Civil SLP in Supreme Court of India: Article 136, 90-Day Limitation, Stay, Status Quo, Additional Documents & Procedure 2026
Supreme Court of India • Civil SLP • Article 136 • 90-Day Limitation • Interim Stay • Status Quo • Additional Documents • Concurrent Findings • Pan-India Civil Litigation
A Civil Special Leave Petition (SLP) is the principal constitutional route by which a person, company, institution or public authority asks the Supreme Court of India to examine a civil judgment, decree, determination or order passed by a High Court or another qualifying court or tribunal. The power arises under Article 136 of the Constitution of India and is extraordinary and discretionary. A Civil SLP is not an automatic second or third appeal.
Because Article 136 operates nationally, a Civil SLP may arise from any High Court in India and from qualifying tribunals, subject to the governing statute and the constitutional exception in Article 136(2). The case may concern property, contracts, service law, family disputes, commercial litigation, arbitration-related questions, consumer disputes, tenancy, succession, injunctions, public employment or another civil controversy.
This article focuses specifically on Civil SLP practice in the Supreme Court: limitation, Form 28, interim relief, status quo, stay, additional documents, concurrent findings, caveats, Registry defects, grant of leave and the transition from SLP to civil appeal.
Quick legal position
- A Civil SLP is ordinarily filed under Article 136 of the Constitution of India.
- Special leave is discretionary; the Supreme Court does not function as a routine additional appellate court.
- Under Order XXI Rule 1 of the Supreme Court Rules, a Civil SLP is ordinarily filed within 90 days from the judgment or order sought to be challenged.
- Where a qualifying certificate of fitness to appeal has been refused by the High Court, the ordinary period is 60 days from the refusal, subject to Order XXI and the Limitation Act.
- The petition is filed in Form 28.
- Order XXI provides that no separate application for interim relief need be filed merely for the interim relief claimed in the SLP; the interim prayer is incorporated in Form 28. Separate applications may still be required for distinct procedural relief such as delay, additional documents, exemption or impleadment.
- Filing a Civil SLP does not automatically stay the High Court judgment or order.
- A petitioner may seek stay, status quo, restraint against alienation, protection from coercive recovery, stay of dispossession, stay of contempt or other narrowly tailored interim relief depending on the case.
- The SLP is ordinarily confined to the pleadings and record below.
- If a document was not part of the lower-court record, Order XXI requires a separate application explaining why it was not produced earlier and why production in the Supreme Court is necessary.
- The Supreme Court ordinarily does not interfere with concurrent findings of fact unless the case demonstrates perversity, statutory error, violation of natural justice, disregard of material evidence or substantial and grave injustice.
- In Bhola Nath v. State of Jharkhand, 2026 INSC 99, the Supreme Court restated this Article 136 standard in a civil appeal arising from SLPs.
- If special leave is granted, the SLP proceeds as a civil appeal.
What is a Civil SLP?
A Civil SLP is a petition asking the Supreme Court to grant special leave to appeal against a civil judgment or order. The petitioner first has to persuade the Court that the case merits entry into its appellate jurisdiction under Article 136. Only after special leave is granted does the proceeding become an appeal.
This distinction matters because Article 136 is not a general right of appeal. A Civil SLP should therefore explain not only why the judgment below is wrong, but why the error is sufficiently serious to justify Supreme Court intervention.
For the broader constitutional framework, see the pillar guide: Special Leave Petition in Supreme Court of India: Article 136, Limitation, AOR Filing & Procedure.
What kinds of civil matters can reach the Supreme Court through SLP?
Depending on maintainability and the applicable statute, Civil SLPs commonly arise from:
- property title, possession, injunction and specific-performance disputes;
- civil suits and first or second appeals;
- commercial and contractual disputes;
- arbitration-related judgments where Article 136 is otherwise available;
- company and insolvency matters where the statutory route permits or Article 136 is invoked;
- service-law and public-employment judgments;
- family and matrimonial judgments;
- guardianship and custody orders;
- consumer disputes;
- land acquisition and compensation matters;
- tenancy and rent-control disputes;
- succession, probate and inheritance matters;
- co-operative society and statutory authority disputes;
- tax or regulatory matters where the correct appellate route has first been identified;
- writ judgments involving civil rights;
- orders concerning interim injunctions, receiver appointments, possession or status quo in exceptional cases; and
- orders of civil tribunals and quasi-judicial bodies falling within Article 136.
Check the statutory appeal route before filing an SLP
Before invoking Article 136, the filing team should determine whether Parliament has created a specific statutory appeal to the Supreme Court. Certain enactments contain direct appeal provisions, special limitation periods or special leave requirements.
A petition styled as an Article 136 SLP should not be used casually where the governing statute provides another route. The correct case type affects limitation, court fee, paper-book requirements and maintainability.
Limitation for Civil SLP: 90 days and 60 days
Order XXI Rule 1 of the Supreme Court Rules provides the basic limitation framework.
| Situation | Ordinary limitation |
|---|---|
| Civil SLP against a judgment or order | 90 days from the judgment/order sought to be appealed from |
| Qualifying refusal by High Court of certificate of fitness to appeal | 60 days from the order of refusal |
The Rule is subject to relevant provisions of the Limitation Act, 1963, including Sections 4, 5, 12 and 14. Certified-copy dates, exclusion periods and the exact procedural history should therefore be examined before finalising limitation.
The current Supreme Court Rules and amendment notifications are available on the official Supreme Court of India website.
Do not calculate Civil SLP limitation from memory
Limitation errors are among the most avoidable Supreme Court filing defects. Immediately after the High Court order, counsel should record:
- date of the impugned judgment/order;
- date certified copy was applied for;
- date the copy became ready;
- date the copy was delivered;
- whether any certificate application was made;
- whether review was filed;
- whether any period is claimed to be excluded under the Limitation Act; and
- the final calculated last date for the SLP.
The Supreme Court also provides an official limitation-calculator facility, but professional filing teams should independently verify the legal computation against the Rules and the facts of the case.
Condonation of delay in a Civil SLP
If the Civil SLP is filed beyond limitation, a separate application for condonation of delay should explain the entire period with dates and supporting material.
A stronger delay application ordinarily addresses:
- certified-copy chronology;
- date of receipt of the High Court judgment;
- steps taken to obtain legal opinion;
- change of counsel, if genuinely material;
- board or institutional approvals where the petitioner is a company or public body;
- medical or other unavoidable circumstances where supported by records;
- review or related proceedings and why they were pursued;
- period attributable to record collection or translation; and
- every material gap in the chronology.
Generic assertions such as “administrative delay”, “file was under process” or “legal opinion was awaited” are weaker than a date-based explanation showing diligence.
Form 28: the prescribed Civil SLP format
Order XXI Rule 3 requires a Civil SLP under Article 136 to be filed in Form 28. Form 28 is not merely a cover page. It structures the petition around the issues the Supreme Court needs to see quickly.
Form 28 includes:
- parties and their position in the court below and the Supreme Court;
- identification of the impugned judgment/order;
- questions of law;
- declaration concerning prior SLPs;
- declaration concerning annexures;
- grounds for special leave;
- grounds for interim relief;
- main prayer; and
- interim prayer.
The current form and filing resources can be checked on the Supreme Court Forms page.
No automatic stay merely because a Civil SLP is filed
One of the most important practical rules is that filing a Civil SLP does not automatically stay the High Court judgment. A judgment may remain operative unless the Supreme Court grants protection.
This can be critical in matters involving:
- possession of property;
- execution of a decree;
- recovery of money;
- demolition or sealing;
- termination of service;
- appointment or promotion;
- transfer of assets;
- corporate control;
- custody or visitation;
- injunctions affecting business operations; or
- creation of third-party rights.
Interim relief in a Civil SLP
Order XXI specifically provides that the interim prayer may be incorporated in Form 28 and that a separate application for interim relief need not be filed merely for that interim prayer.
Depending on the facts, the petitioner may seek:
- stay of operation of the impugned judgment;
- stay of execution proceedings;
- status quo;
- restraint against dispossession;
- restraint against alienation or creation of third-party rights;
- stay of recovery;
- stay of contempt or consequential proceedings;
- stay of termination or coercive service action;
- protection of possession;
- stay of a receiver or administrator order;
- protection against demolition or sealing;
- interim custody or visitation-related protection where legally appropriate; or
- another narrowly tailored order necessary to preserve the subject matter.
How should interim relief be drafted?
An effective interim prayer identifies the precise consequence that will occur if protection is not granted. Instead of seeking a vague “stay of the entire proceedings”, the petition should identify:
- the exact operative direction in the High Court order;
- the date on which it becomes enforceable;
- what irreversible or serious prejudice will occur;
- why later restoration would be inadequate; and
- the minimum order required to preserve the controversy until the SLP is heard.
Status quo versus stay: they are not identical
A prayer for stay ordinarily asks the Court to suspend operation or enforcement of an identified order. A status quo order generally preserves the existing factual or legal position as of a specified point.
The two should not be used interchangeably without analysis. In a property case, for example, “status quo regarding possession and title” may have a different effect from a stay of execution of a particular decree. The petition should state exactly what is to be preserved.
Can a Civil SLP challenge an interim order?
Yes, Article 136 is broad enough to reach interlocutory civil orders, but the Supreme Court ordinarily exercises restraint where proceedings remain pending below and an effective remedy is still available.
An interim-order SLP becomes stronger where the order:
- causes irreversible prejudice;
- effectively decides the dispute despite being labelled interim;
- suffers from jurisdictional error;
- violates binding precedent;
- disregards a statutory limitation;
- results in immediate dispossession or destruction of the subject matter; or
- creates consequences that cannot realistically be repaired after final judgment.
Questions of law in a Civil SLP
The questions of law are central to a well-structured Civil SLP. They should not merely restate factual grievances in question form.
Stronger questions may concern:
- interpretation of a statutory provision;
- conflict between High Court judgments;
- departure from binding Supreme Court precedent;
- jurisdiction of a court or tribunal;
- application of limitation law;
- natural justice;
- constitutional equality or due-process principles;
- incorrect legal test applied to admitted facts;
- scope of appellate interference;
- legal effect of a contract, decree or statutory order; or
- a recurring question of general importance.
Grounds for special leave in a civil matter
A Civil SLP should demonstrate why the Supreme Court should exercise Article 136 discretion. Depending on the case, grounds may include:
- binding Supreme Court precedent ignored;
- statutory provision misconstrued;
- jurisdiction exercised illegally;
- jurisdiction wrongly declined;
- material evidence ignored;
- finding based on no evidence;
- finding contrary to pleadings;
- finding based on irrelevant or extraneous material;
- violation of natural justice;
- manifest arbitrariness;
- perverse appreciation of the record;
- relief granted beyond pleadings;
- serious procedural irregularity affecting the result;
- conflict with settled law; or
- substantial and grave injustice.
Bhola Nath v. State of Jharkhand, 2026 INSC 99
In Bhola Nath v. State of Jharkhand, 2026 INSC 99, decided on 30 January 2026, the Supreme Court considered civil appeals arising from SLPs challenging concurrent High Court judgments in a service-law dispute.
The Court restated that Article 136 confers a wide and discretionary power, but interference with concurrent findings is justified only in exceptional circumstances. The judgment specifically recognised interference where findings are:
- perverse;
- rendered in violation of natural justice;
- in disregard of statutory provisions; or
- such that operation of the impugned judgment would result in substantial and grave injustice.
This is an important 2026 authority because it illustrates the correct way to frame a Civil SLP against concurrent findings: not by asking the Supreme Court to conduct a routine rehearing, but by identifying the legal or perversity threshold that justifies Article 136 intervention.
The official judgment is available from the Supreme Court of India.
Concurrent findings of fact: when will the Supreme Court interfere?
The Supreme Court generally does not reappreciate the entire evidence merely because another factual view is possible. A stronger Civil SLP shows something more serious.
Interference may become arguable where:
- the finding does not arise from the pleadings;
- the finding is wholly divorced from the evidence;
- material evidence was ignored;
- irrelevant material was treated as decisive;
- the conclusion contradicts a statutory provision;
- the conclusion is one no reasonable judicial mind could reach;
- the finding is internally inconsistent;
- the High Court misread a decisive document; or
- the result produces grave injustice.
Second appeal and Section 100 CPC cases
Many Civil SLPs arise from second-appeal judgments. In such cases, the petition should analyse whether the High Court correctly applied the statutory requirement of a substantial question of law under Section 100 CPC.
Potential SLP grounds may include:
- second appeal allowed without a valid substantial question of law;
- substantial question framed but never actually decided;
- concurrent findings reversed without satisfying the Section 100 threshold;
- pure factual reappreciation undertaken in second appeal; or
- a genuine substantial question of law wrongly refused consideration.
Property and possession Civil SLPs
Property SLPs frequently concern title, possession, specific performance, injunction, partition, adverse possession, easements, cancellation of documents or execution.
In such cases, urgent Supreme Court review may focus on:
- irreversible dispossession;
- creation of third-party rights;
- sale or transfer during pendency;
- demolition or alteration of the property;
- execution of a decree before the SLP can be heard;
- incorrect interpretation of title documents; or
- perverse concurrent findings.
Commercial and contractual Civil SLPs
Commercial Civil SLPs should distinguish between a mere contractual disagreement and a legal error justifying Article 136 intervention.
Possible issues include:
- interpretation contrary to settled contract law;
- jurisdiction clause incorrectly applied;
- specific-relief principles misapplied;
- interim injunction contrary to settled standards;
- statutory limitation ignored;
- award or judgment exceeding jurisdiction; or
- commercial consequences so immediate that interim preservation is necessary.
Service-law Civil SLPs
Service-law SLPs may concern appointment, promotion, seniority, disciplinary action, pension, regularisation, reservation, recruitment rules or termination.
Bhola Nath itself arose from service litigation and is particularly useful for understanding how the Supreme Court approaches concurrent High Court findings under Article 136.
Matrimonial and family-law Civil SLPs
Family-law SLPs can arise from divorce, maintenance, custody, guardianship, transfer, foreign-decree recognition and other matrimonial judgments.
Because many such orders are fact-sensitive and discretionary, a stronger SLP identifies the precise legal test wrongly applied rather than reproducing the entire matrimonial history.
For connected reading, see Foreign Divorce Decree Validity in India: Section 13 CPC & Recognition Issues.
Can new documents be filed in a Civil SLP?
Order XXI is strict on this point. A Civil SLP is ordinarily confined to the pleadings and documents that were before the court or tribunal whose order is challenged.
If the petitioner wants to produce a document that was not part of the lower-court record, a separate application should explain:
- what the document is;
- why it was not produced below;
- why it is necessary for the Supreme Court to consider it;
- whether the opposite party had knowledge of it;
- whether its authenticity is disputed; and
- why permitting it would not unfairly convert the SLP into a fresh trial.
The Supreme Court’s current interlocutory-application list separately recognises applications for permission to file additional documents/facts/annexures and for admission of new evidence.
Annexures in a Civil SLP
The Rules require annexures to remain tied to the lower-court record. Filing teams should therefore verify that every annexure:
- was part of the record below, unless separate permission is sought;
- is legible;
- is correctly paginated;
- is arranged chronologically where required;
- is properly certified or affirmed as a true copy where permissible; and
- is actually necessary to support a question of law or ground in the SLP.
Certified copy of the impugned judgment
The Supreme Court Rules contemplate filing of the certified copy of the judgment or order sought to be challenged. If exemption is sought, the filing team should not assume that the exemption is automatic.
As a matter of good practice, the certified-copy application should be made promptly and the receipt retained because the dates may also affect limitation analysis.
List of dates and synopsis
A good Civil SLP should allow the Bench to understand the controversy quickly. The chronology should therefore identify only legally material events.
A useful list of dates may include:
- origin of rights or contractual relationship;
- institution of the suit, petition or tribunal proceeding;
- critical interim orders;
- trial-court or tribunal judgment;
- first appellate judgment;
- second appeal or writ proceedings;
- review or certificate proceedings;
- date of the impugned High Court judgment; and
- events establishing current urgency.
Caveat in a Civil SLP
A successful party expecting a Civil SLP may consider lodging a caveat where legally and procedurally appropriate. This is particularly relevant where the losing party is expected to seek urgent ex parte relief.
Caveats are commonly considered in matters involving:
- possession;
- execution of decrees;
- property transfers;
- corporate control;
- service reinstatement or termination;
- custody;
- injunctions; and
- high-value commercial recovery.
The official Supreme Court site provides a dedicated caveat service page.
What happens when notice is issued?
A respondent to whom notice is issued may oppose the grant of leave and interim relief. Order XXI also permits objections to be filed within the prescribed framework.
At this stage, the respondent may focus on:
- absence of any substantial Article 136 issue;
- concurrent findings;
- delay and laches;
- suppression of material facts;
- alternate statutory remedy;
- interim relief causing greater prejudice;
- undertakings that can adequately protect the petitioner; or
- why the impugned judgment should remain operative.
Registry scrutiny and common Civil SLP defects
Common filing defects include:
- incorrect limitation computation;
- missing certified copy or exemption application;
- defective cause title;
- party positions not correctly shown as in the court below and Supreme Court;
- missing prior-SLP declaration;
- annexures not forming part of the lower-court record;
- additional documents filed without permission;
- vernacular documents without proper translation or exemption;
- defective affidavit;
- defective vakalatnama;
- incorrect pagination;
- illegible documents;
- incomplete list of dates;
- prayers not corresponding to the impugned order; or
- failure to cure notified defects within the permitted period.
The Supreme Court’s Default List / scrutiny resources are useful for understanding current Registry checks.
Diary Number versus final registration
A Diary Number indicates initial lodging; it does not mean the SLP has been admitted or that all Registry defects have been cured. Final registration follows procedural compliance.
This distinction matters where urgent interim relief is required. A filing strategy should allow time for defect curing rather than assuming that lodging on the last day will immediately produce a listed matter.
What happens at the first hearing?
At the leave stage, the Supreme Court may:
- dismiss the SLP at threshold;
- issue notice;
- issue notice limited to a particular question;
- grant or refuse interim relief;
- direct status quo;
- seek a response on delay or maintainability;
- grant special leave; or
- pass another appropriate order.
Registration of the petition does not create a right to notice.
What happens after special leave is granted?
Once special leave is granted, the proceeding becomes a civil appeal. The Supreme Court is then exercising appellate jurisdiction rather than merely deciding whether the Article 136 threshold should be crossed.
This distinction also affects the doctrine of merger and the legal consequences of the Supreme Court’s eventual judgment.
Dismissal of Civil SLP and doctrine of merger
A non-speaking dismissal of a Civil SLP at the leave stage does not necessarily mean the Supreme Court has approved every reason in the High Court judgment. The effect depends on the nature of the Supreme Court order and whether leave had been granted.
The distinction between refusal of special leave and dismissal of an appeal after grant of leave remains central to Kunhayammed v. State of Kerala and subsequent Supreme Court jurisprudence.
Can a second Civil SLP be filed?
The Supreme Court Rules require disclosure of any earlier SLP against the same impugned judgment or order. A second SLP cannot be used simply to obtain a fresh hearing after an earlier SLP was dismissed.
Before contemplating any subsequent proceeding, counsel should examine:
- the exact earlier Supreme Court order;
- whether leave was granted;
- whether review is maintainable;
- whether there is a subsequent distinct order; and
- whether the proposed proceeding is barred by merger, finality or abuse-of-process principles.
Civil SLP document checklist
- Impugned High Court or tribunal judgment/order.
- Judgments/orders of courts below.
- Certified-copy application and delivery record.
- Synopsis.
- List of dates.
- Form 28 petition.
- Questions of law.
- Grounds for special leave.
- Grounds for interim relief.
- Main prayer.
- Interim prayer.
- Affidavit.
- Annexures forming part of the record below.
- Application for condonation of delay, if required.
- Application for additional documents, if required.
- Application for exemption from certified copy, if required.
- Application for official translation/exemption, if required.
- Impleadment/intervention applications, if required.
- Prior-SLP disclosure.
- Vakalatnama and AOR filing documents.
Pan-India pre-filing checklist after a High Court civil judgment
- Obtain the operative judgment immediately.
- Apply for certified copy.
- Calculate the 90/60-day limitation.
- Identify whether a statutory appeal exists instead of an SLP.
- Identify the strongest questions of law.
- Separate factual disagreement from Article 136 grounds.
- Check for concurrent findings.
- If concurrent findings exist, identify perversity or legal error specifically.
- Identify any immediate enforcement consequence.
- Draft precise interim relief.
- Check whether status quo, stay or another form of protection is actually required.
- Collect the complete lower-court record relied upon.
- Identify documents not forming part of the record below.
- Prepare separate permission application for additional documents if necessary.
- Check translation requirements.
- Identify all necessary parties.
- Check whether a caveat may have been lodged.
- Disclose prior Supreme Court proceedings.
- Complete AOR documentation.
- Review the latest Supreme Court Rules, forms and Registry default list before filing.
Common mistakes in Civil SLPs
- treating Article 136 as a routine second or third appeal;
- failing to identify a clear question of law;
- rearguing all evidence without showing perversity;
- assuming filing automatically stays the High Court order;
- seeking vague interim relief;
- using “status quo” without defining what position is to be preserved;
- poor limitation calculation;
- filing new documents without permission;
- annexing material that was never part of the lower-court record;
- failing to distinguish statutory appeal from Article 136 SLP;
- not disclosing an earlier SLP;
- ignoring adverse Supreme Court precedent;
- missing necessary parties; or
- waiting until execution/dispossession is imminent before preparing the Supreme Court record.
Frequently asked questions
What is the limitation for a Civil SLP in the Supreme Court?
Ordinarily 90 days from the judgment or order sought to be challenged. Where a qualifying certificate of fitness has been refused, Order XXI provides a 60-day period from the refusal, subject to the Rule and the Limitation Act.
Does filing a Civil SLP automatically stay the High Court judgment?
No. Interim protection must be specifically sought and granted.
Do I need a separate interim-relief application in every Civil SLP?
Order XXI provides that the interim prayer itself should be incorporated in Form 28 and a separate application for interim relief need not be filed merely for that relief. Separate interlocutory applications may still be needed for other procedural requests.
Can the Supreme Court order status quo?
Yes, in an appropriate case. The petition should identify exactly what factual or legal position requires preservation.
Can I file new documents in a Civil SLP?
Not as a matter of course. If a document was not part of the record below, a separate application explaining the reason and necessity is ordinarily required.
Will the Supreme Court reappreciate all evidence?
Ordinarily no. Article 136 interference with concurrent findings is exceptional and usually requires perversity, legal error, disregard of material evidence, natural-justice violation or grave injustice.
What did Bhola Nath v. State of Jharkhand hold about Article 136?
The 2026 decision restated that the Supreme Court can interfere with concurrent findings where they are perverse, violate natural justice, disregard statutory provisions or produce substantial and grave injustice.
Can an interim High Court order be challenged by Civil SLP?
Yes, but the Supreme Court usually exercises restraint unless the order causes serious or irreversible prejudice, suffers from jurisdictional error or otherwise warrants immediate Article 136 intervention.
Can a property decree be stayed by the Supreme Court?
Yes, in an appropriate SLP the Court may stay execution, protect possession, restrain alienation or grant another order necessary to preserve the subject matter.
Who files a Civil SLP?
Filing and acting in the Supreme Court are ordinarily undertaken through an Advocate-on-Record, apart from recognised party-in-person procedure.
What happens after special leave is granted?
The matter proceeds as a civil appeal before the Supreme Court.
Official Supreme Court resources
- Supreme Court Rules and Amendment Notifications
- Supreme Court Forms and Form 28
- Interlocutory Application Categories
- Registry Default List / Scrutiny Resources
- Supreme Court e-Filing 3.0
- Bhola Nath v. State of Jharkhand, 2026 INSC 99
Key takeaways
- A Civil SLP is an extraordinary Article 136 remedy, not an automatic appeal.
- The ordinary limitation is 90 days, with a 60-day certificate-refusal situation under Order XXI.
- Form 28 contains both the main prayer and interim prayer.
- Filing does not automatically stay the impugned judgment.
- Stay and status quo are distinct and should be drafted precisely.
- New documents require careful procedural treatment and often a separate permission application.
- Concurrent findings are ordinarily respected unless the Article 136 threshold is met.
- Bhola Nath, 2026 INSC 99 is a current authority on interference with concurrent civil findings.
- The petition should remain anchored to the record below.
- After special leave is granted, the matter proceeds as a civil appeal.
This article is intended for general legal education and Supreme Court procedure research across India. It does not constitute solicitation, advertisement or case-specific legal advice. Limitation, statutory appeal routes, interim relief, Registry practice and applicable Supreme Court Rules should be checked against the latest official material and the facts of the individual case.
Contact Information
Adv Govind Bali
Managing Partner, Fastrack Legal Solutions LLP
Phone: 7697671219
Email: advgovind@fastracklegalsolutions.com
Website: www.fastracklegalsolutions.com
Contact details are provided for identification and professional correspondence. The article is for general legal information and does not constitute solicitation or advertisement.