AngloGold Ashanti Limited (AGA.gh) HY2017 Presentation

first_imgAngloGold Ashanti Limited (AGA.gh) listed on the Ghana Stock Exchange under the Mining sector has released it’s 2017 presentation results for the half year.For more information about AngloGold Ashanti Limited (AGA.gh) reports, abridged reports, interim earnings results and earnings presentations, visit the AngloGold Ashanti Limited (AGA.gh) company page on AfricanFinancials.Document: AngloGold Ashanti Limited (AGA.gh)  2017 presentation results for the half year.Company ProfileAngloGold Ashanti Limited is a global mining company with extensive interests in the Americas, Continental Africa, South Africa and Australasia. It boasts a portfolio of 17 operations and 3 projects in 10 countries, including long-life, relatively low-cost operating assets with differing ore body types located in key gold-producing regions. The company was formed in 2004 through the merger of AngloGold and the Ashanti Goldfields Corporation. There are seven mines in the Continental Africa region, of which 6 are operational. In Ghana, the company has two mines; Iduapriem and Obuasi. AngloGold Ashanti Limited is the third-largest gold mining company in the world, measured by production. In addition to its mining operations, it has established several exploration programmes in regions around the world. AngloGold Ashanti Limited is listed on the Ghana Stock Exchangelast_img read more

Vestment of murdered Archbishop Thomas Becket returns to Canterbury Cathedral

first_img Tags Assistant/Associate Rector Washington, DC Director of Music Morristown, NJ This 17th-century glass reliquary, which houses the vestment thought to have been worn by Archbishop Thomas Becket when he was martyred in 1170, is being loaned to Canterbury Cathedral by the Vatican. Photo courtesy: Anglican Communion News Service[Anglican Communion News Service] The tunicle that former Archbishop of Canterbury Thomas Becket is thought to have been wearing when he was murdered is to return to Canterbury Cathedral for an exhibition marking the 850th anniversary of his martyrdom. Archbishop Becket was murdered in Canterbury Cathedral on Dec. 29, 1170 by four knights of Henry II. Tradition says that they interpreted Henry’s words “Will no one rid me of this turbulent priest?” as a command for him to be assassinated.The relic will go on display to mark 850 years since his death and 800 years since his remains were moved from the cathedral’s crypt into a new shrine. The tunicle is housed inside a 17th century glass reliquary which usually resides at the Papal Basilica of Santa Maria Maggiore in Rome. It is being loaned to the cathedral by the Vatican for public display from July 4 to Aug. 3.Read the entire article here. Rector Shreveport, LA Episcopal Charities of the Diocese of New York Hires Reverend Kevin W. VanHook, II as Executive Director Episcopal Charities of the Diocese of New York Director of Administration & Finance Atlanta, GA Course Director Jerusalem, Israel Rector Hopkinsville, KY Rector Belleville, IL TryTank Experimental Lab and York St. John University of England Launch Survey to Study the Impact of Covid-19 on the Episcopal Church TryTank Experimental Lab Rector Bath, NC Inaugural Diocesan Feast Day Celebrating Juneteenth San Francisco, CA (and livestream) June 19 @ 2 p.m. PT Rector and Chaplain Eugene, OR Rector Martinsville, VA Anglican Communion Assistant/Associate Rector Morristown, NJ Vestment of murdered Archbishop Thomas Becket returns to Canterbury Cathedral The Church Investment Group Commends the Taskforce on the Theology of Money on its report, The Theology of Money and Investing as Doing Theology Church Investment Group New Berrigan Book With Episcopal Roots Cascade Books Join the Episcopal Diocese of Texas in Celebrating the Pauli Murray Feast Online Worship Service June 27 Virtual Celebration of the Jerusalem Princess Basma Center Zoom Conversation June 19 @ 12 p.m. ET Family Ministry Coordinator Baton Rouge, LA Submit a Press Release Rector (FT or PT) Indian River, MI Featured Jobs & Calls Submit an Event Listing Priest Associate or Director of Adult Ministries Greenville, SC Associate Priest for Pastoral Care New York, NY Assistant/Associate Priest Scottsdale, AZ Bishop Diocesan Springfield, IL Press Release Service Rector/Priest in Charge (PT) Lisbon, ME Curate Diocese of Nebraska Missioner for Disaster Resilience Sacramento, CA Rector Collierville, TN Episcopal Migration Ministries’ Virtual Prayer Vigil for World Refugee Day Facebook Live Prayer Vigil June 20 @ 7 p.m. ET Rector Smithfield, NC The Church Pension Fund Invests $20 Million in Impact Investment Fund Designed to Preserve Workforce Housing Communities Nationwide Church Pension Group Featured Events Rector Albany, NY Rector Washington, DC Rector Pittsburgh, PA AddThis Sharing ButtonsShare to PrintFriendlyPrintFriendlyShare to FacebookFacebookShare to TwitterTwitterShare to EmailEmailShare to MoreAddThis This Summer’s Anti-Racism Training Online Course (Diocese of New Jersey) June 18-July 16 Cathedral Dean Boise, ID An Evening with Presiding Bishop Curry and Iconographer Kelly Latimore Episcopal Migration Ministries via Zoom June 23 @ 6 p.m. ET Associate Rector for Family Ministries Anchorage, AK Rector Tampa, FL Seminary of the Southwest announces appointment of two new full time faculty members Seminary of the Southwest Curate (Associate & Priest-in-Charge) Traverse City, MI Submit a Job Listing Rector Knoxville, TN In-person Retreat: Thanksgiving Trinity Retreat Center (West Cornwall, CT) Nov. 24-28 Posted Mar 16, 2020 Ya no son extranjeros: Un diálogo acerca de inmigración Una conversación de Zoom June 22 @ 7 p.m. ET Canon for Family Ministry Jackson, MS Priest-in-Charge Lebanon, OH Remember Holy Land Christians on Jerusalem Sunday, June 20 American Friends of the Episcopal Diocese of Jerusalem Associate Rector Columbus, GA Youth Minister Lorton, VAlast_img read more

In case you missed it: The Apopka news week in review

first_img Free webinar for job seekers on best interview answers, hosted by Goodwill June 11 Share on Facebook Tweet on Twitter LEAVE A REPLY Cancel reply Please enter your comment! Please enter your name here Save my name, email, and website in this browser for the next time I comment. You have entered an incorrect email address! Please enter your email address herecenter_img Apopka City Hall TAGSWeek in Review Previous article1,200 votes cast in The Apopka Voice Reader’s Poll 2.0Next articleOrange County Mayor Teresa Jacobs invites community to participate in two new solar co-ops Denise Connell RELATED ARTICLESMORE FROM AUTHOR The Anatomy of Fear Support conservation and fish with NEW Florida specialty license plate 5 stories that shaped Apopka’s news week:December fundraising slow for all Apopka candidatesApopka mayoral debate set for this monthOrange County Mayor Jacobs speaks out on alleged remarks by President TrumpApopka remembers: The tornado of 1918 and the sycamore trees1,200 votes cast in The Apopka Voice Reader’s Poll 2.0last_img read more

Hackney Council for Voluntary Services chooses IRIS Exchequer to streamline its financial processes

first_imgHackney Council for Voluntary Services chooses IRIS Exchequer to streamline its financial processes Howard Lake | 4 June 2009 | News About Howard Lake Howard Lake is a digital fundraising entrepreneur. Publisher of UK Fundraising, the world’s first web resource for professional fundraisers, since 1994. Trainer and consultant in digital fundraising. Founder of Fundraising Camp and co-founder of GoodJobs.org.uk. Researching massive growth in giving. AddThis Sharing ButtonsShare to TwitterTwitterShare to FacebookFacebookShare to LinkedInLinkedInShare to EmailEmailShare to WhatsAppWhatsAppShare to MessengerMessengerShare to MoreAddThis  25 total views,  1 views today AddThis Sharing ButtonsShare to TwitterTwitterShare to FacebookFacebookShare to LinkedInLinkedInShare to EmailEmailShare to WhatsAppWhatsAppShare to MessengerMessengerShare to MoreAddThiscenter_img In conclusion Manish comments, “IRIS Exchequer ticked all the boxes for us in terms of reporting and analysis capabilities, compatibility, ease of use, adaptability, robustness and knowledge base. We fully expect to see a return on our investment through increased productivity, efficiency and accuracy.”IRIS Accounting and Business SolutionsWith over 20,000 medium sized organisations as clients, IRIS is a leading provider of mid-market accounting and business solutions. IRIS’ objective is to empower those operating in clearly defined sectors that include wholesale and distribution, retail, construction, not-for-profit, architectural practices, engineering, and management and IT consultancies with the tools and services to optimise operational efficiency and enable the best chance of competitive advantage.Within the IRIS product portfolio are a wide range of business critical solutions including the ‘flagship’ product, IRIS Exchequer, project management and professional services automation software and HR and payroll products; all underpinned by superior managed hosted and Saas service offerings.Personal service is a key factor that has helped IRIS to secure consistent success in independent user surveys and in industry award programmes.IRIS Accounting and Business Solutions is part of IRIS, one of the fastest growing and now the largest privately owned software and services business in the UK. It has revenues of c£120m p.a. and c1,200 employees servicing over 60,000 UK businesses from a national network of offices. Hackney CVS promotes and supports the development of the voluntary and community sector in Hackney. The organisation has recently reviewed its accounting software in the light of expanding its services. The accounts team are currently using Quickbooks Premier 2008, but feel it has some limitations when it comes to spreadsheet reporting and user permissions.“When we researched financial management solutions, IRIS Exchequer (www.iris.co.uk/exchequer) stood out from the crowd with its well-designed features – especially its project reporting,” comments Manish Panjabi. “We are looking to streamline and automate our finance processes and build closer relationships with our stakeholders. IRIS Exchequer can help us realise these goals by enabling us to utilise our resources more efficiently in the future.”When Hackney CVS goes live with IRIS Exchequer V6 next month, it intends to equip project teams with on demand access to detailed financial information without wasting time and resources in collating and sifting through the data. Advertisement Tagged with: Advanced NFP Finance Technologylast_img read more

Right wing rebuffed in Ecuador

first_imgLenín MorenoLenín Moreno, candidate for the Alianza País, won the runoff election on April 2 by more than 2 percent of the vote over the rightist candidate Guillermo Lasso, a banker and pro-imperialist candidate who had the support of the Ecuadorean oligarchy and U.S. imperialism. Progressive governments and left parties all over Latin America and the Caribbean, including revolutionary Cuba, supported a Moreno victory, which is a continuation of the existing government. The same party, Alianza País, is the leading party in the National Assembly by an even greater margin.The left in the region see Moreno’s win as a positive step blocking rightist gains following the election of a right-winger in Argentina and rightist victories through virtual coups in Brazil and Paraguay. So far Lasso refuses to recognize this clear electoral victory, crying fraud, although international observers, including the Organization of American States, said there were no irregularities in the election.FacebookTwitterWhatsAppEmailPrintMoreShare thisFacebookTwitterWhatsAppEmailPrintMoreShare thislast_img read more

River rescue

first_imgFacebook Limerick City Fire And Rescue service undertaking a rescue operation off Sarsfield BridgeA WOMAN in her 40’s has been rescued from the River Shannon after entering the water.At ten to five this (Sunday) evening, Munster Fire control were called to say that a woman had entered the water in the city at Browns Quay in Thomondgate.Limerick city fire service immediately dispatched four appliances to the scene, including the rescue boat, ‘Fireswift’.Within four minutes of receiving the call, specially trained swift water rescue technicians helped the woman from the water.Sign up for the weekly Limerick Post newsletter Sign Up She had been kept afloat by two passersby. She was treated on the scene by two HSE paramedics and transferred to the University Hospital Limerick where her condition is described as “not life threatening.” Advertisement No vaccines in Limerick yet NewsBreaking newsRiver rescueBy Bernie English – November 17, 2019 10008 Twitter Linkedin Is Aer Lingus taking flight from Shannon? Print New high-end jobs for Shannoncenter_img Walk in Covid testing available in Limerick from Saturday 10th April WhatsApp Email RELATED ARTICLESMORE FROM AUTHOR Local backlash over Aer Lingus threat TAGSfeaturedFire serviceFireSwiftrescue LimerickShannon Previous article€7.5 million Kilmallock school extension will help student progressionNext articleBudgeting service denies it is starving Limerick of resources Bernie Englishhttp://www.limerickpost.ieBernie English has been working as a journalist in national and local media for more than thirty years. She worked as a staff journalist with the Irish Press and Evening Press before moving to Clare. She has worked as a freelance for all of the national newspaper titles and a staff journalist in Limerick, helping to launch the Limerick edition of The Evening Echo. Bernie was involved in the launch of The Clare People where she was responsible for business and industry news. Shannon Airport braced for a devastating blow last_img read more

Today’s Mortgage Relief May Be Tomorrow’s Market Confusion

first_imgSign up for DS News Daily Servicers Navigate the Post-Pandemic World 2 days ago The Best Markets For Residential Property Investors 2 days ago in Daily Dose, Featured, Investment, News April 29, 2020 1,411 Views Tagged with: Forbearance Housing Market Today’s Mortgage Relief May Be Tomorrow’s Market Confusion Servicers Navigate the Post-Pandemic World 2 days ago Forbearance Housing Market 2020-04-29 Seth Welborn Data Provider Black Knight to Acquire Top of Mind 2 days ago Governmental Measures Target Expanded Access to Affordable Housing 2 days ago Related Articles Previous: Lender Agrees to Pay $15.06M to Resolve Allegations Next: DS5: How Servicers are Adapting Tech to the Crisis Demand Propels Home Prices Upward 2 days ago Share Save Data Provider Black Knight to Acquire Top of Mind 2 days ago Governmental Measures Target Expanded Access to Affordable Housing 2 days ago The Week Ahead: Nearing the Forbearance Exit 2 days ago With more than 6% of borrowers in forbearance plans on their mortgage loans, the question on many housing professionals’ minds is what’s next?More than 3.4 million homeowners will benefit from temporarily suspending their mortgage payments, according to data from Black Knight, but the details of how and when they repay those missed months of payment are still being ironed out. In order to help borrowers as quickly as possible in this unique and sudden financial crisis, the federal government is extending forbearance for any borrowers of government-backed loans who claim financial hardship. Borrowers did not have to undergo a lengthy application process. As such, the task of working with individual homeowners to determine the best approach to repayment will be left for later. Thus, “the real chaos won’t start until the pandemic passes,” stated an article in Bloomberg this week. Servicers will be dealing with a large volume of borrowers who need to work out repayment plans, while also working to ensure they are following new requirements set by the Federal Housing Finance Agency, Fannie May, or Freddie Mac. Meanwhile borrowers may be facing confusion or misinformation regarding their loan terms following forbearance.Servicers are already dealing with an uptick in call volumes. Thus far, Mr. Cooper Group Inc., told Bloomberg it has bolstered its servicing centers by 40% since the pandemic ensued, and the company’s website encourages borrowers to apply for assistance online due to the “high volume of calls we are now seeing and anticipate for the foreseeable future.” Michael Stegman, senior research fellow in the Center for Household Financial Stability at the Federal Reserve Bank of St. Louis, told Bloomberg, “expect even more chaos when forbearance ends.” Already, the Federal Housing Finance Agency is working hard to dispel any rumors or worries that borrowers will have to repay their missed mortgage payments in a lump sum at the end of their forbearance period. Fannie Mae and Freddie Mac will require servicers to set up a repayment plan or loan modification before the end of the forbearance plan if the borrower’s financial hardship has ended. The loan modification could lower a borrower’s monthly mortgage payment and may add missed payments on to the end of the mortgage loan. In cases where it is necessary, forbearance may be extended, according to FHFA. The Federal Housing Administration will allow missed loan payments to become a second lien for borrowers that they will repay when they refinance or sell their home. The FHFA may announce a similar plan. There is the potential for servicers to become overloaded with loan modification applications similar to in the 2008 financial crisis. About Author: Krista F. Brock The Best Markets For Residential Property Investors 2 days ago Krista Franks Brock is a professional writer and editor who has covered the mortgage banking and default servicing sectors since 2011. Previously, she served as managing editor of DS News and Southern Distinction, a regional lifestyle publication. Her work has appeared in a variety of print and online publications, including Consumers Digest, Dallas Style and Design, DS News and DSNews.com, MReport and theMReport.com. She holds degrees in journalism and art from the University of Georgia. Home / Daily Dose / Today’s Mortgage Relief May Be Tomorrow’s Market Confusion  Print This Post Demand Propels Home Prices Upward 2 days ago Subscribelast_img read more

Mc Conalogue concerned at impact of proposed VAT increase

first_img By News Highland – November 22, 2011 WhatsApp Google+ LUH system challenged by however, work to reduce risk to patients ongoing – Dr Hamilton Calls for maternity restrictions to be lifted at LUH Newsx Adverts Pinterest Google+ Pinterest Previous articleBadminton – Chloe Closing In On Olympic QualificationNext articleGardai investigate fire as Letterkenny school is forced to close News Highland WhatsApp Guidelines for reopening of hospitality sector published center_img Twitter Mc Conalogue concerned at impact of proposed VAT increase RELATED ARTICLESMORE FROM AUTHOR Deputy Charlie McConalogue says  a 2% increase in VAT will put serious pressure on businesses in border towns and villages.The Donegal North East TD says Ireland is at the mercy of global economic factors when it comes to currency fluctuations, but we do have complete control over our own domestic VAT rate.Taoiseach Enda Kenny argues that currency fluctuations have a greater impact on cross-border trade, but Deputy Mc Conalogue doesn’t accept that arguement……..[podcast]http://www.highlandradio.com/wp-content/uploads/2011/11/cmcc830.mp3[/podcast] Facebook Business Matters Ep 45 – Boyd Robinson, Annette Houston & Michael Margey Twitter Almost 10,000 appointments cancelled in Saolta Hospital Group this week Facebook Need for issues with Mica redress scheme to be addressed raised in Seanad alsolast_img read more

Investigation & Arrest Under Immoral Traffic (Prevention) Act To Be Conducted By Special Police Officer; Power Cannot Be Delegated: Kerala High Court

first_imgNews UpdatesInvestigation & Arrest Under Immoral Traffic (Prevention) Act To Be Conducted By Special Police Officer; Power Cannot Be Delegated: Kerala High Court LIVELAW NEWS NETWORK30 Nov 2020 1:37 AMShare This – xThe Kerala High Court has made it clear that any investigation or arrest under the Immoral Traffic (Prevention) Act, 1956 has to be conducted only by a Special Police Officer authorized in that behalf. It has been held that there is no provision in the Act that empowers such Special officer to authorise the investigation of the case to be conducted by any other Police…Your free access to Live Law has expiredTo read the article, get a premium account.Your Subscription Supports Independent JournalismSubscription starts from ₹ 599+GST (For 6 Months)View PlansPremium account gives you:Unlimited access to Live Law Archives, Weekly/Monthly Digest, Exclusive Notifications, Comments.Reading experience of Ad Free Version, Petition Copies, Judgement/Order Copies.Subscribe NowAlready a subscriber?LoginThe Kerala High Court has made it clear that any investigation or arrest under the Immoral Traffic (Prevention) Act, 1956 has to be conducted only by a Special Police Officer authorized in that behalf. It has been held that there is no provision in the Act that empowers such Special officer to authorise the investigation of the case to be conducted by any other Police officer. The observation is made by a Bench of Justice MR Anitha in an application for quashing of FIR filed by a lodge owner, who was booked under the Act. As per the facts of the case, Circle Inspector of Police, Perinthalmanna conducted a search in the lodge run by the Petitioner and found that the accused No. 2 to 7 were inside the lodge rooms engaged in prostitution for money. The accused were arrested and a case was registered. Thereafter, Circle Inspector, Pandikkad conducted the investigation, questioned the witnesses and filed charge under Secs 3, 4, 5 and 7 of the Immoral Traffic (Prevention) Act. According to the petitioner, under the provisions of the Act, arrest and investigation has to be conducted by a Special Police Officer as provided under Section 2(i) and 13 of the Act. [Section 13 states: There shall be for such area to be specified by the State Government in this behalf a special police officer appointed by or on behalf of that Government for dealing with offences under this Act in that area.] In this case, he pointed out, the investigation was conducted by Circle Inspector, Pandikkad whereas the place of occurrence of the alleged incident was within the jurisdiction of Perinthalmanna police station. It was also his contention that there is no provision under the Act to empower the special police officer to authorise investigation of the case to be conducted by any other officer. Finding merit in this submission, the High Court held, “Section 14(ii) does not empower the Special Police Officer i.e. Inspector of Police, Perinthalmanna to authorise the investigation of the case to be conducted by the Police Inspector, Pandikkad. So the investigation conducted by the Inspector of Police, Pandikkad who is not the Special Police Officer is not in compliance with the provisions of law. So as rightly contended by the learned counsel, the criminal prosecution initiated against the petitioner based on the final report filed by the Circle Inspector, Pandikkad is not sustainable in law.” [Section 14(ii) states: when the special police officer requires any officer subordinate to him to arrest without warrant otherwise than in his presence any person for an offence under this Act, he shall give that subordinate officer an order in writing, specifying the person to be arrested and the offence for which the arrest is being made; and the latter officer before arresting the person shall inform him of the substance of the order and, on being required by such person, show him the order.] Reliance was placed on Joseph v. State of Kerala, 2011 (2) KHC 958, whereby while dealing with Sections 3, 4, 5, 14 (ii) of the Act, the High Court had held that authorisation given by the Special Police Officer to his subordinate officer must mention the name of any of the persons to be arrested. It is also held that Special Police Officer cannot authorise investigation of the case to be conducted by any other officer. The Court observed that the Government of Kerala has appointed Circle Inspector of Police attached to the police stations in the State as Special Police Officers for dealing with offences under the Act within their respective area of jurisdiction. Perinthalmanna and Pandikkad have been given under the separate jurisdictional limits and that would in turn indicate that Circle Inspector of Police, Perinthalmanna would be Special Police Officer within the jurisdiction of Perinthalmanna circle and the Circle Inspector of Police, Pandikkad would be the Special Police Officer within the Pandikkad circle. In this backdrop the Bench quashed the FIR and criminal proceedings, and observed, “Circle Inspector of Police, Pandikkad will not be the Special Police Officer with respect to a crime committed within the jurisdictional limits of Perinthalmanna circle. So, in view of the settled position of law, the final report filed by the Inspector of Police, Pandikkad who is not the Special Police Officer empowered under Section 13 of the Act is not in compliance with the provisions of the Act and hence is not sustainable in law.”Other reports pertaining to this Act: Victim Under Immoral Traffic (Prevention) Act Can’t Be Sent To Correctional Home Against Her Wishes If She Is An Adult: Bombay HCNot Mandatory To Call Two ‘Respectable’ Persons For A Raid Under Immoral Traffic (Prevention) Act: Rajasthan HC Case Title: Ali Ahammed v. State of Kerala Click Here To Download Order Read OrderSubscribe to LiveLaw, enjoy Ad free version and other unlimited features, just INR 599 Click here to Subscribe. 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Lt. Col. Nitisha vs Union of India: The Supreme Court Recognises Indirect Discrimination

first_imgColumnsLt. Col. Nitisha vs Union of India: The Supreme Court Recognises Indirect Discrimination Gautam Bhatia30 March 2021 7:09 AMShare This – xIn early 2020, the Supreme Court delivered judgment in Secretary, Ministry of Defence vs Babita Puniya, holding that the Indian Army’s policy of denying women officers a permanent commission [“PC”] was discriminatory. Following this judgment, the Union Government put into place a procedure for the grant of PCs to eligible women officers. The results of this process – that involved 615…Your free access to Live Law has expiredTo read the article, get a premium account.Your Subscription Supports Independent JournalismSubscription starts from ₹ 599+GST (For 6 Months)View PlansPremium account gives you:Unlimited access to Live Law Archives, Weekly/Monthly Digest, Exclusive Notifications, Comments.Reading experience of Ad Free Version, Petition Copies, Judgement/Order Copies.Subscribe NowAlready a subscriber?LoginIn early 2020, the Supreme Court delivered judgment in Secretary, Ministry of Defence vs Babita Puniya, holding that the Indian Army’s policy of denying women officers a permanent commission [“PC”] was discriminatory. Following this judgment, the Union Government put into place a procedure for the grant of PCs to eligible women officers. The results of this process – that involved 615 eligible women officers – spurred a second round of litigation before the Supreme Court. In a judgment delivered yesterday, Lt. Col Nitisha vs Union of India, the Supreme Court – speaking through a bench of Chandrachud and Shah JJ – held that the implementation of the Babita Puniya judgment had also been discriminatory. In particular, the importance of Lt. Col. Nitisha lies in the fact that the criteria for grant of PCs to women were facially neutral, but found to be indirectly discriminatory. This marks the first occasion that the Supreme Court has categorically held indirect discrimination to violate the Constitution, and set out an account of what indirect discrimination entails.As in Babita Puniya, the facts of the case are somewhat complicated, and this post must necessarily present a somewhat schematic account. Broadly, there were three contentious criteria of assessment for the grant of PC: first, that the women officers had to clear a certain percentage score, as well as score higher than the lowest-scoring male officer who had been awarded a PC; secondly, that Annual Confidential Reports [“ACRs”] were to form part of the grading; and thirdly, certain medical requirements had to be fulfilled.On the face of it, these criteria were neutral, i.e. they did not, on their face, discriminate between male and female officers. On digging a little deep, however, it was found that the very fact that for all these years, women had not been eligible for the grant of PCs, had a direct bearing on some eligible candidates’ failure to fulfil the criteria. For example, ACRs were prepared with a view to recommendations for the grant of a PC. Given that female officers had not been eligible for PCs, in their case, the reports were more lackadaisical than those of their male counterparts; these were also affected by the fact that women officers had not applied for a range of opportunities, or courses, that were supposed to be considered in the ACRs. This was because their career options had hitherto been blocked – thus, effectively, leading to a cycle of discrimination that now meant that they applied with relatively unfavourable ACRs. Similarly, with respect to the medical criteria, the Court found that male officers took their medical tests at the time they applied for PCs (and once granted PCs, they were not required to maintain the same levels of fitness). However, female officers – who had been ineligible all these years – were now required to prove the very level of fitness that otherwise similarly situated male officers were no longer required to prove (as they had been granted PCs many years before).Of course, other than the requirement of scoring higher than the lowest-scoring male candidate, none of the eligibility criteria required any facial comparison between women and men. For this reason, the Supreme Court was required to reach further, and articulate an alternative model of equality and discrimination. It did so by drawing a distinction between intention and effect, and discrimination wrought by individual acts on the one hand, and by the impersonal workings of institutions and structures on the other. Chandrachud J. held that the concept of substantive equality – to which the Constitution was committed – required accounting for both systemic and indirect discrimination (paragraph 45). After an extended comparative examination (paragraphs 51 – 65), Chandrachud J. held that the two-step test for discrimination evolved in the Canadian Supreme Court case of Fraser (discussed on this blog here) was the most appropriate. The Fraser test – as set out by the Supreme Court – requires that:First, the Court has to enquire whether the impugned rule disproportionately affects a particular group. As an evidentiary matter, this entails a consideration of material that demonstrates that “membership in the claimant group is associated with certain characteristics that have disadvantaged members of the group”. However, as such evidence might be hard to come by, reliance can be placed on evidence generated by the claimant group itself. Further, while statistical evidence can serve as concrete proof of disproportionate impact, there is no clear quantitative threshold as to the quantum of disproportionality to be established for a charge of indirect discrimination to be brought home. Equally, recognizing the importance of applying a robust judicial common sense, the Court held: “In some cases, evidence about a group will show such a strong association with certain traits—such as pregnancy with gender—that the disproportionate impact on members of that group will be apparent and immediate” … Second, the Court has to look at whether the law has the effect of reinforcing, perpetuating, or exacerbating disadvantage. Such disadvantage could be in the shape of: “[e]conomic exclusion or disadvantage, [s]ocial exclusion…[p]sychological harms…[p]hysical harms…[or] [p]olitical exclusion”, and must be viewed in light of any systemic or historical disadvantages faced by the claimant group.” (para 65)The Court also noted that while statistical data would aid in establishing a finding of indirect discrimination, it would not necessarily exist in every case (paragraph 68); and that while due deference ought to be accorded to employer arguments around suitability criteria for the job, the Court would have to be vigilant to avoid endorsing the same stereotypes or generalisations that were responsible for the discrimination in the first place (paragraph 70). Effectively, the Court indicated that it would have to check whether the employer had acted proportionately – ensuring, for example, that there were no other measures that could have been taken that did not have the same discriminatory effect. The Court correctly noted, as well, that structural discrimination would often require structural remedies (paragraph 73).Applying this analytical framework to the case at hand, indirect discrimination was easily made out. It was the very fact that female officers had been formally denied a set of opportunities for all these years, that now ensured that a seemingly neutral set of criteria – neutral in that the same set of criteria was applied to eligible male candidates – was discriminatory in effect (note that the female candidates were not competing against male candidates in this case, so this judgment also shows that a finding of discrimination does not need a comparator group). The quality of the ACRs, the limited consideration of awards or achievements attained only as on the 5th or 10th year of service, and so on, were all indications of this. Thus, as Chandrachud J. pointed out: “A formalistic application of pre-existing policies while granting PC is a continuation of these systemic discriminatory practices. WSSCOs were continued in service with a clear message that their advancement would never be equal to their male counterparts.” (para 96). The same was the case with the medical fitness criteria, as explained above: while there was nothing wrong with the criteria per se, it was their application that was indirectly discriminatory. Female officers, who were not eligible for PC for all these years, were asked to pass a medical test now that their similarly situated male counterparts had been entitled to take at a substantially younger age (and then not required to maintain). Thus the Court held:The WSSCOs have been subject to indirect discrimination when some are being considered for PC, in their 20th year of service. A retrospective application of the supposedly uniform standards for grant of PC must be modulated to compensate for the harm that has arisen over their belated application. In the spirit of true equality with their male counterparts in the corresponding batches, the WSSCOs must be considered medically fit for grant of PC by reliance on their medical fitness, as recorded in the 5th or 10th year of their service. (para 112)While the facts of this case are undoubtedly complex, it will be easy to see what the Court was trying to remedy by looking at another similar case, but with much simpler facts. In Australian Iron and Steel Co v Bankovic, a company imposed a “last in, first out” retrenchment policy (i.e., you got retrenched based on how short a time you spent in the company). It turned out, however, that the company had only recently begun to employ women, and that therefore, the retrenchment policy was much more likely to target women, simply for this reason. This was found indirectly discriminatory. Thus, this was the sequence: first, there was formal and direct discrimination, that put women at a disadvantage. Then, formal discrimination was ended, but criteria were put in place that failed to account for that prior disadvantage – and thus ended up entrenching and perpetuating it, indirectly. In a very similar way, in this case, for the longest time, women faced formal and direct discrimination by not being eligible for the grant of PC. This formal discrimination was struck down by the Court in Puniya – but the policy that was framed for implementing it failed to account for the disadvantage that had been caused (directly) all these years. Thus, by the very fact of its “neutrality”, the policy was indirectly discriminatory.Of course, not all such examples of indirect discrimination will be as clean-cut – that is, effectively piggybacking off former direct discrimination. Importantly, however, as we have seen above, Chandrachud J.’s formulation was detailed enough to address those more complex cases when they do arise. The proof of the pudding is, of course, in the eating, but for now Lt Col Nitisha’s Case marks an important advance in its acknowledgement, recognition, and articulation of indirect discrimination under the Indian Constitution.Gautam Bhatia is a lawyer practicing in the Supreme Court of India. This article was first published here.Subscribe to LiveLaw, enjoy Ad free version and other unlimited features, just INR 599 Click here to Subscribe. All payment options available.loading….Next Storylast_img read more