Professional Documents
Culture Documents
INTRODUCTION
1.1 Introduction
Bangladesh is a small country with a huge population. Perhaps it is the country
with largest consumer comparing its small area. Though in many sectors
Bangladesh improves but it is matter of sorrow that after 40 year of independence
consumer rights are yet been introduced in a significant manner in Bangladesh.
Though there is lot of organization working for human rights in Bangladesh but
no organization except Consumer Association of Bangladesh (CAB) working for
consumer rights. But consumer rights are integral parts of human rights. As a
student of law we know that consumer is treated as king to marketer. In developed
country we see that consumer is very much honored. The Consumer Rights
Protection Act, 2009(the Act) was passed by the Government of Bangladesh in
April 2009 to ensure consumer protection by realizing consumer’s right to quality
goods and services at fair prices. Despite the enactment, there has been little in the
way of Government action to implement and enforce the law to prevent
malpractices in the market. Aggrieved consumers are not able to seek redress
under existing circumstances due to lack of adequate institutional arrangements
for the implementation of the Act. 1 Bearing in mind both the importance of
protecting consumers, and the contribution this will make to economic and social
development, it is important that steps are taken to encourage the Government to
consider the adequacy of the present Act, make any necessary amendments About
1
Ahamuduzzaman etal, Consumer Protection Law 1986, 1st ed., (New Delli: Rita Court,
1997), pp.123-24
1
25 years ago, the UN General Assembly adopted the “Guidelines for Consumer
Protection 1985”. In 1999, the guidelines were extended to include a A.K. M.
chapter on Sustainable Consumption. This report is a comparative study of the
Bangladesh Act against those guidelines, making a number of recommendations
to greater align the Government of Bangladesh’s efforts at consumer protection
with those international standards to ensure its effectiveness, and to assign
sufficient resources and provide institutional arrangements to implement and
enforce the law.
2
Chapter 2
CONCEPT OF CONSUMER RIGHTS
2
G. Borrie and A. L. Diamond. The Consumer, Society and the Law, 2nd ed. (New
York, 1983), p.9
3
d) Who,
i) Hires or receives otherwise any service by payment or promises to pay the
price.
ii) Hires or receives otherwise any service by part payment or promises to pay
partly the price.
iii) Hires or receives otherwise any service by paying the price in an extended
term or by installments.
e) Who consumers the service received under clause (d) with the consent of
the service consumer.
Although it may be difficult for a seller to decide whether a purchaser is a
consumer or not it depends on the purchaser’s intention in buying the goods for
him. It is said that consumer protection is the achieved or intended result of
consumer policy.3
3
Ibid., p.79.
4. Ibid., p.78.
4
and those unable to take care of themselves. Consumer protection laws are a form
of government regulation which aims to protect the rights of consumers. For
example, a government may require businesses to disclose detailed information
about products particularly in areas where safety or public health is an issue, such
as food. Consumer protection is linked to the idea of “consumer rights” (that
consumers have various rights as consumers), and to the formation of consumer
organizations, which help consumers make better choices in the marketplace and
get help with consumer.
Other organizations that promote consumer protection include government
organizations and self-regulating business organizations such as consumer
protection agencies and organizations, the Federal Trade.
Commission, ombudsmen, Better Business Bureaus, etc. A consumer is
defined as someone who acquires goods or services for direct use or ownership
rather than for resale or use in production and manufacturing. Consumer interests
can also be protected by promoting competition in the markets which directly and
indirectly serve consumers, consistent with economic efficiency, but this topic is
treated in competition law.5
5
M. Humayun Kabir Chowdhury, etal, Consumer Perceived Value Formation in
Bangladesh, 3rd ed., (Dhaka: Law Book Company, 2012), Vol.1, pp.1-4.
5
businesses that sell those goods and services. Consumer protection covers a wide
range of topics, including but not necessarily limited to product liability, privacy
rights, unfair business practices, fraud, misrepresentation, and other
consumer/business interactions.
Consumer protection laws deal with a wide range of issues including credit
repair, debt repair, product safety, service and sales contracts, bill collector
regulation, pricing, utility turnoffs, consolidation, personal loans that may lead to
bankruptcy.6
6
Dr. Mizanur Rahman, Consumer Protection in Bangladesh 2nd ed., (New York: University of
Chicago Press, 1993), pp. 56-57.
7
Ibid., p.82.
6
Commissions and District Forums; Pakistan set up the Islamabad Consumer
Protection Council; Sri Lanka and Nepal set up the office of the Commissioner of
Internal Trade and the Consumer Protection Council respectively.
Third, the aspect of ‘statutory protection’, which can be guaranteed by
enacting relevant laws for protecting the rights and interests of the consumers.
Many countries of the world, including those in Asia, have already enacted
comprehensive laws in this regard. For example, the Consumer Protection
Fundamental Act 1968 in Japan, Consumer Protection Act 1979 in both Thailand
and Sri Lanka, Consumer Protection Act 1986 in India, Consumer Act of the
Philippines 1990 in the Phillippines, Islamabad Consumers Protection Act 1995 in
Pakistan, Consumer Protection Act 1998 in Nepal, The Law on Consumer
Protection 1999 in Indonesia and Consumer Protection Act 1999 in Malaysia were
enacted. However, Bangladesh is yet to enact such a comprehensive Consumers
Protection Act.
7
customers are often put into a disadvantaged and unequal
bargaining situation. Therefore, consumers need to be protected.
o Honesty should govern competitive business enterprises and the
maxim ‘buyer be aware’ should not be relied upon to reward
fraudulent and deceptive businesses.
o The concept of consumer rights cannot be separated from the
human rights perspective.
o Consumer rights are regarded as a facet of ‘social justice’.
o Ralph Nader, pioneer of the American consumer movement said,
‘consumers are the vital force of the economy’.
8
8. Right to Healthy Environment: to live and work in an environment that
does not affect consumers’ welfare and health.8
2.9 Responsibilities of the Consumer
Use the product safely, following all safety instructions and remaining
alert for future precautions.
Choose vigilantly at a fair price.
Make the effort to seek compensation for a wrong.
• Make choices that minimize the environmental impact of your purchase on
others.
• Consume in a sustainable manner, so as not to preventothers from meeting
their own needs.
8
Bangladesh research Publications Journal ISSN: 1998-2003 Volume: 1, Issue: 2, Page: 166 -
176, 20th February- August, 2018, www.bdresearchpublications.com, last visited on
December 18, 2017.
9
A. L. Borrie and Diamond. The Consumer, Society and the Law, 1st ed., (New York: 1983),
p.9
9
activists to speak to them on consumer rights and remedies available under the
law to protect them.
(b) As regards businessmen, it is expected that producers, distributors,
dealers, wholesalers as well as retailers should pay due regard to consumer rights
in their own interest. They should ensure supply of quality goods and services at
reasonable prices. To prevent unfair practices, associations of traders, chambers
of commerce and industry, and manufacturers’ associations should entertain
consumer complaints against their members and take proper action against those
guilty of malpractice.
(c) For Government, consumer protection is a responsibility to be undertaken
in the general interest of society. Enforcement of various laws and amending
existing laws to protect consumer interests are required to be taken up in the light
of viewpoints of consumer associations. Representations of consumer groups
should also be associated with the policymaking bodies set up by government at
the centre and the states. A number of measures have been taken by Government
from time to time.
10
purpose. The standards and testing institution needs to be strengthened to oversee
product quality. It is also the responsibility of the government to interact with
International Organization for Standardization (ISO), FAO and WHO for updating
food standards.10
Mandatory arbitration clauses in consumer contracts have to be incorporated
to help the consumer avoid the hassle of litigation.
The government should make and update the rules for businesses to disclose
detailed information about products-particularly in areas where safety or public
health is an issue such as food. Consumer protection is linked to the idea of
consumer rights, and to the formation of consumer organizations which help
consumers make better choices in the marketplace.
10
A.B.M. Mafizul Islam Patwary, Liberty of the People, 1st ed., (Dhaka: Institute of Human
Rights and Legal Affairs, 1987) p.29.
11
lawful profession or occupation, and to conduct any lawful trade or business.
These fundamental rights interalia are enforceable by the Supreme Court of
Bangladesh in accordance with Article 102 read with Article 44 of the
Constitution.11
The Consumer Rights Protection Act, 2009 provided both civil and criminal
remedies. A consumer is entitled to lodge complain to the Consumer Rights
Protection Department for any violation of the Act. The DC‟s of different districts
can exercise the same power as given to the department. A consumer although
barred from filing a direct complains to the police station under the Consumer
Rights Protection Act, 2009 can file a case to the Police station under other Laws.
The Bangladeshi laws provides for the establishments of different organizations
to protect the rights of the consumers including various Courts or Tribunals such
as-
(i) Consumer Rights Protection Department; (ii) National Consumer Rights
Protection Council; (iii) Special Tribunal; (iv) Mobile Court (can work/ function
under various Laws; It may be constituted by a special executive order); (v) Drug
Court; (vi) Food Special Court; (vii) Ordinary Criminal Courts; (viii) Ordinary
Civil Courts; (ix) Marine Courts; (x) BSTI; (xi) Claims Tribunal etc.12
11
S.Pirzada Sharifuddin, Fundamental Rights and Cconstitutional Remedies in Pakistan, 1st
ed., (Lahor: All Pakistan Legal Decisions, 1966) p.169.
12
Mizanur Rahman, ‘Consumer Protection in Bangladesh: Law and Practice’ (1994) 17(3)
Journal of Consumer Policy 349.
12
The Constitution of Bangladesh, under its ‘fundamental principles of state
policy’ part, recognises the rights of consumers to a limited extent. The provisions
of consumer protection can be found at Articles 15 and 18 of the Constitution.
However, these provisions are mainly focussed on the vital issues of ‘health’ and
‘food’ than on other consumer rights. Moreover, the said provisions are mentioned
under the ‘fundamental principles of state policy’ part and not under the
‘fundamental rights’ part of the Constitution. Hence, they remain mostly non-
enforceable in the courts of law.
Further, there are certain legislations, part of which has got direct bearings on
consumer protection. For example, sections 264-267, 272-276, 478-483 of the
Bangladesh Penal Code 1860, the Poison Act 1919, the Dangerous Drug Act
1930, the Trade Mark Act 1940, the Animals Slaughter (Restriction) and Meat Act
1957, the Special Powers Act 1974, the Standards of Weights and Measures
Ordinance 1982, the Bangladesh Standards and Testing Institute Ordinance 1985,
the Narcotics (Control) Act 1990, and the Safe Blood Transfusion Act 2002, etc.13
(a) The current laws are faulty and do not meet the present needs;
(b) Under the existing legal regime, the aggrieved consumers themselves cannot
go to the court to sue against the violators. It is only the designated government
officials empowered under these laws, who can initiate and sue against the
violators.
(c) The provisions of penalty or punishment under the current laws are so
negligible that nobody cares to abide by such laws; and
(d) Finally, the laws are not effectively enforced.
13
The relevant Verses Of Al Qura’n on consumer’s rights are - (83:1, 6:152, 17:35, 83:1-6,
2:172-173, 6:145, 2:168)
13
Bangladesh. Its main goal is to protect the rights and interests of consumers as
well as to educate them on about their rights and responsibilities in order to be a
wise consumer. CAB provides legal assistance and advice to consumers whose
rights have been violated. In essence, CAB is working towards ensuring
consumers and businessmen will have a safe, fair and competitive marketplace.
14
Chapter 3
OVERVIEW OF CONSUMER PROTECTION RIGHTS ACT
2009
15
person authorized by him. To make a complaint to Magistrate or to file a criminal
case requires the permission of the DG or of person authorized by him on this
behalf. The DG holds power to investigate, to search or to issue summons and
warrant. Besides this, he may also issue directives to close any shop or business
enterprise engaged in activities that violate consumer rights.14
14
Turin Afroz, “Consumer Rights Day: What do we want”, The daily Star, “Law & our
Rights”, 2nd ed., (Dhaka: Mullick Brothers, 2010), p. 258.
16
3.1.6 Mobile Court
The mobile court has jurisdiction to try offences relating to activities that violate
consumer rights. An executive Magistrate runs the mobile court. Besides, the DG
has also the same power as an Executive Magistrate to run the mobile court. He
has jurisdiction all over Bangladesh. A Magistrate may at once recognize an
offence under this Act, if committed in front of him and punish him, on the basis
of his confession, with an imprisonment for a period of maximum two years.
However, if the offence is serious in nature; he will take steps to file a criminal
case in the criminal court.15
15
Justice Latifur Rahman, The Constitution of the People’s Republic of Bangladesh, 2nd
ed., (Dhaka: Mullick Brothers, 2004), p. 123.
16
Ibid., p.124.
17
1. The buyer might be under orders to buy at the lowest price. The Caterpillar
salesperson’s task is to convince the buyer’s manager that buying on price alone
wills result inlowerlong-termpofits.
2. The buyer will retire before the company realizes that the Komatsu tractor is
more expensive to operate. The buyer will look good in the short run; he is
maximizing personal benefit. The Caterpillar salesperson’s task is to convince
other people in the customer company that Caterpillar delivers greater customer
value.17
3. The buyer enjoys a long-term friendship with te Komatsu salesperson. In this
case, caterpillars’ salesperson needs to show the buyer that the Komatsu tractor
will draw complaints from the tractor operators when they discover its high fuel
cost and need for frequent repairs.
The point of these examples is clear: Buyers operate under various constraints
and occasionally make choices that give more weight to their personal benefit than
to the company’s benefit. However, customer perceived value is a useful
framework that applies to many situations and yields rich insights. Here are its
implications:
First, the seller must assess the total customer value and total customer cost
associated with each competitor’s offer in order to know how his or her offer rates
in the buyer’s mind.18
Second, the seller who is at a customer perceived value disadvantage has two
alternatives: to increase total customer value or to decrease total customer cost.
The former calls for strengthening or augmenting the offer’s product,
services, personnel, and image benefits. The latter calls for reducing the buyer’s
product, services, personnel, and image benefits. The latter calls for reducing the
buyer’s costs by reducing the price, simplifying the ordering and delivery process,
or absorbing some buyer risk by offering a warranty.
17
A.K. M. Shamsul Huda, The Constitution of Bangladesh,1st ed., (New Delli: Rita Court,
1997), Volume-1, pp. 166 -176.
18
ibid., p. 126.
18
3.1.8 Concept of consumer rights protection Law
According to a leading European author on the subject, consumer law comprises
“the body of standards, rules and instruments representing the juridical fruit borne
by the various efforts that have been made to secure or improve the protection of
the consumer on the economic market and to promote the interests of the
consumerist” to establish a balance of power between consumers and their
economic partners or, probably more realistically, to define the means whereby
the existing imbalance can be reduced.
In a narrower sense, consumer law “focuses mainly on citizens entering
transactions to obtain products and services from commercial enterprises.
It is now accepted in Sweden and other Scandinavian countries that the “legal
consumer concept must be confined to private persons who are acquiring goods,
services or anything else of value mainly for their own use and not for resale or
use in business.
19
Trade Organizations (WTO) has a great role in regulating trade affairs
through different agreements among various nations. The United Nations (UN)
has adopted guidelines for the protection of consumer rights.
It is widely accepted by the scholars that „trade and business relates to the
socio-economic and religious conditions of a particular community. Bangladesh, a
developing country with over population, is dependant upon the foreign countries
for its essential commodities and imports huge quantities of food, cosmetic and
essential products every year especially from India, Japan, China, the USA and
the EU countries. It has very good relations with the Middle East countries and
earns huge foreign exchanges by exporting goods, medicines and apparels.
The religious prohibition on consumption of some food and food items has a
great impact over consumer rights. It is the prime responsibility of the state to
ensure all those rights to its citizens.
So, the importance of the protection of consumer rights carries a great value
towards humanity. To ensure security and safety in life, the consumer rights
protection related Laws should be effectively enforced. The number of immature
and unnatural death will be reduced if the consumer rights are duly ensured.
effective enforcement of consumer rights shall impact widely on economic
progress in national.19
19
Humayun Kabir Chowdhury, et al, Consumer Perceived Value Formation in Bangladesh: A
latent Structure Approach, ASA University Review, vol.1, Issue No.01, pp-1-4, passim;
20
Chapter 4
DIFFERENT STATUS ON CONSUMER PROTECTION IN
BANGLADESH
21
Therefore we can see that the Consumer Protection Act 2009 provides that
only competent government officers are entitled to institute a case against the
culprit for violation of such laws. A common consumer cannot initiate any legal
action against him except lodging a complaint to the department concerned. The
existing Consumer Rights Protection department is situated inside the Secretariat
that discourages people to lodge complaint because of the restriction on entrances
to the Secretariat. No court shall take cognizance if charge sheet is not submitted
within 90 days from the date of compliant. So, the Court is virtually ineffective
and the power is assumed by the department and they have a wide scope in
involving corruption. Traders know it well that the customers are not eligible to
institute a suit or take action against them except the Government officials and
they also know how to manage such officers. Due to these legal flaws consumers
are not duly protected. Therefore, these legal flaws are to be removed to allow the
consumers to institute a suit in the court of law. In case of exceptional
circumstances the Department may lodge complaint to the Special Tribunal
instead of going to the Magistrate Court (Section-75).20
20
Monjur Kader and Md. Muajjem Hussain, Criminology, 2nd ed., (Dhaka: Eastern University,
2010), p.313.
22
machineries at the district and national levels- such as Disputes Redressal Forum
and National Consumers Disputes Redressal Forum.
23
Less interest of the NGO’s in this
sector; Lack of expertise in the
BSTI;
No law to check price hike of essential commodities, if the rate/ price
is not fixed; No Law to maintain/ check halal and haram for the interest of
the consumers;
The above are the basic problems of the existing consumer Rights that should
be addressed with proper attention and due care. Even no law ensures proper legal
action against the fraudulent and unfair trade practices except the ‘Monopolies
and Restrictive trade practices (Control & Prevention) Ordinance, 1970 in a
limited scale. There should have been some directives for unlawful trade practices
like in European Countries.21
21
Badrul Haider Chowdhury, The Long Ecoes, 1st ed., (Dhaka: Naima Haider, 1990) p.26.
24
Chapter 5
LEGAL PROVISION RELATING TO CONSUMER RIGHTS
5.1 Introduction
The legal basis of consumer protection is found in part III in the constitution of
Bangladesh, which deals with fundamental principles of the state policy. Article
18 of the constitution provides that “the state shall regard the raising of the level
of nutrition and the improvement of the public health as among its primary duties,
and in particular shall adopt effective measures to prevent the consumption,
except for medical purpose or for such other purposes as may be prescribed by
law if alcoholic and other intoxication drinks and of drugs which are injurious for
health.” This article obligates upon the state to take measures for protecting
consumers from products, processes and services, which can endanger their health
and safety. Apart from the constitutional safeguard there are some specific laws
regarding consumer protection, but these laws are so outdated that little or no
protection is provided to the consumers. These laws are also inadequate,
ineffective and do not meet the present needs as most of the laws are based on
contemporary issues. An idea can be obtained about these conventional laws from
the following elaboration.
25
Moreover, using false trademark and counterfeiting trademark or property mark
are described as punishable offences.22
22
Ibid., p.170.
26
5.6 The drug (control) ordinance 1982
It was promulgated with a view to controlling manufacture, import and
distribution of 1707 medicines were prohibited and registration or license with
regard to them stood cancelled. It made provisions for punishment for drugs, for
sale of medicine or import or sale of pharmaceutical material at a higher price for
illegal advertisement and claims.
The Breast-Milk Substitute (Regulation of Marketing) ordinance 1984: It was
enacted with a view to promoting breast Legal Provisions for Protection of
Consumers’ Rights and Control of Deception in Bangladesh- Reasons for Concern
feeding by regulating the marketing of breast-milk substitute through following
the general principles of the international code of marketing 1981.
23
Ibid., p.171.
27
5.11 The Special Power Act, 1974 (Act No XIV of 1974-as modified up to the
31st July, 1978)
An Act to provide special measures for the prevention of certain prejudicial
activities, for more speedy trial and effective punishment of certain grave
offences.
24
Adilur Rahman Khan, ‘Court Division in a recent judgment ordered all the medical service
providers to pay the VAT by themselves not to charge the consumers, The Daily Star, (30
January 2000.)
28
The Government has enacted “The Iodine Deficiency Disorders Prevention
Act, 1989 for universal salt iodization & banned non-iodized salt from market,
aimed at virtual elimination of IDD from the country.
5.17 Fish and Fish product (Inspection and Quality Control) Rules, 1997
This section of the Fish and Fish products (Inspection and Control) Ordinance
1983 (Ord. xx of 1983) and in conjunction with fish and fish products Inspection
and Quality Rules 1989, and other related provisions made there under, the
Government has made the Rules: Fish and Fish product (Inspection and Quality
Control) Rules, 1997. These Rules are basically meant to develop quality
improvement to promote export of trade. The quality control of fish and fish
products in the country has earned good reputation of the importing countries.25
25
Fish and Fish Product Rules , 1997
29
Bangladesh Food and Nutrition Policy, 1997 and National Plan of Action on
Nutrition, National Agricultural Policy, 1999; Integrated Pest Management Policy,
2002 etc are linked with the country's food safety and quality control.
The most interesting features of these laws are that aggrieved consumers
cannot sue the violators themselves. It is only the designated government officials
empowered under these laws, who can initiate and sue the violators. Besides,
provision of penalty or punishment is so negligible that nobody cares to abide by
the rules under these laws and as such there is no effective implementation of the
laws. As a result the consumers in Bangladesh are completely dependent upon the
mercy of the business houses, the professionals and the vested interest group.26
Considering these issues a research gap has been observed by the researchers
regarding consumer deception and consumer protection laws in our country,
which has driven the researcher’s motive to conduct a study on the subjected field.
26
Lord Templeman Michael T Molan, Constitutional Law the Machinery of Government, 2nd
ed., (New York :Old Bailey Press, 1997), pp. 212.
30
Chapter 6
CONCLUSION
6.1 Recommendation
The suggestion of my legal research is how to increase the consumer’s rights and
how to protect the consumer’s rights in Bangladesh. That’s discussed in the
research now here stated the key point there as follows. This enumeration of the
types of action needed to promote consumers interests provides an accurate
indication of the fields in which consumer law should come to play, foremost
among which are:
31
adopted the basic guidelines for consumer rights protection. The guidelines
stipulate that ‘all citizens, regardless of their incomes or social standing, have
basic rights as consumers.
6.2 Concluding
In conclusion, the naive consumers of Bangladesh are in critical need of having the
fortification of broad consumer protection legislation. So, the government of Bangladesh
is required to enact a widespread Consumer Protection Act as quickly as possible and
advance strictly ensures the efficient execution of such legislation. We should always
remember that an efficient consumer protection legislation of a inhabitants not only
protects and promotes the privileges and happiness of its consumers, but it also enhance
definite socio-economic targets of its macro economy, such as scarcity alleviation,
competent, fair and translucent market method, good governance and beyond all, socio-
economic impartiality for its citizens. Many declare as, our current law is old-fashioned,
not capable to look after the consumers, defective and doesn’t meet the current
necessities. Therefore, endorsement of new law is a must. Yet, one may query, how far
the endorsement of new law will in some real sense explain the current consumer hitch? If
the already obtainable law is not completely imposed then how come we can look
forward that the new law will protect our customers and their privileges properly
improved than today.27
27
M. Faiz Uddin and M.A. Hannan, ‘Protection of Human Rights in Criminal Justice
Bangladesh Perspective’, Research Project 1998), Rajshahi Universit; p.418.
32
REFERENCES
Books
1. Ahamuduzzaman et al, Consumer Protection Law, 1st ed, (New Delli:
Rita Court, 1997).
2. G. Borrie and A. L. Diamond. The Consumer, Society and the Law 2nd ed.,
(New York, 1983).
4. Turin Afroz, “Consumer Rights Day: What do we want”, “Law & our
Rights”, 2nd ed, (Dhaka: Mullick Brothers, 2010).
7. Monjur Kader and Md. Muajjem Hussain, Criminology, 2nd ed. (Dhaka:
Eastern University, 2010), p.313.
8. Badrul Haider Chowdhury, The Long Ecoes 1st ed., (Dhaka: Naima Haider,
1990).
9. A. L. Borrie and Diamond. The Consumer, Society and the Law, 1st ed,
(New York, 1983).
33
Website :
Bangladesh research Publications Journal ISSN: 1998-2003 Volume: 1, Issue: 2, Page:
166 -176, 20th February- August, 2018, www.bdresearchpublications.com, last visited on
December 18, 2017.
Bangladesh research Publications Journal ISSN: 1998-2003 Volume: 1, Issue: 2,
Page: 166 - 176, July - August, 2008,
Mizanur Rahman, ‘Consumer Protection in Bangladesh: Law and Practice’ (1994)
17(3) Journal of Consumer Policy 349.
The relevant Verses Of Al Qura’n on consumer’s rights are - (83:1, 6:152, 17:35,
83:1-6, 2:172-173, 6:145, 2:168)
www.bdresearchpublications.com.
www.bdresearchpublications.com
34