Plagiarists are contraceptives (How a Senator arguing against contraceptives becomes one)

By Siesta-friendly

Okay, so far we’ve had 3 notorious incidents of plagiarism (the previous two we’ve  tackled in 2 posts: EATING YOUR OWN WORDS (Plagiarism) and By Your Own Hand or Not, who cares? (When Plagiarism isn’t Plagiarism according to the Supreme Court). These acts of plagiarism were attributed (pun intended) to society’s leaders no less: business leader and then Chairman of the Ateneo University Board of Trustees Manuel Pangilinan, Supreme Court Justice Mariano Del Castillo (also an Ateneo graduate), and now Senator Vicente “Tito” Sotto III (we have yet to find out who among his staff is from Ateneo from where his speech writer/s graduated).  

It doesn’t help anti-plagiarists (which we should all be) that the Supreme Court, in In The Matter Of The Charges Of Plagiarism, Etc., Against Associate Justice Mariano C. Del Castillo, cleared Justice Del Castillo of plagiarism.  The SC compounds the problem by including intent (not universally required but often used as a defense) as an element of plagiarism when it stated that “plagiarism is essentially a form of fraud where intent to deceive is inherent”[1] Neither is Congress helping by failing to as yet impeach Justice Del Castillo for plagiarism. It is not far-fetched to assume that these actions (or non-actions) have further left the impression on the public – used to buying pirated dvds - that it’s really not that big a deal to take from other people’s works without giving due credit.

Perhaps this is why we now have the 3^rd infamous case of plagiarism.

The Law on Copyright

The most recent allegations of plagiarism involve Sen. Tito Sotto, and to date, 5 blogs and 1 briefing paper. Details of the alleged liftings can be found in Raissa Robles’ blog posts “Did Sen. Sotto copy from 5 bloggers?”[2]  and “UPDATE: Senator Sotto lifted from 5 bloggers and 1 briefing paper[3]

Not only were the lines taken without due credit, but the office of Sen. Sotto, through his Chief of Staff, Atty. Hector A. Villacorta, defends their acts as follows:

“Blog site is public domain, you should be open to be quoted from all over the world. What law did we violate only her sensitivity was.  Because there is no crime, we used information from public domain they're making issue of the way it was quoted."

"The rule of copyright gives government a chance to use some of materials. There's principle in law if there's a crime there should be a law punishing it. Was she commercially injured? Wala naman eh. No crime, no law violated."

xxx

"Blogs are public domain. Anybody can use it [sic]. Government is exempted from the copyright rule. As a general principle, you cannot withhold information from government,"

xxx

"Bloggers, beware what you put out on the web. You should not cry if used by the web,".[4]

These are reckless statements. We daresay that the office of the Senator and his lawyer-Chief of Staff will fail the challenge of finding legal bases to back their claims that 1) "Blogs are public domain”, 2) “Government is exempted from the copyright rule”, 3) that they did not violate any law, 4) that only the author’s sensitivity was violated, and 5) that plagiarism requires commercial injury to the author.   

Surrounded by laws and law-making being part of their daily functions, one would think they would be the first to know what’s legal or not.  How can a legislator and his staff - of all people - forget that the Philippines is signatory to different international conventions on intellectual property including: the Berne Convention for the Protection of Literary and Artistic Works, (September 9, 1886), and the WIPO Copyright Treaty, (December 20, 1996)?

Blogs are protected by copyright laws

Even a high school student would know that blog articles are copyrighted work and should be duly credited when copied. Section 172.1, Chapter II (Copyright Original Works), Part IV (The Law on Copyright), of the Intellectual Property Code[5] states:

172.1.    Literary and artistic works, hereinafter referred to as "works", are original intellectual creations in the literary and artistic domain protected from the moment of their creation and shall include in particular

(a)    Books, pamphlets, articles and other writings;

xxx

(o)    Other literary, scholarly, scientific and artistic works. 

while Chapter III (Derivative Works)  Section 173.1 states that the following are protected by copyright: 

(a)                Dramatizations, translations, adaptations, abridgments, arrangements, and other alterations of literary or artistic works; and 

(b)               Collections of literary, scholarly or artistic works, and compilations of data and other materials which are original by reason of the selection or coordination or arrangement of their contents. (Sec. 2, [P] and [Q], P.D. No. 49) 

Thus, a blog is a literary work clearly covered by copyright.  The law makes no description where the writings/works are made – be they on tissue paper or stone or web log. 

Atty. Villacorta finally admits laziness in explaining why they chose to copy a blog post which quoted a book instead of reading the book itself and citing it -

“… Researchers tried clicking the book but ayaw mag download. Kaya ang pinakamaganda, refer to blog dahil baka accurate naman,” Villacorta said.”[6]

Public Domain has specific meaning when it comes to copyright

It seems that the Senator’s lawyer-Chief of Staff mistakes public domain with out-in-public.  Works in the public domain do not have private ownership while works out-in-public are not necessarily without private ownership.  For one to declare that a work is in public domain, one must have already researched that the work no longer has private ownership, like a work whose copyright has lapsed (like Shakespeare’s works).  For one to declare outright that just because an author’s work is contained in a blog it has become part of the public domain, is ignorance - excusable coming from a pre-schooler, but from a Senator and his lawyer-Chief of Staff?

Of course, Atty. Villacorta’s excuses still don’t explain the un-credited lifting from a briefing paper. Perhaps he has already decided that a briefing paper - because it can also be found on the internet like a blog - is also in the public domain?  

No copyright in any government work

Atty Villacorta shows his lack of knowledge of copyright law when he justifies their acts of appropriating other people’s works because he claims it is common practice in Congress to copy bills -

"Kopyahan po to talaga, eh.  Pag natapos ang isang Congress, lahat ng bill na hindi naipasa, kopyahan. Bakit mo iisipin ulit eh nandyan na? A bill not acted upon dies with a Congress. The new Congress senators will find out what can still be revived. Kopyahan po, pero hindi masamang kopyahan,” he said.”[7]

Works of the government are specifically listed as one of the Works Not Protected under  Chapter IV. Works Not Protected, Part IV of of the IP Code) -

CHAPTER IV

WORKS NOT PROTECTED

SEC. 175. Unprotected Subject Matter

       Notwithstanding the provisions of Section 172 and 173, no protection shall extend, under this law, to any idea, procedure, system method or operation, concept, principle, discovery or mere data as such, even if they are expressed, explained, illustrated or embodied in a work; news of the day and other miscellaneous facts having the character of mere items of press information; or any official text of a legislative, administrative or legal nature, as well as any official translation thereof. (n) 

Sec. 176. Works of the Government. –

176.1. No copyright shall subsist in any work of the Government of the Philippines.  However, prior approval of the government agency or office wherein the work is created shall be necessary for exploitation of such work for profit.  Such agency or office may, among other things, impose as a condition the payment of royalties. No prior approval or conditions shall be required for the use of any purpose of statutes, rules and regulations, and speeches, lectures, sermons, addresses, and dissertations, pronounced, read or rendered in courts of justice, before administrative agencies, in deliberative assemblies and in meetings of public character. (Sec. 9, First Par., P. D. No. 49)  [emphases supplied]

In any case, it is not convincing for the plagiarist to say that he acted in good faith in lifting a portion from someone else’s work because the plagiarist also makes it appear that the lifted portion is his creation (since he failed to give due credit).  In the cases of Justice Del Castillo and Senator Sotto - the 1^st case involving Manny Pangilinan was satisfactorily ended with his admission, apology and resignation as university board of trustee chairman - it’s very difficult to swallow each good faith excuse for each of the several portions they lifted from several sources. One stolen line may be excusable - although the academic and journalism worlds might find that already one too many - but lifting several lines from several sources and failing to give credit to any one? 

Atty. Villacorta’s excuses imply that their acts of plagiarism only affected the blog writer.  That is incorrect. In plagiarism, theft may have been committed against the author, but fraud is committed on the plagiarist’s reader/listener/viewer because the plagiarist misrepresents to his reader/listener/viewer that the work is his.

The Senator and his lawyer–Chief of Staff make light of their actions.  These actions constitute theft and fraud that’s why there are international conventions and local laws prohibiting and punishing intellectual property violations.

Since conception can also be defined as an idea or the act of forming an idea, Senator Sotto is not helping his cause against contraceptives (“contra conception”) by being a contraceptive or contra conception himself.      

---

[1]   A.M. No. 10-7-17-SC, October 12, 2010.

[2]  Robles , R. (2012, August 16). Did sen. sotto copy from 5 bloggers?. Retrieved from http://raissarobles.com/2012/08/16/did-sen-sotto-copy-from-4-bloggers/

[3]   Robles, R. (2012, August 17). Update: Senator sotto lifted from 5 bloggers and 1 briefing paper . Retrieved from http://raissarobles.com/2012/08/17/update-senator-sotto-lifted-from-5-bloggers-and-1-briefing-paper/

[4]  Cruz, R. (2012, August 17). Sotto immune from plagiarism raps, top aide says. Retrieved from http://www.abs-cbnnews.com/-depth/08/17/12/sotto-immune-plagiarism-raps-top-aide-says

[5]  Republic Act No. 8293, An Act Prescribing The Intellectual Property Code And Establishing The Intellectual Property Office, Providing For Its Powers And Functions, And For Other Purposes, June 6, 1997.

[6]   Castaneda, J. (2012, August 22). Sotto, staff didn't read mcbride book. Retrieved from http://www.abs-cbnnews.com/-depth/08/22/12/sotto-staff-didnt-read-mcbride-book

[7]  Ibid.

NEWER POST       |       PREVIOUS POST

By Your Own Hand or Not, who cares? (When Plagiarism isn’t Plagiarism according to the Supreme Court)

The Supreme Court recently held in In The Matter Of The Charges Of Plagiarism, Etc., Against Associate Justice Mariano C. Del Castillo (A.M. No. 10-7-17-SC, October 15, 2010), how certain acts of lifting direct quotes without making proper attributions in Justice De Castillo’s penned decision in Vinuya, et al. vs The Executive Secretary, et al. (G.R. No. 162230, April 28, 2010) do not constitute plagiarism.

Let’s see for ourselves, shall we?

Lifted lines from the introductory chapter of Enforcing Obligations Erga Omnes in International Law by Christian J. Tam, (Cambridge University Press 2005) as enumerated in the annex of Mr. Tams’ letter to the Supreme Court

The following are the lifted lines comprising 3 lines forming 1 paragraph of page 30 of the main text plus its relevant footnote.  None of the 3 lines are enclosed in quotation nor indented to indicate they were lifted from another’s work.  None of the lines are attributed.While the 3^rd line has a footnote, the footnote begins with another line taken from the same unattributed source.

The Latin phrase ‘erga omnes’ thus has become one of the rallying cries of those sharing a belief in the emergence of a value-based international public order based on law. [However, as is so] often [the case], the reality is neither so clear nor so bright.  [W]hatever the relevance of obligations erga omnes as a legal concept, its full potential remains to be realized in practice. ^[69] [the changes made in the Vinuya decision are enclosed in parenthesis.]

_______

“^[69] Bruno Simma’s much-quoted observation encapsulates this feeling of disappointment:‘Viewed realistically, the world of obligations erga omnes is still the world of the “ought” rather than of the “is” ’The Charter of the United Nations: A commentary 125 (Simma, ed. 1995). See Tams, Enforcing Obligations Erga omnes in International Law (2005) ... ”

As written, the footnote seems to merely state the writer’s comments to his main text paragraph.  It does not look like Bruno Simma is cited as the source of the 3^rd line - much less the entire paragraph - especially in the absence of quotations or indentation.

The only reference to Tams (“See Tams, Enforcing Obligations Erga omnes in International Law (2005). …”) gives the impression that Tams’ work might be read to gain more information on the matter. It does not make it appear that the entire paragraph on the main text or the introductory line of the footnote is taken from Tams’ book. 

       

Without indicating in any way that the above 4 lines were lifted word for word from another source, the writer makes it appear all the words and ideas are his.

The Supreme Court, however, explains the lack of plagiarism in all these instances as follows –

“…The Justice primarily attributed the ideas embodied in the passages to Bruno Simma, whom Tams himself credited for them.  Still, Footnote 69 mentioned, apart from Simma, Tams’ article as another source of those ideas. 

The Court believes that whether or not the footnote is sufficiently detailed, so as to satisfy the footnoting standards of counsel for petitioners is not an ethical matter but one concerning clarity of writing.  The statement “See Tams, Enforcing Obligations Erga Omnes in International Law (2005)” in the Vinuya decision is an attribution no matter if Tams thought that it gave him somewhat less credit than he deserved.  Such attribution altogether negates the idea that Justice Del Castillo passed off the challenged passages as his own.   

That it would have been better had Justice Del Castillo used the introductory phrase “cited in” rather than the phrase “See” would make a case of mere inadvertent slip in attribution rather than a case of “manifest intellectual theft and outright plagiarism.” If the Justice’s citations were imprecise, it would just be a case of bad footnoting rather than one of theft or deceit.  If it were otherwise, many would be target of abuse for every editorial error, for every mistake in citing pagination, and for every technical detail of form.”

Not an ethical matter but one concerning clarity of writing?  Mere inadvertent slip in attribution?  Bad footnoting?

Hmmm.  Sure.

Lifted lines from the article Breaking The Silence: Rape As An International Crime by Mark Ellis, (Case Western Review Journal of International Law, 2007)

The lines are too many to list but they comprise almost all 6 paragraphs of footnote 65 of the Vinuya decision.  The lines were taken from parts III-VI, pages 3-12 of Ellis’ article.  Nowhere in the entire Vinuya decision is Mark Ellis or his article cited.  Nowhere is there any indication that substantially all 6 paragraphs were not Justice Del Castillo’s words or ideas.

Lifted lines from the article A Fiduciary Theory of Jus Cogens by Evan J. Criddle & Evan Fox-Decent (Yale Journal of International law, 2009)

8 sentences, 8 footnotes (footnotes 70 - 78) in 3 paragraphs (the 2^nd, 3^rd and 4^th to the last paragraphs) of the Vinuya decision were taken from different parts of the more than 50 pages of the Criddle & Fox-Decent article.  As with Mark Ellis, neither Criddle, Fox-Decent nor their article are cited in the entire Vinuya decision.  Unlike the lifted Ellis lines (which are found in a footnote), the Criddle & Fox-Decent lines form part of the main text, yet, no lines were with quotation nor were they indented to indicate they were sourced elsewhere. 

The Supreme Court explains the Ellis and Criddle & Fox-Decent citation snubs thus –

“… [Justice Del Castillo’s researcher] electronically “cut” relevant materials from books and journals in the Westlaw website and “pasted” these to a “main manuscript” in her computer that contained the issues for discussion in her proposed report to the Justice.  She used the Microsoft Word program.  Later, after she decided on the general shape that her report would take, she began pruning from that manuscript those materials that did not fit, changing the positions in the general scheme of those that remained, and adding and deleting paragraphs, sentences, and words as her continuing discussions with Justice Del Castillo, her chief editor, demanded.  Parenthetically, this is the standard scheme that computer-literate court researchers use everyday in their work.

Justice Del Castillo’s researcher showed the Committee the early drafts of her report in the Vinuya case and these included the passages lifted from the separate articles of Criddle-Descent and of Ellis with proper attributions to these authors.  But, as it happened, in the course of editing and cleaning up her draft, the researcher accidentally deleted the attributions.”  

It is one thing to accidentally delete attributions, but you have to use several strokes to “accidentally” delete quotation marks at the beginning and end of, and to delete the indentation encompassing, the lifted work. Unless, of course, they weren’t there in the first place. 

In ending, the Supreme Court noted that –

“What is important is that, in this case, Justice Del Castillo retained control over the writing of the decision in the Vinuya case ...  The Justice’s researcher was after all competent in the field of assignment given her.  She finished law from a leading law school, graduated third in her class, served as Editor-in Chief of her school’s Law Journal, and placed fourth in the bar examinations when she took it.  She earned a master’s degree in International Law and Human Rights from a prestigious university in the United States under the Global-Hauser program, which counsel for petitioners concedes to be one of the top post graduate programs on International Law in the world ...”

Justice Del Castillo is a former MTC judge, RTC judge and Associate Justice of the Court of Appeals.  He’s used to writing intellectual works.  Based on her credentials, so is his researcher.  How then, with all their writing experience put together, could numerous accidental deletions referencing 3 different sources and inappropriate referencing have occurred in one single work?

Intent now an element of plagiarism

Apart from excusing plagiarism, the Supreme Court has now also added an element to plagiarism.

In finding that the claim of “accidental removal of proper attributions to the three authors is credible,” the Supreme Court also pronounced that:

“ … plagiarism is essentially a form of fraud where intent to deceive is inherent.  [The petitioners’ theory that intent is not material in plagiarism] provides no room for errors in research, an unrealistic position considering that there is hardly any substantial written work in any field of discipline that is free of any mistake.  The theory places an automatic universal curse even on errors that, as in this case, have reasonable and logical explanations.”

             

Now, all plagiarists can claim lack of intent as an excuse for dishonesty.  Elsewhere, lazy, dishonest writers are celebrating …

In recent memory, we’ve already had a captain of industry and a Supreme Court justice both caught very publicly “unintentionally” copying another’s work.  It’s even more alarming when the university and the court concerned did not acknowledge the actions for what they really were: acts of plagiarism.  Giving credit where it is due is a deliberate act and its absence through accident or mere lack of intent is simply inexcusable.

NEWER POST       |       PREVIOUS POST

EATING YOUR OWN WORDS (Plagiarism)

By Obiter 07

Nothing could be more embarrassing, to be a titan of industry as well university board member and use the words of another without attribution and worse, to be found out.  Worst of all, to commit the plagiarism in a commencement speech at a university.  Legally speaking (as contrasted to a less than legal speech in this case), what law if, any, is possibly violated by plagiarism?

Protected Literary and Artistic Works

Under the Intellectual Property Code (Republic Act No. 8293), even lectures and speeches are protected from the moment of their creation.  Needless to say, only original speeches are protected by the law. 

Literary and artistic works are original intellectual creations in the literary and artistic domain protected from the moment of their creation and shall include in particular:

a)      Books, pamphlets, articles and other writings;

b)      Periodicals and newspapers;

c)      Lectures, sermons, addresses, dissertations prepared for oral delivery, whether or not reduced in writing or other material form;

d)     Letters; xxx

e)      Other literary, scholarly, scientific and artistic works.

Works are protected by the sole fact of their creation, irrespective of their mode or form of expression, as well as of their content, quality and purpose. [1]

Economic Rights

An author enjoys certain economic rights over his creation as follows:

Subject to the provisions of Chapter VIII of the Code, copyright or economic rights consist of the exclusive right to carry out, authorize or prevent the following acts:

1)      Reproduction of the work or substantial portion of the work;

2)      Dramatization, translation, adaptation, abridgment, arrangement or other transformation of the work;

3)      The first public distribution of the original and each copy of the work by sale or other forms of transfer of ownership;

4)      Rental of the original or a copy of an audiovisual or cinematographic work, a work embodied in a sound recording, a computer program, a compilation of data and other materials or a musical work in graphic form, irrespective of the ownership of the original or the copy which is the subject of the rental; (n)

5)      Public display of the original or a copy of the work;

6)      Public performance of the work; and

7)      Other communication to the public of the work. [2]

Moral Rights

Apart from economic rights, an author has certain moral rights as well. The author of a work shall, independently of the economic rights in Section 177 (mentioned above) or the grant of an assignment or license with respect to such right, have the right:

1)      To require that the authorship of the works be attributed to him, in particular, the right that his name, as far as practicable, be indicated in a prominent way on the copies, and in connection with the public use of his work;

2)      To make any alterations of his work prior to, or to withhold it from publication;

3)      To object to any distortion, mutilation or other modification of, or other derogatory action in relation to, his work which would be prejudicial to his honor or reputation; and

4)      To restrain the use of his name with respect to any work not of his own creation or in a distorted version of his work. [3]

Fair Use

The defense of fair use may be available but only if there is at least attribution to the original author. If using another’s words, the least one can do is to acknowledge it. There is no infringement of copyright in the making of quotations from a published work if they are compatible with fair use and only to the extent justified for the purpose, including quotations from newspaper articles and periodicals in the form of press summaries: Provided, That the source and the name of the author, if appearing on the work, are mentioned.[4]

Enforcement

If a copyright holder’s economic or moral rights have been violated as action for injunction to restrain the same, and for damages, among other forms of relief, are available.

Any person infringing a right protected under this law shall be liable:

a)      To an injunction restraining such infringement. The court may also order the defendant to desist from an infringement, among others, to prevent the entry into the channels of commerce of imported goods that involve an infringement, immediately after customs clearance of such goods.

b)      Pay to the copyright proprietor or his assigns or heirs such actual damages, including legal costs and other expenses, as he may have incurred due to the infringement as well as the profits the infringer may have made due to such infringement, and in proving profits the plaintiff shall be required to prove sales only and the defendant shall be required to prove every element of cost which he claims, or, in lieu of actual damages and profits, such damages which to the court shall appear to be just and shall not be regarded as penalty.

c)      Deliver under oath, for impounding during the pendency of the action, upon such terms and conditions as the court may prescribe, sales invoices and other documents evidencing sales, all articles and their packaging alleged to infringe a copyright and implements for making them.

d)     Deliver under oath for destruction without any compensation all infringing copies or devices, as well as all plates, molds, or other means for making such infringing copies as the court may order.

e)      Such other terms and conditions, including the payment of moral and exemplary damages, which the court may deem proper, wise and equitable and the destruction of infringing copies of the work even in the event of acquittal in a criminal case.

In an infringement action, the court shall also have the power to order the seizure and impounding of any article which may serve as evidence in the court proceedings.[5]

Criminal Liability

Criminal liability might likewise attach and be imposed on the infringer.  Any person infringing or aiding or abetting such infringement shall be guilty of a crime punishable by:

a)      Imprisonment of 1 year to 3 years plus a fine ranging from P50,000- P150,000 for the first offense.

b)      Imprisonment of 3 years and 1 day to 6 years plus a fine ranging from P150,000 - P500,000 for the second offense.

c)      Imprisonment of 6 years and 1 day to 9 years plus a fine ranging from P500,000) to P1,500,000 for the third and subsequent offenses.

d)     In all cases, subsidiary imprisonment in cases of insolvency.[6]

Civil Liability

The author or his heirs may be be entitled to damages.  Violation of any of the rights conferred under the Code entitle those charged with their enforcement to the same rights and remedies available to a copyright owner.  In addition, damages which may be availed of under the Civil Code may also be recovered. Any damage recovered after the creator's death shall be held in trust for and remitted to his heirs, and in default of the heirs, shall belong to the government.[7]

Decided Case

In UNIVERSITY OF THE PHILIPPINES BOARD OF REGENTS, et al. vs. COURT OF APPEALS, et al. [G.R. No. 134625.  August 31, 1999], the Supreme Court upheld a university’s power to withdraw a doctorate agree it had awarded based on a finding of plagiarism.   

With respect to the injury that a copyright owner must suffer in order for an infringement action to prosper, the Supreme Court ruled that it “does not necessarily require that the entire copyrighted work, or even a large portion of it, be copied. If so much is taken that the value of the original work is substantially diminished, there is an infringement of copyright and to an injurious extent, the work is appropriated. In determining the question of infringement, the amount of matter copied from the copyrighted work is an important consideration. To constitute infringement, it is not necessary that the whole or even a large portion of the work shall have been copied. If so much is taken that the value of the original is sensibly diminished, or the labors of the original author are substantially and to an injurious extent appropriated by another, that is sufficient in point of law to constitute piracy. The essence of intellectual piracy should be essayed in conceptual terms in order to underscore its gravity by an appropriate understanding thereof. Infringement of a copyright is a trespass on a private domain owned and occupied by the owner of the copyright, and, therefore, protected by law, and infringement of copyright, or piracy, which is a synonymous term in this connection, consists in the doing by any person, without the consent of the owner of the copyright, of anything the sole right to do which is conferred by statute on the owner of the copyright.” [HABANA, et al.vs. ROBLES, et al. [G.R. No. 131522.  July 19, 1999.]

Apart from the legal issues, what may matter more is how we respond to such cases of intellectual dishonesty, whether inadvertent or premeditated.  There are reports that students of the same university where the plagiarizing speaker made his commencement speech have been prevented from graduating.  Fair enough.  But the speaker/titan/board member’s tender of resignation from the university board has not yet been accepted.  Why the delay?  If any of the plagiarizing students, say, donated a building to the university would he/she be allowed to graduate then?  Shouldn’t there be the same standards for students as well as alumni, no matter how well-placed or successful? 

For those who were about to graduate and to whom the speeches were delivered, they certainly deserved more than what they heard.  In the end, the lesson for them may be that values can never be transactional, that they are constant and upheld in every instance, or should be, even when no one is looking.

---

[1]  Section 172.1

[2]   Section 177

[3]  Section 193

[4]  Section 184.1, as amended by

[5]  Section 216.

[6]  Section 217

[7]  Section 199

NEWER POST       |       PREVIOUS POST