Ketan Swaraj Nair & Inian R.


A) Origin and Spread

Humankind has been a witness to the outbreak of several diseases. The Black Death, SARS (Severe Acute Respiratory Syndrome), MERS (Middle East Respiratory Syndrome), Cholera, Ebola are some of the deadliest diseases which have caused millions of deaths. Although, none of them quite resemble the vastness and spread such that of as COVID-19. Among the seven types of coronaviruses, SARS-CoV-2 (COVID-19) has engraved its devastating impact on all human life and its activities[1]. The zoonotic disease[2] has engulfed the entire world and has caused severe disruptions to the modern economy and life. A zoonotic disease is transmitted from the germs existing in an animal to a human. Similar to the HIV and Ebola[3] viruses, the feature of being a zoonotic disease is shared by the coronavirus.

Identified through the outbreak in December 2019, finding its epicentre in China, the virus was officially termed by the World Health Organization (WHO) as the SARS-CoV-2. The disease is virally transmitted and causes a respiratory tract infection which in severe instances endangers the respiratory system leading to death. The origin and the liability attached with the spread of the disease remains the subject of debate and has even transfigured itself in an international security issue which has hindered relations among several nations. The consensus on the distinct origin of the virus remains a subject of controversy, however, scientific and ecologic data indicate to infection from bats and pangolins in Asia and Southeast Asia.

With official claims of the origin of the disease dating back to December 2019, initially an epidemic, which could have been contained, but due to negligence and non-disclosure grew itself into a pandemic. A pandemic is an epidemic which is spread over multiple countries and continents.

B) Impact

In the words of Aristotle ‘man is by nature a social animal’. The virus challenged this tenet and imposed a halt on it in an unprecedented manner. Fuelled by globalization and modern travel, the virus had an exponential growth.

India reported its first case on January 30, 2020 from Kerala in a student who returned from Wuhan, China[4]. With India’s densely populated cities the virus was quickly transmitted and despite the prescribed guidelines of social distancing and the orders for lockdown, the number of cases in India has passed the 3 million mark in August, 2020 with reported deaths relating to the virus has crossed a total number of 60,000. India now has the 2nd highest number of cases in the world surpassed only by United States of America.

These numbers and statistics give us a prima facie information about the impact or spread of the disease, but they do not adequately represent the impact exact impact of the disease. To illustrate the problem, USA has less than 1/4th of the population of India and has conducted more tests than several nations combined but has less than double the number of cases than India. The US President has been quick and repetitive to boast these facts ignoring the deaths caused by the disease.

The modern economy operates within the proximity of people. The only perceivable safeguard against the disease which could have been undertaken was to socially distance oneself[5]. Social distancing or physical distancing is the measure of distancing oneself from other possible carriers to avoid the spread of disease. It is one of the measures against coronavirus along with regular sanitation. As there is no vaccine available against the virus, the non-pharmaceutical measures of intervention of contagious diseases such as social distancing and sanitization are the only reliable methods to counter the spread of COVID-19.


Judicial workspace in a jurisdiction depends on a State’s own laws, articles, acts, provisions and interpretations. Its main and ultimate aim is to resolve the dispute and maintain peace, order and good governance with a robust ecosystem in place.

According to the May 2016 statistics, India has only 60,000 judges for the Indian population of 1.2 billion, which is very much remote for the large number of population. Adding to this there are 32 million cases are pending in the country till May 2016, which may increase in the following years.[6] As per the quote “Delay in Justice is Also Injustice” it is to be understood that the judicial system in India is acting leisurely and interminable. Extending on adding extra pressure to the judicial system, this pandemic and lockdown enhances the burden on the judiciary. To resolve the modern temporary and urgent problem the judicial practice in India is digitalized by stating the pandemic and lockdown as the reason. Which is one of the cheap and efficient solution to the underlying struggle.

A) Legal profession and the headway to the change:

The traditional legal practice in India follows the manual process of judiciary for years and years. This exciting system has some lacunae and it is very stringent process and it is slow as compared to the population of India. To make it align and straight there were many more suggestions kept in front, and among those the very time efficient and easy one is the digitalization of the judicial system. It improves the process and quality of efficiency with the prior security process it integrates a conventional digitized records system.

As this situation is adventitious and unexpected there has been the concern of the lockdown, there is a countrywide lockdown and the need for the justice in the state, the long suggested digitalization of court has been enforced in the judicial system. This digitalization is a far reaching suggestion in India, where the initial process of digitalization was already started in 2007 through the first phase of implementation started from 2010-2015, and the E-courts Mission Mode Project was launched, as part of the National e-Governance Plan (NeGP).[7] The eCourts Mission Mode Project is a Pan-India Project, monitored and funded by Department of Justice, Ministry of Law and Justice, Government of India for the District Courts across the country as per the rules and regulations.

B) Transforming the courts during pandemic:

The novel Corona virus has an imperial effect on the world and shook the mass by suffering and death, so to prevent this social distancing is being followed in the entire world, so the normal court practice is unimaginable in the hazardous situation. Parallel to this the judiciary should be made affordable, easily accessible and transparent, these aim leads the idea of the digitalization. It can be accessible from any part of the world and it is easy for the NJDG system to maintain the data of the pending case, disposed cases. It is very useful to done with the efficient working system.[8]Already by 2015 14,249 courts were digitalized and case information software has been developed and maintained in the judiciary separately.[9] Although the measures are been taken to maintain the status-quo of the courts and justice for limited period and since it a interim order, there may be several problems which may arise by following it further for long time, where it may be easy and acceptable for the time being. And it can be used as an opportunity to make the system trend and update the old traditional process.

C) Digitization of judicial process:

Since it is the modern and digital era, and the globe moves towards the globalization and digitalization, now it is time for the judicial system join the development. As there is transparency tracking, online payments, video conference and digital forms and records it is easy to make a trial system and space of the justice[10]. And developing the AI could help to improve the value and the effect of the trial and makes the trial time efficient. The filing of the petition and any further application is now made as digital and can be filed through the email as the digital copy, and the arguments are made into a video conferencing which enhances the safety and maintains the social distancing. Since the e-court system is already in progress, so the information’s and the updates are being uploaded in the ecourt website/mobile application manually within little time of the decision taken. Therefore, legal academia must work closely with the judiciary and members of the fraternity to revisit legal curricula and pedagogy techniques.[11]

D) Technology being the only solution:

Digitalization and the e-courts is a key solution to many practical problems. According to the Supreme Court registry, 640 cases were registered online between 22 March and 8th July. Where since it was less as compared to the other days, but due to the lockdown and the pandemic and the less awareness about the new process it is acceptable and it is considered as an efficient and safe method.[12] Through the medium of the virtual courts, it has been adopted that these are used in the urgent matters and the practice must be temporarily being suspended and not permanently.

E) Effects and ill effects by the new system:

In the digital ecosystem of the judiciary there are some of the problems and benefits in the implementation of the modern technology and maintaining the transparency and equity in the justice through the technology with the trust of the people and belief.

The benefits of the system are follows,[13]

The video conferencing and the virtual mode can be used in the legal matters like bail application and remain hearing any civil matters like family and matrimonial disputes. The evidence can be presented before the court by this way.

Virtual court helps us to overcome the geographical hurdle in physical appearance in case of the struggle in appearing before the court. And it makes the lawyers from any part of the country to appear for the client who hired the advocate.

Where speaking of the open court cannot be recorder as likely to the words said by the witness, but where in the video conferencing the speech can be recorded and can be viewed many times at any place.

And speaking and recording of the digital library in the legal reference books, and other legal source single place will not make any in of the chaos and the information is collective and not be in spread of the knowledge.

Even though there are more advantages in the way to make the judicial process easy and flexible towards the convenience, there are many disadvantages also engaged in the new system like,[14]

there is only lesser part of the judicial side benefits by this and the problems like the application and the procedural authentication of witness cannot be maintained and followed through the virtual process.

Since there is no strong database and the security to the digital system, where there is no specific platform to run the digital courts, there shall be risk in the security, where the whole setup has odd chance to be viewed by the unauthorized persons.

And digitalization of all the courts in India will definitely need a lot of funding by the government and it will take time to setup the uniform safety and secure procedure for all the courts. And maintaining will also needs fund and the proper updating and designing should be important.

At last, one important aspect is that the speedier justice would result in detention of the quality of justice. The ultimate aim is to have more effective judicial system than the easily accessible and transparent system.[15]

Where it helps to understand that the traditional method of access of the court is very much maintained and the digitalization will not be full sufficient and convincible to get the realistic justice and the challenge of the people towards the court will be osculating towards down.[16]


Even though this method is very much useful in the contemporary and current situation, it cannot be followed for future continuously. India is placed 128th position in the mobile broadband and 66th in the fixed broadband internet connection and only that is considered as the fastest internet in the country, but when it comes to digitalization not only lawyers, even the client also should have the broadband connection and while raising it for everyone, there will be connectivity issues. It seems to be a one time investment, but maintaining good connectivity is costlier and harder than imagined.

And e-courts in India is a complicating process. Many most lawyers and judges may find it hard to learn it and due to some practical shortcomings, technical glitches or connectivity, quality of the judgment and the argument. It brings injustice to the experience and their success. And all the evidence cannot be produced in the digital format, where lack of the techno legal expertise the main barrier in the reach of the e-court centers through the country. So, not everything can be digitalized and some of the traditional court practice must be done only in the court to get the proper justice to the society

Benefits of this changes and new judiciary to layman:

The changes in system are especially for the betterment of the judicial practitioners and to improve their judicial practice. The only benefit to the lay man by this system is the speedy judgment where all the quick judgment may not include the accurate interpretation of the law. And it will not bring any extra benefits to the layman in the society and according to them the court and the justice is same.[17]


As a virus, with the scale and impact, unlike any other encountered before, the government had the monumental task of conceptualizing policies according to the preventive measures as developed at the time. Not only healthcare, safekeeping and sustaining the economy was also to be considered and allotted the complete attention by the government. Administration of the citizens and catering to their problems which the disease and the accompanying guidelines and safety measures to be imposed on people were also to be reconciled by providing various mechanisms, schemes, or any other efforts.

A chronological description of the responses by the government:

A) Immediate Measures

i) Airlift of Students

Airlift is an operation either intended to supply cargo to disaster struck areas or rescue citizens or other persons from a situation of danger. While the disease was increasing in the city of Wuhan, Indian government launched airlift missions to bring back its citizens from the epicenter and other parts of China[18]. Government, in a situation of disaster, such as presented by the epidemic in China, owes a moral responsibility for the safekeeping of its citizens abroad. In 1990, when the Iraqi forces invaded Kuwait, and the violence of war brewed vigorously, India conducted the largest civilian airlift mission and rescued close to a million of its citizens from the sensitive territory. Similarly, when the disease grew its intensity and fatality became an apparent probability, the government of India, organized and executed the operation to rescue its citizens from China.

The evacuation of Indian nationals began on January 31, 2020 and they were airlifted through the Air India flights from China. The same planes and missions were also responsible for evacuation of certain other nationals. The airlift operation was concluded on February 27.

ii) Cancellation of all Visas

In order to stop the spread of disease from the epicenter, the Indian government cancelled the visas for Chinese and Foreign Nationals who had visited in the country in the previous two weeks in January[19]. Also, e-visa facility for Chinese nationals in India were temporarily suspended and the foreigners who were at India with a travel history in China after January 15 were directed to contact the Ministry of Health and Family Welfare.

iii) Screening of all passengers on the airport

Initially, only selected international passengers were screened. Now with the direction of the government, all the international passengers were screened. Screening included analyzing the body temperatures of the patients. All international travelers were supposed to submit the information relating to their travel history and if they have any symptoms.

iv) Janta Curfew

In the times of viral diseases such as COVID-19, the government must assume the position of a stern regulator in order to guide the health challenge imposed. The Hon’ble Prime Minister’s through his address while describing the nature of the disease and the challenges it posed to the health and economy of the nation called for a ‘janta curfew’. The address reached out to people requesting them for solidarity and observe a self-imposed curfew. Since it was self-implicated, there would not be any legal action if anyone ‘violated’ the curfew. It can be interpreted as a trial before the actual lockdown.

v) Lockdown

Through another address, boasting the success of the janta curfew, on March 24, 2020, the Prime Minister announced that the country would be under ‘lockdown’ to curb the spread of COVID-19. Only essential services[20] such as food, medicine and healthcare and other such services would be allowed to operate. The lockdown was further extended in 4 phases till June 30. The janta curfew acted as a preliminary trial for the lockdown. It was somehow hinted before the enforcement to grant people time to move to their suitable locations and stockpile on the essentials. However, the unprecedented announcement of the lockdown caused a massive problem of migration of people.

The definition of disaster as provided in Section 2(d) of the Act does not cover viral diseases, but the Home Ministry deemed COVID-19 as a ‘notified disaster’.

The lockdown places restrictions on the fundamental right under Article 19(1) as it imposes a restriction on the freedom of movement and further orders the closure of business. The EDA (Epidemic Diseases Act of 1897 under Section 2 and 2A empower the Center and State to implement necessary steps to control an epidemic outbreak.

The guidelines regarding the restriction on operation of businesses, services and travel were placed within the powers allocated under the Section 10(2)(l) of the Disaster Management Act. An additional step to ensure compliance was made as any act violating the guidelines and the containment measures were made liable under Section 51 to 60 (Offenses and Penalties) of the Disaster Management Act and punishable under Section 188 of the Indian Penal Code.


A) Reserve Bank of India

i) Role of the Central Bank

As the central bank of the country, the Reserve Bank of India (RBI) has the responsibility of regulating the monetary market and the banking sector. COVID-19 forced the world to shun down the economic activities to prevent the spread of the virus. Consequently, the flow of currency was also affected, and the RBI had to bring measures to minimize the impact of the pandemic on the highly vulnerable banking sector and the monetary market. It is essential to understand that banks are gateways to the monetary market, i.e., regulating them leads to the regulation of the monetary market in a modern economy, whether directly or indirectly.

The minting of currency, maintenance of gold reserves, acting as the banker to the government and other banks are just some of the important duties performed by the central bank.[21] In the event of economic uncertainty, such as the one posed by the pandemic, the market becomes volatile and the duties of the RBI increase significantly and the impact any policy imposed has a significant affect on the health of the market. Therefore, the bank must tread with extra caution while formulating monetary policies relating to credit and interest control rate.

ii) The Financial Crunch

The policies of the central bank to adapt to the pandemic-imposed recession is developed while being in a constant interaction with the financial markets and its stakeholders. The banks in India were already going through with a liquidity crunch with the likes of Yes Bank, Dena Bank among others coming up liquidity and funding shortages in the recent year[22]. The crisis of the Non-Banking Financial Corporations such as the IL&FS and DHFL also unfolded. Therefore, it becomes paramount for the apex bank to enforce policies which would minimize the risk of any financial insufficiency in the Indian banking sector.

The extent of the damage caused by the pandemic could not be possibly ascertained yet as the volatility of the market still lurches in the shadow of the disease and the damage continues to unfold. The Gross Domestic Product (GDP) has been consistently declining after peaking out at 7.9% in Q4 of FY 2018. In the midst of the pandemic, sharing the trends with global decline, India’s GDP posted a growth of only 4.5% in Q2 of F.Y. 2020. Unemployment increased and exports have been constantly low for several months. Layoffs, due to declining business have also been gaining traction. The prevalent down trend of the economy makes the policies of the RBI and the regulation of the market a much more stringent and essential task.

iii) The Measures Adopted

The lockdown also stopped the economic activities and therefore, to provide for the sustainability of the economy the regulator adopted the method of allowing various relaxations and rate cuts with measures to shore up liquidity and provide forbearance on several financial and compliance commitments.

The banking system is the backbone of the financial market of the country. Ensuring the smooth operation and steady flow of cash and credit results in a significant support to the economic activities within the country. In order to overcome the unpredictable contingency, the central bank implemented numerous measures and relaxations.

a) Operational and Business Continuity Measures

Before the lockdown was implemented or implementation of any strategic plans to prevent the spread of the disease, the economy was already taking the brunt of the pandemic. On March 16, 2020[23], when the number of reported cases just jumped past one hundred, an advisory was issued, and banks were directed to promote to their customers the use of digital services or net banking.

The key issues on which the advisory emphasized upon were the following:

  • Reanalyzing the BCP (Business Continuity Plan) to enable the smooth operation of business. Adaptation to the preventive measures to enable a hygienic and safe working environment was advised.

  • Sensitization about the nature of the virus to the staff members at all levels. The essential step to inform about the manner in which the virus spread, created an initial bubble of responsibility in the staff.

  • Advertise, encourage, and promote the facilitation of digital banking facilities was also directed to enable the continued operation banks.

b) Liquidity Management Measures

Maintaining their liquidity ratios to meet any liability or obligation which may arise is one of the most important cornerstones of banking institutions[24].

  • Targeted Long-Term Repos Operations (TLTROs) – Introduced on March 27, TLTRO was intended for the purpose of injecting small and medium NBFCs and MFIs (Micro Finance Institution). This measure ensured a steady flow of credit into the economy. The RBI specifically ‘targeted’ for injection of money in investment-grade corporate debt and wanted banks opting for funds under the TLTRO rather than the short-term liquidity which the RBI extends which only cover a period of 28 days with the tools of Liquidity Adjustment Facility (LAF) and Marginal Standing Facility (MSF).

  • Repo Rates and Reverse Repo Rates – As borrowing and consumption has declined, the banks have stashed more than required liquidity with them. To overcome this problem the reverse repo rate, or the reverse repurchase agreement rate at which the RBI may borrow money from commercial banks was ultimately reduced to 3.35%. The repo rate or the rate at which banks may borrow from RBI is reduced to 4.00%.

  • Cash Reserve Ratio (CRR) - It is the specified minimum fraction or percentage of total deposits which the banks must hold in reserve either as cash or as deposits with the central bank. RBI on March 27, 2020 through press release announced a significant reduction in the CRR by 100 basis points to 3.0% for a period of one year ending on March 26, 2021. This will unlock a sum of 1.37 lakh free for flow in the financial market of the country.

  • Liquidity Coverage Ratio – From April 1 onwards banks are required to set aside 100 percent of high liquidity assets to meet short-term obligation.

  • Refinancing Facilities – In the wake of stress caused to the cash flow by COVID-19, the RBI, introduced refinancing facilities for the All India Financial Institutions (AIFIs). The amount of over Rs 50,000 crore were to be directed to NABARD, SIDBI, and NHB (National Housing Bank).

c) Financial Market Measures

These measures are intended to stabilize the value of the fluctuating Rupee and the consequent impact in the currency market. RBI through the notification dated on March 27, 2020 permitted banks which operate within the segments International Financial Services Centre (IFSC) Banking Units (IBUs) of to deal in Offshore Non-Deliverable Rupee Derivative Markets(Offshore NDF Rupee Market).

d) Regulatory Measures

The impactful decisions made by RBI under the power delegated to them was vital in ensuring continuity of businesses. These were:

  • For working capital financing, the deferment period for recovery of interest was extended till August 31, 2020. Easing of such obligations helps the banks to make a better assessment of the usage of their funds and then create a differentiated classification of industries and then lend them according to the impact of COVID-19 on that industry.

  • A transformative shift was made when RBI announced the moratorium of term loans. All commercial and co-operative banks, NBFCs and AIFIs were granted a moratorium of three months on all term loans and working capital facilities. The dates were finally extended till August 31. The classification on non-payment of interest in Special Mention Account (SMA) and Non-Performing Asset (NPA) was also brought to an asset classification standstill till the end of the moratorium period.

e) Measures to support Exports and Imports

Suspension of business activities have caused importers and exporters a great deal of trouble such as delay in orders or payments and hence RBI announced that announced that the time period for realization and repatriation of export proceeds for exports made up to or on July 31, 2020. Period for export credit has also been extended by a period of 3 months.

f) Debt Management Measures

The State governments were also affected adversely by COVID-19, therefore, the RBI on May 22, eased the rules governing withdrawal from the Consolidated Sinking Fund which will remain valid till March 31, 2021, resulting in release of additional Rs 13,300 crore to the states. The CSF or Consolidated Sinking Fund is the reserve fund created by states with the RBI for amortization of their debt obligations.

[1] World Health Organization, Key Messages and Actions for COVID-19 Prevention and Control in Schools, 2 (March 2020). [2]Zi-Wei Ye et al., Zoonotic origins of human coronaviruses, 16(10) International Journal of Biological Sciences, (2020). [3] David Pigott et al., Mapping the zoonotic niche of Ebola virus disease in Africa, eLife(Sep. 8, 2014), https://elifesciences.org/articles/04395. [4] Bindu Perappadan, India’s first coronavirus infection confirmed in Kerala, The Hindu (Jan. 30, 2020, 01:47 PM). [5] World Health Organization, Coronavirus disease (COVID-19) advice for the public, https://www.who.int/emergencies/diseases/novel-coronavirus-2019/advice-for-public (as visited on Aug. 29, 2020). [6]Kumar, A., 2020. How Many Judges Does India Really Need?. [online] Livemint. Available at: <https://www.livemint.com/Politics/3B97SMGhseobYhZ6qpAYoN/How-many-judges-does-India-really-need.html> [Accessed 30 August 2020]. [7]Services.ecourts.gov.in. 2020. About Us - Ecourt India Services. [online] Available at: <https://services.ecourts.gov.in/ecourtindia_v6/static/about-us.php> [Accessed 30 August 2020]. [8]Njdg.ecourts.gov.in. 2020. Welcome To NJDG - National Judicial Data Grid. [online] Available at: <https://njdg.ecourts.gov.in/njdgnew/index.php> [Accessed 30 August 2020]. [9]Services.ecourts.gov.in. 2020. About Us - Ecourt India Services. [online] Available at: <https://services.ecourts.gov.in/ecourtindia_v6/static/about-us.php> [Accessed 30 August 2020]. [10]The Hindu. 2020. Virtual Methods Of Real-Time Justice. [online] Available at: <https://www.thehindu.com/education/virtual-methods-of-real-time-justice/article31822123.ece> [Accessed 30 August 2020]. [11] ‘Supreme Court Constitution Day | Introduction of Artificial Intelligence in Judicial Domain’, SCC Online Blog, 2019, available at- https://www.scconline.com/blog/post/tag/supreme-court-vidhik-anuvaad-software/ (last accessed on August 30, 2020). [12]JapnamBindra, S., 2020. Digitization Of Judicial Process Gets Big Push Amid Pandemic, Says Govt. [online] Livemint. Available at: <https://www.livemint.com/news/india/digitization-of-judicial-process-gets-big-push-amid-pandemic-says-govt-11594950575437.html> [Accessed 30 August 2020]. [13]Articles. 2020. Virtual Litigation And E-Filing: The Future Of The Indian Judiciary?. [online] Available at: <https://itatonline.org/articles_new/virtual-litigation-and-e-filing-the-future-of-the-indian-judiciary/> [Accessed 30 August 2020]. [14]Singh, M., 2020. Fallacies Of Digitization Of Judicial System Of India | Lawlex.Org. [online] LawLex.Org. Available at: <https://lawlex.org/lex-pedia/fallacies-of-digitization-of-judicial-system-of-india/21050> [Accessed 30 August 2020]. [15]INSIGHTSIAS. 2020. RSTV: THE BIG PICTURE- VIRTUAL COURTS AND WAY FORWARD - INSIGHTSIAS. [online] Available at: <https://www.insightsonindia.com/2020/04/10/rstv-the-big-picture-virtual-courts-and-way-forward/> [Accessed 30 August 2020]. [16]Cis-india.org. 2020. The Internet In The Indian Judicial Imagination — The Centre For Internet And Society. [online] Available at: <https://cis-india.org/raw/blog_the-internet-in-the-indian-judicial-imagination> [Accessed 30 August 2020]. [17]Vyas, A., 2020. DIGITALIZATION OF COURTS: ONLY A PANDEMIC PREVENTION MECHANISM? - RGNUL Student Research Review (RSRR). [online] RGNUL Student Research Review (RSRR). Available at: <http://rsrr.in/2020/04/24/digitalization-courts-pandemic-prevention/#_ednref54> [Accessed 30 August 2020]. [18]ET Bureau,Govt Prepares to Airlift Indians from China, The Economic Times, (Jan 28, 2020, 08:27 AM). [19] PTI, Coronavirus: India cancels valid visas to Chinese, foreigners who visited China in last two weeks, The Economic Times, (Feb 04, 2020, 01:15 PM). [20] Ministry of Home Affairs, Guidelines on Essential Services in View of Covid-19 Outbreak Crisis and National Lockdown (March 24, 2020). [21] Mandeep Bansal, Role of Reserve Bank of India in Indian Economy, 7(1) International Journal of Business Administration and Management, (2017). [22] Rahul Oberoi, From diamonds to dust: Will the YES Bank crisis spill over to other lenders, The Economic Times, (Mar 06, 2020, 09:50 PM). [23] Reserve Bank of India, COVID-19- Operational and Business Continuity Measures, RBI/2019-20/172, (March 16, 2020). [24]Abir Dey &Arshi Siddiqui, Covid-19 Response On Banking And Finance: Measures And Reliefs By RBI, L&L Partners, (June 6, 2020).

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