12 Interesting Facts you should know about Consumer Rights

CONSUMER PROTECTION ACT, 2019

The Consumer Protection Bill, 2019 was introduced in the Lok Sabha by the Minister of Consumer Affairs, Food and Public Distribution on 8th July 2019.[i] It was soon passed by both the houses and received the President’s assent. The Act came into effect by 20th July 2020 replacing the Consumer Protection Act, 1986.[ii]

WHO IS A CONSUMER?

According to Section 2(7) of Consumer Protection Act, 2019[iii], a “consumer” is defined as a person who buys any goods or avails a service for a consideration. It does not include a person who obtains a good for resale or a good or service for commercial purpose. For example, a person buying milk from the shop for personal use is termed as a consumer whereas, a person buying the milk for making sweets which he is going to sell in his shop is not a consumer.

It covers transactions through all modes including offline, and online through electronic means, teleshopping, multi-level marketing or direct selling.

RIGHTS OF THE CONSUMERS

Previously, there were a total of seven Consumer Rights which have been defined in the Consumer Protection Act, 1986. [iv] After the enactment of the Consumer Protection Act, 2019, five new rights were introduced to the existing ones.[v]

12 Interesting Facts you should know about Consumer Rights

1.  YOU CAN REMAIN PROTECTED FROM HAZARDOUS GOODS

Every consumer has the right to be protected against the marketing of goods which are hazardous to life and property. There are various risks involved in the consumption and use of products such as food, drugs, toys, electrical appliances, etc. For example, gas cylinder if not sealed properly, may cause injury to life or even death. The consumers have the right to get protection against such risks.

Products should not cause any physical danger to the consumers or put them in difficulty due to any reason. Consumers must have assurance regarding quality, reliability, and performance. There are so many common household items now available to consumers that contain potentially harmful substances. For example, artificial colours in food products can damage the liver. With the advancement of science and technology, consumer products have become highly complex and intricate. Therefore, responsibility for their safety should be fixed on producers and distributors.

2. YOU CAN KNOW ALL THE PRODUCT INFORMATION

Every consumer has the right to get informed about all the features of the product or services such as quality, quantity, potency, purity, standard and prices of the goods he intends to purchase.

It is the duty of the manufacturer and seller to provide all the information about a) the product including its ingredients, date of manufacture, technical specifications, etc. b) the precautions, if any, to be taken in the use and maintenance of the product, c) strength, durability, serviceability and reuse value of the product, d) the side effects and risks in the use of the product, etc. Such information should enable the consumer to intelligently exercise his decisions to buy a product. The right to information is meant to protect the consumer from deceptive advertising, misleading labelling and warranties, etc.

3. YOU CAN CHOOSE YOUR PRODUCT AND NEGOTIATE THE PRICE

Every consumer has a right to choose the product or services of his choice. The seller has no right to force the consumer to buy the particular product of any brand. There should be freedom to choose from alternative products. This requires free competition in the market. If enough varieties of products at competitive prices are available in the market, consumers have the opportunity to make a free choice.

There is an interesting fact which most of the consumer don’t know is that consumer can do bargain on the mentioned MRP as this price is fixed by the producer only and there is no interference of government.

4. YOU CAN VOICE YOUR COMPLAINTS

It is referred to as the right to be heard and to be assured that consumers’ interests will receive due consideration at appropriate forums. This right was introduced for a consumer in order to ensure that all the complaints and issues of the consumers are heard duly under the appropriate authority. It is because of this right that almost all the big selling companies have a separate department known as the customer service to help the consumers in case of any dispute or any complaint regarding the quality or quantity of the product.

5. YOU CAN SEEK REDRESSAL

This right provides that consumer has a right to get compensation or seek redressal against unfair trade practice or restricted trade practices. Compensation may be in the form of money or replacement of the good as per the demand or satisfaction of the customer. There are consumer forums at the district, state, and national levels to deal with the cases of consumer protection.

6. YOU CAN SEEK CONSUMER EDUCATION

It is the right of each and every person who is a citizen of India to have knowledge about all the laws and policies relating to the consumer. This will help to make the consumers conscious and protect themselves against frauds by businessmen. An ignorant consumer cannot escape cheating and may not come forward to seek redressal against malpractices by sellers.

Many awareness programs have been organized by the government of India such as ‘Jago Grahak Jago’, etc. to educate the people of the remote areas on the Consumer Protection laws.

7. YOU CAN SEEK A HEALTHY ENVIRONMENT

Consumers have the right to be protected against environmental pollution so as to improve the quality of life. This right includes protection against degradation of the environment. Non-renewable resources of the country need to be conserved for future generations.

8. YOU CAN FILE A COMPLAINT FROM ANYWHERE

According to this new right, consumers can now file a complaint with the District Consumer Commission or State Consumer Commission from anywhere, home, office or while on a weekend trip. Presently, the consumers are required to file a case only at the place where the product was purchased or where the seller of the product has his registered office. The consumer affairs ministry will now frame rules for electronic filing of complaints and specify norms for paying the required fee digitally. This will reduce harassment of consumers to a great extent.

9. YOU CAN SEEK COMPENSATION UNDER PRODUCT LIABILITY

Any complainant can file a case against the manufacturer or seller of a product for any loss caused to the complainant on account of a defective product, which applies to all services. If there is a manufacturing defect or the product in question does not conform to the express warranty the manufacturer or the seller will be held liable. This provision brings e-commerce under its ambit.

10. YOU CAN GET PROTECTION AS A CLASS

If you have a complaint that relates to a violation of consumer rights or unfair trade practices or misleading advertisements that are prejudicial to the interests of consumers as a class, you can do two things. Forward the complaint in writing or in electronic mode to district collector or the commissioner of regional office or the Central Consumer Protection Authority (CCPA) for a class action.

11. YOU CAN SEEK A HEARING USING VIDEO CONFERENCING

According to this, any complaint will be presented before the district commission based on an affidavit and documentary evidence placed before it. If an application has been forwarded by a consumer for hearing through video conference, the commission can allow for this provision.

12. YOU CAN KNOW WHY A COMPLAINT WAS REJECTED

No commission can reject a complaint without hearing the complainant. The commission, in fact, must decide about admitting or rejecting a complaint within 21 days, by which if it is not decided then the complaint is deemed as having been admitted.

[i] “Consumer Protection Bill, 2019”, PRS India.

Available at: https://www.prsindia.org/billtrack/consumer-protection-bill-2019

[ii] http://egazette.nic.in/WriteReadData/2019/210422.pdf

[iii] Section 2(7) of Consumer Protection Act, 2019

[iv] http://www.jagograhakjago.com/consumer-rights/

[v] “5 new consumer rights that every citizen of India should know”, India Today, August 13, 2019

Available at: https://www.indiatoday.in/education-today/gk-current-affairs/story/5-new-consumer-rights-india-consumer-protection-bill-divd-1580371-2019-08-13

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INTRODUCTION

Previously, cases on matrimonial cruelty of a woman were dealt with by general provisions of Indian Penal Code like hurt, grievous hurt, assault etc. In the year 1983, the Indian Penal Code was amended for inserting Section 498A which primarily concerns “Cruelty against women”. The main objective behind this amendment was to protect women from being harassed by her husband or relatives of the husband. An offence under this section is cognizable, non-compoundable and non-bailable.

Section 498A of Indian Penal Code

 Whoever, being the husband or the relative of the husband of a woman, subjects such woman to cruelty shall be pun­ished with imprisonment for a term which may extend to three years and shall also be liable to fine.

Explanation.—For the purpose of this section, “cruelty” means—

(a) any willful conduct which is of such a nature as is likely to drive the woman to commit suicide or to cause grave injury or danger to life, limb or health (whether mental or physical) of the woman; or

(b) harassment of the woman where such harassment is with a view to coercing her or any person related to her to meet any unlawful demand for any property or valuable security or is on account of failure by her or any person related to her to meet such demand.[i]

MISUSE OF SECTION 498A OF IPC

As per the reports of the National Crime Records Bureau (NCRB), out of 4,66,079 cases that were pending in the start of 2013, only 7,258 were convicted while 38,165 were acquitted and 8,218 were withdrawn. The conviction rate of cases registered under Section 498A IPC was also a staggering low at 15.6%. This provision has been always been in the news with allegations of false complaints and very low conviction rate.[ii]

There are many instances where the woman has filed the complaint with a mala fide intention of causing harassment to her husband and in-laws. In such cases, even though the husband and his relatives get acquitted, they suffer from immense mental and economic distress. The media coverage further hampers the reputation of the accused. According to the Indian Courts, misuse of 498A can be termed as legal terrorism.[iii]

This article would further discuss the Judgments delivered by the Supreme Court on the misuse of Section 498A of Indian Penal Code, 1860.

Given below are the Top 10 Supreme Court Judgments on the misuse of Section 498A of IPC

FACTS

Sunita Kumari was found dead at the residence of her in-laws in Punjab. The death was found to have occurred not under the ordinary circumstances but was the result of suffocation. After investigation and prosecution, charges were filed under the husband and in-laws of the deceased.

JUDGEMENT

The Court observed that for the fault of the husband, the in-laws or any other relations cannot, in all cases, be held to be involved in the demand of dowry. In cases where such accusations are made, the overt acts attributed to persons other than the husband are required to be proved beyond a reasonable doubt.

In their over enthusiasm and anxiety to seek conviction for maximum people, the parents of the deceased have been found to be making efforts for involving other relations which ultimately weaken the case of the prosecution even against the real accused as appears to have happened in the instant case. Thus, charge-sheet and criminal prosecution against the in-laws were quashed.

2. SUSHIL KUMAR SHARMA V. UNION OF INDIA[v] (2005)

FACTS

The petition was filed under Article 32 of Indian Constitution for declaring Section 498A of IPC as unconstitutional and ultra vires in the alternative to formulate guidelines so that innocent persons are no longer falsely accused. Further, prayers were made that if any allegation under this section was unfounded then strict actions must be taken against him.

JUDGEMENT

It was observed that there have been many instances where the complaints were not bona fide and have been filed with oblique motive. In such cases acquittal of the accused does not in all cases wipe out the ignominy suffered during and prior to trial.

The Court opined that merely because the provision is constitutional and intra vires, it does not allow unscrupulous persons to wreck personal vendetta or unleash harassment. Till the time the legislature does not find a solution to the frivolous complaints, the courts have to take care of the situation within the existing framework.

3. NEELU CHOPRA & ANR. V. BHARATI[vi] (2009)

FACTS

The appellant Neelu Chopra and Krishan Sarup Chopra are husband-wife and the respondent Bharti was their daughter-in-law. According to Bharati, her married life with Rajesh (son of appellants) was not very smooth as there were unreasonable demands for doubts and misbehaviour from Rajesh and his parents. Thus, in 1993, Bharati filed a complaint against her husband and in-laws under Section 498A of IPC. In 2006, Rajesh expired and hence the present case only lies against the in-laws.

JUDGEMENT

The Court observed that the complaint did not show as to which accused had committed what offence and what was the exact role played by these appellants in the commission of offence. There could be said something against Rajesh, as the allegations were made against him more precisely but he was no more and had already expired. Under such circumstances, it would be an abuse of process of law to allow the prosecution to continue against the aged parents of Rajesh, on the basis of vague and general complaint which was silent about the precise acts of the appellants. The Court thus directed to quash the complaint under Section 482 of CrPC.

4. MANJU RAM KALITA V. STATE OF ASSAM[vii] (2009)

FACTS

The wife alleged that her marital relationship was not cordial as her husband used to torture her mentally and physically. She left her matrimonial home and started residing with her father but later got to know that her husband has remarried a lady. The husband was charged under Section 498A of IPC but he denied all the allegations and preferred an appeal before the apex court.

JUDGEMENT

The court relying on several precedents observed that the meaning of “Cruelty” differs in each statutory provision and hence must be established in the context of Section 498A of IPC. The conduct of the man, the seriousness of his acts must be compared with the likeliness of the woman to commit suicide, etc. It must be established that the woman has been subjected to cruelty continuously or at least in close proximity of time of lodging the complaint. Petty quarrels would not come under the purview of “cruelty”. Accordingly, the Court set aside the conviction order under Section 498A of IPC.

5, PREETI GUPTA & ANR. V. STATE OF JHARKHAND[viii] (2010)

FACTS

The complainant Manisha was married to Kamal Poddar in the year 2006. In 2007, she alleged her husband and her husband’s relatives for demanding dowry and assaulting her physically. Thereafter, a complaint was filed under Section 498A and others of IPC.

The present appeal is filed by Preeti Gupta, the married sister-in-law and her husband against the impugned judgment passed by the High Court of Jharkhand.

JUDGEMENT

The Court observed that the tendency of implicating husband and all his immediate relations is not uncommon. At times, even after the conclusion of the criminal trial, it is difficult to ascertain the real truth. Hence, the courts have to be extremely careful and cautious in dealing with these complaints and must take pragmatic realities into consideration while dealing with matrimonial cases.

In the present case, the allegations of harassment of husband’s close relations who had been living in different cities and never visited or rarely visited the place where the complainant resided would have an entirely different complexion. The allegations of the complaint are required to be scrutinized with great care and circumspection. Therefore, in the interest of justice, the court directed to quash all the charges filed against the appellants as the same could not be proved.

6. BHASKAR LAL SHARMA & ANR. V. MONICA[ix] (2014)

FACTS

Monica married Vikas Sharma (son of appellants), who had two children from his first wife. After their marriage, the relationship between the husband and wife deteriorated and Monica left her matrimonial home. Thereafter, she filed a complaint against her husband and other appellants (father-in-law and mother-in-law) under Section 498A, 406 and 34 of IPC. Monica also claimed maintenance of 2 lakhs per month in addition to the interim maintenance.

JUDGEMENT

The Supreme Court observed that all the essential elements required for an offence under Section 498A of the IPC were not fulfilled in the present case. The respondent took all coercive steps to ensure the presence of appellants in India without making any effort at conciliation. The court was of the view that merely because the mother-in-law kicked the daughter-in-law and threatened her with divorce, the same did not amount to cruelty under Section 498A of IPC. Thus, no case was made out against the appellants under Section 498A of IPC.

7. ARNESH KUMAR V. STATE OF BIHAR[x] (2014)

FACTS

The wife alleged that her in-laws demanded 8 lakh Rupees, a Maruti car, an air-conditioner etc. from her family. When her husband got to know about these demands, he supported his mother and threatened to marry another woman. It was also alleged that she was driven out of the matrimonial home due to non- fulfilment of the demand of dowry.

Denying these allegations, the husband filed an appeal for anticipatory bail before the Supreme Court.

JUDGEMENT

The Court observed that since Section 498A is a cognizable and non-bailable offence, women often use it as a weapon rather than a shield to harass her husband and his relatives. Sometimes, even the bedridden grandparents of the husband, their relatives living abroad are brought under this provision on false allegations. The Court laid down certain guidelines stating that arrest under this section must be made after reaching reasonable satisfaction and after conducting a proper investigation as to the genuineness of allegation. The Magistrate shall not order detention casually and mechanically. The Court, therefore, granted provisional bail to the accused.

8. BIBI PARWANA KHATOON @ PARWANA KHATOON V. STATE OF BIHAR[xi] (2017)

FACTS

According to the facts of the case, it was alleged that the husband and his relatives killed the wife by setting her on fire. Aggrieved by the decisions passed by the lower Courts, the brother-in-law and the sister-in-law of the deceased preferred an appeal before the Supreme Court.

JUDGEMENT

The court after going through the oral and documentary evidences observed that the lower courts have erred in giving the conviction orders. The evidences on the brother-in-law and sister-in-law torturing the deceased could not be proved beyond reasonable doubts. Further, the appellants used to reside in a different village and they had no common intention with the husband for committing the crime. Accordingly, the conviction orders were set aside.

9. RAJESH SHARMA & OTHERS V. STATE OF U.P.[xii] (2017)

FACTS

Sneha’s father gave dowry to Rajesh at the time of their marriage. Rajesh was not happy with the amount of dowry given and hence started abusing his wife. Sneha filed a case under Section 498A of IPC against her husband and his relatives. The present appeal was filed by the relatives seeking for certain directions to prevent the misuse of Section 498A of IPC. The main contention was that in most of the cases, all family members are dragged to settle a matrimonial dispute even when they are not party to the case.

JUDGEMENT

The Supreme Court gave the following directions:

Family Welfare Committee:

Investigating Officer: The Investigating Officer for complaints under Section 498A should undergo a training of four months for such duration (not less than one week) as may be considered appropriate.

Bail: When a bail application is filed to the Public Prosecutor/complainant with a day’s notice then it must be decided on the same day. Recovery of disputed dowry items cannot be regarded as a ground of bail if maintenance or other rights of wife/minor children can be protected.

NRIs: Impounding of passports or issuing Red Corner Notice must not be a routine for NRIs.

Video Conferencing: Personal appearance of all family members and particularly outstation members may not be required and the trial court can grant exemption and permit video conferencing.

The Court observed that large number of cases under Section 498A on trivial and false issues is a matter of serious concern. Apart from directing the investigating officers and trial courts, involving the civil society in administration of justice can be one of the steps to remedy this situation

10. SOCIAL ACTION FORUM FOR MANAV ADHIKAR & ANOTHER V. UNION OF INDIA MINISTRY OF LAW AND JUSTICE & ORS.[xiii] (2018)

FACTS

 The petition was filed under Article 32 of Indian Constitution seeking uniform system of monitoring and reviewing the cases filed under Section 498A of IPC. It was contended that there are no concrete data specifying that the section has been misused. The social purpose behind Section 498A is being lost as a result of various qualifications and restrictions prescribed by the apex court in case of Rajesh Sharma and others v. State of U.P and another.

JUDGEMENT

The three judge bench referred to the principles laid down in the cases of Joginder Kumar v. State of U.P[xiv], D.K. Basu v. State of W.B[xv], Lalita Kumari v. Government of U.P.[xvi] and Arnesh Kumar v. State of Bihar[xvii] and directed the investigating officers to be careful and be guided by the same.

The Court held that the directions with respect to Family Welfare Committees and their duties are not in accordance with the provision of Code of Criminal Procedure, 1973. The offence of cruelty is a non-bailable and cognizable offence but due to the direction making it impossible to arrest before the report of such committee has made this ineffective. Thus the direction given in Rajesh Sharma case has been modified by the court.

[i] Section 498A of Indian Penal Code, 1860

[ii] “Crime in India 2013 statistics” Published by National Crime Records Bureau

[iii]https://timesofindia.indiatimes.com/city/delhi/Misuse-of-dowry-provisions-is-legal-terrorism Court/articleshow/7615680.cms

[iv] Kans Raj v. State of Punjab, AIR 2000 SC 2324

[v] Sushil Kumar Sharma v. UOI, (2005) 6 SCC 281

[vi] Neelu Chopra & Anr. v. Bharati, AIR 2009 SC(Supp) 2950

[vii] Manju Ram Kalita v. State of Assam, (2009) 13 SCC 330

[viii] Preeti Gupta & Anr v. State of Jharkhand, (2010) 7 SCC 3363

[ix] Bhaskar Lal Sharma & Anr. v. Monica, (2014) 3 SCC 383

[x] Arnesh Kumar v. State of Bihar, (2014) 8 SCC 273

[xi] Bibi Parwana Khatoon @ Parwana Khatoon v. State of Bihar, (2017) 6 SCC 792

[xii] Rajesh Sharma & Ors. v. State of U.P., 2017 SCC OnLine SC 821

[xiii] Social Action Forum for Manav Adhikar & Another v. UOI Ministry of Law and Justice & Ors., (2018) 10 SCC 443

[xiv] Joginder Kumar v. State of U.P., (1994) 4 SCC 260

[xv] D.K. Basu v. State of W.B., (1997) 1 SCC 416

[xvi] Lalita Kumari v. Government of U.P., (2014) 2 SCC 1

[xvii] Supra note x

[xviii] Gian Singh v. State of Punjab, (2012) 10 SCC 303

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INTRODUCTION

The present generation is often targeted by unwanted and harassing phone calls where one person abuses, threatens or hurts the dignity of another. The fact becomes more serious because the person on the other side of the phone call is completely unknown. Such calls come under the purview of criminal offence in India; hence, they must be reported to the concerned authority as early as possible.

According to a report published by “Truecaller” in 2020, almost 8 out of 10 women in India receive harassment and inappropriate sexual phone calls at least once a week. The cities that mostly face these issues are Chennai, Kolkata, New Delhi and Pune. Indian women have the tendency of sharing their contact numbers quite frequently in shopping malls, restaurants, stores, or while filling any forms. However, when it comes to taking actions against such calls, only 12% of women reported it to police and the rest have just blocked the number.[i] Blank calls also amount to harassment. Such calls are mostly anonymously made with the sole purpose of threatening or harassing a person.

According to police sources, after Section 66A of the Information Technology Act, 2000 (punishment for sending offensive messages through communication service, etc.) was struck down by Supreme Court in the year 2015, cases relating to phone call harassment increased immensely.[ii] In one of the cases, a college student repeatedly received obscene messages and phone calls from an unknown number. The police later found out that the number belonged to one of her classmate. As per survey, in most of the cases, the caller was someone known to the victim.[iii]

HOW TO IDENTIFY A HARRASSING PHONE CALL

All unwanted phone calls do not come within the meaning of “harassment”. The factors that are required for an unwanted phone call to become a harassing one are as follows[iv]:

EFFECTS OF HARASSMENT CALLS ON WOMEN

In 2019, Truecaller conducted a survey on 2150 women aged between 15-35 years from 14 different cities. According to the findings, nearly four out of every five women said that they felt irritation and anger due to these harassment calls. One out of every three women said that such calls affected them mentally and they felt frightened, worried or troubled. Further, the affected numbers keeps on increasing every year indicating that more women are getting affected due to such calls.[v]

REMEDIES IN INDIA

The first step that the victim must take against phone call harassment is to inform the police and lodge a complaint in the general diary. The gender of the caller, his voice tone, date and time of the phone call, the conversation details and the estimated age of the caller can be noted by the victim as evidence to help the police in identifying the offender. If the harassment on phone calls continues for a long span of time then the victim must file an FIR.

In India, the provisions under which the harasser can be charged are as follows:

Journalist Barkha Dutt was receiving threat calls for her reportage on JNU; hence she filed an FIR at South Delhi’s Greater Kailash Police Station. Soon, the harasser was identified and a case was registered under Section 354D and 509 of IPC.

WOMEN HELPLINE NUMBERS[vi]

181 (Abhayam Helpline) is solely intended for women. There are female counsellors who will answer the call and take down the details of the harasser. After which, the details will be forwarded by the helpline center to the police who will take further actions of tracing and filing a complaint against him.

1091 is another women’s helpline number throughout the country. Whenever a woman is facing harassment over phone calls, all she needs to do is dial this number after which the police will take necessary actions.

100 is a general number that can be availed by both male and female for reporting a harassing phone call.

POSITION IN OTHER COUNTRIES

The Federal Communications Act, specifically 47 U.S. Code § 223 and several state laws prohibit harassments over phone call and specifies the legal remedies and enforcement mechanisms.[vii]

In California, Penal Code 653m PC prohibits phone calls and messages that are obscene, repeated or threatening and made with an intention of harassing the recipient. Such offences are punishable with imprisonment up to 6 months and a fine up to $ 1000.[viii]

According to Texas Penal Code, the act of using the telephone to ring repeatedly or make anonymous calls with the intention of harassing, abusing and annoying is punishable with imprisonment up to 180 days and a fine up to $ 2000. If the caller has already been charged once harassment then he will be punished with increased imprisonment up to one year and fine up to $ 4000.[ix]

In Canada, Section 264 of Criminal Code provides that repeatedly communicating a person with the intention of harassing or threatening is punishable with an imprisonment of not less than ten years.[x]

CONCLUSION

Although there are laws against harassing phone calls but a person can also tackle these issues in other ways. Not disclosing personal number and other contact details to strangers, random shops and social media can help in lessening the chances of harassments. Another way that most of the Indian women and girls resort to is hanging the call, blocking the number and marking it as spam. However, all such methods are only temporary and it will not stop the harasser from repeating the offence on somebody else. Thus, it is highly recommended that such harasser must be reported at the earliest and strict legal actions should be taken against them to prevent it in future.

[i]Third Edition of “Understanding the impact of harassment calls and SMS for women in India.” [Available at: https://www.business-standard.com/article/pti-stories/8-out-of-10-women-in-india-have-faced-harassment-via-calls-sms-truecaller-120030501544_1.html]

[ii] Harassment of women over phone, The Hindu (Updated on January, 2017)

[iii] Ibid

[iv] Harassing Phone Calls, Information Technology Services. [Available at: https://its.fsu.edu/harassing-phone-calls]

[v] “Stalker alert: 1 in 3 women who use mobiles in India face harassment, receive inappropriate calls”, The Economic Times [Last Updated: March 25, 2019]

[vi] https://indianhelpline.com/WOMEN-HELPLINE/

[vii] How to deal with Telephone Harassment (Legally). [Available at: https://www.lawyers.com/legal-info/personal-injury/types-of-personal-injury-claims/options-telephone harassment.html]

[viii] Penal Code 653m PC.

[ix] Texas Penal Code § 42.07.

[x] Criminal Harassment, The Canadian Resource Centre for Victims of Crime. [Available at https://www.crcvc.ca/docs/crimharass.pdf]

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