“Raising the living standard and socio-economic uplift of industrial workers is the cornerstone of the government policy, which is being achieved by providing the basic and other social amenities of life to workers in the country. WWF (Workers Welfare Fund) has been playing a vital and progressive role in providing various important services to industrial workers. WWF has established many housing schemes for workers throughout the country. Development works of new schemes are under progress. In the medical sector, WWF has established hospitals and dispensaries in the areas of workers’ concentration. As for the education sector, primary to higher secondary level educational and training institutions have been established and being run all over the country. WWF also awards fully funded scholarships to the talented children of industrial workers. A number of other welfare activities such as marriage grant and death grant are also being run by WWF.”
— Syed Zulfiqar Abbas Bukhari, Special Assistant to Prime Minister/Minister of State for Overseas Pakistanis and Human Resource Development.
It is settled law and an express command of the Constitution that the law enunciated by the august Supreme Court become binding precedent for all forums of the country. All the executive and judicial authorities and forums are constitutionally obliged to implement the orders of and the principles and law laid down by the Supreme Court. Even if a review is pending against a judgment, the existing judgment shall be binding unless it has been reviewed and a different conclusion has been reached by the august Supreme Court. A judgment of the apex court will have due effect and deference if it decides a question of law or passes a judgment on the basis of law and/or enunciates a principle of law. These positions have been reiterated in the following cases:
- Khan Gul Khan and others versusDaraz Khan [2010 SCMR 539],
Muhammad Tariq Badr and another versus National Bank of Pakistan and others [2013 SCMR 314]. - Sindh High Court Bar Association through its Secretary and others versus FOP through M/O Law and Justice, Islamabad and others [PLD 2009 SC 879].
- Commissioner Income Tax versus Habib Bank Ltd. ANZ and Grindlays Bank [2015 PTD 619].
- Pakistan Telecommunication Employees Trust (PTET) through M.D. Islamabad and others versus Mohammad Arif and others [2015 SCMR 1472].
- Nazir Ahmed and others versus The State and others [PLD 2014 SC 241].
On October 10, 2018, the Federal Minister for Inter Provincial Coordination, Dr Fehmida Mirza, chaired a meeting to resolve issues of the Employees’ Old Age Benefits Institution (EOBI) and the Workers Welfare Fund (WWF) in the wake of the Constitution (Eighteenth Amendment) Act, 2010 which made many changes to the Constitution of Pakistan, including omission of the entire Concurrent Legislative List and certain amendments within the Federal Legislative List contained in the Fourth Schedule of the Constitution. The meeting was also attended by Syed Zulfiqar Abbas Bukhari, Special Assistant to the Prime Minister/Minister of State for Overseas Pakistanis and Human Resource Development and representatives of the Employers’ Federation of Pakistan and Pakistan Workers Federation from the provinces and Islamabad.
The meeting discussed in detail the issues faced by the Workers Welfare Fund and the Employees’ Old Age Benefits Institution following the Eighteenth Amendment. Dr. Fehmida Mirza observed,
“We are not against devolution or provincial autonomy but we need the welfare of our workers.”
Representatives of workers emphasized that the social security net should not be distributed among the provinces, rather it should be managed through the center and implemented by the provinces. They argued that the trans-provincial fund, assets, institutions and programs run by EOBI and WWF would be difficult to divide among the provinces. Moreover, the migration of workers would pose a big challenge. If the matter was devolved to the provinces, the welfare of workers would be affected.
The Federal Minister for Inter Provincial Coordination assured that the workers were the main stakeholders in the matter and their viewpoint needed to be given due importance. She directed the participants to formulate a strategy and submit their point of view in documented form, adding the following:
“We believe in cooperative federalism, we need to strengthen each other, the government is committed to devise a mechanism based on consensus, to ensure the welfare of the workers.”
The representatives of workers thanked the Minister for providing them with the opportunity to bring forth their viewpoint, scheduling the next meeting soon. What happened thereafter has not been made public. It appears that a deadlock persists on the issue between the federation and the federating units.
It is obvious that the Minister for Inter Provincial Coordination and the Special Assistant to Prime Minister/Minister of State for Overseas Pakistanis and Human Resource Development are not even aware that since 2006, the amendments made within various labour laws to broaden their scope, have been struck down by the Supreme Court in its order dated November 10, 2016 reported as Workers Welfare Funds m/o Human Resources Development, Islamabad through Secretary and others v East Pakistan Chrome Tannery (Pvt.) Ltd through its GM (Finance), Lahore etc. and others [(2016) 114 TAX 385 (S.C. Pak.)]. To date, no remedial measures have been taken to recover the losses caused to the funds/institutions established under these laws for the welfare of millions of workers.
The Supreme Court held the following in 2016 114 TAX 385 S.C. Pak:
“2. The facts pertaining to these matters are broadly divided into three categories for ease of reference. The first set of facts are that Sections 2 and 4 of the Worker Welfare Ordinance, 1971 (Ordinance of 1971) were amended by Section 12 of the Finance Act of 2006 and subsequently by Section 8 of the Finance Act of 2008 which broadened the scope of the obligation on industrial establishments to contribute towards the Workers’ Welfare Fund established under Section 3 of the Ordinance of 1971. The said amendments (and notices demanding enhanced payment by virtue of the amendments) were challenged through writ petitions before various High Courts of the country. It is pertinent to mention that there are divergent views of the learned High Courts on this question. The view of the learned Lahore High Court in the judgment dated 19.8.2011 reported as East Pakistan Chrome Tannery (Pvt.) Ltd Vs. Federation of Pakistan and others (2012) 105 TAX 81 (H.C. Lah.) = (2011 PTD 2643) is that the levy in question was a fee and not a tax, therefore the amendments made by the Finance Acts of 2006 and 2008 to the Ordinance of 1971 could not have been lawfully brought through a money bill, rather should have been brought through the regular legislative procedure under the Constitution. The learned Peshawar High Court, vide judgment dated 29.5.2014, followed suit. Subsequently the learned Peshawar High Court disposed of numerous tax references on the basis of this decision, against which the appeals are before us. We would like to point out at the very outset that as regards those cases in which the revenue authorities/collecting agencies have assailed the judgment of the learned Peshawar High Court, although no rights of the collecting agencies have been affected as their job is to merely collect contributions for the Workers’ Welfare Fund, we are nevertheless deciding those cases as well keeping in view the importance of the matter and the conflicting judgments impugned before us. There is a contrary view of the Full Bench of the learned High Court of Sindh expressed in the judgment dated 1.3.2013 reported as Shahbaz Garments (Pvt.) Ltd Vs. Pakistan through Secretary Ministry of Finance, Revenue Division, Islamabad and others (2013) 107 TAX 89 (H.C. Kar.) = (PLD 2013 Kar 449) (Full Bench judgment) to the effect that the levy in question was a tax and not a fee, therefore the amendments made by the Finance Acts of 2006 and 2008 to the Ordinance of 1971 were lawfully brought through a money bill. The aforementioned judgments have been challenged by the parties before us.
3. The second set of facts are that various provisions of the Employees Old Age Benefits Act, 1976 (Act of 1976) pertaining to contributions to be made there under were amended by Section 9 of the Finance Act of 2008 effectively widening the scope of the obligation on employers to contribute towards the Employees’ Old-Age Benefits Fund established under Section 17 of the Act of 1976. These amendments were challenged through constitution petitions before the learned High Court of Sindh which, through its judgment dated 3.10.2012 reported as Soneri Bank Limited through Jaffar Ali Khan and others Vs. Federation of Pakistan through Secretary Law and Justice Division, Pak Secretariat, Islamabad and others (2013 PLC 134), held that the levy in question was a fee and not a tax, therefore the amendments made by the Finance Act of 2008 to the Act of 1976 could not have been lawfully brought through a money bill.
4. The third set of facts are that various provisions of the Workmen Compensation Act, 1923, the West Pakistan Industrial and Commercial Employees (Standing Orders) Ordinance, 1968 (Ordinance of 1968), the Companies’ Profit Workers’ Participation Act, 1968 (Act of 1968), the Minimum Wages for Unskilled Workers Ordinance, 1969 (Ordinance of 1969) and the Act of 1976 were amended through the Finance Act of 2007 which amendment(s) in effect broadened the scope of the obligation of the employers in the respective statutes (the obligation(s) in each statute shall be discussed during the course of the opinion). These amendments were challenged through a constitution petition before the learned High Court of Sindh which, through its judgment dated 26.2.2011, held that the changes sought to be made by amendments through the Finance Act of 2007 did not fall within the purview of Article 73(2) of the Constitution, hence, the said amendments could not have been lawfully brought through a money bill. All the aforementioned judgments have been challenged before us.”
Sections 2 and 4 of the Workers Welfare Ordinance 1971 were amended by the Finance Act of 2006 and subsequently by the Finance Act of 2008 to broaden the scope of the obligation on industrial establishments to contribute towards the Workers Welfare Fund established under Section 3 of the 1971 Ordinance. The amendments were declared ultra vires to the Constitution by the Lahore High Court in East Pakistan Chrome Tannery (Pvt.) Ltd v Federation of Pakistan and others (2012) 105 TAX 81 (H.C. Lah.). The order was endorsed in 2016 by the Supreme Court in the order cited above. The issue was whether WWF was a “fee” or “tax”. The Supreme Court said it was a ‘fee’ and not ‘tax’, therefore, the amendments made by the Finance Acts of 2006 and 2008 as Money Bills had been unlawful.
Through the Finance Act 2008, various provisions of the Employees’ Old Age Benefits Act 1976, pertaining to contributions to be made thereunder, were also amended, widening the scope of obligation on employers to contribute towards the Employees’ Old Age Benefits Fund established under Section 17 of the 1976 Act. The amendments were challenged through Constitution Petitions before the Sindh High Court which, through its judgment dated 3.10.2012 reported as Soneri Bank Limited through Jaffar Ali Khan and others v Federation of Pakistan through Secretary Law and Justice Division, Pak Secretariat, Islamabad and others (2013 PLC 134), held that the levy was a fee and not a tax, therefore, the amendments made by the Finance Act of 2008 could not have been lawfully brought about through a Money Bill. Sindh High Court’s view was also upheld by the Supreme Court.
Through the Finance Act of 2007, various provisions of the Workmen Compensation Act 1923, the West Pakistan Industrial and Commercial Employees (Standing Orders) Ordinance 1968, the Companies’ Profit Workers’ Participation Act 1968, the Minimum Wages for Unskilled Workers Ordinance 1969 and the Act of 1976 were amended to broaden the scope of obligation of employers within the respective statutes. The amendments were challenged before the High Court of Sindh which, through its judgment dated 26.2.2011, held that the amendments through the Finance Act of 2007 not falling within the purview of Article 73(2) of the Constitution could not have been lawfully inserted through a Money Bill. Judgments of the Lahore and Sindh High Courts were challenged in the Supreme Court which upheld the same in 2016 114 TAX 385 (S.C. Pak.) with the following conclusion:
“There may very well be certain levies/contributions that do not fall within the purview of Article 73(3) but still do not qualify the test of Article 73(2) and therefore cannot be introduced by way of a Money Bill, and instead have to follow the regular legislative procedure…”
All this reflects sheer incompetence on part of our government and parliamentarians for not being able to distinguish which laws were to be presented as Money Bills and which laws should have gone to both Houses. The seemingly benevolent amendments made wrongly within labour laws for the working classes over a decade ago have neither been corrected by the Pakistan People Party (PPP) and the Pakistan Muslim League (Nawaz) during the “Decade of Democracy” (2008-2018), nor by the coalition government of Pakistan Tehreek-i-Insaf (PTI) since coming into power in August 2018. It can be deemed the worst expression of callousness towards labour. All parties during elections claim to be the champions of the cause of the downtrodden but in reality are merely paying lip-service. The PMLN and PPP had ten years to rectify the mistake pointed out by the courts but they remained unmoved. The same apathy is being demonstrated by the PTI government. This confirms that when it comes to the welfare of workers, our legislators are totally insensitive, but when the issue pertains to raising their own salaries, they are able to pass laws within a few minutes only in the National Assembly and the Senate. They are least bothered that their lapse has affected over half a million pensioners under EOBI and around five million workers of various categories registered for contributions, including women.
Before the Eighteenth Amendment, the Federal Board of Revenue (FBR) had the power to collect contributions under the Workers Welfare Funds Ordinance 1971 and the Profits (Workers’ Participation) Act 1968 from across the country. After the Eighteenth Amendment, the powers were devolved to the provinces. The Sindh Assembly was the first province to pass the Sindh Workers Welfare Fund Act 2014 to collect workers’ welfare fund (WWF) and the Sindh Companies Profits (Workers’ Participation) Act 2015 to collect workers’ profit participation fund (WPPF). The Punjab Assembly, following the Sindh Assembly, enacted the Punjab Workers Welfare Fund 2019.
The Sindh High Court in its order reported as 2018 CLD 1088 held that the Sindh Companies Profits (Workers’ Participation) Act 2015 would apply to all trans-provincial companies employing a total of 100 workers or more at any time of the year and operating across the country irrespective of the regional location of their registration. It elaborated that the principle of territorial limitation was not violated as it was only meant to establish parameters that would make the scheme applicable. The condition which related to the value of fixed assets of a company, according to the Sindh High Court, was irrelevant as the same could be located within or outside the province. The court directed that the law in the province of Sindh was to be applied and the workers were to get an amount proportionate to their number calculated. The workers in the province of Punjab were to get an amount proportionate to their number calculated at five percent and the same would not be discriminatory. The court enunciated that legislative competence was exclusively provincial and territorial extent was limited. According to the judgment, each province was entitled to legislate in its own manner in respect of a matter exclusively within its domain. It was irrelevant where the registered office and/or industrial undertaking of a trans-provincial company was located i.e. the same could be located in the province of Sindh or elsewhere and while making computation, all profits made by the company were to be used, regardless of where they were earned within the country.
In its order, the Sindh High Court said that the purpose of WPPF was the welfare of labour and there should have been no problems applying it to all the workers of a company throughout Pakistan. WPPF had retained its character from 1973 to 2010 i.e. from the commencement of the Constitution to the Eighteenth Amendment.
“The Act thereafter ‘fractured’ into provincial legislation and was then replaced by the Sindh Act,” the Sindh High Court’s order said in plain words.
On the basis of this judgment, officials of the Sindh Revenue Board (SRB) asserted that the provincial revenue authority was mandated to collect the amount from corporate and industrial units operating within the jurisdiction of the province or their offices or officers working in any other province or within the jurisdiction of the federal government.
The concluding paragraphs of the judgment are as under:
“33. Secondly, on the view that has been taken the specific problem identified by the learned Additional Attorney General, relating to dispute resolution also disappears. It is obvious that in our view, the 1968 Act as applicable in the other Provinces and the Capital respectively will apply there in the same manner as the Sindh Act in this Province, i.e. in respect of all the workers within the relevant territorial domain. Thus, if a worker, say in Punjab, has a dispute with a company that has its registered office here, he does not have to come to this Province for redressal; he can simply invoke the procedure available under the 1968 Act, as applying in Punjab as provincial legislation. The reverse would, obviously, also be true. Thirdly, a potential issue of a variation in the amount of distributable profits would also cease to be a problem. Currently, in each Province and in the Capital, the same percentage of the total profits is to be distributed, being five percent. But of course, that need not always be the case. Since the competence is now exclusively provincial, each Province (or the Federation in respect of the Capital) can vary the amount. Suppose the Sindh Act were to be amended so as to increase the amount to, say, seven percent. What would be the position of a trans-provincial company that had its registered office in, say, Punjab where the amount continued to remain at five percent? Could such a company argue that it was only liable to distribute to the workers in Sindh a proportionate amount calculated on the basis of five percent? In our view, the answer would have to be in the negative. The law in this Province would have to be applied, and workers here would get an amount proportionate to their number calculated at seven percent. Of course, the workers in Punjab would get an amount proportionate to their number calculated at five percent. But would this not be discriminatory? Again, the answer is that it would not. The reason is that the legislative competence is exclusively provincial, and the territorial extent is limited. Each Province is entitled to legislate in its own manner in respect of a matter that is exclusively within its domain.
34. In view of the foregoing discussion, we therefore answer the issue specified in para 2 above, which relates to the third category identified in the order of 19.09.2017, as follows. In the case of trans-provincial companies, it is the Sindh Act that applies, but interpreted, read and applied such that the obligation under the Act is only to make distribution to the workers in this Province, and only of an amount that is proportionate to their number here. It is irrelevant where the registered office and/or the industrial undertaking of the trans-provincial company are located, i.e., they could be located in this Province or elsewhere. Furthermore, in making the computation, the whole of the profits made by the company are to be used, regardless of where they were earned in the country.”
On the other hand, the august Supreme Court in the case of Messers Sui Southern Gas Ltd & Others v Federation of Pakistan & Other 2018 SCMR 802 extensively elucidated the post-Eighteenth Amendment position vis à vis the legislative competence of the federation and federating units in the following words:
“2. The Islamic Republic of Pakistan is a democratic State (Federation) with its Federating Units (Provinces) and the Constitution of the Islamic Republic Pakistan, 1973 (Constitution) recognizes and creates a balance between the authority of the Federation and the autonomy of the Provinces, which recognition has been given an iron cladding by virtue of the Eighteenth Amendment, passed vide the Constitution (Eighteenth Amendment) Act, 2010. This Amendment to the Constitution has inter alia introduced a drastic enhancement in the legislative authority of the Provinces by deleting the Concurrent Legislative List (CLL), whereby previously both the Parliament and the Provincial legislatures could legislate on the subjects enumerated therein. The omission of the CLL, left only a single Legislative List in the Constitution which exclusively list subjects that can be legislated upon by the Parliament alone, and by virtue of Article 142(c) of the Constitution any subject not enumerated in these two lists would subject to the Constitution, be within the legislative competence of the Provinces. Entry No. 26 of the erstwhile CLL contained the subjects of “welfare of labor; conditions of labor, provident funds; employer’s liability and workmen’s compensation, health insurance including invalidity pensions, old age pensions”, whereas, Entry 27 of the same dealt with the subjects of “trade unions; industrial and labor disputes”. Thus, prior to Eighteenth Amendment, the subject of labour and trade unions were in the domain of both the Parliament as well as the Provincial Assemblies. The labour laws enacted by the Parliament which were applicable in the Federation as well as the Federating Units. However, after the Eighteenth Amendment, the Parliament enacted the Industrial Relations Act 2012 (IRA 2012) which was challenged before the concerned High Courts (all the provincial High Courts as also the Islamabad High Court) mainly on the ground that the same is incompetently enacted by the Parliament as the subject of labour and the trade unions was no more in the legislative domain of the Parliament rather within the domain of the Provincial Assemblies. All the High Courts held (through judgments impugned herein as also other judgments) in favour of the constitutionality/validity of the IRA 2012.
20. At this juncture it is to be noted that when a provincial legislature is not competent to legislate with regard to the workmen of trans-provincial establishments, obviously the Federation has to interfere in the matter with a Federal Legislation to preserve and protect the fundamental rights of the said workmen ensured under Article 17 of the Constitution. We are in agreement with the observation made by the learned High Court that though in a Federal system, provincial autonomy means capacity of a province to govern itself without interference from the Federal Government or the Federal legislature, but as the Provincial legislature does not possess extra-territorial legislative authority i.e. it cannot legislate regarding the establishments operating beyond the territorial boundaries of that province. In absence of a Federal legislation, the right to form a trade union that can operate beyond the provincial boundaries could not be secured by any provincial law, and as such, any matter or activity of a trans-provincial nature would remain unregulated. The only solution to the above said problem is a Federal legislation. The effect of non-promulgation of IRA 2012 would be that the employer would not recognize the right of the workmen to form a countrywide trade union and carry out unified activities in his establishment at trans-provincial level; and also the number of workmen working in each unit of an establishment working in a certain Province would be counted separately which in turn would have adverse impact on the rights of the workmen, in so far as applicability of benefits and security of job granted under various labour laws are concerned as certain rights granted under various labour laws become available to the workmen depending upon the total strength of the workmen in an establishment. Needless to observe that as mentioned in its preamble, the object of promulgation of IRA 2012 is “to consolidate and rationalize the law relating to formation of trade unions, and improvement of relations between employers and workmen in the Islamabad Capital Territory and in trans-provincial establishments and industry”. Further, as per Section 3 thereof “it shall apply to all persons employed in any establishment or industry, in the Islamabad Capital Territory or carrying on business in more than one province”. Hence, the parliament in its wisdom has intentionally left it for a Province to make legislation concerning the establishments/trade unions functioning only within the limits of that Province, without transgressing the territorial limits of the said Province. Thus, neither does the IRA 2012 in any manner, defeat the object of the Eighteenth Amendment nor does it destroys or usurps the provincial autonomy or the principle on which the Federation was formed under the Constitution; rather it facilitates to regulate the right to form unions at trans-provincial level, which could not be attained through a provincial law.
23. For the foregoing reasons, the appeals as also the petition are dismissed and it is held as under:
- the Federal Legislature has extra-territorial authority but no such extra-territorial authority has been conferred to the Provincial Legislature by the Constitution;
- the Federal legislature does, but the Provincial Legislature does not, have legislative competence to legislate to regulate the trade unions functioning at trans-provincial level;
- the matters relating to trade unions and labour disputes, etc., having been dealt with and protected under the International Conventions, are covered under Entries No.3 and 32 of Part-I of the FLL. Thus, the Federal Legislature has legislative competence to legislate in this regard;
- under the command of Entry No.13 in Part-II of the FLL, the Federation has competence to enact laws relating to the inter-provincial matters, Entry No.18 thereof further enlarges the scope of the said Entry; therefore, the Federal Legislature has legislative competence to legislate in this regard too;
- the IRA 2012 neither defeats the object of the Eighteenth Amendment to the Constitution nor does it destroy or usurp the provincial autonomy;
- the IRA 2012 has been validly enacted by the Parliament and is intra vires the Constitution;
- the workers of the establishments/industries functioning in the Islamabad Capital Territory or carrying on business in more than one provinces shall be governed by the Federal legislation i.e. IRO 2012; whereas, the workers of establishments/industries functioning or carrying on business only within the territorial limits of a province shall be governed by the concerned provincial legislations;
- as we have held that the IRA 2012 is valid piece of legislation, it is held that the National Industrial Relations Commission (NIRC) formed under Section 35 of the IRA 2012 has jurisdiction to decide the labour disputes, etc., relating to the employees/workers of companies/corporations/institutions/establishments functioning in more than one Province;
- the IRA 2012, being a procedural law, would be applicable retrospectively w.e.f. 01.05.2010, when the IRO 2008 ceased to exist; and
- M/s Shaheen Airport Services is not a charitable organization and IRA 2012 is applicable to it as it is operating in more than one Province.”
[Underlined for emphasis].
The above pronouncement of the Supreme Court is not restricted to any particular law. It covers all laws, including those related to the welfare of labour and provision of social security to citizens. It is binding under Article 189 of the Constitution. Since the issue at hand relates to trans-provincial applications/operations, in light of the above order of the Supreme Court, through the democratic process vide Article 144/147 of the Constitution, all laws related to workers and social security can be federalized, instead of being ‘fractured’ or fragmented, and managed by multiple agencies/institutions in the provinces.
It is high time that the PTI government come to the rescue of all those affected, through curative amendments or by supporting the review petition pending in Workers Welfare Funds m/o Human Resources Development, Islamabad through Secretary and others v East Pakistan Chrome Tannery (Pvt.) Ltd through its GM (Finance), Lahore etc. and others [(2016) 114 TAX 385 (S.C. Pak.)] on the basis of the above case cited as 2018 SCMR 802. The better course will be for the Ministry of Inter Provincial Coordination, in consultation with the Ministry of Law, to get a Bill prepared in light of the observations of the Supreme Court in the above cited cases and ensure the retrospective retrieval of lost contributions outstanding since 2006. Any party in the National Assembly or Senate to oppose such a Bill will only get exposed for being anti-labour. The recovery of money and its settlement between the federal government and the provinces can be sorted by the Ministry of Inter Provincial Coordination under Article 144 of the Constitution.
The proposed curative amendment will bring the much needed billions to the national exchequer and be able to provide pension, decent housing, free education and healthcare facilities to the beneficiaries of welfare laws. The PTI government is looking for money for such objectives, unaware that billions are already lying unpaid with industrial undertakings/employers. The legislators have also failed to take note that any Provincial Assembly, through a resolution under Article 144 of the Constitution, can ask the National Assembly to enact laws for the welfare of workers and the social security of citizens (PTI has a two-third majority in Khyber Pakhtunkhwa and coalition governments in Punjab and Balochistan to be able to pull this off). The funds can go into the National Fund to provide help to all workers and citizens wherever they may be residing. It is strange that even the Law Ministry has not considered this advice after the judgment of the Supreme Court involving Article 149 of the Constitution in the Suo Moto Case 1 of 2020.
The views expressed in this article are those of the authors and do not necessarily represent the views of CourtingTheLaw.com or any organization with which they might be associated.
