title: Hélio Gracie

text: Gracie was born on October 1, 1913, in Belém, Brazil. Contrary to popular belief, he was a talented athlete, and trained and competed in rowing and swimming since his childhood. He had his first contact in martial arts at 16, when he started training judo (at that time commonly referred to as "Kano Jiu-jitsu" or simply "Jiu-Jitsu"), with his brothers Carlos and George. He also learned catch wrestling under the renowned Orlando Americo "Dudú" da Silva, who taught his brothers for a time.


title: Hélio Gracie

text: When he was 16 years old, he had the opportunity to teach a judo class, which helped him develop his family style, "Gracie Jiu Jitsu". When the director of the Bank of Brazil, Mario Brandt, arrived for a private class at the original Gracie Academy in Rio de Janeiro as scheduled Carlos Gracie, the instructor, was running late. Hélio offered to teach the class in Carlos's stead. When the Carlos arrived with apologies, Brandt assured him it was no problem, and even requested that he be allowed to continue learning with Hélio .


title: Hélio Gracie

text: Gracie realized, however, that even though he knew the techniques theoretically, the moves were much harder for him to execute. Consequently, he began adapting Mitsuyo Maeda's brand of judo, already heavily based around "newaza" ground fighting techniques. From these experiments, Gracie Jiu-Jitsu was created. Like its parent style of judo, these techniques allowed smaller and weaker practitioners the capability to defend themselves and even defeat much larger opponents. "Carlos and Helio Gracie ... brought a fresh eye to jujitsu just as their fellow countryman brought a special new approach to football."


title: Hélio Gracie

text: Aside from training with his brothers, Gracie learned further judo under Sumiyuki Kotani and Argentinian judo pioneer Chugo Sato. He might have also got training under a practitioner named Hiraichi Tada. However, the extent of his official training in this art remains unknown. According to Masahiko Kimura, Gracie held the rank of 6th dan in judo in 1951, while according to Robert Hill, Kodokan records show Gracie at the rank of 3rd dan at the time, though Hill also noted that it was not unusual for Kodokan records to show a lower rank than that actually held by non-Japanese judo practitioners.


title: Hélio Gracie

text: Gracie began his professional fighting career at 18 years old against boxer Antonio Portugal. The fight took place in the undercard of a "jiu-jitsu vs. boxing" event on January 16, 1932, which saw judoka Geo Omori defeating boxer Tavares Crespo. Gracie won his fight by submission in a short time, probably an armlock in 40 seconds. Portugal is sometimes incorrectly billed as a boxing champion.


title: Hélio Gracie

text: His second match would be the same year in a jiu-jitsu exhibition against Takashi Namiki in September. As Namiki had a 7 kg (15 lb) weight advantage and was a native of Japan just like the art of jiu-jitsu, he was expected to defeat Gracie. Namiki dominated the match, but Gracie wasn't defeated, leading it to a draw after several rounds.


title: Hélio Gracie

text: Also in 1932, Gracie faced professional wrestler Fred Ebert on November 6. It was his biggest challenge up to the point, as Ebert outweighed him by 29 kg (64 lb) and was a decorated freestyle wrestler, and their match would have no time limit. Gracie was positive, claiming he would submit Ebert in a short time. However, the bout lasted almost two hours, and was eventually stopped by the police at the promoters's discretion as none of the fighters was progressing or advancing position. Again, this fight is sometimes registered as a vale tudo match, but it was hosted under grappling only rules. In an interview, Gracie claimed that he had to undergo an urgent operation the next day and that the stop was demanded by the doctor due to Gracie having a high fever caused by a swelling.


title: Hélio Gracie

text: In 1934, Gracie faced another jiu-jitsu practitioner named Miyaki. The latter (whose first name is unknown) was billed as a judo black belt, although he had fought only one professional fight, a loss against professional wrestler Robert Ruhmann. He is usually identified as the famous judoka and catch wrestler Taro Miyake, a theory possibly initiated by Mark Hewitt in his book "Catch Wrestling: A Wild and Wooly Look at the Early Days of Pro Wrestling in America" (2005). However, Miyake was 54 years old and weighted 90 kg (200 lb) at the time, while Miyaki's official stats were about 20 years old and 64 kg (141 lb), and photographic material seems to support them being different people.


title: Hélio Gracie

text: In any case, Gracie passed the first 20 minutes of the match in guard position before he climbed up to mount. He then applied a gi choke which Miyaki didn't surrender to, making the Japanese fall unconscious for the victory.


title: Hélio Gracie

text: On July 28, Gracie faced renowned professional wrestler Wladek Zbyszko who, very much like Ebert, had a 40 kg (88 lb) weight advantage (albeit was 22 years older) and was billed as a world champion. Although the match was promoted as a "catch-as-catch-can vs. jiu-jitsu" challenge, it was fought under jiu-jitsu rules, including judogis and a 20-minute time limit. It was an uneventful affair; Gracie pulled guard at the opening and they spent the rest of the match in said position, ending in a draw. Still, it was seen as a moral victory for Gracie not to have been finished by the larger Wladek. The wrestler himself praised Gracie's courage and resistance.


title: Hélio Gracie

text: Gracie's next opponent was his own former teacher, Orlando Americo "Dudú" da Silva, who had defeated Hélio's brother George in a catch wrestling match earlier in the year 1935. Their match was stipulated as a vale tudo bout with a 20-minute time limit on February 2. During the match, the two fighters exchanged punches before Dudú, heavier by 20 kg, took Gracie down. Gracie defended from the guard, but Dudú landed heavy punishment in form of ground and pound, breaking Gracie's nose with a headbutt and making him bleed profusely. However, the wrestler ended up spending all his energy in the assault, and it allowed Gracie to counterattack gradually with short punches from the bottom. When they returned to standing by the referee, Gracie landed two side kicks of the kind called "pisão" in capoeira, and the tired Dudú submitted verbally shortly after.


title: Hélio Gracie

text: After the fight against Dudú, Gracie was challenged by 5th dan judoka Yasuichi Ono to another vale tudo fight. This was met with heat by the Gracie side, as Ono had defeated George Gracie by choke in a jiu-jitsu match. Calling Ono a "cretin" in a newspaper interview, Gracie claimed to accept the challenge and the two were stipulated to fight in April 1935, but the bout was scrapped when Gracie pulled out. Eventually, Gracie accepted to fight Ono, but only under jiu-jitsu rules, without points or judges and in December. He also came to the match wearing a judogi with very short sleeves in order to make gripping difficult.


title: Hélio Gracie

text: The affair saw Ono, though lighter than Gracie by 4 kg (9 lb), executing an exact number of 32 judo throws on Gracie through the entire match, as well as almost finishing him with a juji-gatame in the first round. However, Gracie never gave up and escaped all his holds, including one in which he dived out of the ring to avoid a choke (a legal action at the time), and even had his own modest submission attempts in the form of an armlock and a gi choke near of the ending. After 20 minutes, the bout ended in a draw.


title: Hélio Gracie

text: On June 13, 1936, Gracie fought judoka Takeo Yano, a training partner of Ono who also had dominated George Gracie the previous year in a time draw. Again, Gracie demanded a match without judges and wore a modified judogi, and his brother Carlos predicted that Yano wouldn't last a single round. Indeed, Gracie showed improvement, threatening Yano with a gi choke in the second round, but Yano threw and took down Gracie repeatedly through the three rounds of the match, which ended in a draw. Ono challenged Gracie for a future rematch after the bout, which Gracie accepted. The same month, Gracie was involved in a challenge consistent in fighting three opponents the same night, being those Geroncio Barbosa, Manuel Fernandes and Simon Munich, but Gracie pulled out before the event and was replaced by his brother George.


title: Hélio Gracie

text: On September 12, Gracie faced a 2 kg heavier fighter named Massagoishi. He was billed as both a sumo wrestler and judo black belt, although Takeo Yano was quoted as skeptical of the second claim. Gracie submitted Massagoishi with an armlock after 13 minutes of fighting. However, the match was criticized by the press, calling it "a comedy and a farce" due to Gracie and his opponent not living up to expectations. The Brazilian Federation of Pugilism actually suspended Massagoishi for his inactivity during the bout.


title: Hélio Gracie

text: Gracie met Yasuichi Ono for the second time on October 3, 1936, again in a match under jiu-jitsu rules and with no points of judges. Press and critics were unanimous in Hélio's improvement from their first match, although Ono again threw Gracie a number of 27 times and controlled most of the match. Around the time, Gracie had another rematch, it being against Orlando Americo da Silva and under grappling only rules. Gracie lost the match when he was disqualified for using a forbidden hold. Gracie had also a match against Erwin Klausner in 1937. Klausner was mainly a boxer (although he was also known as a wrestler), but the match was contested under the usual jiu-jitsu rules. Gracie won by armlock at the second round.


title: Hélio Gracie

text: In 1937, Gracie retired from competition for the first time. He did not fight again until 1950. The year of his return, Gracie challenged famous boxing champion Joe Louis to a vale tudo match in one of his visits to Brazil, but Louis declined and proposed a boxing match, which Gracie rejected.


title: Hélio Gracie

text: In 1951, Gracie issued a challenge against a touring judoka and professional wrestler, Masahiko Kimura.


title: Hélio Gracie

text: Oswaldo Fadda represents a non-Gracie line of Brazilian jiu-jitsu. He was trained by Luiz França who was a student of Mitsuyo Maeda around the same time as Carlos and Hélio Gracie. Fadda was known for training the poor in Rio de Janeiro, and for the use of leg locks, which the Gracies considered low class. He trained a number of students and challenged Gracie's academy in 1953. Fadda's academy won the majority of the matches.


title: Hélio Gracie

text: In 1955, Gracie was challenged by Valdemar Santana, a former student of his academy who now trained and fought under the management of Carlos Renato and Haroldo Brito. Reasons why Santana left the Gracie team are diffuse; one of them is that he was expelled for taking a professional wrestling bout, something that their fighters had forbidden, while another tells how Santana accidentally flooded Gracie's gym while doing cleaning chores. Gracie accepted the challenge of a vale tudo match, even though Santana was 16 years younger and 60 lb heavier.


title: Hélio Gracie

text: They fought in May, both wearing a jiu-jitsu gi. The bout lasted almost four hours, possibly three hours and 40 minutes. Gracie defended from his guard for most of the fight, hitting elbows to the head and heel kicks to the back, while his opponent threw punches through the guard. After a long time of fighting, Gracie got eventually tired, and Santana took over with headbutts and more strikes. At the end, Santana lifted Gracie up and slammed him on the mat, and then landed a soccer kick to the head of a kneeling Gracie. Gracie was knocked out and his cornermen threw the towel.


title: Hélio Gracie

text: Although luta livre veteran Euclydes Hatem challenged Gracie after the fight, Gracie's bout with Santana was his final match before his retirement.


title: Hélio Gracie

text: A dispute between Gracie's brother Carlos and Manoel Rufino dos Santos worsened after Dos Santos won a public bout against Carlos. Subsequently, the conflict then moved to the newspapers, where Rufino criticized Carlos's skill and dismissed his jiu-jitsu credentials, leading Carlos, George and Hélio Gracie to assault him in front of his teaching place at the Tijuca Tênis Clube on October 18. They hit him repeatedly with a steel box and immobilized him for Carlos to apply an armlock, dislocating Rufino's shoulder so badly that it needed surgery. The brothers were arrested and were convicted to two years and a half in prison for assault, as well as for trying to run away during the arrest, but their connections to President of Brazil Getúlio Vargas granted them a pardon.


title: Hélio Gracie

text: Gracie's son, Rorion Gracie, was among the first Gracie family members to bring Gracie Jiu-Jitsu to the US. Royce Gracie, Rorion's younger brother, went on to become the first UFC champion in the organization's history; Helio coached Royce from outside the cage at UFC 1 and UFC 2.


title: Hélio Gracie

text: Gracie died on the morning of January 29, 2009, in his sleep in Itaipava, in the city of Petrópolis, Rio de Janeiro. The cause of death, reported by the family, was natural causes. His last words were: "I created a flag from the sport's dignity. I oversee the name of my family with affection, steady nerves and blood." Gracie was able to utilize the same Jiu-Jitsu techniques which he helped to develop until his death. He was 95 years old, and was teaching/training on the mat until 10 days before his death, when he became ill.


title: Hélio Gracie

text: Gracie had been married to Margarida for 50 years. During their marriage, Gracie became the father of three sons (Rickson, Rorion, and Relson) with Isabel 'Belinha' Soares and four sons (Royler, Rolker, Royce, Robin), two daughters (Rerika and Ricci) with Vera. After Margarida's death, he married Vera who was 32 years his junior. Gracie was grandfather to many BJJ black belts, including Ryron, Rener, Ralek, Kron, and Rhalan.


title: Hélio Gracie

text: In his late years, Gracie was quoted as saying: "I never loved any woman because love is a weakness, and I don't have weaknesses."


title: Hélio Gracie

text: Gracie was a member of the Brazilian movement Brazilian Integralism, which first appeared in Brazil in 1932. Today, many members of the Gracie family are also close to the Brazilian President Jair Bolsonaro, who received an honorary black belt from Robson Gracie in 2018.


title: Yasak Elma

text: Yasak Elma (English title: "Forbidden Apple") is a Turkish television series created by Medyapım, starring Şevval Sam and Eda Ece and others. It was written by Melis Civelek and Zeynep Gür, and directed by Neslihan Yeşilyurt for three seasons, by Murat Öztürk in the fourth season and by Ece Erdek Koçoğlu from the fifth and sixth seasons.


title: Yasak Elma

text: Ender, a woman from the high society and wife of successful businessman Halit Argun, hires Yildiz Yilmaz as her husband's personal waitress. The latter is asked to seduce Halit so Ender can get finances after their divorce but Yildiz betrays Ender and exposes her plan. Halit divorces Ender upon learning the truth. She is left without money and begins her struggle to maintain her past position in society. Meanwhile, Yildiz and Halit get married.


title: Yasak Elma

text: Ender's and Yildiz's enmity and intrigue continue. Yildiz's first husband, Kemal, now well off, returns with a plan to take revenge on Yildiz because she divorced him on the wedding day as she had been accepted for an acting opportunity and Kemal was poor, so she left him for fame and money. Later, Kemal and Yildiz fall for each other and Kemal asks Yildiz to choose between him and Halit. Yildiz finds it difficult to leave the life she has because of Halit. Kemal marries Zehra Argun, Yildiz's stepdaughter and Halit's daughter from his first wife, which disappoints Yildiz. Later, she successfully sends him away.


title: Yasak Elma

text: Ender's first love Kaya comes and his sister, Sahika joins too. Halit is impressed by Sahika and falls for her. Yildiz is pregnant at that time. Halit kicks her out of the house and she starts living in a village.


title: Yasak Elma

text: Ender and Kaya's son Yigit, of whom Ender and Kaya are both unaware because Kaya never knew of Ender's pregnancy and Ender had given him for adoption when he was born, starts working for Sahika. He pushes Ender into the sea.


title: Yasak Elma

text: Ender and Yildiz become friends against Sahika. Yildiz names her son Halitcan and divorces Halit. Yildiz falls for Kerim but they dont end up together. Yildiz experiments with new career options, doing a weather show on tv and starts a project of producing apple puree. It turns out Sahika is working for Nadir who is Halit's enemy and he also becomes a partner in the company. Sahika later kills him by poisoning.


title: Yasak Elma

text: Halit dies as a result of Ender and Sahika protecting Yildiz from him. Yildiz marries Cagatay, whose father HasanAli becomes a partner in the company. HasanAli kicks Ender and Sahika out of the company and they become poor. During this time they help each other. Later, they join the company back, Sahika marries HasanAli and later is killed by Cansu, a spy hired by Ender and Sahika. The season ends with a bomb blast in HasanAli's house where he is present along with Ender and Yildiz.


title: Yasak Elma

text: Cagatay cheats on Yildiz with Kumru, a model and their neighbor. Yildiz is disheartened after she learns of this. She starts making her own shampoo and wins an award for it. At the ceremony she publicly disgraces Cagatay and Kumru. She divorces Cagatay and marries Doğan, Kumru's father, this is a paper marriage to teach a lesson to Kumru and Cagatay. Kumru leaves Cagatay on the wedding day when she learns he is with her to take revenge on Dogan. Handan, Dogan's ex wife returns and manages to win her daughter Kumrus heart and becomes a partner in the company. Later, Cagatay teams up with Ekin, Kumrus husband and Dogan's enemy's son, against Dogan. The season ends with a car accident planned by Dogan to kill Cagatay in which Cagatay dies.


title: Yasak Elma

text: Yıldız, upon learning Doğan's involvement in the car accident, complained against him and he was sent to prison. The season starts with a 2 year time lapse. Doğan and Yıldız's daughter Yıldızsu is born while Doğan is still in prison. Later, he is freed and him and Ender team up against Yıldız.


title: Fallopian tube

text: The fallopian tubes, also known as uterine tubes, oviducts or salpinges (singular salpinx), are paired tubes in the human female that stretch from the uterus to the ovaries. The fallopian tubes are part of the female reproductive system. In other mammals they are only called oviducts.


title: Fallopian tube

text: Each tube is a muscular hollow organ that is on average between 10 and 14 cm in length, with an external diameter of 1 cm. It has four described parts: the intramural part, isthmus, ampulla, and infundibulum with associated fimbriae. Each tube has two openings a proximal opening nearest and opening to the uterus, and a distal opening furthest and opening to the abdomen. The fallopian tubes are held in place by the mesosalpinx, a part of the broad ligament mesentery that wraps around the tubes. Another part of the broad ligament, the mesovarium suspends the ovaries in place.


title: Fallopian tube

text: An egg cell is transported from an ovary to a fallopian tube where it may be fertilized in the ampulla of the tube. The fallopian tubes are lined with simple columnar epithelium with hairlike extensions called cilia which together with peristaltic contractions from the muscular layer, move the fertilized egg (zygote) along the tube. On its journey to the uterus the zygote undergoes cell divisions that changes it to a blastocyst an early embryo, in readiness for implantation.


title: Fallopian tube

text: Almost a third of cases of infertility are caused by fallopian tube pathologies. These include inflammation, and tubal obstructions. A number of tubal pathologies cause damage to the cilia of the tube which can impede movement of the sperm or egg.


title: Fallopian tube

text: The name comes from the Italian Catholic priest and anatomist Gabriele Falloppio, for whom other anatomical structures are also named.


title: Fallopian tube

text: Each fallopian tube leaves the uterus at an opening at the uterine horns known as the proximal tubal opening or "proximal ostium". The tubes have an average length of that includes the intramural part of the tube. The tubes extend to near the ovaries where they open into the abdomen at the distal tubal openings. In other mammals the fallopian tube is called the oviduct which may also be used in reference to the fallopian tube in the human. The fallopian tubes are held in place by the mesosalpinx a part of the broad ligament mesentery that wraps around the tubes. Another part of the broad ligament, the mesovarium suspends the ovaries in place.


title: Fallopian tube

text: intramural or interstitial part, that links to the narrow isthmus, the isthmus connects to the larger ampulla, which connects with the infundibulum and its associated fimbriae that opens into the peritoneal cavity from the distal tubal opening.


title: Fallopian tube

text: The intramural part or interstitial part of the fallopian tube lies in the myometrium, the muscular wall of the uterus. This is the narrowest part of the tube that crosses the uterus wall to connect with the isthmus. The intramural part is 0.7 mm wide and 1 cm long.


title: Fallopian tube

text: The narrow isthmus links the tube to the uterus, and connects to the ampulla. The isthmus is a rounded, and firm muscular part of the tube. The isthmus is 1–5 mm wide, and 3 cm long. The isthmus contains a large number of secretory cells.


title: Fallopian tube

text: The ampulla is the major part of the fallopian tube. The ampulla is the widest part of the tube with a maximal luminal diameter of 1 cm, and a length of 5 cm. It curves over the ovary, and is the primary site of fertilization. The ampulla contains a large number of ciliated epithelial cells. It is thin walled with a much folded luminal surface, and opens into the infundibulum.


title: Fallopian tube

text: The infundibulum opens into the abdomen at the distal tubal opening and rests above the ovary. Most cells here are ciliated epithelial cells. The opening is surrounded by fimbriae, which help in the collection of the oocyte after ovulation. The fimbriae (singular fimbria) is a fringe of densely ciliated tissue projections of approximately 1 mm in width around the distal tubal opening, oriented towards the ovary. They are attached to the ends of the infundibulum, extending from its inner circumference, and muscular wall. The cilia beat towards the fallopian tube. Of all the fimbriae, one fimbria known as the ovarian fimbria is long enough to reach and make contact with the near part of the ovary during ovulation. The fimbriae have a higher density of blood vessels than the other parts of the tube, and the ovarian fimbria is seen to have an even higher density.


title: Fallopian tube

text: An ovary is not directly connected to its adjacent fallopian tube. When ovulation is about to occur, the sex hormones activate the fimbriae, causing them to swell with blood, extend, and hit the ovary in a gentle, sweeping motion. An oocyte is released from the ovary into the peritoneal cavity and the cilia of the fimbriae sweep it into the fallopian tube.


title: Fallopian tube

text: When viewed under the microscope, the fallopian tube has three layers. From outer to inner, these are the serosa, muscularis mucosae, and the mucosa.


title: Fallopian tube

text: The outermost covering layer of serous membrane is known as the serosa. The serosa is derived from the visceral peritoneum.


title: Fallopian tube

text: The muscularis mucosae consists of an outer ring of smooth muscle arranged longitudinally, and a thick inner circular ring of smooth muscle. This layer is responsible for the rhythmic peristaltic contractions of the fallopian tubes, that with the cilia move the egg cell towards the uterus.


title: Fallopian tube

text: The innermost mucosa is made up of a layer of luminal epithelium, and an underlying thin layer of loose connective tissue the lamina propria. There are three different cell types in the epithelium. Around 25% of the cells are ciliated columnar cells; around 60% are secretory cells, and the rest are peg cells thought to be a secretory cell variant. The ciliated cells are most numerous in the infundibulum, and the ampulla. Estrogen increases the formation of cilia on these cells. Peg cells are shorter, have surface microvilli, and are located between the other epithelial cells. The presence of immune cells in the mucosa has also been reported with the main type being CD8 T-cells. Other cells found are B lymphocytes, macrophages, NK cells, and dendritic cells.


title: Fallopian tube

text: The histological features of tube vary along its length. The mucosa of the ampulla contains an extensive array of complex folds, whereas the relatively narrow isthmus has a thick muscular coat and simple mucosal folds.


title: Fallopian tube

text: Embryos develop a genital ridge that forms at their tail end and eventually forms the basis for the urinary system and reproductive tracts. Either side and to the front of this tract, around the sixth week develops a duct called the paramesonephric duct, also called the Müllerian duct. A second duct, the mesonephric duct, develops adjacent to this. Both ducts become longer over the next two weeks, and the paramesonephric ducts around the eighth week cross to meet in the midline and fuse. One duct then regresses, with this depending on whether the embryo is genetically female or male. In females, the paramesonephric duct remains, and eventually forms the female reproductive tract. The portions of the paramesonephric duct which are more cranial—that is, further from the tail-end, end up forming the fallopian tubes. In males, because of the presence of the Y sex chromosome, anti-Müllerian hormone is produced. This leads to the degeneration of the paramesonephric duct.


title: Fallopian tube

text: As the uterus develops, the part of the fallopian tubes closer to the uterus, the ampulla, becomes larger. Extensions from the fallopian tubes, the fimbriae, develop over time. Cell markers have been identified in the fimbriae which suggests that their embryonic origin is different from that of the other tube segments.


title: Fallopian tube

text: Apart from the presence of sex chromosomes, specific genes associated with the development of the fallopian tubes include the Wnt and Hox groups of genes, Lim1, Pax2, and Emx2.


title: Fallopian tube

text: Embryos have two pairs of ducts that will let gametes out of the body when they are adults; one pair (the Müllerian ducts) develops in females into the fallopian tubes, uterus, and vagina, while the other pair (the Wolffian ducts) develops in males into the epididymis and vas deferens.


title: Fallopian tube

text: The fallopian tube allows the passage of an egg from the ovary to the uterus. When an oocyte is developing in an ovary, it is surrounded by a spherical collection of cells known as an ovarian follicle. Just before ovulation, the primary oocyte completes meiosis I to form the first polar body and a secondary oocyte which is arrested in metaphase of meiosis II.


title: Fallopian tube

text: At the time of ovulation in the menstrual cycle, the secondary oocyte is released from the ovary. The follicle and the ovary's wall rupture, allowing the secondary oocyte to escape. The secondary oocyte is caught by the fimbriated end of the fallopian tube and travels to the ampulla. Here, the egg is able to become fertilized with sperm. The ampulla is typically where the sperm are met and fertilization occurs; meiosis II is promptly completed. After fertilization, the ovum is now called a zygote and travels toward the uterus with the aid of the hairlike cilia and the activity of the muscle of the fallopian tube. The early embryo requires critical development in the fallopian tube. After about five days, the new embryo enters the uterine cavity and, on about the sixth day, begins to implant on the wall of the uterus.


title: Fallopian tube

text: The release of an oocyte does not alternate between the two ovaries and seems to be random. After removal of an ovary, the remaining one produces an egg every month.


title: Fallopian tube

text: Almost a third of cases of infertility are caused by fallopian tube pathologies. These include inflammation, and tubal obstructions. A number of tubal pathologies cause damage to the cilia of the tube which can impede movement of the sperm or egg. A number of sexually transmitted infections can lead to infertility.


title: Fallopian tube

text: Salpingitis is inflammation of the fallopian tubes and may be found alone, or with other pelvic inflammatory diseases (PIDs). A thickening of the fallopian tube at its narrow isthmus portion, due to inflammation, is known as salpingitis isthmica nodosa. Like another PID endometriosis, it may lead to fallopian tube obstruction. Fallopian tube obstruction may be a cause of infertility or ectopic pregnancy.


title: Fallopian tube

text: If a blocked fallopian tube has affected fertility, its repair where possible may increase the chances of becoming pregnant. Tubal obstruction can be proximal, distal or mid-segmental.Tubal obstruction is a major cause of infertility but full testing of tubal functions is not possible. However, the testing of patency – whether or not the tubes are open can be carried out using


title: Fallopian tube

text: hysterosalpingography, laparoscopy and dye, or hystero contrast sonography (HyCoSy). During surgery, the condition of the tubes may be inspected and a dye such as methylene blue can be injected into the uterus and shown to pass through the tubes when the cervix is occluded. As tubal disease is often related to "Chlamydia" infection, testing for "Chlamydia" antibodies has become a cost-effective screening device for tubal pathology.


title: Fallopian tube

text: Occasionally the embryo implants outside of the uterus, creating an ectopic pregnancy. Most ectopic pregnancies occur in the fallopian tube, and are commonly known as "tubal pregnancies".


title: Fallopian tube

text: The surgical removal of a fallopian tube is called a salpingectomy. To remove both tubes is a bilateral salpingectomy. An operation that combines the removal of a fallopian tube with the removal of at least one ovary is a salpingo-oophorectomy. An operation to remove a fallopian tube obstruction is called a tuboplasty. A surgical procedure to permanently prevent conception is tubal ligation.


title: Fallopian tube

text: Fallopian tube cancer, which typically arises from the epithelial lining of the fallopian tube, has historically been considered to be a very rare malignancy. Evidence suggests it probably represents a significant portion of what has previously been classified as ovarian cancer, as much as 80 per cent. These are classed as serous carcinomas, and are usually located in the fimbriated distal tube.


title: Fallopian tube

text: In rare cases a fallopian tube may prolapse into the vaginal canal following a hysterectomy. The swollen fimbriae can have the appearance of an adenocarcinoma.


title: Fallopian tube

text: The fallopian tube was first described as a structure linked to fertilization by the Greek physician Soranus of Ephesus (1st century AD). The fallopian tubes were named by Vesalius after his assistant the 16th-century Italian anatomist Gabriele Falloppio, the first person to provide a detailed description of the tubes. He thought they resembled trumpets, "" in Italian, which was misunderstood and became the English "tube".


title: Fallopian tube

text: Though the name "Fallopian tube" is eponymous, it is often spelt with a lower case "f" from the assumption that the adjective "fallopian" has been absorbed into modern English as the "" name for the structure. Merriam-Webster dictionary for example lists "fallopian tube", often spelt "Fallopian tube".


title: Connective tissue

text: Connective tissue is one of the four primary types of animal tissue, along with epithelial tissue, muscle tissue, and nervous tissue. It develops from the mesenchyme derived from the mesoderm the middle embryonic germ layer. Connective tissue is found in between other tissues everywhere in the body, including the nervous system. The three meninges, membranes that envelop the brain and spinal cord are composed of connective tissue. Most types of connective tissue consists of three main components: elastic and collagen fibers, ground substance, and cells. Blood, and lymph are classed as specialized fluid connective tissues that do not contain fiber. All are immersed in the body water. The cells of connective tissue include fibroblasts, adipocytes, macrophages, mast cells and leucocytes.


title: Connective tissue

text: The term "connective tissue" (in German, "Bindegewebe") was introduced in 1830 by Johannes Peter Müller. The tissue was already recognized as a distinct class in the 18th century.


title: Connective tissue

text: Connective tissue can be broadly classified into connective tissue proper, and special connective tissue.


title: Connective tissue

text: Connective tissue proper consists of loose connective tissue and dense connective tissue (which is further subdivided into dense regular and dense irregular connective tissues.) Loose and dense connective tissue are distinguished by the ratio of ground substance to fibrous tissue. Loose connective tissue has much more ground substance and a relative lack of fibrous tissue, while the reverse is true of dense connective tissue. Dense regular connective tissue, found in structures such as tendons and ligaments, is characterized by collagen fibers arranged in an orderly parallel fashion, giving it tensile strength in one direction. Dense irregular connective tissue provides strength in multiple directions by its dense bundles of fibers arranged in all directions.


title: Connective tissue

text: Special connective tissue consists of reticular connective tissue, adipose tissue, cartilage, bone, and blood. Other kinds of connective tissues include fibrous, elastic, and lymphoid connective tissues. Fibroareolar tissue is a mix of fibrous and areolar tissue. Fibromuscular tissue is made up of fibrous tissue and muscular tissue. New vascularised connective tissue that forms in the process of wound healing is termed granulation tissue. All of the special connective tissue types have been included as a subset of fascia in the "fascial system".


title: Connective tissue

text: Bone and cartilage can further be grouped into supportive connective tissue. Blood and lymph can further be classed as fluid connective tissues.


title: Connective tissue

text: Membranes can be either of connective tissue or epithelial tissue. Connective tissue membranes include the meninges (the three membranes covering the brain and spinal cord) and synovial membranes that line joint cavities. Mucous membranes and serous membranes are epithelial with an underlying layer of loose connective tissue.


title: Connective tissue

text: Fiber types found in the extracellular matrix are collagen fibers, elastic fibers, and reticular fibers.


title: Connective tissue

text: Ground substance is a clear, colorless, and viscous fluid containing glycosaminoglycans and proteoglycans allowing fixation of Collagen fibers in intercellular spaces. Examples of non-fibrous connective tissue include adipose tissue (fat) and blood. Adipose tissue gives "mechanical cushioning" to the body, among other functions. Although there is no dense collagen network in adipose tissue, groups of adipose cells are kept together by collagen fibers and collagen sheets in order to keep fat tissue under compression in place (for example, the sole of the foot). Both the ground substance and proteins (fibers) create the matrix for connective tissue.


title: Connective tissue

text: Type I collagen is present in many forms of connective tissue, and makes up about 25% of the total protein content of the mammalian body.


title: Connective tissue

text: Connective tissue has a wide variety of functions that depend on the types of cells and the different classes of fibers involved. Loose and dense irregular connective tissue, formed mainly by fibroblasts and collagen fibers, have an important role in providing a medium for oxygen and nutrients to diffuse from capillaries to cells, and carbon dioxide and waste substances to diffuse from cells back into circulation. They also allow organs to resist stretching and tearing forces. Dense regular connective tissue, which forms organized structures, is a major functional component of tendons, ligaments and aponeuroses, and is also found in highly specialized organs such as the cornea. Elastic fibers, made from elastin and fibrillin, also provide resistance to stretch forces. They are found in the walls of large blood vessels and in certain ligaments, particularly in the ligamenta flava.


title: Connective tissue

text: In hematopoietic and lymphatic tissues, reticular fibers made by reticular cells provide the stroma—or structural support—for the parenchyma—or functional part—of the organ.


title: Connective tissue

text: Mesenchyme is a type of connective tissue found in developing organs of embryos that is capable of differentiation into all types of mature connective tissue. Another type of relatively undifferentiated connective tissue is the mucous connective tissue known as Wharton's jelly, found inside the umbilical cord.


title: Connective tissue

text: Various types of specialized tissues and cells are classified under the spectrum of connective tissue, and are as diverse as brown and white adipose tissue, blood, cartilage and bone. Cells of the immune system, such as macrophages, mast cells, plasma cells and eosinophils are found scattered in loose connective tissue, providing the ground for starting inflammatory and immune responses upon the detection of antigens.


title: Dhananjaya Y. Chandrachud

text: Dhananjaya Yashwant Chandrachud (born 11 November 1959) is an Indian judge who is serving as the 50th and current Chief Justice of India. He is a former ex-officio executive chairman of National Legal Services Authority whilst being J1 (or the senior-most judge after the chief justice) of the Supreme Court of India. In addition, he is a former chief justice of the Allahabad High Court and a former judge of the Bombay High Court.


title: Dhananjaya Y. Chandrachud

text: Born to Y. V. Chandrachud, he was educated at Delhi University and Harvard University before practising for Sullivan & Cromwell and in Bombay High Court. He became a judge at the Bombay High Court and then the chief justice of Allahabad High Court.


title: Dhananjaya Y. Chandrachud

text: A liberal judge, he has been part of benches that delivered landmark judgments such as Privacy verdict and Sabarimala case. He has visited the universities of Mumbai, Oklahoma, Harvard, Yale and others as a professor.


title: Dhananjaya Y. Chandrachud

text: He succeeded Justice Uday Umesh Lalit on November 9, 2022 as the chief justice of India (at the age of 62 years, 11months and 29days) before which his nomination was challenged on the grounds of conflict of interest. A bench headed by Justice Uday Umesh Lalit had dismissed the plea a week before Chandrachud's oath-taking ceremony.


title: Dhananjaya Y. Chandrachud

text: Dhananjaya Chandrachud was born in a prominent Chandrachud family on 11 November 1959. His father is Yeshwant Vishnu Chandrachud, the longest serving chief justice of India in history. His mother, Prabha, was a classical musician who sang for All India Radio.


title: Dhananjaya Y. Chandrachud

text: After attending the Cathedral and John Connon School, Mumbai and St. Columba's School, Delhi, he graduated with honours in economics and mathematics from St. Stephen's College, Delhi in 1979. He then obtained a Bachelor of Laws degree from the Faculty of Law at the University of Delhi in 1982, followed by a Master of Laws degree from Harvard Law School in 1983. He studied on the prestigious Inlaks Scholarship, offered to Indian citizens pursuing graduate education abroad, and received the Joseph H. Beale Prize at Harvard. He stayed at Harvard to complete a Doctorate of Juridical Science, which he finished in 1986. His doctoral dissertation was on affirmative action, and considered the law in a comparative framework.


title: Dhananjaya Y. Chandrachud

text: Chandrachud studied law at Delhi University in 1982 at a time when few jobs were available to young law graduates. He worked for a while, as a junior advocate assisting lawyers and judges, including drafting some briefs for Fali Nariman. After graduating from Harvard, Chandrachud first worked at the law firm Sullivan and Cromwell. He described this experience as "sheer fluke" due to the strong pecking order that existed at that time, and a strong bias against hiring Indians and similar developing countries. Upon returning to India, he practised law at the Supreme Court of India and the Bombay High Court. He was designated a Senior Advocate by the Bombay High Court in June 1998. That year, he was appointed an Additional Solicitor General of India, a role he held until his appointment as a Judge.


title: Dhananjaya Y. Chandrachud

text: He became a judge at the Bombay High Court from 29 March 2000 until his appointment as Chief Justice of the Allahabad High Court. During this time, he was also Director of the Maharashtra Judicial Academy. He was chief justice of the Allahabad High Court from 31 October 2013 until appointment to the Supreme Court of India on 13 May 2016. From 24 April 2021 onwards, he became a part of the Collegium of the Supreme Court of India, which is a body composed of the five senior-most judges of the Supreme Court of India and is responsible for the appointment of judges in the Supreme Court of India and all the High Courts. He is the executive chairman of National Legal Services Authority. On 17 October 2022, he was appointed as chief justice of India after the retirement of then chief justice, Uday Umesh Lalit. He was sworn in as the 50th chief justice of India on 9 November 2022.


title: Dhananjaya Y. Chandrachud

text: Apart from his judicial service, Chandrachud was also a visiting professor of comparative constitutional law at the University of Mumbai and University of Oklahoma College of Law in the United States. He has lectured at the Australian National University, Deakin University, Melbourne Law School, Harvard Law School, Yale Law School, the William S. Richardson School of Law at the University of Hawai‘i and the University of Witwatersrand, South Africa.


title: Dhananjaya Y. Chandrachud

text: During his Supreme Court service, he has been on the highest number of constitution benches (five judges or more) constituted to hear matters on constitutional questions. During his tenure at the Supreme Court, he has delivered judgements on Indian constitutional law, comparative constitutional law, human rights, gender justice, public interest litigation, commercial law and criminal law.


title: Dhananjaya Y. Chandrachud

text: Among his notable judgments is his lead opinion in Justice K. S. Puttaswamy (Retd.) and Anr. vs Union Of India And Ors. as part of a unanimous nine-judge bench decision of the Indian Supreme Court, which affirmed that the right to privacy is a constitutionally guaranteed right. Chandrachud grounded the right to privacy in dignity, liberty, autonomy, bodily and mental integrity, self-determination and across a spectrum of protected rights. Writing for himself and three other judges, he stated:Dignity cannot exist without privacy. Both reside within the inalienable values of life, liberty and freedom which the Constitution has recognised. Privacy is the ultimate expression of the sanctity of the individual. It is a constitutional value which straddles across the spectrum of fundamental rights and protects for the individual a zone of choice and self-determination.The judgment is also noteworthy for his observations on sexual autonomy and privacy.


title: Dhananjaya Y. Chandrachud

text: In 2013, a two judge bench of the Supreme Court of India in Suresh Kumar Koushal v. Naz Foundation upheld Section 377 of the Indian Penal Code which criminalized homosexuality. Chandrachud referred to the decision as striking "a discordant note which directly bears upon the evolution of the constitutional jurisprudence on the right to privacy." He observed that the decision was wrong as "the purpose of elevating certain rights to the stature of guaranteed fundamental rights is to insulate their exercise from the disdain of majorities, whether "legislative or popular"." He concluded by disagreeing "with the manner in which Koushal has dealt with the privacy – dignity-based claims of LGBT persons" and held that:The test of popular acceptance does not furnish a valid basis to disregard rights which are conferred with the sanctity of constitutional protection. Discrete and insular minorities face grave dangers of discrimination for the simple reason that their views, beliefs or way of life does not accord with the 'mainstream'. Yet in a democratic constitution founded on the rule of law, their rights are as sacred as those conferred on other citizens to protect their freedoms and liberties. Sexual orientation is an essential attribute of privacy. Discrimination against an individual on the basis of sexual orientation is deeply offensive to the dignity and self-worth of the individual.The above observations played a role in the judgment of the Supreme Court declaring Section 377 of the Indian Penal Code unconstitutional.


title: Dhananjaya Y. Chandrachud

text: He is also known for expressly overruling the ADM Jabalpur v. Shiv Kant Shukla (Habeas Corpus) case in which the lead opinion was written by his father - former chief justice of India Y. V. Chandrachud.


title: Dhananjaya Y. Chandrachud

text: Terming dissent as "the safety valve of democracy", he has authored judgments upholding the right to the freedom of speech in numerous cases. In Indibility Creative Pvt Ltd v State of West Bengal, he authored a judgment which imposed a fine on the State of West Bengal and granted remedial compensation for disallowing the screening of the political satire "Bhobishyoter Bhoot" through extra-constitutional measures. The Court had, by an interim order, directed that there must be no bar on the screening of the movie. In the final judgment, Chandrachud held that even if there was any apprehension of public discontent, police protection must be provided instead of prohibiting the display of the movie. The judgment is noteworthy for its recognition of the positive duty on the State to protect the freedom of speech and expression. He held that:Free speech cannot be gagged for fear of the mob…Political freedoms impose a restraining influence on the state by carving out an area in which the state shall not interfere. Hence, these freedoms are perceived to impose obligations of restraint on the state. But, apart from imposing 'negative' restraints on the state these freedoms impose a positive mandate as well. In its capacity as a public authority enforcing the rule of law, the state must ensure that conditions in which these freedoms flourish are maintained. In the space reserved for the free exercise of speech and expression, the state cannot look askance when organized interests threaten the existence of freedom. The state is duty bound to ensure the prevalence of conditions in which of those freedoms can be exercised. The instruments of the state must be utilized to effectuate the exercise of freedom.The judgment was reported for preventing the censorship of free speech and limiting its exceptions strictly to the grounds mentioned in Article 19(2) of the Constitution. In another occasion, he has given judgment against freedom of expression: in the UPSC Jihad case, "Your client is doing a disservice to the nation and is not accepting India is a melting point of diverse cultures. Your client needs to exercise his freedom with caution".


title: Dhananjaya Y. Chandrachud

text: In Romila Thapar & Ors. v. Union of India & Ors, Chandrachud dissented with the majority which refused to constitute a Special Investigation Team to probe the case concerning the arrest of five activists in connection with the 2018 Bhima Koregaon violence and held that in light of the particular circumstances of the case, the constitution of a Special Investigation Team was necessary to ensure a fair and impartial investigation.


title: Dhananjaya Y. Chandrachud

text: In Chief Election Commissioner of India v. M.R. Vijayabhaskar, Chandrachud upheld the freedom of speech and expression of the media in reporting court proceedings. In this case, the Election Commission of India sought restraint on the media from reporting oral observations of judges. The plea came in the context of media reports carrying observation of judges of the Madras High Court stating that the Election Commission was responsible for the second wave of COVID-19 pandemic in the country for allowing political parties to hold massive rallies without adhering to the COVID-19 protocols. Dismissing the plea, the Supreme Court held that the plea by the Election Commission "strikes at the two fundamental principles guaranteed under the Constitution – open court proceedings; and the fundamental right to freedom of speech and expression." The Court also recognised that reporting of judicial proceedings on social media is an extension of freedom of speech and expression that the media possesses.


title: Dhananjaya Y. Chandrachud

text: In the "suo motu" writ petition dealing with the management of the COVID-19 pandemic, Chandrachud criticized certain State Governments for clamping down on free speech of citizens when they sought help for resources online. During the second wave of the COVID-19 pandemic, many Indians resorted to social media websites to source medical aid - procure oxygen, essential drugs or locate a hospital bed. State Governments in a bid to control the information on the abysmal state of healthcare system in their territories started registering police complaints against persons for posting pleas of help by stating that these were fake and were a bid to create panic and diminish the national image. Coming down harshly against such tactics in open court, Chandrachud remarked that there could be no clampdown on free flow of information, especially during a humanitarian crisis. The Supreme Court's order directed all Director Generals of Police to note that any such direct or indirect threats of prosecution or arrest against persons who air their grievances will amount to a contempt of court and invite penal action.


title: Dhananjaya Y. Chandrachud

text: Chandrachud authored the judgment through which bail was granted to Arnab Goswami, the Editor In-Chief of Republic TV, who had been arrested by the Mumbai police in connection with a suicide of an individual and his mother, who claimed that Goswami had not paid him money which was owed for certain contract work. Through his judgment, Chandrachud noted that the High Court of Bombay had failed to "prima facie" evaluate whether a case of abetment of suicide was made against Goswami. Finding that "prima facie" no such offence was made out from the facts of the matter, the Supreme Court held that he would be entitled to bail. In an important section on "Human liberty and the role of Court", Chandrachud noted that it was important to ensure that criminal law did not become a tool for selective harassment of citizens. Underscoring the importance of bail, the Court held:


title: Dhananjaya Y. Chandrachud

text: "More than four decades ago, in a celebrated judgment in State of Rajasthan, Jaipur vs Balchand, Justice Krishna Iyer pithily reminded us that the basic rule of our criminal justice system is "bail, not jail'. The High Courts and Courts in the district judiciary of India must enforce this principle in practice, and not forego that duty, leaving this Court to intervene at all times. We must in particular also emphasise the role of the district judiciary, which provides the first point of interface to the citizen. Our district judiciary is wrongly referred to as the 'subordinate judiciary'. It may be subordinate in hierarchy but it is not subordinate in terms of its importance in the lives of citizens or in terms of the duty to render justice to them. High Courts get burdened when courts of first instance decline to grant anticipatory bail or bail in deserving cases. This continues in the Supreme Court as well, when High Courts do not grant bail or anticipatory bail in cases falling within the parameters of the law. The consequence for those who suffer incarceration are serious. Common citizens without the means or resources to move the High Courts or this Court languish as undertrials. Courts must be alive to the situation as it prevails on the ground – in the jails and police stations where human dignity has no protector. As judges, we would do well to remind ourselves that it is through the instrumentality of bail that our criminal justice system's primordial interest in preserving the presumption of innocence finds its most eloquent expression. The remedy of bail is the ―solemn expression of the humaneness of the justice system. Tasked as we are with the primary responsibility of preserving the liberty of all citizens, we cannot countenance an approach that has the consequence of applying this basic rule in an inverted form. We have given expression to our anguish in a case where a citizen has approached this court. We have done so in order to reiterate principles which must govern countless other faces whose voices should not go unheard."


title: Dhananjaya Y. Chandrachud

text: Further, the judgment, using publicly available data on the National Judicial Data Grid, also highlighted the number of pending bail applications throughout the country and directed the High Courts and lower Courts to use all tools at their disposal, including technology, to ensure that these applications are disposed off swiftly.


title: Dhananjaya Y. Chandrachud

text: In another case of "Rahna Jalal v. State of Kerala," Chandrachud dealt with the question of whether anticipatory bail can be granted to a person (Muslim man) accused of the offence of pronouncement of triple talaq to his wife, punishable under Section 4 of the Muslim Women (Protection of Rights on Marriage) Act 2019. Section 7(c) of the said Act provides that notwithstanding anything contained in the Code of Criminal Procedure 1973, no person accused of this offence would be granted bail, unless the Magistrate has heard the Muslim woman and is satisfied that there are reasonable grounds for granting bail to the accused. The State of Kerala argued that the non-obstante clause in Section 7(c) barred the courts from exercising their powers under Section 438 of the Code of Criminal Procedure to grant anticipatory bail.


title: Dhananjaya Y. Chandrachud

text: Rejecting this argument, Chandrachud observed that the right to personal liberty and the grant of bail is a recognition of presumption of innocence where a trial is yet to take place. Given the value of personal liberty, in the absence of an express bar by the Legislature making the provisions of Section 438 inapplicable, no such bar can be presumed. It was further reiterated that a statutory exclusion of the right to access remedies for bail is to be construed strictly.


title: Dhananjaya Y. Chandrachud

text: Chandrachud has authored several judgments on gender justice that call for a 'change in mindsets' as well as affirm the equal entitlements of women under the Constitution. In Indian Young Lawyers Association v. State of Kerala, he authored a concurring judgment holding that the practice of prohibiting women of menstruating age from entering the Sabarimala temple was discriminatory and violated the fundamental rights of women. In his judgment, he highlighted that "the individual right to the freedom of religion was not intended to prevail over but was subject to the overriding constitutional postulates of equality, liberty and personal freedoms recognised in the other provisions of Part III." He held that:The Court must lean against granting constitutional protection to a claim which derogates from the dignity of women as equal holders of rights and protections… Does the Constitution permit this as basis to exclude women from worship? Does the fact that a woman has a physiological feature – of being in a menstruating age – entitle anybody or a group to subject her to exclusion from religious worship? The physiological features of a woman have no significance to her equal entitlements under the Constitution… To exclude women is derogatory to an equal citizenship.The judgment was acknowledged for recognizing that denying entry into temples to women on the basis of physiology amounted to a constitutionally prohibited practice of untouchability under Article 17. He stated that "the social exclusion of women, based on menstrual status, is a form of untouchability, which is contrary to constitutional values. Notions of 'purity' and 'pollution', which stigmatise individuals, have no place in a constitutional order."


title: Dhananjaya Y. Chandrachud

text: Following protests against the judgment in the State of Kerala, a five judge bench of the Indian Supreme Court, while hearing a review petition against the judgment in November 2019, decided to refer the matter to a larger bench. Chandrachud and Nariman (who were both part of the original bench that passed the majority judgment) dissented and held that the parameters for the exercise of the review jurisdiction of the Court had not been met.


title: Dhananjaya Y. Chandrachud

text: In Joseph Shine v Union of India he authored a concurring judgment declaring the provision of the Indian Penal Code which concerned the adultery law in India unconstitutional. Emphasizing the constitutional commitment to equality and dignity, he held that:The creation of a just, egalitarian society is a process. It often involves the questioning and obliteration of parochial social mores which are antithetical to constitutional morality…The ability to make choices within marriage and on every aspect concerning it is a facet of human liberty and dignity which the Constitution protects… Implicit in seeking to privilege the fidelity of women in a marriage, is the assumption that a woman contracts away her sexual agency when entering a marriage. That a woman, by marriage, consents in advance to sexual relations with her husband or to refrain from sexual relations outside marriage without the permission of her husband is offensive to liberty and dignity. Such a notion has no place in the constitutional order. Sexual autonomy constitutes an inviolable core of the dignity of every individual.His concurring opinion was noticed for its emphasis on the sexual autonomy of women even within the bounds of a marital relationship. He held that:…. in adjudicating on the rights of women, the Court is not taking on a paternalistic role and "granting" rights. The Court is merely interpreting the text of the Constitution to re-state what is already set in ink — women are equal citizens of this nation, entitled to the protections of the Constitution. Any legislation which results in the denial of these Constitutional guarantees to women, cannot pass the test of Constitutionality.It is reported that the above observations have a significant bearing on the law employed for the restitution of conjugal rights as well as the exception carved out in law from criminalizing marital rape. Interestingly, this case was the second case where Chandrachud overruled a decision of his father, former Chief Justice of India Y. V. Chandrachud.


title: Dhananjaya Y. Chandrachud

text: In 2020, he authored two decisions in the realm of gender justice and the armed forces of the country. In The Secretary, Ministry of Defence v Babita Puniya he directed the government to consider all woman officers in the Army appointed on Short Service Commissions for the grant of Permanent Commissions on an equal basis with their male counterparts. The Union Government had contended that "women are not employed on duties which are hazardous in nature unlike their male counterparts in the same Arm/Service." It was also contended that the "inherent physiological differences between men and women preclude equal physical performances resulting in lower physical standards."


title: Dhananjaya Y. Chandrachud

text: In a section titled 'Stereotypes and women in the Armed Forces', he emphasized on the need for a change in mindsets and came down heavily on the submissions of the Union Government and held that:The submissions advanced…are based on sex stereotypes premised on assumptions about socially ascribed roles of gender which discriminate against women. Underlying the statement that it is a "greater challenge" for women officers to meet the hazards of service "owing to their prolonged absence during pregnancy, motherhood and domestic obligations towards their children and families" is a strong stereotype which assumes that domestic obligations rest solely on women. Reliance on the "inherent physiological differences between men and women" rests in a deeply entrenched stereotypical and constitutionally flawed notion that women are the "weaker" sex and may not undertake tasks that are "too arduous" for them. Arguments founded on the physical strengths and weaknesses of men and women and on assumptions about women in the social context of marriage and family do not constitute a constitutionally valid basis for denying equal opportunity to women officers…If society holds strong beliefs about gender roles – that men are socially dominant, physically powerful and the breadwinners of the family and that women are weak and physically submissive, and primarily caretakers confined to a domestic atmosphere – it is unlikely that there would be a change in mindsets.The judgment was reported internationally as well as in national media as a "landmark verdict ending gender bias" which is "against deeply embedded patriarchal mindsets and strong institutional biases." At the International Judicial Conference hosted by India on the 'Judiciary and the Changing World', which saw the participation of Chief Justices and judges from over 23 countries, the President of India welcomed the judgment and commended it for its "progressive social transformation"


title: Dhananjaya Y. Chandrachud

text: In 2021, the women who received the benefit of "Babita Puniya" contended that the Union Government applied a facially neural standard for their belated assessment for Permanent Commission, on medical standards that were applicable to men when they were 25–30 years old and by discounting their subsequent achievements. In granting relief to these women, he elaborated on the doctrine of systemic discrimination and indirect discrimination as a relevant framework for assessing claims of discrimination and structuring remedies. He noted:


title: Dhananjaya Y. Chandrachud

text: "Indirect discrimination is caused by facially neutral criteria by not taking into consideration the underlying effects of a provision, practice or a criterion….. Exclusive reliance on tools of direct or indirect discrimination may also not effectively account for patterns arising out of multiple axles of discrimination. Therefore, a systemic view of discrimination, in perceiving discriminatory disadvantage as a continuum, would account for not just unjust action but also inaction. Structures, in the form of organizations or otherwise, would be probed for the systems or cultures they produce that influence day-to-day interaction and decision making"


title: Dhananjaya Y. Chandrachud

text: The judgement was hailed internationally, nationally and by scholars for broadening the horizons of Indian jurisprudence on Article 14 and 15(1) of the Indian Constitution.


title: Dhananjaya Y. Chandrachud

text: A short time after "Babita Puniya", he authored the judgment in Union of India v Ld. Cdr. Annie Nagaraja wherein the Court directed a similar relief to be granted to women sailors in the Indian Navy. The Court noted the submission of the Union Government that "certain avenues such as sea-sailing duties are ill-suited for women officers as there is no return to the base" and that "Navy ships of today are not structured nor have the infrastructure to accommodate women sailors alongside men sailors" and rejected these submissions as "illusory and without any foundation". The judgment received similar international attention and was widely reported upon in national media.


title: Dhananjaya Y. Chandrachud

text: Recently, he authored a judgment which affirmed that sexual harassment at the workplace violates the fundamental rights of women guaranteed under the Indian Constitution. The verdict was based on a complaint made by a senior officer of the Punjab and Sind Bank that she was transferred out from Indore to Jabalpur because she had complained about irregularities and corruption. The woman, a chief manager and Scale IV officer, said she was also allegedly sexually harassed by her senior officer. He held that:Sexual harassment at the workplace is an affront to the fundamental rights of a woman to equality under Articles 14 and 15 and her right to live with dignity under Article 21 of the Constitution as well as her right to practice any profession or to carry on any occupation, trade or business… There can be no manner of doubt that the respondent (woman officer) has been victimized. This is symptomatic of a carrot and sticks policy adopted to suborn the dignity of a woman who is aggrieved by unfair treatment at her workplace. The law cannot countenance this. The order of transfer was an act of unfair treatment and is vitiated by malafides.He directed the bank to send the woman employee back to the Indore branch and held that the bank may pass any other order only after she has completed a tenure of one year at the Indore branch.


title: Dhananjaya Y. Chandrachud

text: On April 27, 2021, he authored a judgement which considered caste and the disability of the woman as a relevant factor in sentencing of the accused for the offence of rape. The judgement further held that a true reading of the SC & ST Act, 1989 shows that it will be attracted to a criminal offence as long as caste identity is one of the grounds for the occurrence of the offence. This was an important intervention since certain earlier Supreme Court cases had held that a SC & ST Act would only be attracted if the crime was committed solely on the ground that the victim belonged to the Scheduled Caste or Scheduled Tribe community.


title: Dhananjaya Y. Chandrachud

text: Chandrachud undertook an intersectional analysis to examine how gender violence can be a result of combination of various oppressions and observed that, "[w]hen the identity of a woman intersects with, "inter alia", her caste, class, religion, disability and sexual orientation, she may face violence and discrimination due to two or more grounds. Transwomen may face violence on account of their heterodox gender identity. In such a situation, it becomes imperative to use an intersectional lens to evaluate how multiple sources of oppression operate cumulatively to produce a specific experience of subordination for a blind Scheduled Caste woman."


title: Dhananjaya Y. Chandrachud

text: He further criticised single axis legislations which focus on oppression on account of a singular source, be it caste, gender or disability, noting that they make invisible the experiences of minorities within these broader groups who suffer on account of multiple oppressions. Further, he also noted that such legislations impose an unrealistic evidentiary burden on individuals who are at the intersection of various marginalized identities since "evidence of discrete discrimination or violence on a specific ground may be absent or difficult to prove". He noted that the 2015 amendment to the SC & ST Act, which changed the evidentiary requirement of proving that the crime was committed on the basis of the caste identity to a standard where knowledge of the caste identity was sufficient to sustain a conviction, was a positive development and enabled an intersectional analysis of caste violence.


title: Dhananjaya Y. Chandrachud

text: Another significant aspect of this judgement was the holding of the Court that testimony of a disabled witness cannot be considered weaker or inferior to their able-bodied counterparts. Chandrachud also issued certain guidelines to make the criminal justice system more disabled-friendly.


title: Dhananjaya Y. Chandrachud

text: One of Chandrachud's significant opinions in the sphere of environmental law is his judgment in Hanuman Laxman Aroskar vs Union of India. A challenge was brought before the Supreme Court against the order of the National Green Tribunal upholding the grant of an Environmental Clearance to a proposed greenfield international airport at Mopa in Goa. A myriad of contentions were urged by the appellants questioning the grant of the clearance, which included the failure to make disclosures on forests and Ecologically Sensitive Zones as well as a faulty appraisal process and the use of erroneous sampling points. The Court observed the numerous deficiencies in the process leading to the grant of the clearance and directed that a rapid EIA be conducted afresh by the project proponent. The Court highlighted that compliance with the core governing notification is mandatory in the following terms:The 2006 notification represents an independent code with the avowed objective of balancing the development agenda with the protection of the environment. An applicant cannot claim an EC, under the 2006 notification, based on substantial or proportionate compliance with the terms stipulated in the notification. The terms of the notification lay down strict standards that must be complied with by an applicant seeking an EC for a proposed project. The burden of establishing environmental compliance rests on a project proponent who intends to bring about a change in the existing state of the environment… There can be no gambles with the environment: a 'heads I win, tails you lose' approach is simply unacceptable; unacceptable if we are to preserve environmental governance under the rule of law.The judgment has expounded on the concept of the 'environmental rule of law' as a groundwork for the protection of the environment. The judgment was also welcomed by the United Nations Environment Program. In a separate section titled the 'Environmental Rule of Law', the Court drew from vast literature on environmental law which included the UN Sustainable Development Goals and the work of Amartya Sen and Dhvani Mehta to draw a link between the protection of the environment and the right to life under Article 21 of the Indian Constitution.


title: Dhananjaya Y. Chandrachud

text: In Bangalore Development Authority v Mr Sudhakar Hegde, he authored a judgment directing the appellant to conduct a rapid EIA as a result of the numerous deficiencies in the process leading up to the grant of Environmental Clearance. The Court noted the "patent contradiction" in disclosing the existence of forest land to be diverted for the project connecting Tumkur Road to Hosur Road. In a section titled 'Courts and the Environment', he highlighted the importance of a broad-based approach to the protection of the environment in the following terms:The protection of the environment is premised not only on the active role of courts, but also on robust institutional frameworks within which every stakeholder complies with its duty to ensure sustainable development. A framework of environmental governance committed to the rule of law requires a regime which has effective, accountable and transparent institutions. Equally important is responsive, inclusive, participatory and representative decision making. Environmental governance is founded on the rule of law and emerges from the values of our Constitution. Where the health of the environment is key to preserving the right to life as a constitutionally recognized value under Article 21 of the Constitution, proper structures for environmental decision making find expression in the guarantee against arbitrary action and the affirmative duty of fair treatment under Article 14 of the Constitution.Chandrachud has also authored a judgment on the validity of grating "ex post facto" Environmental Clearances in Alembic Pharmaceuticals Ltd v Rohit Prajapati. The erstwhile Ministry of Environmental and Forests had issued an administrative circular in 2002 envisaging the grant of "ex post facto" clearances to those industries that had failed to comply with the mandatory EIA notification of 1994. The ex post facto clearances granted to a group of drug and pharmaceutical companies located in Gujarat were challenged. Chandrachud set aside the administrative circular of 2002 and noted that the concept of "ex post facto" ECs derogates from the fundamental principles of the environmental rule of law. He noted that the grant of "ex post facto" ECs was contrary to both the precautionary principle as well as the principal of sustainable development. Chandrachud noted that all the industries in question had made significant infrastructural investments. In this backdrop, he imposed a fine of Rs 10 crores each for the purpose of restitution and restoration of the environment. He held:Requirements such as conducting a public hearing, screening, scoping and appraisal are components of the decision-making process which ensure that the likely impacts of the industrial activity or the expansion of an existing industrial activity are considered in the decision-making calculus. Allowing for an ex post facto clearance would essentially condone the operation of industrial activities without the grant of an EC. In the absence of an EC, there would be no conditions that would safeguard the environment. Moreover, if the EC was to be ultimately refused, irreparable harm would have been caused to the environment. In either view of the matter, environment law cannot countenance the notion of an ex post facto clearance. This would be contrary to both the precautionary principle as well as the need for sustainable development.


title: Dhananjaya Y. Chandrachud

text: In a recent judgment in Himachal Pradesh Bus Stand Management and Development Authority v. The Central Empowered Committee, Chandrachud directed the demolition of a Hotel-cum-Restaurant structure in the Bus Stand Complex in McLeod Ganj, Himachal Pradesh, which had been constructed in violation of permissions granted under the various environmental laws. The construction of the structure had been in dispute for nearly 14 years, before it was finally resolved through this judgment. Developing on the concept of environmental rule of law propounded by him in Hanuman Laxman Aroskar v Union of India, he discussed how actual implementation may suffer from lack of access to scientific data to ascertain concrete harm. However, he held:


title: Dhananjaya Y. Chandrachud

text: "The environmental rule of law calls on us, as judges, to marshal the knowledge emerging from the record, limited though it may sometimes be, to respond in a stern and decisive fashion to violations of environmental law. We cannot be stupefied into inaction by not having access to complete details about the manner in which an environmental law violation has occurred or its full implications. Instead, the framework, acknowledging the imperfect world that we inhabit, provides a roadmap to deal with environmental law violations, an absence of clear evidence of consequences notwithstanding."


title: Dhananjaya Y. Chandrachud

text: In the wake of the pandemic, Chandrachud judicially reviewed a decision of the State of Gujarat to suspend some provisions of overtime pay, work intervals, working hours and other labour protections by resorting to Section 5 of the Factories Act, 1948 by terming it an 'emergency therein'. In tightly interpreting the scope of Section 5, which envisaged suspension of protections only when the 'public emergency threatens the security of the state', Chandrachud warned against "rendering hard-won protections of the Factories Act, 1948 illusory and the constitutional promise of social and economic democracy into paper-tigers."


title: Dhananjaya Y. Chandrachud

text: In addition to its contribution on labour jurisprudence and the interpretation of directive principles of state policy, the judgement was also hailed for critically examining executive actions, which were otherwise given a wide leeway during the COVID-19 pandemic.


title: Dhananjaya Y. Chandrachud

text: Chandrachud was a part of the seven-judge bench in Krishna Kumar Singh v. State of Bihar, which concerned the re-promulgation of ordinances. The enduring rights theory, according to which the rights and liabilities accrued by virtue of an ordinance were said to have an enduring effect even after the expiration of the ordinance was held bad in law. Chandrachud writing for the majority held that the rights and liabilities accrued during the force of the ordinance would continue to exist even after the expiration of the ordinance only in public interest or on the basis of constitutional necessity and that 'irreversibility' and 'impracticability' are the yardsticks to determine what constitutes 'public interest'. He observed:The Constitution bench equated an ordinance with a temporary act enacted by the competent legislature. This approach, with respect fails to notice the critical distinction between an enactment of a competent legislature and an ordinance. Acceptance of the doctrine of enduring rights in the context of an ordinance would lead to a situation where the exercise of power by the Governor would survive in terms of the creation of the rights and privileges…The legislature may not have had an opportunity to even discuss or debate the Ordinance…. The enduring rights theory attributes a degree of permanence to the power to promulgate ordinances in derogation of parliamentary control and supremacy.He also observed that laying down ordinances before the Parliament is a mandatory constitutional obligation that cannot be bypassed. The judgment was recognised for expanding the grounds of judicial review of an ordinance and limiting the scope of the "mala fide" exercise of ordinance promulgation.


title: Dhananjaya Y. Chandrachud

text: Chandrachud was part of the constitution bench in National Capital Territory v. Union of India, in which the nature of power of the Lieutenant Governor of Delhi vis-à-vis the Government of Delhi was decided. The majority unanimously observed that the Chief Minister, not the Lieutenant Governor, is the executive head of the territory and that the Lieutenant Governor had no independent decision-making power, save and except as provided by the Constitution in exceptional situations. It was observed that he had to follow the aid and advice of the Council of Ministers, except when the matter was related to police, public order and land. It was also held that by virtue of Article 239AA(4) of the Indian Constitution, the Lieutenant Governor could, in the case of any disagreement between the Delhi Government and the Lieutenant Governor, refer 'exceptional' matters to the President seeking his opinion. In such cases, the decision of the President would be final. Chandrachud's concurring opinion which was commented upon for its clarity and nuance, held that an 'exceptional matter' is one in which "the Government of the NCT is likely to impede or prejudice the exercise of the executive power of the Union Government". Chandrachud emphasized on the obligation of the Lieutenant Governor to abide by the aid and advice of the Delhi Government and observed that the interpretation that aids the basic features of representative governance and the cabinet form of government should be adopted. He held:…in defining the ambit of the constitutional powers entrusted to the Council of Ministers for the NCT and their relationship with Lieutenant Governor as a delegate of the President, the Court cannot be unmindful of the constitutional importance which has to be assigned to representative government. Representative government is a hallmark of a Constitution which is wedded to democracy for it is through a democratic form of governance that the aspirations of those who elect their representatives are met.


title: Dhananjaya Y. Chandrachud

text: Chandrachud authored a judgment with far reaching consequences in the political sphere in Shivraj Singh Chouhan. v. Speaker, Madhya Pradesh Legislative Assembly. Chandrachud held that the Governor's exercise of power to convene the legislative assembly for a floor test during an ongoing session of the assembly was "legitimate to the purpose of ensuring that the norm of collective responsibility is duly preserved". He accepted the submission that the Governor commands the power to order a floor test if the Governor has – based on "objective material" – reasons to believe that the government has lost its majority. Significantly, he noted that the power of the Governor is not unbridled in the following terms:Where the exercise of the discretion by the Governor to call a floor test is challenged before the court, it is not immune from judicial review. The court is entitled to determine whether in calling for the floor test, the Governor did so on the basis of objective material and reasons which were relevant and germane to the exercise of the power. The exercise of such a power is not intended to destabilize or displace a democratically elected government accountable to the legislative assembly and collectively responsible to it.In a first of its kind observation, Chandrachud also noted the state of politics in the country and called for changes to strengthen the nature of the Indian democratic system in the following terms:The spectacle of rival political parties whisking away their political flock to safe destinations does little credit to the state our democratic politics. It is an unfortunate reflection of the confidence which political parties hold in their own constituents and a reflection of what happens in the real world of the politics to lure away persons from rival camps… It is best that courts maintain an arm's length from the sordid tales of political life. In defining constitutional principle, however, this Court must be conscious of the position on the ground as admitted by Counsel of both sides and an effort has to be made to the extent possible to ensure that democratic values prevail.


title: Dhananjaya Y. Chandrachud

text: Chandrachud authored a judgment in The State of Jharkhand v. Brahmputra Metallics Limited, where at issue was a notification issued by the State of Jharkhand under which the electricity rebate under the Industrial Policy of 2012 was granted only from 2015 onwards. While the High Court of Jharkhand had struck down the notification based on the doctrine of promissory estoppel, Supreme Court's judgment, through an analysis of English and Indian law, clarified that its basis would instead be the doctrine of legitimate expectation. The Court held that the doctrine of legitimate expectations was one of the ways in which the guarantee of non-arbitrariness enshrined under Article 14 of the Constitution of India finds concrete expression. In striking down the notification, Chandrachud came down harshly on the lethargic attitude of the State of Jharkhand in belatedly issuing the notification and held:


title: Dhananjaya Y. Chandrachud

text: "It is one thing for the State to assert that the writ petitioner had no vested right but quite another for the State to assert that it is not duty bound to disclose its reasons for not giving effect to the exemption notification within the period that was envisaged in the Industrial Policy 2012. Both the accountability of the State and the solemn obligation which it undertook in terms of the policy document militate against accepting such a notion of state power. The state must discard the colonial notion that it is a sovereign handing out doles at its will. Its policies give rise to legitimate expectations that the state will act according to what it puts forth in the public realm. In all its actions, the State is bound to act fairly, in a transparent manner. This is an elementary requirement of the guarantee against arbitrary state action which Article 14 of the Constitution adopts. A deprivation of the entitlement of private citizens and private business must be proportional to a requirement grounded in public interest."


title: Dhananjaya Y. Chandrachud

text: During the second wave of the COVID-19 pandemic in India in April 2021, a bench of the Supreme Court of India headed by the then Chief Justice SA Bobde, Justice LN Rao and Justice S Ravindra Bhat, took "suo motu" cognizance of the situation in the country to deal with issues pertaining to availability of oxygen supply, essential drugs and modalities for vaccination. After the retirement of Chief Justice Bobde on 23 April 2021, the bench composition was altered with Chandrachud replacing Chief Justice Bobde.


title: Dhananjaya Y. Chandrachud

text: The Supreme Court bench led by Chandrachud highlighted that the exercise of its "suo motu" jurisdiction was to discharge its constitutional duty as protector of the fundamental rights during a pandemic, along with the High Courts and not in usurpation of their jurisdiction. Additionally, the bench adopted a bounded-deliberative approach to facilitate dialogue between the Union Government, various State Governments and the relevant stakeholders in order to assess the policy of the Union Government on the touchstone of Article 14 (right to equality) and Article 21 (right to life) of the Constitution of India. Through a series of directions, the Supreme Court directed the Union Government to formulate a national hospital admission policy to ensure no person is denied medical aid on grounds of non-residency in a particular State and raised concerns regarding the augmentation of medical oxygen available and steps taken by the Government. Pertinently, the Supreme Court had made critical observations on the Liberalised Vaccination Policy of the Government of India and noted that the vaccination policy of free vaccination for persons above the age of 45 and paid vaccination for persons between 18 and 44 years was "prima facie" arbitrary and irrational. The court also sought justification for the decentralised procurement leaving the State Governments to approach global vaccine producers, instead of the Union of India acting collectively; concerns regarding augmentation of vaccine production, issues relating to the modality of vaccination through the use of a digital platform, CoWIN given the digital divide in urban and rural India. In light of these issues, the Union Government was directed to provide justifications or revise its policy.


title: Dhananjaya Y. Chandrachud

text: A week after the Supreme court order, the Narendra Modi led Government revised its vaccination policy, centralising its procurement and providing free vaccination to all adults, including between ages 18–44 years. It is widely believed that the change in the vaccination policy was a result of the continuous engagement of the Supreme Court with the Government and its scathing remarks against the Government's vaccination policy.


title: Dhananjaya Y. Chandrachud

text: Chandrachud has authored numerous judgments on affirmative action in India. Foremost amongst these is his judgment in B.K. Pavitra II v. Union of India, where he upheld the constitutional validity of the Karnataka Extension of Consequential Seniority to Government Servants Promoted on the Basis of Reservation (to the Posts in the Civil Services of the State) Act 2018. The Act concerned the grant of consequential seniority to candidates appointed on the basis of reservation. The judgment was recognised for undertaking a critical and nuanced analysis that weighs towards an inclusive definition of 'efficiency' and consequently 'merit', - one that is consistent with the principle of substantive equality, as opposed to formal equality. Drawing on the work of Amartya Sen, he held that:A meritocratic system is one that rewards actions that result in the outcomes that we as a society value…Thus, the providing of reservations for SCs and the STs is not at odds with the principle of meritocracy. "Merit" must not be limited to narrow and inflexible criteria such as one's rank in a standardised exam, but rather must flow from the actions a society seeks to reward, including the promotion of equality in society and diversity in public administration.In Chairman and managing director, Food Corporation of India v Jagdish Balaram Bahira, Chandrachud affirmed the principle that a person who receives the benefit of public employment on the basis of a false caste certificate is not entitled to protection in exercise of the equitable power conferred upon Courts. Chandrachud held that the "withdrawal of civil benefits flowed as a logical result of the validation of a claim to belong to a group or category for whom the reservation is intended" and that "the selection of ineligible persons is a manifestation of a systematic failure and has deleterious effects on good governance." Observing that the governing state legislation explicitly specified the consequences of relying upon a false caste certificate, the Court held that recourse to the inherent powers of the Supreme Court under Article 142 would not be justified. In the same vein, Chandrachud observed that where there was a statutory bar to conferring benefits on the basis of a false certificate, administrative circulars and government resolutions, being subservient to legislative mandate, would not be permitted to cure the defect of a false caste certificate.


title: Dhananjaya Y. Chandrachud

text: In Vikash Kumar v. Union Public Service Commission, Chandrachud elaborated on the concept of reasonable accommodation under the Rights of Persons with Disabilities Act, 2016. In the case, an appellant, who was a civil servant aspirant, suffered from writer's cramp. His application for writing the exam with the assistance of a scribe was rejected by the UPSC as he did not have a benchmark disability under the Act. Chandrachud while allowing the petition held that the concept of reasonable accommodation is at the heart of the Act. It is a positive obligation of the State and private parties to provide additional support to persons with disabilities to ensure their participation in the society. He further held that disability is a social construct which has to be remedied by ensuring conditions that facilitate development of the disabled and must meet the needs of every individual disabled person. Chandrachud also stressed on the intersectional nature of disability based discrimination. In doing so, he held that a previous decision of the Supreme Court in V. Surendra Mohan v. Tamil Nadu, where the Court refused to allow a visually disabled person from becoming a judicial officer, did not incorporate the principle of reasonable accommodation as it was rendered under the old Persons with Disabilities (Equal Opportunities, Protection of Rights and Full Participation) Act 1995 and would no longer be a binding precedent.


title: Dhananjaya Y. Chandrachud

text: Chandrachud has also authored opinions in several commercial disputes and emphasized the principles of certainty and objectivity in the area of commercial law. He rejected the challenge by Adani Gas Limited to the grant of authorisations for the construction and operation of consumer gas distribution networks in the state of Tamil Nadu. The dispute concerned the alleged addition of certain bidding criteria "after the last date for bidding". In upholding the decisions taken by the Petroleum and Natural Gas Regulatory Board, Chandrachud noted that the additional criteria had only been proposed by the regulator as an agenda item, but was never subsequently adopted. He also observed that when a tender is challenged by a bidder, the dispute remains solely between the bidder and the regulator, and the regulator's treatment of other bids that have no bearing on the disputed bid cannot be used to allege a case of arbitrariness against the regulator's actions.


title: Dhananjaya Y. Chandrachud

text: Chandrachud also authored a judgment governing the liquidation of Super Bazar. The once-iconic Co-Operative Society had fallen on hard times and Writers and Publishers had won the bid to revive Super Bazar under a court regulated recovery scheme. However, an audit by the Comptroller and Auditor General of India found several accounting irregularities in the management of Super Bazar by Writers and Publishers. Chandrachud's judgment held that it would be against the first principles of insolvency if a resolution applicant were to be refunded their investment after a failed revival effort. His opinion directed that Super Bazar's assets be handed over to the official liquidator and disposed of in accordance with the statutory order of preferences.


title: Dhananjaya Y. Chandrachud

text: Chandrachud has authored opinions regarding the interpretation of insurance contracts. In one such decision, a claim was filed by the wife of the deceased who while riding his motorcycle, experienced pain in the chest and shoulder, suffered a heart attack and fell from the motorcycle. Chandrachud discussed extensively the jurisprudence on insurance law in various jurisdictions, dealt with the interpretation of the expressions 'accident', 'bodily injury' and 'outward, violent and visible means'. He rejected the claim noting that there is no evidence to show that any bodily injuries were suffered due to the fall from the motorcycle or that it led to the assured suffering a heart attack.


title: Dhananjaya Y. Chandrachud

text: In another decision, Chandrachud relied on the doctrine of "uberrimae fidei" and held that any suppression, untruth or inaccuracy in the statement in the proposal form by the insured is a breach of the duty of good faith and will render the policy voidable by the insurer. Chandrachud noted that the system of adequate disclosures helps to narrow down the gap of information asymmetries between the parties and helps the insurers to assess their risk appetite. He held:Proposal forms are a significant part of the disclosure procedure and warrant accuracy of statements. Utmost care must be exercised in filling the proposal form. In a proposal form the applicant declares that she/he warrants truth. The contractual duty so imposed is such that any suppression, untruth or inaccuracy in the statement in the proposal form will be considered as a breach of the duty of good faith and will render the policy voidable by the insurer. The system of adequate disclosure helps buyers and sellers of insurance policies to meet at a common point and narrow down the gap of information asymmetriesIn a judgment reported in national media, Chandrachud dealt with the question of whether a death caused due to malaria occasioned by a mosquito bite constituted a 'death due to accident' covered under the terms of an insurance policy. He rejected the contention that being bitten by a mosquito is an unforeseen eventuality and should be regarded as an accident. Chandrachud noted the distinction between the occurrence of a disease which may be considered as an accident and a disease which occurs in the natural course of events. He referred to the World Health Organization's World Malaria Report 2018 and noted that in a country severely afflicted with Malaria, the mosquito bite was neither unexpected nor unforeseen and therefore, death caused by a mosquito bite would not be covered by the insurance policy.


title: Dhananjaya Y. Chandrachud

text: Chandrachud has recently authored key judgments in relation to the Insolvency and Bankruptcy Code, 2016. In Phoenix Arc Private Limited v. Spade Financial Services Limited, the issue before the Supreme Court was whether entities who may have been related parties of a corporate debtor at the time of acquiring of a financial debt, but are no longer related parties, can be excluded from the Committee of Creditors. In taking a purposive approach to the issue, Chandrachud looked at the objects of the Insolvency Code and highlighted the importance of checking on actions where the "related party financial creditor devises mechanism to remove its label of a 'related party' before the Corporate Debtor undergoes CIRP, so as to be able to enter the CoC and influence its decision making at the cost of other financial creditors."


title: Dhananjaya Y. Chandrachud

text: Further, Chandrachud also held that "collusive transactions" between two parties would not give rise to "financial debt" for the purposes of Insolvency Code, since the nature of transaction needs to be ascertained to ensure that parties do not collude to the detriment to legitimate creditors. In Ramesh Kymal v. M/S. Siemens Gamesa Renewable Power Private Limited, Justice Chandrachud clarified that the ordinance suspending applications under the Corporate Insolvency Resolution Process after 25 March 2020, in accordance with Section 10A of the Insolvency Code, which had been introduced on 5 June 2020, would also affect any pending application that had been filed after 25 March 2020, since that was consciously the cut-off date chosen by the Parliament.


title: Dhananjaya Y. Chandrachud

text: Chandrachud delivered a significant judgment in Gujarat Urja Vikas Nigam Limited v. Amit Gupta, where the termination of a Power Purchase Agreement with the corporate debtor, solely on account of its insolvency, was under challenge. The judgment clarified the jurisdiction of the National Company Law Tribunal and National Company Law Appellate Tribunal by holding that their jurisdiction is limited to adjudicating disputes which arise solely from or which relate to the insolvency of the Corporate Debtor. It also analysed the validity of "ipso facto" clauses in contracts, which allow termination solely on a party entering insolvency proceedings, across international materials and other jurisdictions. Noting that the validity of such clauses was unclear in India, the judgment resorted to dialogical remedy to direct the Parliament to provide legislative guidance. In the present case, however, the Supreme Court noted that the Power Purchase Agreement was the sole contract of the corporate debtor and held: