Sunday, 5 March 2023

Under which circumstances Circulars issued by IRDAI have retrospective effect?

(ix) It has been argued that the instructions in the

circular dated 12th October 2022 come into

force prospectively. This argument must also be

rejected. The IRDAI has been prompted to

issue the directions in the circular for the sole

reason that it was observed by the regulatory

authority that various insurers were repudiating

the claims on the pretext of the so called

‘exclusions’ in the policy document and hence

the regulatory authority was compelled to issue

the said directions. Thus, it stands to reason

that the directions have been issued to rectify

the arbitrary refusal of claims. Hence, the same

obviously applies to past refusals on the grounds

as mentioned in the circular.

REPORTABLE

IN THE HIGH COURT OF JUDICATURE AT BOMBAY

ORDINARY ORIGINAL CIVIL JURISDICTION

WRIT PETITION NO. 2839 OF 2021

Rita Kirit Joshi Vs NEW INDIA ASSURANCE COMPANY,

CORAM : G.S.Patel & Neela Gokhale, JJ.

PRONOUNCED ON : 1st March 2023

JUDGMENT ( Per Neela Gokhale J) :-

Citation: 2023 Lawweb (Bom HC ) 12.

1. Rule. Rule made returnable forthwith. Heard the Writ

Petition finally on merits with the consent of the Learned counsel

appearing for the Petitioner and the Respondent Nos. 1 and 3.

Though served, Respondent No. 2 is absent.

2. The present petition under Article 226 of the Constitution of

India seeks a declaration that under Clause No. 3.11 of a particular

insurance policy, the Petitioner is entitled to a recovery of all the

expenses she incurred for the treatment of her new-born twin

babies. She seeks a mandamus to the Respondent No. 1 insurance

company to disburse the amounts of her claim. The prayers in the

amended writ petition read thus:

“A. That this Hon'ble Court be pleased to issue a writ of

Mandamus or Certiorari or any other appropriate writ,

order or direction in the nature of a writ of Mandamus or

Certiorari or any appropriate writ, order or direction under

Articles 226 r/w Articles 14 & 21 of the Constitution of

India, to hold and declare that under Clause 3.11 of the

Mediclaim policies bearing Nos.: 14220034179500003932

& 1422003417780000676, the Petitioner would be entitled

to all the expenses incurred by her for the treatment of her

new born twin babies in terms of her claims amounting to

Rs. 11,05,593/-; AND may further be pleased to quash and

set aside the impugned communication dated Nil (which is

at EXHIBIT - "H" to the petition) and the rejection / non

acceptance of her claims under her Mediclaim Policies;

AND further direct the Respondent No. 1 to reimburse the

total expenses/claims submitted by the Petitioner for

treatment of her twin babies under the Mediclaim policies

bearing Nos.: 14220034179500003932 & 14220034177800

00676 amounting to Rs.11,05,593/- along with interest @

18% from the date of refusal i.e. December–2018 till the date

of actual payment to the Petitioner.”

3. FACTUAL MATRIX

A) In 2007, the Petitioner took Mediclaim Policies Nos.

14220034179500003932 and 14220034177800003932

for Rs. 20 Lakhs from the Respondent No. 1 in the

year 2007. These policies were renewed periodically.

The Petitioner regularly paid the premia.

B) On 3rd September 2018, the Petitioner delivered twin

baby boys at 30 weeks’ gestation in an Emergency

Lower Segment Caesarean Section (LSCS). Since the

babies were premature, they had to be admitted to the

Neo Natal Intensive Care Unit (NICU) at Surya

Hospital for life-saving treatment. After their discharge

from the hospital, the Petitioner submitted a claim to

the 1st Respondent under the insurance policies

claiming the expenses she had incurred at the NICU

for the twins. For Twin Baby 1, the claim was Rs.

5,55,378/-. For Twin Baby 2, it was Rs. 5,52,565/-. The

aggregate claim was Rs. 11,05,953/-.

C) Vide its undated letter, a copy of which is at Exhibit

“H” to the Petition, the Respondent No.1 repudiated

the Petitioner’s claim, citing Clause 3.11 of the policy

document. As regards Twin Baby 1, the 1st Respondent

said that firstly, any 'expenses incurred towards postnatal

care, pre-term or pre-mature care or any such

expense incurred in connection with delivery of such

New Born Baby would not be covered, and, secondly, a

Congenital Eternal Anomaly of the New Born Baby

was also not covered under the policy. As regards Twin

Baby 2, there was no immediate communication.

However, it was later conveyed that the claim for Twin

Baby 2 also stood repudiated on identical grounds.

D) Thereafter, the Petitioner and her father-in-law

repeatedly made enquiries with the Respondent No.1.

They requested the Respondent No.1 to reconsider its

interpretation of Clause 3.11 of the policy. However,

the Company refused to alter its decision and the

Petitioner was told that since it was a term of the

policy, nothing could be done in the matter, which

should be considered as closed. The Petitioner was

suffering from post-partum depression, not unusual

after delivery. and was also on a break from her

profession as a legal practitioner. She has also suffered

great financial difficulties on account of the expenses of

medical treatment, especially since the Respondent

No.1 company refused to settle her legitimate claims.

The very purpose for which she had taken out the said

insurance policy was defeated by the repudiation of her

claims by the insurer.

E) The submission by Mr Shetty on behalf of the

Petitioner is that having regularly paid the premium on

the policy and having renewed it from time to time, the

impugned repudiation, especially on such flimsy,

restrictive, unilateral, untenable, incorrect and facially

arbitrary exclusions by the Respondent No.1 company

violates the fundamental rights under Articles 14 and

21 of the Constitution of India, not only of the

Petitioner but also of her new born babies. Hence this

Writ Petition.

F) The Respondent No.1 appeared in the proceedings and

filed its reply. Both parties filed various affidavits from

time to time and also relied on various documents. The

Petitioner filed affidavits dated 16th March 2021, 10th

January 2022, 29th January 2022, 25th April 2022 and

additional documents dated 5th January 2023. Per

contra, the Respondent No.1 filed affidavits dated 10th

March 2021, 7th January 2022, 27th January 2022,

additional documents dated 18th January 2022, and,

finally, an additional affidavit dated 20th July 2022.

G) Thereafter the rival parties made detailed submissions.

Vide order dated 10th February 2023, the parties were

given liberty to file brief written submissions by 17th

February 2023. Accordingly, the Petitioner and the

Respondent No.1 have filed their respective written

submissions.

4. SUBMISSIONS O F THE PETITIONER:

A) Appearing for the Petitioner, Mr Ashok Shetty

contended that any clause in a Mediclaim policy has to

withstand the test of reasonableness, fairness, nonarbitrariness

and non-discrimination. It is a contract of

the utmost good faith, a contract uberrimae fidei.

Therefore, ex hypothesi, it cannot contain restrictive or

unconscionable clauses that are opposed to public

policy.

B) On facts, he pointed out that the exclusion clause did

not exist when the Petitioner purchased the insurance

policies. Even upon renewal, the Petitioner was not

informed about the same.

C) He submitted that Clause 3.11 was hit by the Contra

Proferentum rule: being ambiguous, it had to be

interpreted in favour of the insured.

D) Mr Shetty also laid emphasis on the IRDAI guidelines

which are binding on the Respondent No.1. These have

defined ‘New Born Baby’ to mean a baby born during

the policy period and up to 90 days in age. He drew our

attention to Clauses 3(2) and 4(1), and to Chapter III,

Regulations 11(c) and 13 of the IRDAI Notification, and

to the Master Circular dated 29th July 2016, also issued

by IRDAI, followed by its clarification circulars dated

22nd July 2020 and 12th October 2022.

E) He submitted that the Circular dated 12th October

2022 clearly mentions that all insurance products

which cover newborn/unborn must comply with the

above referred provisions without any deviation and

provide coverage from day one without imposing any

waiting periods/sub-limits or any other restrictive

conditions.

F) Mr Shetty relied upon the fact that corporate group

insurance policies have no clause similar or akin to

Clause 3.11, but the insured still get benefits for

premature new-born babies, a fact not disputed by the

Respondent. Thus, he contended, there is clear

discrimination and manifest arbitrariness within the

meaning of Article 14 of the Constitution of India.

There was no rational classification, nor intelligible

differentia between new-born and premature babies.

G) He also submitted that the repudiation of the claim and

the policy was also contrary to IRDAI guidelines,

which have the force of law.

H) Resultantly, there was also a violation of Article 21 of

the Constitution of India.

I) The Petitioner also relied upon various judgments of

the apex courts in support of her case.

J) The Petitioner thus contended that the repudiation of

the claim by the Respondent No.1 Company is unlawful

and arbitrary and sought relief as prayed in the petition.

5. SUBMISSIONS O F THE RESPONDENT:

A) Shri Joshi on behalf of Respondent No.1 submitted that

the dispute raised in the Writ Petition regarding

repudiation of claim of the petitioner lodged under

Mediclaim Policy is purely contractual in nature and

the Respondent No.1, though a public sector insurance

company cannot be regarded as ‘State’ within the

meaning of Article 12 of the Constitution of India since

the dispute does not relate to statutory or governmental

function carried out by the Respondent No.1. It was

thus argued that the Petitioner has equally efficacious

and alternate remedy in contractual law and hence the

writ petition is not maintainable.

B) The second ground justifying the repudiation raised by

the Respondent No.1 was that the bare reading of

Clause 3.11 clearly indicated that no claim was

admissible for post-natal care and as per the policy

terms and conditions, pre and post-natal expenses are

not payable. It was further canvassed that the terms of

the insurance policy are required to be read as it is

without any addition or subtraction from them.

C) The Respondent No.1 filed an additional affidavit dated

27th January 2022 in pursuance of Order dated 18th

January 2022, permitting the Respondent No.1 to place

on record an affidavit annexing opinion of three

medical practitioners. All the three doctors consulted

by the Respondent No.1 have opined that the

complications in the new-born babies were developed

due to their premature birth and the said complications

would usually not occur in baby born full term. The

Respondent No.1 in its written submissions have also

relied upon expert opinion of Dr Salama Rayani Khan,

a Medico Legal Expert. She has opined that the

sentence in clause 3.11 of the policy regarding coverage

and exclusion have to be read together for

interpretation and cannot read in isolation. She has also

opined that had this case not been a case of pre-term

birth and instead a normal or caesarean delivery at fullterm,

the rest of the complications mentioned in the

discharge summary would not have occurred and hence

the claim does not come within the purview of the

policy terms and conditions.

D) It was also contended on behalf of the Respondent

No.1 that the New India Mediclaim 2012 policy terms

were revised by the Respondent No. 1 in the year 2017

and all the existing policy holders were intimated of the

same by separate letters through RPAD. However, the

letter purported to have been issued to the petitioner is

not placed on record. We were told that this was

because, considering the high volume of issuance of

such letters, it was practically difficult for the Insurance

Company to retain office copies of the same. The

Respondent No.1 sought to rely upon one such letter

issued by it to another policy holder, which has no

connection with the present Petitioner.

E) In a separate affidavit, it has been stated by the

Respondent that coverage for new born babies was

introduced for the first time in the year in which the

twins of the Petitioner were born and the benefit was

extended to all policy holders in the said year, without

payment of additional premium and for subsequent

years, the coverage was extendable subject to payment

of additional premium by including names of new born

babies in the policy.

F) The Respondent No.1, vide its written submissions has

also contested the value of the policy. It is its

submission that the original policy covered the risk to

the limited extent of Rs. One Lakh only. The

Respondent No.1 has contested the claim of the

Petitioner regarding the benefits available under the

original policy stating that the top-up policy was issued

by collecting premium only for the Petitioner and her

husband whereas the new coverage was introduced for

new-born babies without additional premium in the

original policy. It is the contention of the Respondent

No.1 that the policy terms attached with the top-up

policy does not include the coverage for the new-born

babies.

G) Thus, the Respondent No.1 company defended the

repudiation of the claim and reiterated that the terms

and conditions being contractual, the writ petition was

not maintainable and hence this Court, in the exercise

of its extra ordinary writ jurisdiction, may not interfere

with the same.

6. ANALYSIS

A) Maintainability of the petition

(i) Turning first to the issue of maintainability, the

submission on behalf of the Respondent No.1 that the

writ court will normally not entertain contractual

disputes is doubtless correct. However, the question in

the present matter is not one of the jurisdiction of the

Court, but of whether the discretionary power under

Article 226 of the Constitution ought to be exercised in

the particular case.

(ii) The question was considered in some detail in Life

Insurance Corporation of India & Ors v Asha Goel & Anr1.

This Court had allowed a writ petition against the

appellant. The insurance company contended that the

writ court ought not to have entertained a contractual

dispute. The Supreme Court held as follows:

1 (2001) 2 SCC 160.

“10. Article 226 of the Constitution confers extraordinary

jurisdiction on the High Court to issue high prerogative

writs for enforcement of the fundamental rights or for

any other purpose. It is wide and expansive. The

Constitution does not place any fetters on the exercise of

the extra ordinary jurisdiction. It is left to the discretion

of the High Court. Therefore, it cannot be laid down as

a general proposition of law that in no case the High

court can entertain a writ petition under Article 225

of the Constitution to enforce a claim under a life

insurance policy. It is neither possible not proper to

enumerate exhaustively the circumstances in which such

a claim can or cannot be enforced by filing a writ petition.

The determination of the question depends on

consideration of several factors like, whether a writ

petition is merely attempting to enforce his/her

contractual rights or the case raises important

questions of law and constitutional issues, the

nature of the dispute raised; the nature of inquiry

necessary for determination of the dispute etc. The

matter is to be considered in the facts and

circumstances of each case….. The courts have

consistently taken the view that in a case where for

determination of the dispute raised, it is necessary to

inquire into facts for determination of which it may

become necessary to record oral evidence a proceedings

under Article 226 of the Constitution, is not the

appropriate forum…

11. The position that emerges from the discussion in the

decided cases is that ordinarily the High Court should

not entertain a writ petition filed under Article 226 of

the Constitution for mere enforcement of a claim under

the contract if insurance. Where an insurer has

repudiated the claim, in case such a writ petition is

filed, the High Court has to consider the facts and

circumstances of the case, the nature of the dispute

raised and the nature of the inquiry necessary to be

made for determination of the questions raised and

other relevant factors before taking a decision

whether it should entertain the writ petition or reject

it as not maintainable. It has also to be kept in mind

that in case an insured or nominee of the deceased

insures is refused relief merely on the ground that the

claim related to contractual rights and obligations

and he/she is driven to a long-drawn litigation in the

civil court it will cause serious prejudice to the

claimant/other beneficiaries of the policy. The pros

and cons of the matter in the context of the factsituation

of the case should be carefully weighed and

appropriate decision should be taken. In a case where

claim by an insured or a nominee is repudiated raising a

serious dispute and the Court finds the dispute to be a

bona fide one which requires oral and documentary

evidence for its determination then the appropriate

remedy is a civil suit and not a writ petition under

Article 226 of the Constitution. Similarly, where a

plea of fraud is pleaded by the insurer and on

examination is found prima facie to have merit and

oral and documentary evidence may become

necessary for determination of the issue raised, then

a writ petition is not an appropriate remedy.”

(Emphasis supplied)

(iii) In Biman Krishna Bose v United India Insurance Co. Ltd,2

the Supreme Court held that insurance companies

acquiring the trappings of the “State” as other

authorities under Article 12 of the Constitution, and

ought to act reasonably and fairly while dealing with

customers. This judgment makes it clear that the

actions of insurance companies can be tested in writ

proceedings, and set aside, if found to be arbitrary.

(iv) In the present matter, the relief sought by the petitioner

does not merely arise out of the contract of insurance.

It is more a question of an interpretation of Clause 3.11

of the policy. The facts in the present case are not in

serious dispute. The issuance of the policy, renewal of

2 (2001) 6 SCC 477.

the policy, regular payment of premiums or disclosure

of relevant details by the insured are all not

contentious.

(v) The nature of the dispute in the present case only

raises an interpretation of the relevant clause. Neither a

fact-finding exercise nor an inquiry are required to

determine the factual matrix in the present case.

Moreover, the Petitioner is not merely trying to enforce

her contractual rights but has sought a direction to the

Insurance company to act in aid of the terms and

conditions of its policy.

(vi) Thus, applying the principles laid down in the above

cited judgments, we are of the view that the writ

petition cannot be dismissed on the grounds of

maintainability. The petition has been filed to challenge

the decision of a ‘State’ instrumentality as arbitrary,

and the Petition can be decided in accordance with the

principles which govern exercise of jurisdiction under

Article 226 of the Constitution. We hold that the

Petition is maintainable.

B) On Merits:

(i) The principal bone of contention between the

rival parties is the interpretation of Clause

3.11 of the policy. Clause 3.11 reads as thus:

“3.11 DAY ONE BABY COVER

A New Born Baby is covered for any

Illness or Injury from the date of birth till

the expiry of this Policy, within the terms

of this Policy. Any expense incurred

towards post natal care, pre-term or premature

care or any such expense incurred

in connection with delivery of such New

Born Baby would not be covered.

Congenital External Anomaly of the New

Born Baby is covered only after 36 months

Waiting Period. Waiting Period for

Congenital Internal Disease would not

apply to a New Born Baby during the year

of Birth and also subsequent renewals, if

Premium is paid for such New Born Baby

and the renewals are effected before or

within thirty days of expiry of the Policy.

Any Illness or Disease will be covered

within the Sum Insured of the mother till

the expiry of the Policy and No coverage

for the New Born Baby would be available

during subsequent renewals unless the

child is declared for insurance and

covered as an Insured Person.

Note: New Born Baby means a baby born

during the Policy Period to a female

Insured Person, who has twenty-four

months of Continuous Coverage with us.”

(ii) It is relevant to note at this juncture that

coverage for new born babies was introduced for

the first time in the year in which the twins of

the Petitioner were born and the benefit was

extended to all policy holders in the said year,

without payment of additional premium. For

subsequent years, the coverage was extendable

subject to payment of additional premium by

including names of new born babies in the

policy. Thus, it is undisputed that the new-born

twins were also covered under the said policy,

being born in the same year. For this reason, the

contention of the Respondent No.1 that the topup

policy includes the names of the Petitioner

and her spouse only and does not include the

coverage for new-born baby is not relevant.

(iii) A bare reading of the entire policy document

clearly reveals that the term ‘new-born’ has not

been defined in the original policy document.

However, clause 3.11 admittedly covers a newborn

baby for any illness or injury.

(iv) An argument is sought to be made between

‘expenses relating to illness or injury to the new-

born’ as distinct from ‘expenses relating to postnatal

care, pre-term or premature’. This is a

distinction without a difference. None can

explain what the distinction is. Post-natal care

postulates a new-born. One born before term is

a ‘pre-term’ or ‘premature’ baby. ‘Care’

includes tending to illness or injury. Thus, the

only logical reading is that expenses relating to

illness or injury is the same as expenses relating

to post-natal care, pre-term or premature

babies. The submissions needs noted only to be

stated to be rejected.

(v) Further, the words ‘illness’ and ‘injury’ are not

exhaustive. The injury can be on account of the

baby being born premature or pre-term. It is

impossible to accept such a distinction in order

to justify the repudiation. The further

distinction between a ‘new-born’ and a

‘premature baby’ or a baby born ‘pre-term’ is

also baseless as a new-born baby can be one

which is born ‘full term’ or ‘pre-term’. A fullterm

baby does not become more ‘newer’ any

more than a ‘pre-term’ baby becomes an ‘earlier

born’ or, to make it even more pointed, ‘old

born’. The approach is unreasonable, unjust

and contrary to the fundamental utmost goodfaith

ethic of an insurance policy. These

submissions are the sheerest casuistry. They

cannot be allowed to succeed.

(vi) The Petitioner has also placed on record a

circular dated 22nd July 2020, issued by the

regulator of the Respondent No.1 and other

insurance companies namely the Insurance

Regulatory and Development Authority of

India, the Respondent No.3 herein. The said

circular is the master Circular on

Standardization of health Insurance Products.

Clause 29 of the said circular defines the term

‘new-born baby’ to mean ‘baby born during the

policy period and is aged up to 90 days.’ Thus

the new-born twin babies of the petitioner are

clearly included in the definition of the said

clause.

(vii) The Petitioner has further placed on record

another circular dated 12th October 2022 issued

by the IRDAI, containing instructions to

CEO’s/CMD’s of All Insurance Companies

(except ECGC and AIC). The said circular

further issues a clarification to all concerned and

which settles the issue once and for all. The

instructions contained in the said circular read

as thus:

“To

CEOS/CMDs of All Insurance Companies

(except ECGC and AIC)

Re: Insurance cover for new-borns/infants

under health insurance policies :

1. Reference is invited to the Clause (1)

of Chapter -II on 'exclusions not allowed

under health insurance policies' issued vide

Master circular on Standardisation in Health

insurance Business dated 22nd July 2022

wherein it has been mandated that internal

congenital diseases, genetic diseases or

disorders are not allowed to be incorporated

as exclusions in the terms and conditions of

the policy contract. The intent of the above

provision is to cover newborns with internal

congenital birth defects from day one (1).

2. However, it is observed that many

health insurance products that are marketed

by insurers are not providing cover to

newborns/infants with internal congenital

birth defects from day one(1) thus going

against the true spirit of the above referred

clause.

3. In view of the above, it is reiterated

that all insurance products that cover

newborns/unborns shall comply with the

above referred provisions without any

deviation and provide, coverage from day

one (1) without imposing any waiting

periods/sub-limits or any other restrictive

conditions.

4. These instructions shall come into

force with immediate effect.

(YEGNA PRIYA BHARATH)

CHIEF GENERAL MANAGER”

(viii) The aforesaid instructions to insurers are

specifically intended to cover new-borns/infants

with internal congenital birth defects from day

one. The further directions clearly mandate all

insurers to comply with the said directions

without any deviations and provide coverage

from day one without imposing any waiting

periods/sub-limits or any other restrictive

conditions. The regulator therefore has sought

to remind the insurers the true spirit of the

clause.


(ix) It has been argued that the instructions in the

circular dated 12th October 2022 come into

force prospectively. This argument must also be

rejected. The IRDAI has been prompted to

issue the directions in the circular for the sole

reason that it was observed by the regulatory

authority that various insurers were repudiating

the claims on the pretext of the so called

‘exclusions’ in the policy document and hence

the regulatory authority was compelled to issue

the said directions. Thus, it stands to reason

that the directions have been issued to rectify

the arbitrary refusal of claims. Hence, the same

obviously applies to past refusals on the grounds

as mentioned in the circular.

(x) The peripheral reliance by the Respondent No.1

on the opinion of the three medical

practitioners is not relevant in the present

context, since we have already held that ‘newborn

baby’ includes a pre-term/premature born

baby. For this reason also, the opinion of Dr

Salama Rayani Khan, the Medico Legal Expert

is not relevant. Since the illness/injury to the

new born, arising on account of the timing of

their birth is irrelevant.

7. For the reasons stated hereinabove, we are of the view that

the impugned communication, dated Nil, issued by the Respondent,

conveying the rejection of the claim of the Petitioner is contrary to

law, unreasonable and arbitrary, and liable to be set aside.

8. The writ petition is therefore allowed. Accordingly, Rule is

made absolute in terms of prayer clause A. The impugned

communication is set aside. The Respondent is directed to honour

the Petitioner’s claims arising out of the Insurance Policy Nos.

14220034179500003932 & 14220034177800003932 to the extent of

the collective claim/s of Rs.11,05,593/- and pay the said amount to

her along with simple interest at 9 per cent per annum, from the

date of claim till the said amount is actually paid to her.

9. Lastly, we must note that it has taken the Petitioner, a young

mother and a professional, considerable trials and tribulations and

the roller coaster litigation process to bring the matter to its logical

conclusion. The aim of reposing faith in the insurance company, is

pre-eminently to guard/provide against dangers which beset human

life and dealings, by agreeing to pay the consideration in the form of

premiums, as per the terms of the policy. The Petitioner mother had

not even had the time to revel in the birth of her twin babies and

nurse them to health, when she faced the rude shock of rejection of

her legitimate claim/s by the Insurance company. The Insurance

Company, on the other hand appears to have stuck to its dogged

determination in refusing to honour the claim and even refusing to

act in aid of the directions issued by its own Regulating authority.

10. The Respondent No. 1 cannot be permitted to play fast and

loose with the faith reposed by the insured, and that too, supported

by regular renewals and payments of premium, by attempting to

interpret clauses in its policies, contrary to their true spirit and only

with a view to avoid honouring claims. Hence, we deem it fit and

proper, in the interests of justice, to direct the Respondent No.1 to

pay an amount of Rs. 5 Lakhs as costs of litigation, prompted in

addition by its defiance in obeying the directives of its own

Regulator.

11. All amounts are to be paid out in full within four weeks from

today.

12. The Petition is disposed of in these terms.

13. All concerned will act on production of an authenticated copy.

(Neela Gokhale, J) (G. S. Patel, J)


1st March 2023

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