To Right A Wrong - Ju­di­cial Re­course For Home Buy­ers

Re­cent judge­ments and ac­tions against de­fault­ing builders by the ju­di­ciary and the apex court have en­cour­aged buy­ers to ap­proach courts in case of griev­ances and de­vel­op­ers to be more com­pli­ant. Sapna Sri­vas­tava takes stock of the chang­ing sce­nario.

Realty Plus - - Table of Content -

Till very re­cently, the scales be­tween builders and home­buy­ers were tipped in favour of the for­mer. The series of le­gal judge­ments passed, how­ever, seem to be chang­ing this for good. I would call it ‘Right­ing the Wrong”. For long, the buy­ers played the sec­ond fid­dle in the whole ball game of buy­ing a house, hav­ing to fol­low the dik­tat of the builder. The rea­son was they had no quick and ef­fi­cient re­course. With the im­ple­men­ta­tion of RERA and the ju­di­ciary across states be­com­ing more proac­tive in pro­vid­ing fast and com­pe­tent ac­tions against er­rant builders, the cur­rent sce­nario is chang­ing for the bet­ter of the en­tire real es­tate sec­tor.

The pro­fes­sional and well or­ga­nized de­vel­op­ers feel that now it is a level play­ing field for all, as com­pli­ant de­vel­op­ers will not be at a dis­ad­van­tage. This has also en­hanced the

While, the courts have fi­nally re­al­ized the ne­ces­sity of a bal­anced play­ing field be­tween de­vel­op­ers and home­buy­ers, there still re­main sev­eral la­cu­nae in the laws. Also many from the in­dus­try point out, that the ut­most in­ter­est of a buyer in ap­proach­ing the court is to get the home promised. Hence, the courts, con­sumer tri­bunals and RERA bod­ies would need to adopt a con­cil­ia­tory ap­proach to deal with the is­sues be­tween the builders and the buy­ers. KK Ra­mani a vet­eran ad­vo­cate, who has han­dled some very high pro­file real es­tate lit­i­ga­tions, raised some very per­ti­nent points. “Real es­tate sec­tor had come to a sit­u­a­tion where there was a need for a dras­tic surgery. An ef­fec­tive de­ter­rence to serve as ex­am­ple of pos­si­ble con­se­quences was a must to send a proper mes­sage within the sec­tor, for restor­ing the con­fi­dence of hap­less con­sumers. It goes with­out say­ing that harsh puni­tive ac­tion should pre­cede a thor­ough in­ves­ti­ga­tion and fair ap­praisal of facts to en­sure that only the de­fault­ers are pun­ished, and the pun­ish­ment is com­men­su­rate with the ef­fects of de­fault,” he said. Arad­hana Bhansali, Part­ner, Ra­jani As­so­ciates has 15 years of ex­pe­ri­ence in real es­tate mat­ters. She ex­pressed her opin­ion on the tough stand, be­ing taken by the ju­di­ciary and quasi-ju­di­cial au­thor­i­ties against de­fault­ing de­vel­op­ers. “Home­buy­ers can­not be just thrown into a fry­ing fan. The flat buy­ers should get their dues. We would like to know the pro­file of the in­di­vid­u­als as­so­ci­ated with the com­pany, which is will­ing to take over the projects”. This is what the Supreme Court re­marked when an­other builder was ready to take up the project left in­com­pleted by Am­ra­pali builder. In the re­cent past, the ju­di­ciary in­clud­ing the reg­u­la­tory author­ity un­der the Real Es­tate Act, 2016 (RERA) have taken proac­tive steps to pro­tect and pro­vide re­lief to home­buy­ers. Even the per­son who is step­ping in the shoes of an erring de­vel­oper is asked to show/ prove its bonafides so that the home buyer’s rights are pro­tected and di­luted in any man­ner. The clas­sic case of Jaypee De­vel­op­ers, Unitech, Omkar De­vel­op­ers to name a few, are ex­am­ples of courts com­ing to the aid of home buy­ers and have even di­rected in­sol­vency pro­ceed­ings to take into con­sid­er­a­tion the rights of the home­buy­ers. The days of er­rant de­vel­op­ers cheat­ing, de­lay­ing pos­ses­sion and arm twist­ing the home buy­ers have long passed. Now, more than ever, home buy­ers have a right to timely pos­ses­sion, de­liv­ery of their dream homes, to­gether with the ameni­ties and fa­cil­i­ties, to en­joy their in­vest­ment with­out be­ing ha­rassed and fooled by er­rant de­vel­op­ers.” Ex­press­ing her views, Divya Mal­colm, Prin­ci­pal As­so­ciate, Kochhar & Co said, “The ju­di­ciary is not on a witch-hunt for builders. Er­rant and delin­quent de­vel­op­ers have been brought to book. The re­spon­si­ble de­vel­op­ers are, in fact, reap­ing rich div­i­dends. For them, the mar­ket­place is be­com­ing a level play­ing field. Cheat­ing and fraud­u­lent prac­tices can­not be com­pared to the hard­ships wrought by busi­ness cy­cles. News of de­vel­op­ers forg­ing own­er­ship doc­u­ments or en­croach­ing upon

con­fi­dence among re­luc­tant buy­ers to make pur­chases that will help boost sales for the sec­tor. More im­por­tantly, the strict ac­tions against de­viant or­ga­ni­za­tions will help clean up the in­dus­try, leav­ing only the qual­i­fied com­pa­nies to oper­ate in a process driven en­vi­ron­ment.

ad­join­ing lands is sur­fac­ing. In some in­stances, the de­vel­op­ers had over­stretched their po­si­tion. These are the types that have to be weeded out of the sys­tem - and the ju­di­ciary is do­ing a com­mend­able job.” Vivek Daswaney, Part­ner – In­dus­law, a mul­ti­spe­cialty law firm brings up a ma­jor point of con­tention - that is the “In­sol­vency and Bank­ruptcy Code, 2016” (IBC). The IBC al­lows the cred­i­tors of the real es­tate de­vel­oper, to make an in­sol­vency ap­pli­ca­tion be­fore the Na­tional Com­pany Law Tri­bunal (“NCLT”) and ini­ti­ate in­sol­vency res­o­lu­tion pro­ceed­ings against the com­pany. Dur­ing these res­o­lu­tion pro­ceed­ings, the pro­mot­ers lose con­trol over their Com­pany and an in­sol­vency res­o­lu­tion pro­fes­sional (IRP) is ap­pointed to take over the reins of the Com­pany. If this res­o­lu­tion plan fails, liq­ui­da­tion pro­ceed­ings are ini­ti­ated which are in­tended to es­sen­tially wind up the Com­pany. A ques­tion arises as to what hap­pens to the rights of the home buyer in such a sce­nario. “The IBC con­tem­plates two kinds of cred­i­tors - fi­nan­cial and op­er­a­tional. Fi­nan­cial cred­i­tors are those who have given debts to the Com­pany in the na­ture of loans, deben­tures, etc. Whereas op­er­a­tional cred­i­tors are those to whom money is to be paid for the goods or ser­vices pro­vided by such per­sons. One of the big­gest ques­tions aris­ing, is whether or not a home buyer will be con­sid­ered to be an op­er­a­tional cred­i­tor un­der the IBC. The NCLT has held in mul­ti­ple cases that home buy­ers are mere al­lot­tees of flats and not op­er­a­tional cred­i­tors of the Com­pany. How­ever, the courts have also held that, if the Com­pany agrees to give a pe­ri­odic as­sured re­turn to the home buyer, the home buyer will then be con­sid­ered to be a fi­nan­cial cred­i­tor. In the Jaypee case, the apex court took note of this anom­aly and sought clar­i­fi­ca­tion from the Cen­tral Govern­ment. In the back­drop of this chaos, the Min­istry of Hous­ing and Ur­ban Af­fairs is­sued a cir­cu­lar, in­tro­duc­ing a new cat­e­gory of cred­i­tors and sev­eral ex­perts, who are of the view that home buy­ers would fall un­der the head of this new cat­e­gory of “other cred­i­tors”. The IBC pro­vides that an in­sol­vency ap­pli­ca­tion can be made by a fi­nan­cial cred­i­tor, an op­er­a­tional cred­i­tor or the Com­pany it­self. There­fore, if the home buyer is des­ig­nated as an “other cred­i­tor”, it would mean that while the home buyer can­not ini­ti­ate in­sol­vency pro­ceed­ings, they can get a piece of the pie, if the Com­pany is liq­ui­dated. Even then, the home buyer is en­ti­tled to a piece of the pie only af­ter fi­nan­cial cred­i­tors, work­men, em­ploy­ees, op­er­a­tional cred­i­tors and the govern­ment have re­ceived their dues. This begs the ques­tion­whether or not the home buyer will get any­thing at all? As­sum­ing the home buyer does get recog­nised as a fi­nan­cial cred­i­tor by fic­tion of law, the ques­tion then arises - what would be their rights and obli­ga­tions vis-à-vis the other lenders and cred­i­tors, who will then have a jus­ti­fi­able ar­gu­ment of tak­ing a much higher risk com­pared to the home buyer and should there­fore have pri­or­ity,” stated Daswaney.

rera im­ple­men­ta­tion

The Real Es­tate Act, 2016 (RERA), is a fairly new leg­is­la­tion which is a cen­tral en­act­ment to build trans­parency, ac­count­abil­ity and also safe­guard the in­ter­est of gen­uine home­buy­ers. RERA is a bold leg­is­la­tion with a lot of em­pha­sis on pro­ce­dure, dis­sem­i­na­tion of in­for­ma­tion and build­ing ac­count­abil­ity for devel­op­ment of var­i­ous projects. Al­though some states are more proac­tive than oth­ers, over­all there is a sen­ti­ment of con­fi­dence, that this will boost the in­dus­try, cre­ate sta­bil­ity, pro­mote healthy com­pe­ti­tion and en­sure projects are com­pleted as ad­ver­tised. So that there are fewer de­lays and a planned and bal­anced growth of real es­tate across the coun­try can be achieved. Even­tu­ally, this can be achieved with planned and bal­anced growth of real es­tate across the coun­try. By and large RERA has been in­stru­men­tal in in­tro­duc­ing fair­ness, trans­parency and pro­fes­sion­al­ism in the hith­erto chaotic sec­tor. Putting rel­e­vant in­for­ma­tion in pub­lic do­main and the in­sti­tu­tion of the Author­ity for speedy re­dres­sal of griev­ances has gone a long way in as­sur­ing the cus­tomers a fair deal con­sis­tent with their agree­ments, with the pro­mot­ers.

The lat­est re­port of the In­sol­vency law Com­mit­tee has rec­om­mended home buy­ers to be treated as fi­nan­cial cred­i­tors un­der the IBC, since in essence; the amounts paid by the home buy­ers are a means of rais­ing fi­nance.

There are nine states that have not yet set up RERA au­thor­i­ties and de­vised the web­site, which means RERA is a to­tal non-starter in those states. This is highly dis­crim­i­na­tory against the home buy­ers in those states, who are de­prived of the pro­tec­tion granted by the Act. “Uni­for­mity in rules is de­sir­able, but on ac­count of dif­fer­ent mu­nic­i­pal laws, pre­vail­ing state laws and trade prac­tice in dif­fer­ent states it may not be pos­si­ble to have ab­so­lute uni­for­mity in rules. It is nec­es­sary to at least en­sure, that the Rules and Reg­u­la­tions framed un­der the Act re­main within the let­ters and spirit of the law,” com­mented

Ad­vo­cate Ra­mani. RERA be­ing a cen­tral en­act­ment, all states were ex­pected to have proper and com­plete ma­chin­ery for im­ple­men­ta­tion of the de­sired ob­ject in terms of RERA. How­ever, each state hav­ing its own dif­fi­culty in set­ting up the en­tire of­fice in terms of RERA, even af­ter a year since RERA has been in full ef­fect.

Bhansali con­tends that, while this may af­fect the rights of the home buy­ers in those states, over­all, RERA has been ef­fec­tive in driv­ing a pos­i­tive change in the real es­tate sec­tor, by bring­ing more ac­count­abil­ity, trans­parency and also en­sur­ing that the dead­lines for com­plet­ing are met, ex­cept in cases of gen­uine de­lays and prob­lems. “One would ex­pect that the other states will fol­low suit, so that the de­sired re­sults are seen pan In­dia .How­ever as the im­ple­men­ta­tion has been given to each state, there will be some dif­fer­ences and de­lays and of­ten times non uni­for­mity, as each state will give it its own flavour and cre­ate a sys­tem of gov­er­nance within its ex­ist­ing struc­ture. This does not mean that the leg­is­la­tion has been weak­ened by such de­lays, but it pro­vides for dif­fer­ent flavours of the en­act­ment, best suited for the re­quire­ments of the states,” she said. On a pos­i­tive note Mal­colm stated, “Un­der our Con­sti­tu­tion land is a state sub­ject. There are bound to be lo­cal nu­ances which can­not be flat­tened overnight. In the con­text of RERA, dif­fer­ent state rules can­not sabotage the main statute. If, by way of del­e­gated leg­is­la­tion, the act is sought to be com­pro­mised, the con­sti­tu­tional va­lid­ity of such leg­is­la­tion can be eas­ily chal­lenged. Flex­i­bil­ity adds to the strength of the ma­chin­ery, it does not di­min­ish it.

Di­lu­tion Of rera

There are in­stances of di­lu­tion of RERA pro­vi­sions by States which go against the spirit of the Act, par­tic­u­larly in ar­eas of on­go­ing projects and with­drawal from spec­i­fied bank ac­counts. Be­ing a Cen­tral Act, a mech­a­nism needs to be de­vised by the Cen­tral Govern­ment, to con­duct a re­view of the Rules framed by the State and in­ter­vene where rules are con­trary to, or not con­sis­tent with the pro­vi­sions of RERA. Bhansali elab­o­rates. “As per RERA, an on-go­ing project is ba­si­cally a project for which the com­ple­tion cer­tifi­cate has not been is­sued” on the date of com­mence­ment of the Act. How­ever, most of the states di­luted this def­i­ni­tion by stat­ing that any project com­pleted by 60%-70% in all re­spect would not come within the purview of RERA, so that most of the on- go­ing projects were ousted from the ju­ris­dic­tion of RERA. Sim­i­larly, the pro­vi­sions of im­pris­on­ment un­der RERA for not fol­low­ing the or­ders of the com­pe­tent author­ity un­der RERA have been di­luted in most states, by pro­vid­ing for com­pound­ing of of­fences and heavy penal­ties on the de­fault­ing party. While some may say that this di­lu­tion has af­fected the ef­fi­ciency of RERA, in most cases, there has in fact been no such ef­fect, as the com­pe­tent author­ity un­der RERA is proac­tive and pro­vides re­lief to home­buy­ers or the de­vel­oper as the case maybe. Maha RERA (Ma­ha­rash­tra) is quite ac­tive and comes down heav­ily to those stake­hold­ers who are di­lut­ing the core ob­jec­tive of the statute.” Ac­cord­ing to Mal­colm, di­lut­ing RERA will drive away the best of what realty has to of­fer. “SEBI has ad­vanced our se­cu­ri­ties’ mar­ket and not re­tarded it. Sim­i­larly, RERA is merely clear­ing the decks for a stream­lined mar­ket dom­i­nated by re­spon­si­ble play­ers. One as­pect that has not re­ceived enough at­ten­tion is that of the de­vel­op­ers go­ing to RERA for vi­o­la­tion of the Flat Pur­chase Agree­ments by the buy­ers. In cor­rect per­spec­tive, RERA is a win-win sit­u­a­tion. States that choose to get around it, will suf­fer.”

rera ef­fec­tive­ness

RERA be­ing a new leg­is­la­tion is evolv­ing. RERA pre­scribes strict penal­ties for the de­vel­oper, who fails to com­plete the project on time as also for agents who ad­ver­tise and sell in­ven­tory with­out a proper reg­is­tra­tion. Ad­vo­cate Ra­mani men­tioned, “So far RERA has been mainly con­cen­trat­ing on re­dress­ing the cus­tomers griev­ances of the al­lot­tees and en­sur­ing due com­pli­ance by the pro­mot­ers. In do­ing so, the ap­proach of MAHARERA has been to set­tle griev­ances am­i­ca­bly within the frame­work of the Act. The thrust has been to bring pro­mot­ers and al­lot­tees on a com­mon plat­form. It is how­ever ob­served that, in some cases when the delay in com­ple­tion is caused by Air­port Author­ity, En­vi­ron­ment Clear­ance Author­ity

and Mu­nic­i­pal Cor­po­ra­tion, the pro­mot­ers are sub­jected to harsh levy for the mis­takes or neg­li­gence of these au­thor­i­ties. In such cases the Reg­u­la­tory Author­ity ought to adopt le­nient at­ti­tude to­wards pro­mot­ers. For­ma­tion of Con­cil­i­a­tion and Dis­pute Res­o­lu­tion Fo­rum to fa­cil­i­tate res­o­lu­tion of dis­putes am­i­ca­bly, is an im­por­tant step which will save the cost and time of all par­ties in­volved in lit­i­ga­tion.” Bhansali adds, “Also, as per RERA, a model for­mat for agree­ments is pre­scribed, to bal­ance the re­la­tion­ship be­tween home­buy­ers and de­vel­op­ers. If the norms un­der the agree­ment are di­luted in any man­ner what­so­ever, the reg­u­la­tor has come down heav­ily on the de­vel­oper by di­rect­ing the de­vel­oper to be in con­so­nance of the regime. All this en­sures that de­vel­op­ers do not ex­ploit the home­buy­ers and in­sert clauses which are to­tally one sided. The home­buyer has the re­lief of rais­ing his con­cerns be­fore the author­ity and most times, an am­i­ca­ble set­tle­ment is ar­rived at to en­sure that the project is on track and com­pleted and the home­buy­ers are given the apart­ment as per what was promised to them.” Mal­colm, ap­pre­ci­at­ing the ef­fec­tive­ness of Maha RERA said, “When RERA was set-up in Ma­ha­rash­tra, last year, we all summed it up as Realty has got its SEBI. Hope­fully, deal­ing in real es­tate will soon be as sim­ple as trans­act­ing in shares. In­deed, MAHARERA is do­ing an ex­cel­lent job at be­ing realty’s SEBI. Most im­por­tantly, only if a data bank cap­tur­ing the ac­tual value of real es­tate is cre­ated, can we go to the next level of REITS. Lax­ity in the im­ple­men­ta­tion of RERA, is a self-de­feat­ing propo­si­tion. For­eign play­ers or do­mes­tic funds would not in­vest in mar­kets which are all smoke and mir­rors. Maha RERA’S ef­forts have been ex­em­plary in this sphere. Most of its or­ders have been bal­anced and even-handed. Many cases have been set­tled out-of-court. MAHARERA has re­cently set up a con­cil­i­a­tion fo­rum, so that the flat pur­chasers and builders can talk things through. To­day, it’s talk­ing about map­ping the reg­is­tered projects by us­ing GIS tech­nol­ogy. A proac­tive fo­rum for healthy di­a­logue has been cre­ated. Both the de­vel­op­ers as well as the flat pur­chasers are go­ing through a rough time. For in­stance, many flat pur­chasers at the time of book­ing had not fac­tored in the rise in in­di­rect tax from 1% to 12%. Mid­dle classes are un­able to ab­sorb such a hike. If all the flat pur­chasers ex­er­cise their op­tion to with­draw from a project, no build­ing will ever get com­pleted. There­fore, now is the time for greater di­a­logue than ever be­fore.”

anom­alies in rera

Re­cently, the Bom­bay High Court while hear­ing a batch of pe­ti­tions, chal­leng­ing the con­sti­tu­tional va­lid­ity of var­i­ous pro­vi­sions of RERA, ques­tioned the in­ap­pli­ca­bil­ity of RERA on in­di­vid­u­als who form a so­ci­ety and pur­chase a plot, to con­struct flats and apart­ments for their very own mem­bers. Such so­ci­eties need not regis­ter them­selves un­der RERA. Cur­rently, RERA ap­plies only on pro­mot­ers who ad­ver­tise their real es­tate projects for the pur­pose of sell­ing it to con­sumers. The au­thor­i­ties can­not take any ac­tion against the projects which are not reg­is­tered with RERA. The court sought clar­i­fi­ca­tion from the govern­ment that, if so­ci­eties are con­struct­ing apart­ments and sell­ing them to their very own mem­bers, then they would be­come the pro­mot­ers. So, RERA should ap­ply on them too. “What if in the garb of form­ing a so­ci­ety, a pro­moter sells off the flats and earns profits? Given the RERA pro­vi­sion that the so­ci­ety need not regis­ter, then does the author­ity have the pow­ers to take any cog­nizance post this mis­chief? Since the RERA comes in ef­fect only af­ter reg­is­tra­tion of a project, then what if such so­ci­eties are not reg­is­tered un­der the Act.” An­other ques­tion aris­ing, is that of con­trol in case of in­sol­vency pro­ceed­ings. The In­sol­vency and Bank­ruptcy Code (IBC) pro­vides that, when an in­sol­vency ap­pli­ca­tion has been ad­mit­ted against a Com­pany, the con­trol over the Com­pany has been taken over by the in­sol­vency res­o­lu­tion pro­fes­sional (IRP). Even though RERA does not pro­vide that the Author­ity can take over con­trol of the project and com­plete it when the Com­pany is in­sol­vent, it is safe to as­sume that in­sol­vency of the Com­pany will lead to him breach­ing his obli­ga­tions un­der RERA. Daswaney ex­plains, “Sev­eral ex­perts have pointed out the con­flict be­tween the IRP and the Author­ity. Some how­ever feel oth­er­wise, as RERA does not al­low the Author­ity to take over con­trol of the Com­pany, but only of the projects reg­is­tered un­der RERA. The IRP on the other hand will take over con­trol of the en­tire Com­pany. How the IRP and the Author­ity will work to­gether, is yet to be seen. But one can fairly imag­ine that it will not be smooth sail­ing, es­pe­cially for the home buy­ers who may be a dis­jointed com­mu­nity in the whole pro­ceed­ings.” While RERA is in­deed a game changer, there are some ar­eas of con­cerns that de­vel­op­ers list. For in­stance, there is no pro­vi­sion for sin­gle-win­dow clear­ance of ap­provals, which is the sin­gle-most

im­por­tant re­quire­ment to cut de­lays. There is no clar­ity on the dis­tinc­tion be­tween Oc­cu­pancy Cer­tifi­cates and Com­ple­tion Cer­tifi­cate. Also, un­less land rates are based on books of ac­counts, all costs in­curred prior to start­ing of projects would not be added and Joint ven­ture agree­ments would be ad­versely im­pacted. Also, the stip­u­la­tion that sanc­tioned plans must be posted on web­sites would raise is­sues of In­tel­lec­tual Prop­erty Rights.” Milind De­ora, for­mer Mem­ber of Par­lia­ment also in his col­umn in a pub­li­ca­tion had men­tioned cer­tain am­bi­gu­i­ties, re­quir­ing ap­pro­pri­ate amend­ments and cor­rec­tions. He had stated, “RERA puts the onus on de­vel­op­ers to com­plete projects in a timely and ef­fi­cient man­ner, grant­ing con­sumers the right to hold de­vel­op­ers ac­count­able. How­ever, in or­der for them to hon­our their end of the deal, they nec­es­sar­ily re­quire a way to hold bu­reau­crats and politi­cians ac­count­able, who can of­ten hold up their projects due to po­lit­i­cal rea­sons, bu­reau­cratic red­tapism, and bribe-seek­ing. To hold bu­reau­crats ac­count­able, states must have clear, con­cise and un­am­bigu­ous guide­lines for real es­tate devel­op­ment and puni­tive mea­sures for any of­fi­cials who delay de­vel­op­ments for il­le­git­i­mate rea­sons. The real es­tate busi­ness is a mas­sive em­ployer in In­dia, and when it does well, not only does con­struc­tion boom, but also do ce­ment, steel, fur­ni­ture, and other al­lied in­dus­tries. RERA is, af­ter all, a Cen­tral law, and the govern­ment at the Cen­tre must in­ter­vene and put pres­sure on states to en­sure that its pro­vi­sions are ad­e­quately im­ple­mented.” In spite of all the de­fi­cien­cies and lim­i­ta­tions of RERA, it is heart­en­ing to see that the courts and Na­tional Con­sumer Dis­putes Re­dres­sal Com­mis­sion as well as State’s re­spec­tive RERA bod­ies are tak­ing tough stand and set­ting prece­dent in terms of get­ting quick re­lief to the ag­grieved party. In short the buy­ers can no longer be taken for a ride by the builder. For de­vel­op­ers, it means an op­por­tu­nity to put their house in or­der. One can al­ready see a lot of con­sol­i­da­tion and joint ven­tures hap­pen­ing in the sec­tor and that bodes well for the In­dian real es­tate in the long term.

arad­hana Bhansali

KK ra­mani

Divya mal­colm

vivek Daswaney

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