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137 Performance Indicators: Working of Magistrates’ Courts in India
Abstract
Magistrates’ courts form the bedrock of the criminal system in the country. Given the high number of criminal cases pending in the subordinate courts, it is important to understand the manner in which magistrates’ courts handle case flow. In this chapter, the author examines the functioning of the magistrates’ courts, in terms of analysing their workload, pendency of cases, and the rate at which they dispose of cases.
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It has been rightly said, ‘You cannot manage what you cannot measure.’1 However, in the Indian scenario one must amend that statement to, ‘You cannot manage what you have never measured.’ Analysing the workload of the judiciary and assessing the productivity of the system helps in managing workflow efficiently, an exercise which is seldom performed within the judicial system by judges.
It is the primary duty of every court to impart justice not only swiftly but also effectively. Though concepts such as ‘justice delayed is justice denied,’ and ‘justice hurried is justice buried,’ are found in most pieces of literature on judicial delay, their application in practice remains a question.
It is therefore important that data-driven studies that aim to understand the workload of the courts be conducted, so that policy interventions can be focused and meaningful. This chapter examines the efficiency and workload of magistrates’ courts through various performance indicators, providing insight into the working of the magistrates’ courts in India.
In All India Judges’ Assn. (1) v. Union of India,2 the Supreme Court, while highlighting the responsibilities of trial court stated, ‘The trial judge is the kingpin in the hierarchical system of administration of justice. He directly comes in contact with the litigant during the proceedings in court. On him lies the responsibility of building up of the case appropriately and on his understanding of the matter the cause of justice is first answered.’
If one were to prepare a list of the courts with the most number of cases pending in the country, there is no doubt that the list would be dominated by the magistrates’ courts.3 The number of criminal cases pending across the country is twice that of civil cases. Figure 1 shows the proportion of civil and criminal cases, as per the data collected from the National Judicial Data Grid (NJDG).4
Figure 1. Percentage of Civil and Criminal Cases in Subordinate Courts
Note: Data Collected from NJDG as on 5 July 2017.
Figure 1 clearly illustrates that criminal cases dominate the dockets of subordinate court judges. With such a high percentage of pending criminal cases it will be useful and interesting to examine the performance of magistrates’ courts dealing with criminal cases.
Data Collection
The NJDG’s website provides information on the number of cases pending in the subordinate courts across the country. The information on the website is provided at various levels — the state level, district level, court establishment level, and the judge level. In this chapter, the data is analysed at the court establishment level (courts).5
To select the magistrates’ courts with the highest number of pending cases, a list of all the courts and the corresponding number of pending cases was obtained from the NJDG.6 All of the 10 courts chosen for the study had more than one lakh cases pending as on 29 March 2017. Given the enormous data, the focus of this chapter is limited to only 10 courts, which are:
1. Metropolitan Magistrate Court, Ahmedabad, Gujarat.
2. Civil Court, Vadodara, Gujarat.
3. Metropolitan Magistrate Court, Calcutta, West Bengal (WB).
4. Chief Metropolitan Magistrate Court, Kanpur Nagar, Uttar Pradesh (UP).
5. Chief/Additional Chief Metropolitan Magistrate Court, Jaipur Metro Headquarters (HQ), Rajasthan.
6. Chief Judicial Magistrate Court, Allahabad, Uttar Pradesh (UP).
7. Chief Judicial Magistrate Court, Nagpur, Uttar Pradesh (UP).
8. Chief Judicial Magistrate Court, Ghaziabad, Uttar Pradesh (UP).
9. Civil Court, Surat, Gujarat.
10. Chief Judicial Magistrate Court, Pune, Maharashtra.
139 Once the 10 courts were chosen, additional data in terms of number of cases pending per judge, and total number of cases filed and disposed in the previous month was entered manually for these courts between 29 March 2017 and 15 July 2017 from the NJDG.
To evaluate court performance, various metrics can be used for a ‘balanced scorecard of a court’s or court systems performance’.7 For this purpose, several performance indicators have been proposed in different studies. To mention a few, the International Consortium for Court Excellence has designed the ‘International Framework of Court Excellence’, a quality management system which helps in improving court performance.8 It has consolidated 11 performance indicators based on which the performance of courts can be judged.9 Additionally, the National Court Management Systems in India have come up with set of performance standard indicators in the National Framework for Court Excellence.10 In this chapter, I use some of these indicators to assess the performance of the chosen courts. My aim in the chapter is not to rank these courts, but to analyse their performance.
Figure 2 contains details of the chosen magistrates’ courts and number of cases pending before each of them as on 29 March 2017.
Figure 2. Number of Cases Pending in the Chosen Courts
Note: (i) Data collected from NJDG as on 29 March 2017. (ii) Though their names suggest otherwise, Civil Court, Vadodara and Civil Court, Surat include judicial magistrates (magistrates have been referred to as judicial magistrates in this chapter) and that is the reason that these courts have been chosen in the study.
STRUCTURE OF MAGISTRATES’ COURTS
First Class Magistrates are at the grassroot level in the judicial structure. Sections 12 and 17 of the Code of Criminal Procedure (CrPC), 1973 define the role of the Chief Judicial Magistrate (CJM) and the Chief Metropolitan Magistrate (CMM), respectively. In terms of powers and superintendence over magistrates, both the CJM and the CMM enjoy equal status, with the only difference being the area in which they operate.11 According to Section 8 of the CrPC, the state government may notify any city or town to be a metropolitan area when its population exceeds 10 lakhs.
140 Hence, in a metropolitan area the term CMM is used, and in the remaining areas, the term CJM is used. According to CrPC, the High Court has the power to appoint any First Class Magistrate to be the CJM or the CMM for a given area. In terms of hierarchy all judicial magistrates are subordinate to the CJM or the CMM (as the case may be), who are in turn subordinate to the Sessions Judge. As per Sections 17 and 19 of the CrPC, the CJM and the CMM, respectively, have the power to make rules and distribute business amongst the judicial magistrates subordinate to them.
WORKLOAD AND DISTRIBUTION OF CASES
To understand the workload of individual judges in each of the chosen courts, it is important to examine the distribution of cases amongst the judges. Figure 3 portrays the quantum of cases, in terms of percentage, handled by each individual judge in the 10 courts chosen.
Figure 3. Distribution of Cases Pending with Judges
Note: Data collected from NJDG as on 26 June 2017.
In Figure 3 the blue arc denotes the variance in the distribution of cases across 265 judges in the 10 courts combined.12 Although one might think that the workload of the pending cases is distributed to each of the judges equally, the reality seems to be different. From Figure 3, it can be seen that nearly 50 per cent of the cases pending across the 10 courts are being handled by only 23 per cent of judges. The other 50 per cent of cases are being handled by the remaining judges. Since the distribution is disproportionate, cases get accumulated with a few judges, thus increasing their workload.
However, Figure 3 only provides a broad picture in terms of case distribution, since data is aggregated for all the 10 courts. Individually, each of the courts have a varied case distribution scenario. For instance, in the CMM Court, Calcutta, of the 22 judges, five judges handle 50 per cent of the pending cases, while in CJM Court, Ghaziabad, of the 141 13 judges, only three handle 50 per cent of the total number of cases pending.
In terms of pendency, cases handled by the 10 judges who had the most number of cases pending before them had an average pendency of six years, whereas the cases handled by the 10 judges at the bottom of the list, who had the least number of cases pending before them, had an average pendency of four years. Thus, increasing workload of some judges may be contributing to increasing pendency in these courts.
Proper case distribution is important, since it may affect the pendency of cases. One may argue that judges with better performance and more experience must be given more cases or that a few judges can handle high number of cases, hence distribution may not be equal at all. Although there may be merit in this argument, it must be noted that not all judges are able to perform well with the increasing workload of cases. Even in the current scenario, judges that have more number of cases have a higher average pendency as opposed to judges who have fewer cases. Hence, cases must be allocated to a judge keeping in mind the average pendency of cases of that judge, and the rate at which the judge is disposing of cases.
Figure 4 below provides the percentage of cases pending with the CJM and CMM in each of the 10 courts.
Figure 4. Comparison of Cases Pending with the CJM/CMM
Note: Data collected from NJDG as on 26 June 2017
Each of these courts has one CJM or CMM, who distributes work amongst all the judicial magistrates subordinate to them. As per Figure 4, the CMM in Calcutta, as on 22 June 2017, was handling 27 per cent of the entire workload in that establishment, amounting to 40,383 pending cases. The CJM in Ghaziabad had nearly 25 per cent of the entire workload, with close to 29,000 pending cases.
To put facts into perspective, the CMM of Calcutta is handling more cases than the total number of criminal cases pending before the states/union territories of Chandigarh, Tripura, Andaman and Nicobar Islands, Manipur, Meghalaya, Daman and Diu, Mizoram, and Sikkim combined!
Figure 5 illustrates this clearly.
Figure 5. Comparison of Cases Pending with CMM Calcutta with other States/UTs 142
Note: Data collected from NJDG as on 26 June 2017.
In Figure 5, the orange line indicates the number of judges in each of the states/UTs. In Chandigarh, 50 judges in total handle 38,395 cases.
As a practice, the charge sheet is presented to the CJM or CMM, who peruses the charges and then forwards the same to the judicial magistrates subordinate to him. Thus, the CJM and the CMM not only have the task of deciding cases, but also have to deal with administrative work. Apart from daily court work, CJMs are expected to attend computer training and preside over special courts, such as juvenile courts. Given the amount of administrative work and judicial work, it is only reasonable that more cases be allotted to other judicial magistrates subordinate to the CJM or CMM.
AGEING AND CASE BACKLOG
Assessing the age of pending cases helps in understanding how long they have been pending on the courts’ dockets without final disposal. Average pendency is expressed in terms of the number of elapsed calendar days from the date of the institution of the case to the current date.13 Courts with high average pendency indicate that courts have not been able to dispose cases in a timely manner, thus contributing to the increasing backlog.
At this juncture, it is important to demarcate between cases that are pending and delayed. The 245th Law Commission Report,14 which dealt with the problem of arrears and backlog in the judicial system, defined pendency as cases that have not been disposed, irrespective of the date on which they were filed. Delayed cases on the other hand are cases that have not been resolved and been pending in the the court for a longer time than they are expected to be.
The real question is where the benchmark should be set. What is the upper limit for a case to be pending in the court? Several reports and studies have made an attempt to provide a broad upper limit beyond which a case must not remain pending. The Malimath Committee Report,15 while recommending reforms to the criminal system, suggested that all the cases pending for more than two years be considered delayed. The Jagannadha 143 Rao Committee,16 which was constituted as a result of directions given by the Supreme Court in Salem Advocate Bar Assn. (2) v. Union of India,17 framed a model case flow management system for the High Courts and subordinate courts. The report provides model rules which divides cases into different tracks, based on subject matter. Each track needs to be completed within a specific time frame, the upper limit for which is two years.
In a report on delays in the High Court of Delhi,18 the Vidhi Centre for Legal Policy, adhered to the same standards and presumed cases pending over two years to be delayed. Applying this standard to the 10 courts studied in this chapter, 68 per cent of all cases are pending for more than two years. Hence, these cases can be said to be delayed. Further, in the 10 courts, it was interesting to note the number of cases that were filed before the year 2000 but are still pending in the dockets of the court — let us call it the 20th century backlog.
In Figure 6, the orange bar indicates the percentage of cases that were filed before 2000 and are still pending. The blue bar indicates the average number of years for which these cases have been pending.
Figure 6. Pending Cases Filed Prior to 2000
Note: Data collected from NJDG as on 26 June 2017.
As shown in Figure 6, 15 per cent of the entire workload of all the judges in Civil Court, Vadodara, were cases filed before 2000, with an average pendency of 22.8 years. In CJM Court, Nagpur, 14 per cent of the cases were filed prior to 2000 and are still pending, with an average pendency of 26.3 years.
Let us go a step further and analyse the problem of pendency, case type–wise, in each of the 10 courts studied. Figure 7 compares the average pendency of the most frequent type of case handled by each of the studied courts. The case types chosen from each of the courts represent the maximum number of cases in the corresponding courts.
Figure 7. Average Pendency of Certain Case Types 144
Note: (i) Data collected from NJDG as on 26 June 2017. (ii) Average pendency is expressed in years.
It is seen that Criminal Case, Complaint Case, and Summary Case constitute the maximum workload of the judges. The case types are dependent on the nature of the case and the manner in which criminal proceedings have been initiated. The case type ‘Criminal Case’ is used for cases that are instituted on the report/charge sheet submitted by the police after investigation,19 in cognisable offences,20 whereas ‘Complaint Case’ refers to those cases that are instituted on the basis of private complaints given to judicial magistrates.21 Section 260 of the CrPC defines offences that can be summarily tried, and ‘Summary Cases’, as the name suggests, are speedy trials which must be completed without unnecessary delays and formalities.22
According to data from NJDG,23 the Metropolitan Magistrate Court, Ahmedabad has close to 1,200 Summary Cases with an average pendency of 10 years,24 which is ironically more than the Criminal Cases, which are pending for seven years.25 Also, Figure 7 shows that the CJM Court, Allahabad has the highest average pendency of approximately eight years for Criminal Cases.
Furthermore, in the CMM’s court, Jaipur Metro HQ, 34 per cent of the cases filed under the Negotiable Instruments (NI) Act, 1881 have a high average pendency of nearly four years. As per Section 143 of the NI Act, criminal cases tried by judicial magistrates must be continued on a day-to-day basis until their conclusion. Further, Section 143(3) states that the judicial magistrate shall endeavour to conclude the trial within six months from the date of the filing of the case. However, the cases pending under the NI Act in the CMM’s court, Jaipur Metro HQ have an average pendency which is much higher than the statutorily prescribed guidelines.
Case clearance rate is a determining factor in terms of assessing the inflow and outflow of cases. It indicates whether the courts are able to keep up with the incoming caseload.26
145 If courts clear fewer cases when compared to the number of new cases that are being filed, it is certain that the courts will have a backlog. If the courts continue to dispose fewer cases, the backlog will only increase with the increasing number of new filings. Unless courts improve their clearance rate, their backlog will continue to build.27 Hence, case clearance rate helps in determining future productivity.28
The Australian Government’s Productivity Commission’s Report of Government Services 2012,29 provides the method for calculation of case clearance rate. The report states, ‘The clearance indicator is derived by dividing the number of finalisations in the reporting period, by the number of lodgements (generally, demand for judicial services, case filings or referrals) in the same period. The result is multiplied by 100 to convert to a percentage.’
For example, if in a year a total number of 1,00,000 cases have been filed and the court has been able to dispose 95,000 cases then the case clearance rate of the court would be as follows:
|
Clearance rate = |
Total number of cases disposed in a given time frame |
|
Total number of cases filed in a given time frame |
|
Clearance rate = |
95,000 |
x 100 |
|
1,00,000 |
Hence, the case clearance rate of the court is 95. If a court has a case clearance rate of more than 100, it means that the court is able to dispose more cases than that are being filed. Therefore, the court is able to meet the demands of the current case flow.
What happens if the case clearance rate is below 100? In the above example, the court will carry a backlog of 5,000 cases from this year to the next. If the court continues in a similar fashion, then in the next 10 years the backlog will increase to 50,000 cases, which means the court will take about half a year to dispose of the backlog even if no new cases are accepted.30 Figure 8 represents the case clearance rate of the 10 chosen courts.31
Note: Data collected from NJDG as on 20 June 2017
146 A common trend is seen across all the courts. The orange line represents an ideal scenario where the case clearance rate is 100. Only one court, CMM’s court, Jaipur Metro HQ, was able to touch the 100 mark, with a case clearance rate of 101. All of the other courts have backlogs, given that their case clearance rates are below 100. CJM Court, Allahabad has the lowest case clearance rate of 54.
The problems of disproportionate distribution of cases, high average pendency, and clearance rates below 100 are consistent across all the eight courts. One of the reasons for the accumulation of cases is lack of effective case management. Studies have shown that effective implementation of a case flow management system greatly reduces the inventory of pending cases and backlog.32
The National Centre for State Courts, a non-profit organisation working in the sphere of judicial administration in the United States of America, has compiled literature highlighting the positive effects of adopting the case management system. Countries such as Canada,33 United Kingdom,34 and Australia35 have already adopted case management rules.
Case flow management provides regularity and uniformity in case processing, one of the most important attributes required in the current system. It divides cases based on their priority into several tracks and each track has an upper time-limit within which the case must be disposed. Further, in terms of stages, all procedural tasks are allotted to the Court Registrar, keeping only the substantive judicial work for the presiding judge.
In Salem Advocate Bar Assn., while deliberating on the need for case flow management rules, the Supreme Court noted, ‘We hope that the High Courts in the country would be in a position to examine the aforesaid rules expeditiously and would be able to finalise the Rules within a period of four months.’ The case flow management rules were thereafter prepared by the various High Courts on the basis of the recommendation provided by the Law Commission headed by Justice M. Jagannadha Rao.36
Amongst the states from which the 10 courts studied in this chapter were chosen, case flow management rules have been passed in Rajasthan, West Bengal, and Gujarat. The High Court of Rajasthan37 and the High Court of Calcutta38 notified the rules as early as in 2006, whereas the High Court of Gujarat did that only recently, in 2016.39 The courts that have notified the rules clearly mention an upper limit of two years within which a case must be disposed, however cases in these courts are pending for much longer time.40 This shows the lack of implementation of the rules.
There is no doubt that without a concerted effort of the judges and the court staff, process re-engineering is impossible. For case flow management to work, there must be active involvement of the stakeholders who are committed to a shared vision.41 Even the case flow management rules proposed by the Law Commission suggest division of work between the judges and the Registrar.42
It is time that courts play an active role in identifying the problem in their respective systems and establish effective case management, for until a change is brought, the growing backlog will remain a perennial issue associated with the Indian judiciary.
147 Notes
1. Department of Justice, Canada. ‘Guiding Principles for Effective Case Management’, p. 4, available online at http://www.justice.gc.ca/eng/rp-pr/csj-sjc/esc-cde/pdf/eff.pdf (accessed on 10 October 2017).
2. (1992) 1 SCC 119.
3. As per data extracted from the DAKSH database on the number of cases pending per judge in the country as on 29 March 2017, eight of the 10 judges with the highest number of cases pending before them are judicial magistrates.
4. The National Judicial Data Grid (NJDG) is a government-maintained website that provides data in terms of cases pending and disposed in the subordinate courts. It is available online at http://njdg.ecourts.gov.in/njdg_public/main.php (accessed on 10 October 2017).
5. Each of the court establishments studied consists of a group of judges headed by a Chief Judicial Magistrate or a Chief Metropolitan Magistrate.
6. Due to various technical difficulties caused by the NJDG website, data from a few states, particularly Uttar Pradesh, could not be scraped properly. Hence, it is possible that some courts may have been left out.
7. Dan H. Hall and Ingo Keilitz. 2012. Global Measures of Court Performance, International Framework of Court Excellence. Colorado: International Consortium for Court Excellence, p. 5. Available online at http://www.courtexcellence.com/~/media/microsites/files/icce/global%20measures_v3_11_2012.ashx (accessed on 10 October 2017).
8. The website of the International Consortium for Court Excellence is available online at http://www.courtexcellence.com/ (accessed on 10 October 2017).
9. Hall and Keilitz, Global Measures of Court Performance, p. 1.
10. Supreme Court of India. 2013. NCMS Baseline Report on National Framework of Court Excellence. New Delhi: Supreme Court of India. Available online at http://supremecourtofindia.nic.in/pdf/NCMS/National%20Framework%20of%20Court%20Excellence.pdf (accessed on 10 October 2017).
11. S.C. Sarkar. 2012. The Code of Criminal Procedure. New Delhi: LexisNexis Butterworths Wadhwa Nagpur, p. 24.
12. Judges who had more than 1,000 cases pending in the 10 chosen courts were taken into consideration.
13. Hall and Keilitz. Global Measures of Court Performance, p. 34.
14. Law Commission of India. 2014. Report No 245: Arrears and Backlog: Creating Additional Judicial (wo)manpower. New Delhi: Government of India. Available online at http://lawcommissionofindia.nic.in/reports/Report_No.245.pdf. (accessed on 10 October 2017).
15. Committee on Reforms of Criminal Justice System (Malimath Committee). 2003. Committee on Reforms of Criminal Justice System Report. New Delhi: Government of India, Ministry of Home Affairs, p. 164. Available online at http://www.mha.nic.in/hindi/sites/upload_files/mhahindi/files/pdf/criminal_justice_system.pdf. (accessed on 10 October 2017).
16. Jagannadha Rao Committee. 2005. Consultation Paper on Case Management. New Delhi: Law Commission of India, p. 16. Available online at http://lawcommissionofindia.nic.in/adr_conf/casemgmt%20draft%20rules.pdf (accessed on 10 October 2017).
17. (2005) 6 SCC 344 (Salem Advocate Bar Association).
18. Nikita Khaitan, Shalini Seetharam, and Sumathi Chandrasekharan. 2017. Inefficiency and Judicial Delay: New Insights from the Delhi High Court. New Delhi: Vidhi Centre for Legal Policy, p. 8. Available online at https://static1.squarespace.com/static/551ea026e4b0ad ba21a8f9df/t/58db85d25016e15e28a02a56/ 1490781674626/Inefficiency+and+Judicial+Delay_Vidhi.pdf (accessed on 10 October 2017).
19. Section 173, CrPC.
20. Section 154, CrPC.
21. Chapter 14 and 15, CrPC.
22. Sarkar, Code of Criminal Procedure, p. 1183.
23. Data collected as on 26 June 2017.
24. The analysis of the Summary Cases in Metropolitan Magistrate Court, Ahmedabad was carried out separately and therefore it is not represented in the figure.
25. Summary Cases are not displayed in the figure because they do not constitute the maximum number of cases in Metropolitan Magistrate Court, Ahmedabad.
26. Hall and Keilitz, Global Measures of Court Performance, p. 23.
27. Hall and Keilitz, Global Measures of Court Performance, p. 23.
28. Maria Dakolias. 2014. ‘Court Performance Around the World: A Comparative Perspective’, Yale Human Rights and Development Journal, 2(1): 88–142. Available online at http://digitalcommons.law.yale.edu/cgi/viewcontent.cgi?article=1009&context=yhrdlj (accessed on 14 July 2017).
29. Hall and Keilitz, Global Measures of Court Performance, p. 23.
30. Hall and Keilitz, Global Measures of Court Performance, p. 23.
31. 148 Case clearance rate has been calculated on the number of cases filed and disposed between 20 May 2017 and 20 June 2017. Due to paucity of data, Chief Metropolitan Court, Calcutta, West Bengal was not considered.
32. David Steelman, John Goerdt, and James McMillan. 2004. Case Flow Management: The Heart of Court Management in the New Millennium. Virginia: National Center for State Courts.
33. Provincial Court of British Columbia, ‘Criminal Case Flow Management Rules, Youth Criminal Justice Act’, available online at http://laws-lois.justice.gc.ca/eng/acts/Y-1.5/page-1.html#h-2 (accessed on 10 October 2017). See also, Department of Justice, Canada. ‘Guiding Principle for Effective Case Management’, available online at http://www.justice.gc.ca/eng/rp-pr/csj-sjc/esc-cde/pdf/eff.pdf (accessed on 10 October 2017).
34. Part 3 of Practice Directions to the Civil Procedures Rules, available online at https://www.justice.gov.uk/courts/procedure-rules/civil/rules/part03 (accessed on 10 October 2017).
35. Justice Ronald Sackville. 2003. ‘Courts in Transition: An Australian View’, available online at http://www.austlii.edu.au/au/journals/FedJSchol/2003/5.html#fn67 (accessed on 10 October 2017); see also Queensland Courts. 2017. ‘Case flow’, available online at http://www.courts.qld.gov.au/court-users/practitioners/case-flow (last accessed on 10 October 2017).
36. Jagannadha Rao Committee, Consultation Paper on Case Management, p. 16.
37. The Rajasthan Subordinate Courts Case Flow Management Rules, 2006. published vide Notification No. 4/S.R.O./2006/1645, dated 12 September 2006.
38. Case Flow Management Rules, 2006 in the Subordinate Courts,.published vide Notification No. 4680-G, dated 6 December, 2006, by the High Court of Calcutta.
39. The Gujarat High Court Case Flow Management (Subordinate Courts) Rules, 2016, available online at http://gujarathighcourt.nic.in/hccms/sites/default/files/rules_files/CFM_(SUB.CTS_.)_RULES_2016-Gazette_Copy.pdf (accessed on 16 October 2017).
40. The exception is the Rajasthan Subordinate Courts Case Flow Management Rules, 2006 which provides an upper limit for each of the four tracks, but mentions that cases in Track 5 for criminal cases must be disposed as soon as possible. This is a clear deviation from the model rules recommended by the Law Commission, since each track is given an upper limit.
41. Steelman et al., Case Flow Management.
42. Jagannadha Rao Committee, Consultation Paper on Case Management, p. 16.
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