This paper provides an overview of the legal framework governing the gambling and gaming industry in India - its evolution through the ages, its magnitude as an industry and its impact on society.
Accordingly, the paper focusses on the central and state legislations which regulate various facets of this industry, the judicial pronouncements which have had a lasting impact on the manner in which certain sets of 'games' have come to be observed and suggestions to develop this industry in an officially structured manner.
The paper is divided as follows:
- An introduction covering the evolution of gambling and the size of the industry as it stands today;
- A brief overview of the legal framework which governs and regulates the industry;
- A detailed analysis of central and state legislations, including landmark judicial pronouncements;
- A study of judicial pronouncements and legislations governing the card game of poker, online fantasy sports, lotteries, game shows and recreational clubs;
- Suggestions and concluding remarks on the way forward.
"Enough of dicing, son of Gandhari, Vidura does not approve of it. Nor would he, in his great sagacity, tell us aught that is in bad faith that I think Vidura is speaking ......for gambling is found to be divisive. At a breach the kingdom perishes, therefore avoid it, son."1
As indicated in this quotation from the Mahabharata, gambling has been a part of our culture and heritage since ancient times. The pivotal moment in the Mahabharata is the game of dice. Gambling continues to play a significant role in society even today. A sport or a game can be seen on at least two levels as with creation in Hinduism which is regarded as God's 'lila' and this 'lila' takes place both at the level of God and the level of Man.2, a sport or a game may also be seen as such.
Dicing and gambling is a part of the religious and cultural history of India. It has a special significance when connected with myths and rituals - Shiva and Parvati play dice, it is also a part of Deepawali the beginning of the financial year in Hindu society. Dicing involves uncertainty, chance, the vagaries of fortune. The dice game is representative of the challenges that a king must endure during his reign. As a part of religion, gambling is usually discouraged or prohibited, gamblers being typically associated with being of a loose or depraved character.
Nevertheless, this affinity towards gambling continued till the medieval times and the first regularization of gambling in India was introduced by the British in 1867.
In 2016, the value of the Indian gaming industry is estimated to be Rs. 30.8 Billion. It is expected that the industry will more than double and be worth Rs. 71 Billion by 2021. Based on 2015 data, the digital games market in India is dominated by mobile gaming, which was responsible for nearly 50 percent of the revenues in the measured period.
In addition, as of mid-2016, India ranked sixth among the global markets based on the share of mobile game installs - 2.9 percent of global mobile game installs occurred in India.3
Therefore, as can be seen, gambling in India is a significant sector – both culturally and in the manner in which it has evolved.
2. Legal Framework – An Overview
Gambling formally began to be governed by statute only in the year 1867 with the enactment of the Public Gambling Act, 1867 ("Central Legislation"), with a view to provide for "the punishment of public gambling and the keeping of common gaming-houses in the United Provinces, East Punjab, Delhi and the Central Provinces".
It is interesting to note that the Central Legislation did not go on to define/ elaborate what constitutes 'public gambling' and only defined the term 'common gaming-house' to mean "any house, walled enclosure, room or place in which cards, dice, tables or other instruments of gaming are kept or used for the profit or gain of the person owning, occupying, using or keeping such house, enclosure, room or place, whether by way of charge for the use of the instruments of gaming, or of the house, enclosure, room or place, or otherwise howsoever"4; but however, carved out an exception to the extent that the provisions of the Central Legislation shall not apply to any game of mere skill wherever played5.
The question of whether any game is considered gambling is determined by ascertaining whether the game is predominantly one of skill or chance. This has been clarified by the Supreme Court of India in the matter of Dr. K.R. Lakshmanan v. State of Tamil Nadu and Anr.6 which inter alia held that:
"Gambling in a nut-shell is payment of a price for a chance to win a prize. Games may be of chance, or of skill or of skill and chance combined. A game of chance is determined entirely or in part by lot or mere luck. The throw of the dice, the turning of the wheel, the shuffling of the cards, are all modes of chance. In these games the result is wholly uncertain and doubtful. No human mind knows or can know what it will be until the dice is thrown, the wheel stops its revolution or the dealer has dealt with the cards. A game of skill, on the other hand - although the element of chance necessarily cannot be entirely eliminated - is one in which success depends principally upon the superior knowledge, training, attention, experience and adroitness of the player. Golf, chess and even Rummy are considered to be games of skill. The courts have reasoned that there are few games, if any, which consist purely of chance or skill, and as such a game of chance is one in which the element of chance predominates over the element of skill, and a game of skill is one in which the element of skill predominates over the element of chance. It is the dominant element - "skill" or "chance" - which determines the character of the game."
3. Center v. State – An Age Old Debate
With the advent of independence and consequent writing of the Constitution of India (the "Constitution"), the Constitution empowered state legislatures to make laws governing betting and gambling in their respective states.7
While certain states merely adopted the Central Legislation, such as Bihar, Chandigarh, Chhattisgarh, Haryana, Himachal Pradesh, Jharkhand, Madhya Pradesh, Manipur, Punjab, Uttarakhand, etc.; many states enacted new statutes to govern betting and gambling in their states, including but not limited to:
- the Andhra Pradesh Gaming Act, 1974;
- the Assam Game and Betting Act, 1970;
- the Goa, Daman and Diu Public Gambling Act, 1976;
- the Gujarat Prevention of Gambling Act, 1887;
- the Kerala Gaming act, 1960;
- the Bombay Prevention of Gambling Act, 1887; and
- the Rajasthan Public Gaming Ordinance, 1949.
In 1967, the question of whether the game of rummy would fall under gambling came up for consideration in the matter of State of Andhra Pradesh v. K. Satyanarayana and Ors.8 ("Satyanarayana Case"), wherein the Supreme Court inter alia held that:
"The game of Rummy is not a game entirely of chance like the 'three-card' game mentioned in the Madras case to which we were referred. The 'three card' game which goes under different names such as 'flush', 'brag' etc. is a game of pure chance. Rummy, on the other hand, requires certain amount of skill because the fall of the cards has to be memorised and the building up of Rummy requires considerable skill in holding and discarding cards. We cannot, therefore, say that the game of Rummy is a game of entire chance. It is mainly and preponderantly a game of skill. The chance in Rummy is of the same character as the chance in a deal at a game of bridge. In fact in all games in which cards are shuffled and dealt out, there is an element of chance, because the distribution of the cards is not according to any set pattern but is dependent upon how the cards find their place in the shuffled pack. From this alone it cannot be said that Rummy is a game of chance and there is, no skill involved in it. Of course, if there is evidence of gambling in some other way or that the owner of the house or the club is making a profit or gain from the game of Rummy or any other game played for stakes, the offence may be brought home."
4. State Specific Enactments
The Goa, Daman and Diu Public Gambling Act, 1976 allows certain modes of gambling in five star hotels and on board offshore vessels and inter alia states that:
"Notwithstanding anything contained in this Act, the Government may authorise any game of electronic amusement/slot machines in Five Star Hotels and such table games and gaming on board in vessels offshore as may be notified subject to such conditions, including payment of such recurring and non-recurring fees, as may be prescribed.9".
Presently Goa's offshore casinos, which are floating in the River Mandovi off the State's capital Panaji, have been granted a six month extension to operate in River Mandovi until 30th March 2019, pursuant to a cabinet note signed by the Chief Minister10. That said, recent policy intent seems to suggest that six offshore casinos would be closed down by 2020 and moved to "a land-based designated entertainment zone", possibly situated near the new airport in Mopa on Goa's northern border11. In order to facilitate this move, it is proposed that licenses of the offshore (river based) casinos will be renewed, provided they demonstrate their willingness to shift operations to the designated zones within a year from the date of the declaration of the policy, and will thereafter be granted four years for the shifting process12. This proposed casino policy aims to set out the road-map for moving the offshore casinos ashore, along with a new regulatory framework for the State's gaming industry. It is further proposed that a Gaming Commissioner be appointed to regulate and oversee casino activities in the State. It remains to be seen how these proposals may impact the State's economy, given the importance of Goa's casino industry to it.
The growth and spread of the internet was not accounted for in the Central Legislation and the state enacted statutes, hence, they mainly govern gambling in physical places and do not specifically consider online gambling. However, certain states have taken measures in an attempt to regulate this space.
The Sikkim Regulation of Gambling (Amendment) Act, 2005, followed by the Sikkim On-line Gaming (Regulation) Act, 2008 permits the state to issue a license to an individual/ organization that is interested in operating a gambling house. The State has, through the Sikkim Online Gaming (Regulation) Rules, 2009 ("Sikkim Rules"), prescribed that games such as roulette, black jack, pontoon, punto banco, bingo, casino brag, poker, poker dice, baccarat, chemin-de-for, backgammon, keno, and super pan 9 may be played online, after a license has been issued in this regard. The Sikkim Rules even go a step further to specify that these games have to be safe, secure and fair.
Further, the Nagaland Prohibition of Gambling and Promotion and Regulation of Online Games of Skill Act, 2016 ("Nagaland Gambling Act"), permits the state to issue a license for games of skill. The Nagaland Gambling Act defines 'games of skill' as "including all such games where there is a preponderance of skill over chance, including where the skill relates to strategising the manner of placing wagers or placing bets, or where the skill lies in team selection or selection of virtual stocks based on analyses, or where the skill relates to the manner in which the moves are made, whether through deployment of physical or mental skill and acumen." In addition to this definition, certain specific games of skill, including poker, rummy, fantasy sports (football and cricket), virtual fighting and combat games, sudoku, binary options, have been expressly set out in a schedule thereto. The primary objective of the Nagaland Gambling Act is to prohibit gambling and to regulate and promote 'online games of skill' within Nagaland. Subject to a license being obtained from the State Government, specified online games can be played in a legally regulated environment.
The Governor of the state of Telangana promulgated the Telangana State Gaming (Amendment) Ordinance, 2017 ("Telangana Gaming Ordinance"), which seeks to make far reaching amendments to the Telangana State Gaming Act, 1974 ("Telangana Gaming Act") so as to extend its application to online gaming. The Telangana Gaming Ordinance now expands the definition of 'instruments of gaming' to include items such as digital form or record used or intended to be used as a register, record or evidence of gaming and has specifically brought online gaming under the purview of the Telangana Gaming Act, even prescribing high penalties for persons found in contravention of certain provisions of the Telangana Gaming Act, such as freezing of bank accounts, which are being used for the purpose of gaming.
More importantly, the Telangana Gaming Ordinance has inserted three explanations to Section 15 of the Telangana Gaming Act, which goes on to explicitly clarify that rummy is not a game of skill, the three explanations being:
"Explanation I: A skill game is a game which is totally based on skill and ability of the person and not otherwise.
Explanation II: Any game which depends partly on skill and partly on luck or chance cannot be termed as skill game.
Explanation III: Rummy is not a skill game as it is involved partly skill and partly luck or chance."
However, the aforesaid three explanations were vitiated by the Telangana Gaming (Second Amendment) Ordinance, 2017 ("Telangana Second Gaming Ordinance"). The Telangana Gaming (Amendment) Act, 2017 enacted with the object of implementing "the policy of zero tolerance against gambling which has serious impact on the financial condition and well-being of the common public", in turn subsumed and thereby repealed the Telangana Gaming Ordinance and Telangana Second Gaming Ordinance. It is also pertinent to note that the Telangana Prevention of Dangerous Activities of Bootleggers, Dacoits, Drug-Offenders, Goondas, Immoral Traffic Offenders and Land-Grabbers (Amendment) Act, 2017 ("Telangana Prevention of Dangerous Activities Act"), which amends a legislation enacted for preventive detention of bootleggers, dacoits, drug-offenders, goondas, immoral traffic offenders and land-grabbers, and to prevent their dangerous activities prejudicial to the maintenance of public order, goes on to include in its ambit a 'gaming offender', defined to mean a person who commits or abets the commission of offences punishable under the Telangana Gaming Act.
The aforesaid amendments to the Telangana Gaming Act are in contradiction to various landmark judgments held by the Supreme Court. Further, considering the progression of online gaming in India, the Telangana Prevention of Dangerous Activities Act and amendment to the Telangana Gaming Act may act as a hindrance.
After the incident of spot fixing that occurred in 2013 in the Indian Premier League (IPL), two panels were appointed by the Supreme Court to look into the matter (the Mudgal Committee and the Lodha Panel). Both panels made a suggestion that sports betting should be legalized in India. The Supreme Court in July 2016 asked the Law Commission of India to examine the matter and make its recommendations to the Government. The Law Commission of India released its 276th Report titled 'Legal Framework: Gambling and Sports Betting Including in Cricket in India', which is under consideration by the Government of India, after deliberations and having discussed the pros and cons of legalising regulated gambling and betting activities inter alia reached the conclusion that regulated betting and gambling is not desirable in India in the present scenario. Therefore, state authorities must ensure enforcement of a complete ban on unlawful betting and gambling. However, given that it is not possible to prevent these activities completely, effectively regulating them remains the only viable option. Thus, if the Parliament or the State Legislatures wish to proceed in this direction, regulated gambling would ensure detection of fraud and money laundering, etc. Such regulation of gambling would require a three-pronged strategy: (a) reforming the existing gambling (lottery, horse racing) market, (b) regulating illegal gambling, and (c) introducing stringent and over-arching regulations.
5. The Curious Case of Poker
Another card based game which draws parallels to rummy and has been growing in popularity, is poker. Although there has not been any specific verdict on the legality of poker in India, inference can be drawn from the above excerpt of the Satyanarayana Case supra, which classifies rummy as a game of skill, separate from gambling. Furthermore, the West Bengal Gambling and Prize Competitions Act, 1957 specifically excludes games of cards like bridge, poker, rummy or nap from its definition of gaming and gambling, providing further backing to the legality of poker.13
In 2012, a Division Bench of the Madras High Court in relation to a raid of a gambling club by the Madras Police in the matter of The Director General of Police v. Mahalakshmi Cultural Association14 ("Mahalakshmi Case") while acknowledging that rummy is a game of skill even though an element of chance is involved, held that rummy when played for stakes would amount to gambling. Thereafter, the Mahalakshmi Cultural Association ("MCA") filed a Special Leave Petition ("SLP") with the Supreme Court. Several online rummy companies intervened in this SLP, fearing that the ruling in the Madras High Court would apply to them as well. With respect to the intervention of the online rummy companies, the Supreme Court dismissed the applications on the ground that the Madras High Court judgment did not deal with online rummy or the online rummy companies. Thereafter, in 2015, the Supreme Court in its order15 allowed the MCA to withdraw the original Writ Petition filed before the Madras High Court since the prosecution's case was that the members of MCA were playing a local game 'ulle, velliye' for profit and there was no allegation that the members were playing rummy. While dismissing the SLP, the Supreme Court observed that since the Writ Petition was dismissed as withdrawn, the observations made by the Madras High Court do not survive.
In recent times, members of the police force have been proactive in curbing illegal gambling activities played for money. In October 2016, an illegal casino set up in a farmhouse in Delhi for Diwali with the minimum entry fee to the gambling ring was Rs. 5 Lakh, was raided and 36 people, including businessmen, builders and share brokers, were arrested during the raid16. Further, 20 people were arrested in Vadodara in June 2017 for hosting a game of poker17. August 2018 witnessed two raids which took place in two Mumbai and Thane gambling dens which led to the arrest of more than 70 people. 'Matka' and 'Teen Patti' gambling were taking place at the venues when the raids were conducted18. It is mention worthy that none of these arrests stemmed from the fact that these games were hosted in public places.
Another case of significance in the gaming/ gambling world in 2012 was the M/s. Gaussian Network Pvt. Ltd. v. Ms. Monica Lakhanpal19 ("Gaussian Case") wherein Gaussian Network Private Limited ("Gaussian") approached the District Court in Delhi under Order 36 of the Code of Civil Procedure seeking its opinion with respect to various questions in relation to online gaming portals. In its judgment, the District Court inter alia observed that there is a difference in games of skill being played in the physical form and those played online and held that skill based games played online would be illegal. The District Court also took into account the order passed by the Madras High Court in the aforementioned Mahalakshmi Case wherein the game of rummy was held as illegal. The District Court inter alia also stated that:
"There can be no equation in the degree of skills in games to be played in the physical form and those to be played online. In the Real games, all the aforesaid games require the presence of mind in the presence of competitors. There is a marked difference in the games being played online. The brick and mortar rooms have been replaced by online gaming sites where people can bet from the comfort and confines of the four walls of their own domain.
A question does come to mind, that if betting on a game of Skill played in the Real form is legal, why would it be illegal Online? An argument may be advanced that what is legal off line should be legal online as well. To answer this, a crucial factor, and perhaps the most determining one which has to be considered, is the role of the service provider offering various games (even those acknowledged as games of Skill) on payment of money. There are various sites which offer games of Skill online, free of charges. There is no illegality involved. But when the service provider partakes a slice of the winning component, it is no better than a gaming house which are illegal.
The facilities offered by a gaming portal would be covered within the definition and ambit of a gaming house offering games of skill on taking commissions from the winning hand. Attracting business or enticing players by alluring them with prize money is illegal. Such portals merely seek to replace the brick and mortar gaming rooms, offering all the frills and facilities of a gaming house and are nothing better than virtual Casinos, banned in most States."
Since this order of the District Court was binding only on the parties in the matter, it did not alter the position with respect to gaming/ gambling laws in the country. This order was thereafter challenged by Gaussian through a Civil Revision Petition before the Delhi High Court. Thereafter, however, upon a request made by the parties to the Gaussian Case, the Delhi High Court granted permission to withdraw the petition filed before it, and ordered that the observations of the District Court do not survive.
In December 2017, a single judge of the Gujarat High Court in the matter of Dominance Games Pvt. Ltd. v. State of Gujarat20 also took a similar view as the District Court of Delhi in that of the Gaussian Case and held that poker amounts to gambling under the Gujarat Prevention of Gambling Act, 1887. This order has been appealed and the Division Bench has fixed the date of hearing on 21st December 201821.
6. Online Fantasy Sports
Online fantasy sports have also been gaining in popularity in India. Typically, this format involves participants playing the role of an owner/ manager having a limited budget and the power to buy, sell, transfer, substitute players before each game week/ match day, based on the opposition and player availability. The points are then allocated to the participant based on the outcome of the real matches and more specifically, the performance of the selected players in their team. In 2016, the Indian online gaming market value was estimated at USD 300 Million which is expected to rise 3.4 times by 2021 to USD 1 Billion22.
The question of whether such online fantasy sports can be considered as gambling was decided in the matter of Varun Gumber v. Union Territory of Chandigarh and Others23 by the High Court of Punjab and Haryana in April 2017, which studied the model of the fantasy website Dream11 and held that such online fantasy sports do not fall within the activity of gambling for the invocation of the Central Legislation and inter alia also stated that:
".....playing of fantasy game by any participant user involves virtual team by him which would certainly requires a considerable skill, judgment and discretion. The participant has to assess the relative worth of each athlete/sportsperson as against all athlete/sportspersons available for selection. He is required to study the rules and regulations of strength of athlete or player and weakness also. The several factors as indicated above submitted by the respondent company would definitely affect the result of the game.
The respondent company's website and success in Dream 11's fantasy sports basically arises out of users exercise, superior knowledge, judgment and attention. I am of the further view that the element of skill and predominant influence on the outcome of the Dream11 fantasy than any other incidents are and therefore, I do not have any hesitation in holding the any sports game to constitute the game of "mere skill" and not falling within the activity of gambling for the invocation of 1867 Act and thus, the respondent company is therefore, exempt from the application of provisions, including the penal provisions, in view of Section 18 of 1867 Act. Equally so, before I conclude, I must express that gambling is not a trade and thus, is not protected by Article 19(1)(g) of Constitution of India and thus, the fantasy games of the respondent company cannot said to be falling within the gambling activities as the same involves the substantial skills which is nothing but is a business activity with due registration and paying the service tax and income tax, thus, they have protection granted by Article 19(1)(g) of Constitution of India."
7. Lotteries, KBC, and Recreational Clubs
The Courts of India have by and large adopted the 'dominant factor test', or 'predominance test' that has been followed by Courts in the United States of America to distinguish between games of skill versus games of chance. Essentially, the test requires an assessment and determination of whether chance or skill is the dominating factor when determining the result of the game.
That being said, recreational clubs often, and usually charge a fee to its members for activities and things that they provide to their member, which fee is used to manage the club and its amenities. Therefore, charging a reasonable fee for playing cards will not amount to such club making a profit or gain and consequently be classified as a common gaming-house.
Only a fee or charge that is substantial in nature or disproportionate to the general provision and maintenance of the amenities being provided to the members could result in the place, where the game is to be played, being viewed as a common gaming-house.
However, regardless of the above, the enforcement authorities can exercise their powers to investigate and enforce the law, as the determination as to whether a game is preponderantly that of skill or chance would depend upon the facts and circumstances of each case.
Certain categories of gaming/ gambling are regulated by specific legislations, including but not limited to:
- Lotteries (Regulation) Act, 1998 ("Lotteries Act");
- Prize Competitions Act, 1955 ("Prize Competitions Act").
The Constitution empowers the Central Legislature to enact laws with respect to lotteries24. The Lotteries Act (which governs lotteries) read with the Lotteries (Regulation) Rules, 2010 permits the State Government to organize a paper lottery or online lottery or both, subject to the conditions specified in the Lotteries Act and the rules made thereunder.25
Prize competitions are regulated under the Prize Competitions Act, which defines 'prize competition' as "any competition (whether called a cross-word prize competition, a missing-word prize competition, a picture prize competition or by any other name) in which prizes are offered for the solution of any puzzle based upon the building up, arrangement, combination or permutation, of letters, words or figures." The Prize Competitions Act prohibits the promotion or conduction of any prize competition(s) where the total value of the prize(s) (whether in cash or otherwise) offered in any month exceeds Rs. 1,000. Further, the Prize Competitions Act also restricts the number of entries in every prize competition to two thousand.26
8. Concluding Remarks
On an analysis of the above, it can reasonably be said that games which are preponderantly that of skill even though an element of chance may exist, are outside the purview of 'gambling'. Games widely played across India fall under this rule, such as, golf, chess and rummy. Therefore, a competition which substantially depends on skill, cannot be termed as 'gambling', as gambling is generally understood to mean betting on games of chance. However, as detailed above, considering the ambiguity in this space, there is a necessity to frame guidelines and criteria for determination of what constitutes game of skill, including the criteria that would satisfy the preponderance test of "skill versus chance" that has been historically adopted by Indian courts.
We are now at a crossroads with respect to the legality of the Indian gaming industry – with an industry size of ~Rs. 30 Billion, which is expected to double in the next 5 years, this industry can no longer be ignored.
Institutional investments such as the investment by Sequioa capital in Dream 11, a cricket and football fantasy game; participation of China based Tencent Holdings in funding of Dream 11; Nazara Technologies, popularly known for its games on world crick championship, 'Chhota Bheem' and 'Motu Patlu' series recently received funding from IIFL Asset Management; and the acquisition by the Goa based Deltin group of Adda52, a leading online poker website, have brought this sector into the limelight. While some see the lack of regulation as a risk, more opportunistic investors may view the lack of regulation on algorithms, the lack of caps on margins and the general lack of regulatory supervision as a boon, rather than a bane. As a sector, the question still lingers, whether gaming in India is headed for its own 'Black Friday'; or whether it will continue in its current semi-regulated manner.
* This submission has been prepared by Team Anuj Bhasme. Please note that this submission is not meant for onward circulation without the prior written consent of the authors, who may be contacted at email@example.com, Anuj Bhasme, Partner; firstname.lastname@example.org, Gaurav Dugar, Senior Associate; and email@example.com, Rutvi Shrimankar, Associate.
1. Quotations of Mahabharata: J.A.B. Van Buitenen, Mahabharata. Chicago Press, 1971
2. William Sturman Sax, The Gods at Play: Lila in South Asia. New York: Oxford University Press, 1995.
3. Value of the gaming industry in India from 2007 to 2021, STATISTA, available at: https://www.statista.com/statistics/235850/value-of-the-gaming-industry-in-india/
4. Section 1 of the Central Legislation
5. Section 12 of the Central Legislation
6. AIR 1996 SC 1153
7. Article 246(3) and Entry 34 of the State List (i.e. List II) of the Seventh Schedule to the Constitution
8. 1968 AIR 825
9. Section 13A of the Goa, Daman and Diu Public Gambling Act, 1976
10. Goa govt gives Mandovi River casinos 6-month extension, THE INDIAN EXPRESS, available at: https://indianexpress.com/article/business/goa-government-mandovi-river-casinos-extension-5379326/
11. Goa's CM pushes forward with new casino policy, CASINO REVIEW, available at: https://www.casino-review.co/goas-cm-pushes-forward-with-new-casino-policy/
12. Parrikar promises to unveil casino policy by month-end, TIMES OF INDIA, available at: https://timesofindia.indiatimes.com/city/goa/parrikar-promises-to-unveil-casino-policy-by-month-end/articleshow/65265060.cms
13. Section 2(1)(b) of the West Bengal Gambling and Prize Competitions Act, 1957
14. W.A. No. 2287 of 2011
15. Special Leave to Appeal (C) No. 15371 of 2012
16. 5 lakh entry fee and posh cars: South Delhi's illegal casino in pics, HINDUSTAN TIMES, available at: https://www.hindustantimes.com/delhi-news/in-pics-illegal-casino-set-up-in-south-delhi-for-diwali-busted-36-held/story-uDu84BKXmZBzfqGRmOxouO.html
17. 20 arrested in midnight poker raid, TIMES OF INDIA, available at: https://timesofindia.indiatimes.com/city/vadodara/20-arrested-in-midnight-poker-raid/articleshow/59377025.cms
18. 70 arrested in Mumbai Gambling Crackdown, GUTSHOT MAGAZINE, available at: https://www.gutshotmagazine.com/news/details/70_arrested_in_mumbai_gambling_crackdown
19. Suit No. 32 of 2012
20. Special Civil Application No. 6903 of 2017
21. Letters Patent Appeal No. 193 of 2018
22. Online Gaming Market Value across India in 2016 and 2021, STATISTA, available at: https://www.statista.com/statistics/754586/india-online-gaming-market-size/
23. CWP No. 7559 of 2017
24. Entry 40 of the Union List (i.e. List I) of the Seventh Schedule to the Constitution
25. Section 3 of the Lotteries (Regulation) Rules, 2010
26. Sections 2 and 4 of the Prize Competitions Act
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.