Policy Analysis

The Homoeopathy Central Council Amendment Ordinance, 2021


Author: Aparna Bhatnagar, 1st year student at Maharashtra National Law University, Mumbai.

Introduction

“One of the most striking features of unorthodox, or complementary and alternative medicine (CAM)”, writes Irvine Loudon, “has been its ability to survive for centuries in a very wide variety of forms.”[1] The birth of Homeopathy, one of the most popular Complementary and Alternative Medicines, can be traced back to Meissen, Germany in the late eighteenth century. Samuel Hahnemann, the father of modern Homeopathy, devised a novel field of medicine based on principles such as similia similibus curentur­– ‘like cures like’.[2] Since its advent in the Indian subcontinent in the early 19th century, homeopathy flourished in Bengal under Mahendra Lal Sircar, the first Indian to become a homeopathic physician.[3] The field gradually gained popularity owing to its easy access, economical costs and holistic approach. In India, the field is rising exponentially by 25% each year, with more than 100 million people relying completely on it for their medical treatment. [4]

In light of this, the Homoeopathy Central Council (Amendment) Ordinance, 2021, promulgated on May 16, 2021 must be analyzed meticulously. The ordinance, which amends the Homoeopathy Central Council Act, 1973 to extend the period of reconstitution of Central Council from three years to four  years, has been both critiqued and advanced by various academics and policy experts. The aim of this article, therefore, is to describe, analyze, and present recommendations to contribute to better implementation.

A Wave of Amendments

A deeper study into the trends of homeopathy legislation in India inevitably leads one to trace its history. The present ordinance relates to a series of amendments brought forth by the government to reconstitute the Central Council and introduce a multitude of institutional changes.

The Homeopathy Central Council Act, 1973

The main purpose behind the legislation of The Homoeopathy Central Council Act, 1973 was to establish the Central Council of Homeopathy, and to provide for the upkeep and administration of the Central Register of Homeopathy.

The Act was amended in 2002 to make provisions and seek permission from the central government for the setting up of new colleges or starting new courses or increasing the admissions in the existing colleges.[5] The Council was conferred the powers to prescribe and recognize all homeopathic medicine qualifications. The Council, apart from maintaining the Central Register of Homoeopathy, was also given the authority to appoint examiners and visitors to inspect facilities.[6] The Central Council of Homoeopathy (CCH) was established to regulate homoeopathy colleges in India. This statutory apex body was envisioned to prescribe course curriculum, evolve standards of education, and maintain central registers of homoeopathy physicians.

The Homeopathy Central Council (Amendment) Bill, 2018

The Homoeopathy Central Council (Amendment) Bill, 2018 replaced an ordinance brought by the government and provided for supersession of the Central Council of Homeopathy and the constitution of a Board of Governors in order to ‘overcome the irregularities in the Council’.[7]

The statement of objects and reasons of the Bill referred to instances of serious malpractices within the Council, leading to a compromise in the quality of medical education. This was widely believed to be in reference to the CBI arrest of Central Council of Homeopathy President Ramjee Singh on charges of accepting bribes to deliver a favourable inspection report for setting up of a homeopathy college.[8] The statement also pointed out the Council’s efforts to obstruct the Central government’s move to streamline its functioning.

The Bill provided the Central Council to be reconstituted within one year from the date of its supersession, and the Central government was conferred the power to constitute a Board of Governors which would exercise powers of the Central Council in the interim period.

It also called for the formation of a national commission with three autonomous bodies to oversee the Homoeopathy Education Board’s functioning and providing of homoeopathic education. The Board of Assessment and Rating would be given the authority to evaluate and issue approval to Homoeopathic educational institutions, while the Board of Ethics and Registration of Homoeopathic Practitioners would keep a nationwide register. All ethical issues relating to practice would now fall under the National Commission for Homoeopathy in a move to curb the malpractices of the Council.

Furthermore, the Bill recommended mandatory practising licences as well as a teacher eligibility test to evaluate teachers prior to their appointment and promotions. Finally, the Bill attempted to modify homoeopathic clinical training in accordance with the National Medical Commission’s proposal to establish an allopathic medical system.[9]

The Homeopathy Central Council (Amendment) Bill, 2019

The Homoeopathy Central Council (Amendment) Bill, 2019, introduced in the Lok Sabha by Shripad Yesso Naik (Minister of State for the Ministry of AYUSH), allowed the government to prolong the Board of Governors’ tenure for another year, with effect from May 17, 2019.

The Bill replaced the ordinance issued in the same regard by the previous government. It further provided the Board of Governors to comprise renowned homoeopathic doctors, as well as eminent administrators.

The Homeopathy Central Council (Amendment) Bill, 2020

The Homoeopathy Central Council (Amendment) Bill, 2020 was introduced in Rajya Sabha on September 14, 2020, replacing the Homoeopathy Central Council Amendment) Ordinance, 2020, promulgated on April 24.

The Bill amended the Homoeopathy Central Council Act, 1973 to further extend the time to form the Central Council of Homeopathy by another year, after exhausting two years for the purpose. This was due to the failure of the council to reassemble within a year following its dissolution.  In the interim period, the Centre established a board of governors to perform the functions of the council. The 2020 Bill sought to amend the Act to extend the council’s supersession term from two to three years.

The Bill was passed alongside the sister legislation of The Indian Medicine Central Council (Amendment) Bill, 2020. The IMCC Bill, in a similar fashion, amended the Indian Medicine Central Council Act, 1970. It stipulated for the establishment of a central body to oversee the practice and education of Indian medicine (such as ayurveda, yoga, naturopathy). The council would be reestablished in the first year after its dissolution, according to the proposal. In the meantime, the Centre would appoint a board of governors to implement the council’s powers.[10]

Homoeopathy Central Council (Amendment) Ordinance, 2021

The latest executive action on this issue is the promulgation of the Homoeopathy Central Council (Amendment) Ordinance, 2021 on May 16, 2021. The ordinance once again amends the Homoeopathy Central Council Act, 1973 in order to modify the period of reconstitution of Central Council from three years to four  years.

The Amendment states- “3-A. Power of Central Government to supersede Central Council and to constitute a Board of Governors– The Central Council shall be reconstituted in accordance with the provisions of Section 3 [within a period of four years] from the date of supersession of the Central Council under sub-section (1).”[11]

Unearthing the Intent

The Statement of Objects and Reasons of The Homoeopathy Central Council (Amendment) Bill, 2020 throws some light on the legislative intent behind the current ordinance.

Point two states that as the Central Council of Homoeopathy had failed in its responsibilities and not cooperated wilfully with the Central Government in adhering to its duties in the manner required to safeguard the standards of education and practice of Homoeopathy, the Amendment to the Homoeopathy Central Council Act, 1973 was brought in to empower the Central Government to supersede the Central Council of Homoeopathy and to constitute the Board of Governors to execute the functions and undertake the duties of the Central Council. However, legislator Prof. Manoj Kumar Jha has contended that the statement provides a ‘sweeping denigration’ of the previous structures and processes.[12]

The Statement of Objects and Reasons also provides reasons for the delay in reconstituting the Central Council of Homoeopathy, stating that could not be reconstituted within a period of one year as the State Registers of Homoeopathy were not updated for conducting elections to elect members to the Central Council. Therefore, the Central Council’s reconstitution term was increased from one year to two years.

Thirdly, it states that the supersession of the Central Council of Homoeopath was done in order to streamline the working of the Central Council on membership-related issues, for bringing accountability and transparency in the granting permission to colleges and practice of Homoeopathy and improving the standards in medical education.

The statement provides that the Central Council of Homoeopathy could not be reconstituted within an extended period of two years since Central Council was in the process of conducting inspections for the academic year 2020-21. Additionally, the Parliament was not in session and there was a need for urgent legislation, the Homoeopathy Central Council (Amendment) Ordinance, 2020 (Ord. 6 of 2020) was promulgated by the President on the 24th April, 2020.

Explaining the government’s intent in the House of the People, Dr. Vikas Mahatme stated the 2018 Bill was born out of the recommendations by a committee headed by Dr. Aravind Panagariya.[13] The Bill sought to rectify the many errors of the 1970 and the 1973 Bill. First, the mandate of the Bill was to establish a uniform standard of education. However, the Bill failed to take cognisance of the varying modes of homeopathy followed in various parts of the country, making a standardised education a mammoth task. It is for this reason that the 2018 ordinance was brought in. Second, the lack of registration among the homeopathy practitioners, leading to mushrooming of unlicensed and potentially dangerous practitioners was a major concern. Third, the lack of recognition to homeopathy institutes and colleges led to appalling infrastructure and reduced quality of education. Fourth, the sole presence of representatives from the medical profession in the Central Council led to the underrepresentation of the interests of patients. Fifth, the conflict of interest arising from the membership of college heads in the Council that undertook inspection led to ethical issues.

The election of new members to the Council was dependent on the registration of eligible persons. However, due to lack of adequate registrations, the pool of persons eligible for the elections was narrow and repetitive. Since the work of registrations, which is undertaken by State bodies, was not completed on time, the Dr. Vikas Mahatme of the BJP contended that the promulgation of the ordinance was necessary. [14]

In Support of the Bill

‘Extraordinary situation’ of the Pandemic

Clearing the government’s stance on the necessity of promulgating an ordinance, the Minister of Health, Dr. Harsh Vardhan, has stated that the closing of the Parliamentary sessions due to the Covid-19 pandemic constituted an ‘extraordinary situation’. [15]

He further clarified that Yoga and Naturopathy would be given their own National Medical Commissions as per the recommendations of the NITI Aayog. The Board of Governors would comprise highly reputed technical experts, directors of national institutes and of research bodies. Citing the example of the smooth implementation of the online admissions through NEET exams conducted by the Board of Governors last year, he cleared all doubts pertaining to its efficiency. On issues of encroachment of autonomy of the institutions, the hon’ble minister has assured the House that the government’s intent is not to interfere in the day-to-day workings of the body, rather to provide policy guidance on important issues.[16]

The Board of Governors, he has said, albeit lacking the provisions of reservations to SC/ST persons, is based on competence, quality and the values of non-discrimination. The Centre is also looking into the issues raised regarding the increase of budgetary allocations. A hike of more than 40% in funds allotted to The Union Ministry of AYUSH is a positive step in this direction. [17]

Better Administrative Functioning

Dr. Sudhanshu Trivedi, speaking in support of the passage of the Homoeopathy Central Council (Amendment) Bill, 2020, noted the government’s continuous efforts to bring in smooth administrative functioning at the highest levels of the Homeopathy Council. The 2018 Bill sought to increase the number of members to 27, consisting of one chairperson, seven ex-officio members and nineteen ad hoc or part time members, with 6 of them elected. The Advisory Council would have the power to make recommendations and the members would be selected by a Search Committee headed by the Cabinet Secretary. Further, the previous Act of 1973 provided that existing members could continue in their positions even after the collapse of their term, till the time a new member is appointed. The rampant misuse of this provision led the government to enact a specified term period for each member. The Bill also presented a structured removal process for the members. Dr. Trivedi contended that these changes will inevitably lead to an increase in the efficiency of administrative functioning. [18]

Upskilling the Homeopathy Practitioners

Speaking in support of the 2020 Bill, Dr. Trivedi noted that the Bill envisioned to compile a documented record of all the practitioners of homeopathy, as well as to institute a National Eligibility Test for homeopathy teaching. A joint and interdisciplinary research with other alternative Indian systems of medicine, in order to promote coordination as well as to establish scientific basis to the research has also been provided.[19]

Further, the Central Council act of 2018 was brought in to increase the transparency in homeopathy institutions. The delay in constituting was accompanied by a concomitant decrease in levels of corruption in the functioning of the Board.[20]

Concerns against the Bill

‘Inordinate’ delays

The most obvious criticism to the promulgated ordinance, as pointed out by several legislators, is that despite the repeated extensions to the Board of governors, the government has been unable to constitute the Homeopathy Council.

Following the trend of superseding the Medical Council of India by constituting the National Medical Council, the Councils relating to Homeopathy and Ayurveda were also superseded by way of National Commission of Homeopathy and National Commission of Indian Medicine, respectively. SP MLA Ram Gopal Yadav noted that the inability of the Central government to constitute the Medical Council, despite several scathing remarks by the Supreme Court, is symbolic of a larger trend of governmental inefficiency. [21]

Since a majority of the Indian population relies on homeopathy treatment due to a myriad of factors, such as lower costs among others, it is of utmost importance that the government stop the undue delays. [22]

Against the grain of Cooperative Federalism

Dr. Santanu Sen objected to the government’s ordinance on grounds of wrongfully dissolving the democratically elected body. By dissolving the Homeopathy Council, which had about fifty representatives from various parts of the states, and constituting a Board of Governors with seven unelected members, the government raises issues of a lack of transparency.[23]

Further, by mandating a postgraduate degree in order to be eligible for the post of a lecturer, the government cast a blind eye to the fact that in the lack of specialization degree in homeopathy discipline, the appointment of lecturers will be a mammoth task.

Prof. Manoj Kumar Jha’s remarks regarding the unequal distribution of Central and State powers in the IMCC Bill point to a larger trend of the government’s drifting away from the spirit of cooperative federalism. In the Homeopathy amendment Bill too, the Board of Governors, essentially recommended by the central government, are given sweeping powers. This leads to the destabilizing of a democratic setup, towards what he calls ‘ambitious federalism’.[24]

Misuse of Ordinance

BJD MLA Prasanna Acharya noted that the government’s alleged intention to supersede the Council because of prevalent corruption scandals does not hold much water, as the instances of embezzlement first came to the fore in 2016.[25] However, the Centre only came up with the first amendment in 2018, two years after the impugned incident. Further, several meetings of the Parliament were held during the two-year period- thus invalidating any excuse given to promulgate an ordinance rather than introducing the Bill via the ordinary legislative route. [26]

Dr. L. Hanumanthaiah quoted a report by The Wire on the arbitrarily high number of ordinances brought in by the government from 2014, despite the Houses running regularly.[27]

The ability to promulgate ordinances was enshrined in Article 123 of the Indian constitution, which was derived from Sections 42 and 43 of the Government of India Act, 1935, “if circumstances exist which render it necessary for him to take immediate action”.[28]

During the Parliamentary discussions, the wise observations Chief Justice P.N. Bhagwati in the case of D.C. Wadhwa vs. State of Bihar were also evoked. He had stated, “The power to promulgate an Ordinance is essentially a power to be used to meet an extraordinary situation and it cannot be allowed to be perverted to serve political ends’”.[29]  Once again, in the noted Supreme Court judgement in Etc vs Union Of India And Anr, Justice Gupta remarked, “On the other point, I find it difficult to agree that an ordinance is ‘law’ within the meaning of article 21 of the Constitution.’”[30]

In the case Krishna Kumar Singh v. State of Bihar, the Supreme Court held that re-promulgation was “a fraud on the Constitution and sub-version of democratic legislative processes.[31] The 2021 Homeopathy ordinance, which re-promulgates the 2020 ordinance with the goal of extending its effectiveness, must be scrutinized further.

Unclear Demarcation of Powers

A report by the NITI Aayog on the IMCC recommends a clearer demarcation of powers. In the Homeopathy Bill too, the recommendations must be applied. What is needed is a visionary outlook to identify the institutional deficiencies and improve their functions without granting any excess powers to the Council.[32]

The Bill states that owing to its poor functioning, the Central Council stands superseded for a period of four years from the constitution of the – by the Board of Directors. Further, the Board of Directors will be composed of members of the medical profession or distinguished administrators. The Board will be bound by the recommendations of the Central government on matters of policy decisions. Raising objections over the unclear number of members belonging to the medical and administrative fields respectively, the Member of Parliament warned against the dire situation where the Board will be headed solely by administrators- leading to the erosion of autonomy in the field of academics.[33] Therefore, it becomes crucial to demarcate and reserve the number of seats in the Board of Directors for experts and ex-officio members.

Other Institutional Deficiencies

AAP MLA Sanjay Singh remarked that the budgetary allocation of 144 crores to the Homeopathy medicines in the 2020 National budget is far too inadequate. Keeping into consideration the growing number of homeopathy institutes and colleges, the governmental support must be to grant funds and financial aid.[34]

Dr. Veerabrahmachary, President of the Karnataka Board of Homoeopathic System of Medicine, has noted the growing number of unlicensed practitioners pose a threat to the health of the country. Emphasising on structural reforms, he stated, “any degree or diploma in homoeopathy can be issued only by a university or equivalent that is listed under the Indian University Act. Further, such degree/diploma must be included in the second and third schedule of the Central Council of Homoeopathy Act 1973.”[35]

A similar concern was raised by Mr. K. Somaprasad, who noted that taking into consideration the popularity of homeopathy in the country, as well as the important role played by its practitioners in the Covid-19 pandemic, the rampant practicing of unqualified homeopathy doctors poses a grave threat. In order to keep these hazardous practices in check, the State governments need to engage in dialogue and cooperation with the Union to conduct clinical trials in the field of homeopathy, which has been stalled but for the lack of funds. In this regard, the Centre is duty bound to delineate a portion of the budget to the States to popularize and institutionalize Homeopathy medicine.[36]

Further, the 2018 ordinance was brought in to streamline the admission process. However, in spite of its promulgation, the admission process was delayed by several months due to pending inspections, thereby failing to fulfil its primary purpose.

Furthermore, the conduct of election of members in CCI is the responsibility of the AYUSH Ministry. MLA Adhir Ranjan Choudhary’s valuable remarks regarding the infeasibility of the proposed digital vote for the purposes of reconstituting the body offer a strong critique.[37]

Mr. Ravindrababu’s contended that despite Article 4.2 conferring the power on the Central govt. to suspend the council, the repeated promulgation ordinances ware bad for the spirit of democracy. Furthermore, the absence of strong measures to stop the recurrence of corruption in homeopathy regulation bodies points to a lacuna in the current ordinance.[38]

Lastly, Mr. Ashok Siddharth’s concerns regarding the stark absence of any provisions for reservations of members belonging to the SC/ST/OBC classes in the Central Council or the Board of Governors require serious dwelling into. [39]

Recommendations & Concluding Remarks

The recent ordinance brought by the government, albeit with sagacious intentions, overlooks various structural deficiencies in the Central Council of Homeopathy. A number of valid concerns raised during the Parliamentary debates must be paid heed to.

The bill should delineate a clearer demarcation of powers of the Central Council so as to prevent instances of malpractice. The powers of the Centre and the states must also be set in balance in order to uphold ‘Cooperative Federalism’ in letter and spirit. Without adequate budgetary allocations, the present ordinance does not achieve the intention of regulating and promoting Homeopathy. Therefore, it must allot funds and engage in active development of the field. Further, the bill should also seek to regulate the mushrooming of unlicensed practitioners. Instead of repeatedly extending the time period for the Council’s reconstitution, the government should deliberate on issues such as the feasibility of digital or physical elections. Reservation in the elected Council for members belonging to the SC/ST/OBC classes must be put in place, as our Courts and academicians have, time and again, repudiated the arguments supporting mere merit. Last, and perhaps most importantly, the government should stop the promulgation of ordinances in place of the ordinary legislative route. A three-fold test, evaluating the possibility of another route, the bypassing of legislative scrutiny, and the use of the pandemic as a cover must be employed.

Taking our country’s diverse population with varying needs and interests, the need for discussion, deliberation and debate cannot be discounted. The process of codification and legislation must be held sacrosanct, and bypassing this process should be an exception rather than a norm.


References

[1] Irvine Loudon,A brief history of homeopathy, 99 Journal of the Royal Society of Medicine, 607-10 (2006).

[2] Corrêa AD, Siqueira-Batista R et al., Similia Similibus Curentur: historical background of homeopathic medicine, 43 Rev Assoc Med Bras, 347-51 (1992).

[3]  A.K. Ghosh, A short history of the development of homeopathy in India, 99 Homeopathy : the journal of the Faculty of Homeopathy, 130- 36 (2010).

[4]  Raekha Prasad, Homeopathy Booming in India, 370 The Lancet Special Report, 1679-1680 (2007).

[5]  Express Web Desk, The Homeopathy Central Council (Amendment) Bill, 2019: All you need to know, Indian Express (Jun. 27, 2019, 08.45 p.m.), https://indianexpress.com/article/india/the-homeopathy-central-council-amendment-bill-2019-lok-sabha-monsoon-session-parliament-5803535/.

[6] Homoeopathy – An approach towards legal acceptance, Central Council of Homeopathy, http://www.cchindia.com.

[7]  Indo- Asian News Service, LS passes Homoeopathy Central Council Amendment Bill, 2018, Business Standard (Jul. 30, 2018, 10.05 p.m.), https://www.business-standard.com/article/news-ians/ls-passes-homoeopathy-central-council-amendment-Bill-2018-118073001272_1.html.

[8]  Indo- Asian News Service, CBI arrests Homeopathy Council chief in bribery case, The Statesman ( Oct. 22, 2016, 3.42 p.m.), https://www.thestatesman.com/india/cbi-arrests-homeopathy-council-chief-in-bribery-case-172225.html.

[9] Press Trust of India, National Commission for Homeopathy Bill, 2018 gets cabinet approval, Business Standard (Dec. 28, 2018, 6.29 p.m.), https://www.business-standard.com/article/current-affairs/national-commission-for-homeopathy-Bill-2018-gets-cabinet-approval-118122800579_1.html.

[10]  Anulekha Ray, Homoeopathy Central Council (Amendment) Bill, 2020 passed in Rajya Sabha. Key features, Livemint (Sep. 18, 2020, 4.32 p.m.), https://www.livemint.com/news/india/homoeopathy-central-council-amendment-bill-2020-passed-in-rajya-sabha-key-features-11600426382716.html.

[11]  Bhumika Indulia, Homoeopathy Central Council (Amendment) Ordinance, 2021, SCC Online Blog (May 17, 2021), https://www.scconline.com/blog/post/2021/05/17/homoeopathy-central-council-amendmentordinance-2021/.

[12] Rajya Sabha T.V., Prof. Manoj Kumar Jha’s Remarks: Homoeopathy Central Council (Amendment) Bill, 2020, Youtube (Sep. 18, 2020),  https://www.youtube.com/watch?v=xGUpQ-QtS-k.

[13]  Nivedita Rao, Report Summary Committee on the Reform of the Indian Medical Council Act, 1956, PRS India (Aug. 31, 2016), https://prsindia.org/policy/report-summaries/committee-reform-indian-medical-council-act-1956.

[14] Rajya Sabha T.V., Dr. Vikas Mahatme’s Remarks: Homoeopathy Central Council (Amendment) Bill, 2020, Youtube (Sep. 18, 2020),  https://www.youtube.com/watch?v=G8VN4SsDjbA.

[15] Rajya Sabha T.V., Minister Dr. Harsh Vardhan’s Reply: Homoeopathy Central Council (Amendment) Bill, 2020, Youtube (Sep. 18, 2020), https://www.youtube.com/watch?v=YaYSdHQDVEw.

[16]  Asian News International, Homeopathy Central Council (Amendment) Bill, 2020 passed in Rajya Sabha, Business Standard (Sep. 18, 2020, 1.28 p.m.),

https://www.business-standard.com/article/current-affairs/homeopathy-central-council-amendment-bill-2020-passed-in-rajya-sabha-120091800517_1.html.

[17]  Banjot Kaur, Union Budget 2021-22: How good is the hike in allocation for health?, Down to Earth (Feb. 1, 2021), https://www.downtoearth.org.in/news/health/union-budget-2021-22-how-good-is-the-hike-in-allocation-for-health–75310.

[18] Rajya Sabha T.V., Dr. Sudhanshu Trivedi’s Remarks: Homoeopathy Central Council (Amendment) Bill, 2020, Youtube (Sep. 18, 2020),  https://www.youtube.com/watch?v=hR6fqkU-a74&t=598s.

[19] Ibid.

[20]  Bharatiya Janata Party, Dr. Manoj Rajoria on The Homoeopathy Central Council (Amendment) Bill, 2019 in Lok Sabha, Youtube (Jun. 27, 2019), https://www.youtube.com/watch?v=_OLQaR90TZk.

[21]  The News Wire, Medical Council Reconstituted With 68 Members, Outlook India (Nov. 6, 2013, 10.41 p.m.),

https://www.outlookindia.com/newswire/story/medical-council-reconstituted-with-68-members/816313.

[22] Rajya Sabha T.V., Prof. Ram Gopal Yadav’s Remarks: Homoeopathy Central Council (Amendment) Bill, 2020, Youtube (Sep. 18, 2020), https://www.youtube.com/watch?v=-DHFvie78RQ.

[23] Rajya Sabha T.V., Dr. Santanu Sen’s Remarks: Homoeopathy Central Council (Amendment) Bill, 2020, Youtube (Sep. 18, 2020), https://www.youtube.com/watch?v=kD656SWDAkE.

[24] Rajya Sabha T.V., Prof. Manoj Kumar Jha’s Remarks: Homoeopathy Central Council (Amendment) Bill, 2020, Youtube (Sep. 18, 2020),  https://www.youtube.com/watch?v=xGUpQ-QtS-k.

[25]  Scroll Staff, CBI arrests Central Council of Homeopathy chief for taking Rs 20-lakh bribe, Scroll (Oct. 23, 2016, 8.43 a.m.), https://scroll.in/latest/819744/cbi-arrests-central-council-of-homeopathy-chief-for-taking-rs-20-lakh-bribe.

[26] Rajya Sabha T.V., Prasanna Acharya’s Remarks: Homoeopathy Central Council (Amendment) Bill, 2020, Youtube (Sep. 18, 2020), https://www.youtube.com/watch?v=KEarNN9Xj9A.

[27]  The Wire Staff, Modi Govt, With 76 Ordinances in 7 Years, Surpasses UPA’s 10-Year Record of 61, The Wire (Apr. 13, 2021), https://thewire.in/government/modi-govt-with-76-ordinances-in-7-years-surpasses-upas-10-year-record-of-61.

[28] Shraddha, The Curious Case of the Ordinance Wave, Bar and Bench (Dec. 17, 2020, 5.00 p.m.),

https://www.barandbench.com/apprentice-lawyer/the-curious-case-of-the-ordinance-wave.

[29] Dr. D.C. Wadhwa & Ors vs State Of Bihar & Ors on 20 December, 1987 AIR 579.

[30] A. K. Roy, Etc vs Union Of India And Anr, 1982 AIR 710.

[31] Krishna Kumar Singh & ANR. Vs. State of Bihar & Ors., 2017 Latest Case Law 9 SC.

[32]  Rajya Sabha T.V., Prasanna Acharya’s Remarks: Homoeopathy Central Council (Amendment) Bill, 2020, Youtube (Sep. 18, 2020), https://www.youtube.com/watch?v=KEarNN9Xj9A.

[33] Rajya Sabha T.V., Dr. L. Hanumanthaiah’s Remarks: Homoeopathy Central Council (Amendment) Bill, 2020, Youtube (Sep. 18, 2020), https://www.youtube.com/watch?v=vV0Mwg5P-lU.

[34] Rajya Sabha T.V., Sanjay Singh’s Remarks: Homoeopathy Central Council (Amendment) Bill, 2020, Youtube (Sep. 18, 2020), https://www.youtube.com/watch?v=NLOYQEU_3i8.

[35]  Rasheed Kappan, Homoeopathy not attractive among medical aspirants, The Hindu (Sep. 12, 2005), https://web.archive.org/web/20090418051807/http://www.hindu.com/2005/09/12/stories/2005091218710300.htm.

[36]  Rajya Sabha T.V., K. Somaprasad’s Remarks: Homoeopathy Central Council (Amendment) Bill, 2020, Youtube (Sep. 18, 2020), https://www.youtube.com/watch?v=7CNImV4YQOI.

[37] Indian National Congress, Adhir Ranjan Chowdhury on the Homoeopathy Central Council (Amendment) Bill, 2019, Youtube (Jun. 27, 2019),

https://www.youtube.com/watch?v=Yv8mEflmgbM.

[38] Snehlata Shrivastava, Lok Sabha: Synopsis of Debates, Lok Sabha Secretariat (2018), http://164.100.47.193/Synop/16/XV/Synopsis-30-07-2018.pdf.

[39]  Rajya Sabha T.V., Ashok Siddharth’s Remarks: Homoeopathy Central Council (Amendment) Bill, 2020, Youtube (Sep. 18, 2020),  https://www.youtube.com/watch?v=57OOGE-Ttlo.

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