Indian Law Review最新文献

{"title":"Legalizing executive control: on the law of online journalism in India","authors":"Nakul Nayak","doi":"10.1080/24730580.2023.2266979","DOIUrl":"https://doi.org/10.1080/24730580.2023.2266979","url":null,"abstract":"ABSTRACTThis article critiques the Information Technology (Intermediaries Guidelines and Digital Media Ethics Code) Rules 2021 (“the Rules”) as they relate to online journalism. The Government’s stated objective for making the Rules is to “level the playing field” of online journalism with print journalism. I examine whether and how the Government satisfies this objective. I make two broad claims. First, the Rules fail to “level the playing field”. The objectives, philosophical approach, and substance of the new regulatory scheme are significantly different from those that govern print journalism, and to the disadvantage of online journalism. Second, rather than “levelling the playing field”, the Rules give the Government overwhelming control of online journalism. The Government exercises ultimate control over the regulatory structures and gives itself unprecedented censorship powers over online journalism. If my claims are correct, the Rules will have catastrophic consequences for online journalism and Indian democracy.KEYWORDS: Digital Media Ethics CodePress Council of Indiaonline journalismPress Commissiondigital media ethics AcknowledgmentsFor research support, I am grateful to Arunima Das, Kaustubha Kalidindi, and Ananya Narain. Thanks to Sukumar Muralidharan, Siddharth Narrain, Aakanksha Kumar, Shohini Sengupta, Keerti Pendyal, Ashaawari Datta Chaudhuri, Sandeep Suresh, Rajesh Nayak, and Neytra Nayak for valuable discussions. Errors are mine alone. To Sagarika Nayak, for her unwavering support during good and bad.Disclosure statementNo potential conflict of interest was reported by the author(s).Notes1 A notable exception was the Foreign Contribution (Regulation) Act 2010. Sections 3(1)(g) and 3(1)(h) prohibit “any association or company engaged in the production or broadcast of … current affairs programmes through any electronic mode” or their “correspondent or columnist, cartoonist, editor, owner” from accepting any “foreign contribution”.2 Akriti Gaur, Aniruddh Nigam and Sreyan Chatterjee, “The future of news in India” Vidhi Centre for Legal Policy 33 (30 April 2020) <https://vidhilegalpolicy.in/research/the-future-of-news-in-india/> accessed 6 July 2023.3 The lack of specific regulatory frameworks for DNMs and DNM’s ability to engage in target advertising have resulted in dynamic business models in online journalism. See ibid 18–22.4 Press Information Bureau, “Cabinet approves proposal for Review of FDI policy on various sectors” (28 August 2019) <https://pib.gov.in/PressReleseDetail.aspx?PRID=1583294> accessed 6 July 2023.5 Soumyarendra Barik, “Watch: Why New FDI Rules For Digital Media Companies Are Regressive For The Internet Space In India” Medianama (New Delhi, 5 September 2019) <https://www.medianama.com/2019/09/223-fdi-in-digital-media-regressive/> accessed 6 July 2023.6 Ministry of Information and Broadcasting, ‘Soliciting Suggestions/Comments/Inputs from the Stakeholders on the Draft ”Registration of Press and Periodicals Bill ","PeriodicalId":13511,"journal":{"name":"Indian Law Review","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2023-10-16","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"136113605","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

{"title":"Under-inclusive laws and constitutional remedies: an exploration of the Citizenship (Amendment) Act 2019","authors":"John Sebastian","doi":"10.1080/24730580.2023.2255478","DOIUrl":"https://doi.org/10.1080/24730580.2023.2255478","url":null,"abstract":"ABSTRACTIt has been widely argued that the Citizenship (Amendment) Act 2019 (“CAA”) breaches Article 14’s equality guarantee due to its under-inclusiveness i.e. it does not include within its ambit many migrants who faced persecution similar to the persons it covers. However, it is often argued that under-inclusive laws are subjected to a low standard of review, which increases the justificatory burden on those who challenge its validity. I argue that there is no support in principle or case law for the argument that under-inclusive laws are subject to lower scrutiny than over-inclusive ones. Linked to this is the question of constitutional remedies for under-inclusive laws, which I analyse drawing on jurisprudence from India and other jurisdictions. Contrary to dominant opinion, I argue that, were the CAA to be declared unconstitutional, the appropriate remedy would be to extend its benefits to those hitherto uncovered by it, rather than striking it down.KEYWORDS: Citizenship Amendment Act 2019CAAunder-inclusive lawsstandard of reviewconstitutional remediesseveranceextension of benefits AcknowledgmentsI thank Tarunabh Khaitan, Faiza Rahman, Apoorva Sharma and Anshuman Singh for their detailed comments on previous versions of this paper. I thank the participants in the session on Constitutional Remedies at the ICON.S 2021 conference, where this paper was presented, and two anonymous reviewers for their careful and detailed feedback. I am grateful to Amber Darr, Nakul Nayak, Arun Thiruvengadam and the editorial team at the Indian Law Review for their patient and thoughtful engagement with the paper. Thanks also to the Melbourne Research Scholarship for supporting my research. Any errors are mine alone.Disclosure statementNo potential conflict of interest was reported by the author(s).Notes1 Citizenship (Amendment) Act 2019, ss 2–4, 6 (CAA).2 Murali Krishnan, “In 10 points, Supreme Court hearing on Citizenship Act petitions explained” Hindustan Times (New Delhi, 30 August 2020) <www.hindustantimes.com/india-news/supreme-court-to-hear-144-petitions-on-citizenship-act-petitions-shortly/story-LHiqENFSldrRfSFPBq4OGO.html> accessed 29 July 2023.3 Constitution of India 1950, art 14 (Constitution).4 Abhinav Chandrachud, “Secularism and the Citizenship Amendment Act” (2020) 4 Indian Law Review 138, 154.5 Citizenship (Amendment) Bill 2019, statement of objects and reasons. See also Preliminary Counter-Affidavit on Behalf of the Union of India 26, 81, in Indian Union of Muslim League v Union of India, Writ Petition (Civil) No 1470 of 2019 <www.scobserver.in/wp-content/uploads/2021/10/Counter_Affidavit_filed_by_Union.pdf> accessed 29 July 2023.6 See Kanika Gauba and Anshuman Singh, “Voter, Citizen, Enemy” (2017) 52(23) Economic and Political Weekly 12; Mohsin Alam Bhat, “The Constitutional Case Against the Citizenship Amendment Bill” (2019) 54(3) Economic and Political Weekly 12, 13; Chandrachud (n 4); Jaideep Singh Lalli, “Communalisation of Citizenship Law:","PeriodicalId":13511,"journal":{"name":"Indian Law Review","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2023-09-20","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"136373959","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

{"title":"The non-obstante nuisance: a critique of Section 238 of the Insolvency and Bankruptcy Code","authors":"Vishvesh Vikram, Kannan Shailesh Jhunjhunwala","doi":"10.1080/24730580.2023.2259259","DOIUrl":"https://doi.org/10.1080/24730580.2023.2259259","url":null,"abstract":"ABSTRACTThis paper argues that the non-obstante clause in the Insolvency and Bankruptcy Code 2016 (IBC), which gives supremacy to the IBC over all previous laws in case of conflict, does not serve its purpose of asset preservation, and highlights problems that arise due to its presence. The paper analyses this provision considering the test for determining inconsistency between statutes in Indian law. It argues that the impact of IBC across different fields of operation brings forth several inconsistencies when deciding a conflict between the IBC and another statute. It presents problems arising due to the supremacy given to the IBC through the non-obstante clause, and exhibits how its application sometimes defeats its purpose. Lastly, the paper analyses insolvency regimes of the UK and Singapore, as well as the UNCITRAL Guide on Insolvency, and presents an example of instituting better cooperation between authorities initiating proceedings against a company under different statutes.KEYWORDS: Insolvency and Bankruptcy Codeinsolvencynon-obstanteSection 238IBCIndian lawnotwithstandingoverarchingblanketconflict Disclosure statementNo potential conflict of interest was reported by the author(s).Notes1 South India Corporation (P) Ltd v Secy, Board of Revenue, Trivandrum AIR 1964 SC 207 [215]; Chandavarkar Sita Ratna Rao v Ashalata S Guram (1986) 4 SCC 447; PEK Kalliani Amma (Smt) v K Devi (1996) 4 SCC 76; Moreshwar Balkrishna Pandare v Vithal Vyanku Chavan (2001) 5 SCC 551; Iridium India Telecom Ltd v Motorola Inc (2005) 2 SCC 145.2 Waman Shrinivas Kini v Ratilal Bhagwandas & Co AIR 1959 SC 689.3 ibid.4 ibid.5 M Venugopal v Divisional Manager, Life Insurance Corporation AIR 1994 SC 1343; Hindu Marriage Act 1955, s 16.6 See e.g. Prevention of Money Laundering Act 2002; Electricity Act 2003; Income Tax Act 1961.7 Sandeep Bhalla, Principles of Interpretation in India with Legal Maxims (Lawmystery.com 2006) 121.8 The Insolvency and Bankruptcy Code 2016, s 238.9 Ministry of Finance, Government of India, The Report of the Bankruptcy Law Reforms Committee Volume I: Rationale and Design (2015) 12 <https://ibbi.gov.in/BLRCReportVol1_04112015.pdf> accessed 09 August 2023.10 Aravind Gayam, ‘The Insolvency and Bankruptcy Code: All you need to know’ (PRS Legislative Research, 10 May 2016) <https://prsindia.org/theprsblog/the-insolvency-and-bankruptcy-code-all-you-need-to-know> accessed 09 August 2023.11 Reserve Bank of India, Master Circular, Prudential norms on Income Recognition, Asset Classification and Provisioning pertaining to Advances, RBI/2015–16/101, Issued on October 1, 2021, Paragraph 2, Part A.12 The World Bank, ‘Bank nonperforming loans to total gross loans (%) – United Kingdom, India’ (World Bank Open Data) <https://data.worldbank.org/indicator/FB.AST.NPER.ZS?end = 2022&locations=GB-IN&start = 2005&view=chart> accessed 09 August 2023.13 Ministry of Finance, Government of India, The Report of the Bankruptcy Law Reforms Committee Volume I: Rationale an","PeriodicalId":13511,"journal":{"name":"Indian Law Review","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2023-09-18","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"135148683","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

{"title":"When hypercriminalization falls afoul of the constitution: the need to rethink the Trafficking in Persons (Prevention, Care and Rehabilitation) Bill 2021","authors":"Prabha Kotiswaran, S. Rajam","doi":"10.1080/24730580.2023.2235937","DOIUrl":"https://doi.org/10.1080/24730580.2023.2235937","url":null,"abstract":"ABSTRACT Trafficking is a transnational legal problem that has attracted considerable attention since the adoption of the UN Convention against Transnational Organized Crime. In derogation of a robust indigenous jurisprudence on forced labour, the Indian state has, since 2000, imported the criminal law model of the Convention culminating in the Trafficking in Persons (Prevention, Care and Rehabilitation) Bill 2021. This Bill is a hypercarceral law, the relationship of which with pre-existing labour laws is unclear even as it seeks to abolish sex work. In its zeal to crack down on criminals, its provisions violate fundamental principles of criminal liability and Articles 14, 19, and 21 of the Constitution even while it casts the net of the criminal law wide, threatening to freeze sections of the economy and render the Indian worker a victim who is confined to rehabilitation homes. The article argues for a fundamental rethink of the Bill.","PeriodicalId":13511,"journal":{"name":"Indian Law Review","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2023-07-20","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"79407145","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

{"title":"The Eighteenth Amendment at trial in Pakistan’s Supreme Court","authors":"Bakhtawar Bilal Soofi","doi":"10.1080/24730580.2023.2213030","DOIUrl":"https://doi.org/10.1080/24730580.2023.2213030","url":null,"abstract":"ABSTRACT The Supreme Court of Pakistan plays an important mediatory role in managing political conflict. While there is a growing body of literature on the merits of the Eighteenth Amendment to Pakistan’s Constitution, not much has been written about how those changes have actually played out in practice before the courts. This paper tries to plug this gap by critically examining the implications of the Supreme Court’s decision in Sui Southern Gas Company Ltd v Federation of Pakistan. This paper argues that while the outcome is consistent with a general tendency of constitutional courts to centralize power, the expansive rule laid down by the Supreme Court does not square up with the spirit of the Eighteenth Amendment which was intended to resolve long-standing disputes between the centre and the provinces by conferring greater provincial autonomy.","PeriodicalId":13511,"journal":{"name":"Indian Law Review","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2023-05-15","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"76759424","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

{"title":"Making Constitutions Work Post-War","authors":"Dinesha Samararatne","doi":"10.1080/24730580.2023.2232638","DOIUrl":"https://doi.org/10.1080/24730580.2023.2232638","url":null,"abstract":"In states that are in or emerging out of conflict, what can we learn about constitutionmaking and implementation when we examine them from the status of that conflict, that is to say whether the state is post-war or post-conflict? What specific insights can we obtain when we ask this question from a South Asian perspective? This Special Issue was curated along these two main questions. The insights that emerge confirm that the prospects for constitutional reform can vary significantly depending on whether a state is in the midst of conflict or whether (for an identifiable reason) it can be designated as being post-conflict. It is possible to have an in-between stage too, a state where the “war” is concluded (at least formally) but a formal solution to the conflict has not been reached, known commonly as a post-war stage. These stages are of course not easy to identify but are indicative of distinctions that are useful to bear in mind when considering constitutional reform. In this Special Issue, five authors (including myself) reflect on these broader questions from the experiences of three South Asian jurisdictions. It has become clear that work on South Asia can benefit from intra-regional comparative work on the lesser known jurisdictions. Nepal, Myanmar, and Sri Lanka, in particular, are proximate jurisdictions that easily lend themselves to an intra-regional comparison on experiences and questions related to conflict. When I planned this project in 2019, it included Myanmar but the papers focusing mainly on Myanmar could not be finalized due to the ongoing crisis in the country. Draft papers were presented at an online workshop in 2020 on all three jurisdictions. After the Peace Agreement of 2006 and the adoption of a new constitution in 2015, Nepal is described as a post-conflict state. Even though sustained violence has ceased in Sri Lanka since 2009, a political settlement to the conflict has not yet been reached. The need for a constitutional solution to the conflict is raised from time to time. In Myanmar, reforms of the Constitution of 2008 were on the agenda over the last decade until the coup of 2021. In all three states, constitution-making and implementation have been closely linked with issues related to transitional justice, restoration of the rule of law, security sector reforms, and economic development. All three jurisdictions have had a settlement or agreement relating to the conflict. The conflicts involve ethnicity, historic injustices, religion, and gender in each of these societies. The experience of constitutionmaking and/or implementation in each of these states has been influenced and impacted by international or regional actors as well as international law. This Issue aims to add fresh voices to ongoing debates on these issues. Every effort was made, therefore, to seek submissions from authors who were from these jurisdictions and at an early stage in their career. Power-sharing is a key concern in all three jurisdict","PeriodicalId":13511,"journal":{"name":"Indian Law Review","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2023-05-04","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"72860593","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

{"title":"A mosaic of dovetailing laws: India’s communications surveillance regime","authors":"P. Arun","doi":"10.1080/24730580.2023.2193931","DOIUrl":"https://doi.org/10.1080/24730580.2023.2193931","url":null,"abstract":"ABSTRACT India’s communications surveillance regime can be aptly described as a legal mosaic with different provisions in various statutes, yet they are neatly dovetailed with each other. This Conspectus paper examines India’s communications surveillance law and analyses the characteristics of the state’s surveillance power, the nature and scope of the legal restraints and procedural safeguards afforded to prevent arbitrariness, indiscriminate use and violation of the right to communications privacy. It further identifies the key issues and major decisions of the European courts on mass surveillance in post-Puttaswamy years.","PeriodicalId":13511,"journal":{"name":"Indian Law Review","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2023-04-10","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"73875137","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

{"title":"Indian constitutionalism, the rule of law, and Parsi legal culture","authors":"M. Sharafi","doi":"10.1080/24730580.2023.2197317","DOIUrl":"https://doi.org/10.1080/24730580.2023.2197317","url":null,"abstract":"ABSTRACT Parsi legal culture produced clear benefits for Zoroastrians in the late colonial era. It also played an underacknowledged role in the constitutional life of modern India, helping nationalists pivot from extra-legal resistance to the business of running a state. Independent India could re-activate constitutionalism and the rule of law as ideals because these values were well established among nationalists, albeit in a tradition that had been relegated to the back burner in the run-up to independence. This tradition, exemplified by early Congress figures like Dadabhai Naoroji, Pherozeshah Mehta, and Dinsha Wacha, was heavily influenced by Parsi legal culture. This article also suggests that rule-of-law values were not inescapably colonial. As an ideal, the rule of law caused division within the colonial state, powered anti-colonial critique, and reinforced constitutionalism. Because the rule-of-law agenda was distinct from colonialism, there was no inherent contradiction between Parsi legal culture and the rejection of colonial rule.","PeriodicalId":13511,"journal":{"name":"Indian Law Review","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2023-04-05","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"73068513","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

{"title":"Post-war reforms in Sri Lanka: need to tie minority demands to a rule of law discourse","authors":"Isabelle Lassée","doi":"10.1080/24730580.2023.2175433","DOIUrl":"https://doi.org/10.1080/24730580.2023.2175433","url":null,"abstract":"ABSTRACT In 2015, Sri Lanka underwent a major political change, with the opening of a window of opportunity for both constitutional reform and Transitional Justice (TJ). However, TJ and constitutional reform were routinely presented in mainstream political discourses as two agendas in tension competing for political capital. Furthermore, TJ was perceived as controversial and, for this reason, was isolated conceptually and procedurally from other reform agendas. This reinforced the perception that TJ was a measure benefiting solely minority communities and imposed by foreign powers. This misperception, in turn, fuelled continued opposition to this agenda. After recalling the important links between TJ and the rule of law, I argue that a well-designed communication strategy around TJ should have harnessed the pre-2015 momentum for good governance and rule of law reforms in order to foster greater support for TJ.","PeriodicalId":13511,"journal":{"name":"Indian Law Review","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2023-02-10","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"79204105","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

{"title":"COVID-19 And Rule By Decree – A Case Study Of The NCT of Delhi","authors":"Pranav Verma","doi":"10.1080/24730580.2023.2177813","DOIUrl":"https://doi.org/10.1080/24730580.2023.2177813","url":null,"abstract":"ABSTRACT The article attempts a quantitative as well as a qualitative analysis of the National Capital Territory (“NCT”) of Delhi’s legislative productivity in the year 2020. The Legislative Assembly of Delhi produced only one piece of substantive legislation throughout the year, sitting for one of its fewest number of sessions. However, the business of the Government continued to run apace through several subordinate legislations. While most of these pertained to routine matters of day-to-day administration, two primary regulations embodied the entirety of the State’s pandemic response on the back of a colonial-era skeleton legislation. The article discusses the constitutional questions of concern raised by such promulgation of subordinate legislations, while acknowledging the backdrop of the emergency nature of the pandemic and the unique power-sharing arrangement in the Constitution of India regarding the National Capital Territory of Delhi.","PeriodicalId":13511,"journal":{"name":"Indian Law Review","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2023-01-02","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"79494407","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}