have right to speak. No decision will be taken by court without hearing both the parties. Hence, it is humbly submitted that since there has been a violation of the fundamental rights, the Court has the requisite jurisdiction to entertain this writ petition under Article 226 of the Constitution of India. Page 15 of 21 MEMORIAL ON BEHALF OF PETITIONERS WHETHER REMOVAL OF SOMEONE’S LIVELIHOOD IN THIS ARBITRARY MANNER VALID UNDER ARTICLE 19(1)(G) AND ARTICLE 21 OF INDIAN CONSTITUTION? The constitution of India protects the rights of the street vendors just like any citizen of the country. Article 14 talks about equality before law and most importantly the Article 19(1)(g) guarantees to every citizen the right to practice any profession which grants the street vendors, like any citizen, their right to carry the business or trade of their choice. The Article 21 that talks about the protection of Life and personal Liberty also includes the protection of the livelihood of individuals. Street Trading as an Age- Old Profession Street trading is an age-old vocation adopted by human beings to earn living. It is one of the traditionally recognised business or trade in England. This is so in spite of the fact that there is a complete social security in that country and as such no compulsion on the citizens to be driven to street trading out of poverty or unemployment. On the other hand, abysmal poverty in India warrants outright rejection of the argument that nobody has a right to engage himself in 'street trading'. There is no justification to deny the citizens of their right to earn livelihood by using the public streets for the purpose of trade and business. Article 19- A Right of Street Vendors Article 19(1)(g) of the Constitution guarantees to every citizen the right to practice any profession or to carry on any occupation, trade or business. Likewise, hawkers have the fundamental right to carry on trade or business of their choice. But it is subjected to reasonable restriction imposable under Article 19(6) of Indian Constitution. The guarantee under Article 19(1)(g) extends to practice any profession, or to carry on any occupation, trade or business. The object of using four analogous Page 16 of 21 MEMORIAL ON BEHALF OF PETITIONERS and overlapping words in Article 19(1)(g) is to make the guaranteed right as comprehensive as possible to include all the avenues and modes through which a man may earn his livelihood. In a nut-shell the guarantee takes into its fold any activity carried on by a citizen of India to earn his living. The activity must of course be legitimate and no anti- social like gambling, trafficking in women and the like. Once street-trading is accepted as legitimate trade, business or occupation it automatically comes within the protection guaranteed under Article 19(1)(g) of the Constitution of India. Street trading being a fundamental right has to be made available to the citizens subject to Article 19(6) of the constitution. It is within the domain of the State to make any law imposing reasonable restrictions in the interest of general public. This can be done by an enactment on the same lines as in England or by any other law permissible under Article 19(6) of the Constitution. In the case of South Calcutta Hawkers, Association vs. Govt. of West Bengal16, the court observed that “Street trading being a fundamental right has to be made available to the citizens but subject to Art. 19(6) of the Constitution. It is within the domain of the State to make any law imposing reasonable restrictions in the interest of general public on such right.” The court also observed that proper regulation is essential condition as otherwise the very object of laying out roads to facilitate traffic may be defeated. Article 21- A Pure Right of Vendors The right to life includes protection of means of livelihood. Forcible eviction of hawkers without prior notice is infringement of Article 21 of the Constitution. In Olga Tellis & Ors vs. Bombay Municipal Council17, the court observed that "no person can live without the means of living, that is the means of livelihood. If, the 16 17 AIR 1997 Cal 234: (1997) 1 CALLT 453 HC 1985 SCC (3) 545 Page 17 of 21 MEMORIAL ON BEHALF OF PETITIONERS right to livelihood is not treated as a part of constitutional right to life, the easiest way of depriving a person of his right to life would be to deprive him of his means of his livelihood to the point of abrogation." Performance of public act must be fair and reasonable. So, before eviction of the hawkers from the area, they must be served with notice so that their right is not infringed. This writ petition portrays the plight of many persons who live on pavements in the city of Chandigarh. They constitute majority of the population of the city. It is these men and women who have come to this Court to ask for a judgment that they cannot be evicted from their squalid places without being offered alternative. They rely for their rights on Article 21 of the Constitution which guarantees that no person shall be deprived of his life except according to procedure established by law. They do not contend that they have a right to work on the pavements. Their contention is that they have a right to live, a right which cannot be exercised without the means of livelihood. They have no option but to flock to big cities like Chandigarh, which provide the means of bare subsistence. They only choose a pavement or a slum which is nearest to their place of work. In a word, their plea is that the right to life is illusory without a right to the protection of the means by which alone life can be lived. And, the right to life can only be taken away or abridged by a procedure established by law, which has to be fair and reasonable, not fanciful or arbitrary such- as is prescribed by the Chandigarh Municipal Corporation Act or the Chandigarh Police Act. The Supreme Court, in the case Bombay Hawkers Union v. Bombay Municipal Corporation & Others18, for the first time upheld the right to livelihood of the street vendors and went on to observe that unreasonable restrictions and conditions cannot be imposed on street vendors. In Gainda Ram v. MCD19, the 18 1985 AIR 1206: 1985 SCR Supl. (1) 849 I.A. Nos. 1, 3 and 4 in I.A. No. 1 in I.A. No. 407 and I.A. Nos. 9 and 10 in I.A. No. 407 in W.P. (C) No. 1699 of 1987 19 Page 18 of 21 MEMORIAL ON BEHALF OF PETITIONERS Supreme Court observed that the fundamental right of hawkers, just because they are poor and unorganized cannot be left in a state of limbo nor it can leave completely to be decided by the varying standards of a scheme which changes from time to time under the orders of the Court. Hence, it is humbly submitted that since there has been a violation of the fundamental rights, the Court has the requisite jurisdiction to entertain this writ petition under Article 226 of the Constitution of India. Page 19 of 21 MEMORIAL ON BEHALF OF PETITIONERS WHETHER THE VENDORS ARE ALLOTTED A SEPARATE PLACE FOR THE SALE? A street vendor is broadly defined as a person who offers goods or services for sale to the public without having a permanent built-up structure but with a temporary static structure or mobile stall (or headload). Street vendors may be stationary by occupying space on the pavements or other public/private areas, or may be mobile in the sense that they move from place to place carrying their wares on push carts or in cycles or baskets on their heads, or may sell their wares in moving bus etc. Several laws and policies have been implemented by individuals’ states. The Street Vendors (Protection of Livelihood and Regulation of Street Vending) Act, 2014 has been passed with the aims at protecting the livelihoods of street vendors and regulating their activities by demarcating the vending zones and has put up conditions and restrictions on Street Vending. The law mandates that a survey should be first conducted. The certificates can only be issued after that. It states that no hawkers can be removed from their place of work until and unless this survey is completed. It makes it compulsory that eviction or displacement of the hawkers from their place of work should only be the last resort. Even if it is necessary to evict the vendors from a particular place, there lies a provision of their rehabilitation to an alternative place. Therefore, it is humbly submitted before this Hon’ble Court that the street vendors be given reasonable opportunity to be heard and let them practise the profession of their choice and strength for their livelihood. Hence, it is humbly submitted that since there lies already a provision in the act and it is covered under their fundamental rights, the Court has the requisite jurisdiction to entertain this writ petition to let them practice. Page 20 of 21 MEMORIAL ON BEHALF OF PETITIONERS PRAYER Therefore, in light of the issues raised, arguments advanced and authorities cited, may this Hon’ble Court be pleased: 1. To Allow the Petition and issue the Writ of Prohibition directing upon the police not to take action upon FIRs and investigate. 2. To Order the Suspension of the order of the Chandigarh Administration and Municipal Corporation for evicting the hawkers from public premises. 3. To Direct the Concerned authorities to compensate the street vendors and hawkers for the property damaged during the eviction drive. AND/OR To pass any order(s) as may be necessary and deemed fit and proper in the facts and circumstances of the case to serve the interests of Justice and Equity. All of which is respectfully submitted. And for this act of kindness, the petitioners shall, as duty bound as ever, humbly pray. Respectfully submitted Place: Chandigarh Sd/ Date: (Counsel for the Petitioners) (Roll no.: 1758) Page 21 of 21