"RELATIONSHIP BETWEEN OWNERSHIP

AND POSSESSION"

 

AUTHORED BY- HRITHIK KUMAR

Designation- Pursuing LL.M At Chanakya National Law University, Patna

University- Chanakya National Law University, Patna

 

 

ABSTRACT

This abstract presents a comprehensive analysis of the concept of ownership and possession, with a specific focus on adverse possession in India amidst the backdrop of the globalized economy. Adverse possession, a legal doctrine permitting individuals to acquire ownership rights over property through continuous and exclusive possession over a specified period, is examined within the context of India’s integration into the global economy. The study critically evaluates the implications of globalization on traditional notions of property ownership and possession, considering the influence of economic, social, and legal factors.Through a multidisciplinary approach, incorporating legal analysis, economic theory, and socio-political perspectives, the study aims to elucidate the complexities surrounding property rights in the contemporary Indian context. By exploring the evolution of property laws in response to globalization, including changes in regulatory frameworks and judicial interpretations, it seeks to provide a nuanced understanding of the challenges and opportunities inherent in the intersection of property rights and globalization. The study employs a comparative analysis of Indian property laws with International legal norms and practices, highlighting areas of convergence and divergence. Through examination of case studies and empirical data, it investigates the practical implications of adverse possession on land tenure systems, economic development, and social equity in the globalized Indian economy.Furthermore, the study considers the role of governmental policies, institutional mechanisms, and societal attitudes in shaping patterns of property ownership and possession. By critically assessing the efficacy and fairness of existing legal frameworks, the study offers insights into potential reforms aimed at reconciling traditional property rights with the imperatives of a globalized economy, thereby contributing to scholarly discourse and policy debates on property law and economic development in India.

INTRODUCTION

Ownership is defined as "the complete dominion, title, or proprietary right in a thing or claim...that permits its holder to exercise all the rights of ownership.[1]As with most words in the English language, the word ‘possession’ has a variety of usesand a variety of meanings. Reference to any reasonably comprehensive English dictionary Provides sufficient illustration. Possession is given as: the action or fact of possessing something or of being possessed. Depending on the context, the lexicographer may be foundto give meanings Such as the following: the holding of something as one’s own: actual occupancy as distinguished from ownership; a territory subject to a sovereign ruler or state; the fact of being possessed by a demon; the action of an idea or feeling possessing a person; the action of keeping oneself under control- as in self-possession.

 

It may be objected, however, that it is the concept of possession in the law that is of interest Here, and not the varied used to which the word’ possession’ may be put in the English language. It may be, and has been, urged that there is a unitary concept of possession so far as the law is concerned, and that the analysis and explanation of that concept is the proper function of jurisprudence. It is not difficult to demonstrate, however, that the search for a unitary concept of possession in the law is one doomed. In the era of globalization, the concept of ownership and possession undergoes a nuanced examination, particularly in legal frameworks such as adverse possession within India’s legal landscape. This critical study delves into the intricate interplay between traditional notions of ownership, evolving property rights, and the impact of globalization on legal principles. Adverse possession, a legal doctrine allowing individuals to claim ownership of land they do not originally own through continuous and open possession, presents a compelling case study within this discourse. Under the umbrella of a globalized economy, the traditional boundaries of ownership are challenged by diverse factors such as cultural shifts, economic dynamics, and legal reforms. Understanding the complexities of adverse possession in India necessitates an exploration of its historical, socio-economic, and legal underpinnings. Moreover, examining this concept within a globalized context unveils broader implications for property rights, economic development, and social justice. This study aims to analyze the multifaceted dimensions of ownership and possession, contextualized within the globalized economy, and to scrutinize the relevance and effectiveness of legal doctrines like adverse possession in contemporary India. By engaging with this discourse, we can gain insights into the evolving nature of property rights, the dynamics of economic globalization, and the ongoing quest for justice and equity in modern legal systems.

 

CONCEPT OF OWNERSHIP AND POSSESSION IN JURISPRUDENCE

Explores the distinction between ownership and possession, highlighting ownership as a legal concept granting rights of control, use, and disposal, while possession refers to physical control over property[2].The ideas of possession and ownership are the essential pillars of jurisprudence that support the legal order. Although these terms are frequently used interchangeably in ordinary speech, they have different meanings and have major legal ramifications. The highest kind of legal interest one can have in property is ownership, which includes a range of rights that provide the owner sole control over how the asset is used and disposed of. Contrarily, possession refers to the actual management or occupancy of real estate without necessarily granting the same extensive rights as ownership. Over the course of centuries, under the impact of cultural, economic, and legal developments, the complicated link between ownership and possession has developed, giving rise to legal doctrines and concepts that continue to affect our understanding of property rights.

 

The concept of ownership, deeply rooted In legal history, can be traced back to ancient civilizations, where societies sought to establish rules governing land and resource allocation. In Roman law, the concept of “dominium” laid the foundation for the modern understanding of ownership. Dominium represented absolute ownership, embodying the highest degree of control and authority over property. This concept became a cornerstone for later legal systems, including the civil law systems of continental Europe. The idea of ownership, as an exclusive and transferable right, gradually spread across different regions, adapting to the changing dynamics of societies.

 

The development of ownership in common law systems took a somewhat different path. In English common law, the concept of ownership was traditionally intertwined with the doctrine of estates, which categorized property interests into various forms, such as fee simple, life estates, and leaseholds. The fee simple absolute, akin to the Roman dominium, represented the most comprehensive form of ownership, granting the owner the right to use, enjoy, and dispose of the property indefinitely. Over time, the common law system also recognized the importance of individual property rights, ultimately embracing the idea of fee simple ownership as a cornerstone of property law.

 

The concept of possession, while distinct from ownership, has its own rich history in jurisprudence. Possession can be seen as the tangible manifestation of property rights, as it signifies the physical control and occupancy of a property. Throughout history, possession has often been considered prima facie evidence of ownership, giving rise to the legal maxim “possessiofratres (possessing brothers), non possessiopatris (not possessing fathers),” which reflects the idea that possession is a stronger claim than mere ancestral ownership.

 

However, the relationship between ownership and possession is far from straightforward, and jurisprudence has grappled with the complexities of this interplay. One of the central issues is the recognition of various forms of possession, including adverse possession, which allows an individual to acquire ownership rights over another’s property through open, continuous, and hostile possession for a statutory period. This legal doctrine, prevalent in many common law jurisdictions, challenges the traditional notion that possession always aligns with ownership. Adverse possession reflects the law’s acknowledgment that abandonment or neglect of property rights may lead to a shift in ownership.

 

The relationship between ownership and possession also intersects with the broader context of property law, including the distinction between real property and personal property. Real property, often associated with land and immovable structures, exemplifies the enduring connection between ownership and possession. Personal property, on the other hand, includes movable assets like vehicles, furniture, and financial instruments. The nature of personal property makes it more susceptible to frequent transfers of possession without necessarily transferring ownership, illustrating the separability of these two concepts.

 

Modern jurisprudence further complicates the ownership-possession dynamic through the recognition of equitable interests and limitations on ownership rights. Equitable interests, rooted in principles of fairness and justice, can coexist with legal ownership, providing additional layers of complexity. For example, a trust beneficiary may have an equitable interest in a property held by a trustee, even though legal ownership rests with the trustee. This equitable interest may grant the beneficiary certain rights to use and enjoy the property, further blurring the lines between ownership and possession.

 

Moreover, legal systems have imposed various restrictions and limitations on ownership to address societal concerns and protect public interests. Zoning regulations, environmental laws, and eminent domain are examples of legal mechanisms that restrict an owner’s unfettered control over property. These limitations ensure that ownership rights are exercised in a manner consistent with broader social goals, such as sustainable development and public welfare.

 

The evolving nature of ownership and possession is also evident in the digital age, where intangible assets, such as intellectual property rights and cryptocurrencies, challenge traditional conceptions of property. Intellectual property, including patents, copyrights, and trademarks, represents ownership of ideas and creative works, often without a tangible physical form. Similarly, cryptocurrencies, as decentralized digital assets, raise questions about possession and control, as ownership is defined by cryptographic keys rather than physical presence.

 

EVOLUTION OF OWNERSHIP AND POSSESSION

Examines shifts in property law and the evolving conceptualization of ownership in legal and economic discourse[3].The evolution of ownership and possession has been shaped by social, economic, and legal factors throughout history. Here’s a brief overview:

1. Hunter-Gatherer Societies: In early human history, ownership was often communal, with possessions shared within the group. Possession was based on use rather than legal titles.
2. Agricultural Revolution: With the advent of agriculture, settled communities emerged. Land ownership became critical, often controlled by rulers or elites. Possession of land and its produce was tied to social hierarchies.
3. Feudalism: During the medieval period, feudalism established a hierarchical system of land ownership and possession. Lords owned land, while peasants had possession rights in exchange for labor and tribute.
4. Industrialization: The Industrial Revolution led to the growth of personal property and factory-based production. Ownership of goods and means of production became more individualized.
5. Modern Legal Systems: In contemporary society, ownership is largely governed by legal frameworks. Ownership is defined by legal titles and contracts, while possession involves physical control or use of an item.
6. Digital Age: The digital era has introduced new challenges to ownership and possession, especially in the realm of intellectual property and online assets.Sharing Economy: Concepts like the sharing economy have blurred traditional ownership boundaries, with people sharing possessions like cars and homes.
7. Blockchain Technology: Blockchain and cryptocurrencies are exploring decentralized ownership models, where ownership is recorded on a transparent and immutable ledger.

 

The evolution of ownership and possession continues to adapt to changing social, economic, and technological landscapes, with concepts like property rights and possession rights constantly evolving and being redefined.The ownership and possession is a complex and fascinating topic that has been studied by anthropologists, economists, and legal scholars for many years. There is no single theory that can fully explain the origins of these concepts, but there are a number of factors that are thought to have played a role.

 

One important factor is the development of agriculture. As humans began to domesticate plants and animals, they began to accumulate more possessions, and this led to the need for a system of ownership to protect these possessions from theft or damage. Another important factor was the rise of social complexity. As societies became more complex, with different groups of people having different roles and responsibilities, it became necessary to develop a system of ownership to regulate the use of resources.

 

In the early stages of human evolution, there was probably no clear distinction between ownership and possession. Possession was simply the act of having physical control over an object, and it was not necessarily accompanied by any rights or privileges. However, as societies became more complex, the concept of ownership began to develop. Ownership came to be seen as a right to control and use an object, and it was typically enforced by social norms or laws.

 

There are three main classifications of ownership:

Corporeal ownership refers to ownership of physical objects, such as land, houses, and cars.

Incorporeal ownership refers to ownership of intangible things, such as intellectual property, such as patents and copyrights.

Sole ownership refers to ownership by a single person or entity.

The concept of ownership has evolved over time, and it continues to evolve today. In the modern world, ownership is often regulated by laws and contracts. These laws and contracts help to define the rights and responsibilities of owners, and they help to resolve disputes over ownership.

 

The evolution of ownership and possession is a fascinating example of how human societies have developed complex systems to manage their resources. These systems are essential for ensuring that resources are used efficiently and fairly, and they play a vital role in the functioning of modern societies.

 

OPINIONS OF DIFFERENT JURIST ON OWNERSHIP AND POSSESSION

Ownership and possession have been central themes in legal philosophy for centuries, and various jurists have contributed diverse perspectives on these concepts. This analysis will explore some key opinions from notable jurists, past and present, shedding light on the nuanced understanding of ownership and possession.

 

John Locke’s Labor Theory of Property: John Locke, an influential Enlightenment philosopher, believed that individuals have a natural right to property. He argued that private property originates from an individual’s labor mixing with resources from the common state of nature. Locke’s perspective laid the foundation for the concept of private property rights in modern legal systems, emphasizing the importance of labor as a basis for ownership.

 

Karl Marx’s Critique of Capitalist Ownership: Karl Marx, a prominent critic of capitalism, viewed ownership as a source of exploitation in capitalist societies. He believed that private ownership of the means of production allowed capitalists to extract surplus value from the labor of the working class. Marx advocated for the abolition of private ownership in favor of collective ownership, aiming to eliminate class-based inequalities.

 

H.L.A. Hart’s Legal Positivism: Legal positivism, as advocated by H.L.A. Hart, focuses on the legal framework itself. Hart argued that ownership and possession are determined by positive law and legal systems within a given society. This perspective underscores the importance of legal rules and regulations in defining and recognizing ownership and possession rights, regardless of underlying moral or philosophical principles.

 

St. Thomas Aquinas and Natural Law: St. Thomas Aquinas, a medieval scholar, believed in the existence of natural moral principles that should guide legal systems. He argued that ownership and possession should align with these moral principles, emphasizing the importance of just acquisition and use of property. Aquinas’s perspective integrates moral considerations into the concept of ownership.

 

Oliver Wendell Holmes Jr. and Legal Realism: Legal realists, including Oliver Wendell Holmes Jr., questioned idealistic notions of ownership and possession. They contended that judicial decisions and legal outcomes are often influenced by subjective factors, such as judges’ personal beliefs and societal context, rather than strict adherence to legal principles. This perspective highlights the role of interpretation and pragmatism in the application of property law.

 

Catharine MacKinnon’s Feminist Critique: Feminist legal scholars like Catharine MacKinnon have critiqued traditional property concepts for their historical gender bias and insensitivity to gender-based inequalities. They argue that property laws should be reevaluated to address issues of gender discrimination and violence, shedding light on the intersection of property and social justice.

 

Michel Foucault and Jacques Derrida’s Postmodern Perspectives: Postmodern legal theorists, including Michel Foucault and Jacques Derrida, have deconstructed traditional legal categories, including ownership and possession. They emphasize that language and power dynamics shape legal concepts, highlighting the need for a critical examination of the socio-cultural context in which legal definitions are constructed. This perspective challenges the stability and universality of property concepts.

 

Savigny: Savigny was a German jurist who developed a theory of possession that is still widely used today. Savigny’s theory holds that possession is the intention coupled with the physical power to exclude others from the use of a material object.

 

Ihering: Ihering was a German jurist who also wrote extensively on the concepts of ownership and possession. Ihering’s theory of possession is more practical than Savigny’s. Ihering argued that possession is simply the external manifestation of ownership.

 

Salmond: Salmond was a Scottish jurist who wrote one of the most influential textbooks on jurisprudence. Salmond’s definition of possession is similar to Ihering’s. Salmond defined possession as “the continuing exercise of a claim to the exclusive use of an object.”

 

Bentham: Bentham was an English jurist who was critical of the concept of ownership. Bentham argued that ownership is a social construct that is not necessary for human flourishing.

The opinions of different jurists on ownership and possession continue to be debated today. The concepts of ownership and possession are complex and there is no single definition that is universally accepted. However, the different opinions of jurists provide valuable insights into these important concepts.

In addition to the jurists mentioned above, other notable figures who have written on the concepts of ownership and possession include:

 

Blackstone: Blackstone was an English jurist who wrote one of the most influential legal textbooks in the English language. Blackstone’s definition of ownership is similar to Salmond’s.

 

Jhering: Jhering was a German jurist who was a student of Ihering. Jhering’s work on the concept of possession is highly influential in German law.

 

Gray: Gray was an American jurist who wrote extensively on the concepts of property and possession. Gray’s work is still widely cited by American lawyers and judges.

The concepts of ownership and possession are fundamental to the law of property. The different opinions of jurists on these concepts provide valuable insights into their nature and significance.

These jurists represent a spectrum of views on ownership and possession, showcasing the complexity and evolution of these concepts in legal philosophy. Their opinions reflect different historical periods, legal traditions, and social contexts, contributing to the ongoing discourse on property rights and the role of law in shaping ownership and possession.

 

EFFECTS OF ADVERSE POSSESSION ON OWNERSHIP AND POSSESSION UNDER GLOBALISED ECONOMY

The role of adverse possession in modern property law, considering its impact on property rights, land use planning, and the resolution of boundary disputes[4].Certainly, adverse possession is a legal doctrine that can have significant effects on ownership and possession of real property. This doctrine allows an individual to gain legal title to someone else’s property under conditions. The effects of adverse possession are multifaceted and can vary depending on jurisdiction and specific circumstances. In this analysis, we will delve into the effects of adverse possession on ownership and possession, considering both its historical context and contemporary relevance.

 

Historical Background:

Adverse possession has deep historical roots, dating back to Roman law and English common law. It was originally developed as a means to encourage the productive use of land. The idea was that if a person occupied and improved neglected or abandoned land openly and continuously for a specified period, they should be rewarded with legal ownership. This principle aimed to prevent land from lying fallow and unproductive.

 

Effects on Ownership:

Transfer of Title: The most significant effect of adverse possession is the potential transfer of legal title from the original owner to the adverse possessor. When the statutory requirements for adverse possession are met, the adverse possessor acquires the property’s ownership rights, effectively extinguishing the title of the former owner. This shift in ownership is often irreversible and can lead to disputes and litigation.

Loss of Ownership Rights: For the original owner, adverse possession can result in the complete loss of their ownership rights. Once the adverse possessor meets the necessary criteria, the owner’s ability to reclaim the property diminishes. This can be particularly problematic if the original owner was unaware of the adverse possession or if the adverse possessor’s actions were fraudulent or concealed.

Impact on Property Value: Adverse possession can affect the value of a property. Potential buyers may be hesitant to purchase land with a history of adverse possession, as the title’s legitimacy may be in question. Title insurance and legal due diligence become essential when dealing with properties that have undergone adverse possession.

 

Effects on Possession:

Disruption of Possession: Adverse possession can disrupt the peaceful possession of the original owner. When an adverse possessor occupies the property openly and continuously, the original owner’s use and enjoyment of the land may be compromised. This disruption can lead to disputes and legal battles over possession rights.

Uncertainty of Possession: The doctrine of adverse possession introduces uncertainty regarding possession rights. Property owners must remain vigilant to protect their land from potential adverse possessors. This vigilance can manifest in maintaining fences, conducting regular inspections, and addressing trespassers promptly.

Legal Challenges to Possession: The adverse possessor may face legal challenges during the process. The original owner may contest the adverse possession claim, leading to litigation. These legal battles can be protracted and expensive, further complicating the possession of the property.

 

Contemporary Relevance:

While adverse possession’s historical roots were based on principles of land use and productivity, its contemporary relevance has evolved in the context of modern property law and globalized economies. Here are some of the effects of adverse possession in today’s world:

Property Investment and Development: In the globalized economy, property investment and development play a significant role. Adverse possession claims can disrupt real estate development projects, potentially leading to financial losses and delays. Developers must be cautious when acquiring land to avoid properties with adverse possession issues.

Digital Assets and Intellectual Property: The concept of adverse possession is expanding beyond physical real estate to include digital assets and intellectual property. With the rise of the internet and virtual property, questions arise about the adverse possession of domain names, digital content, and online platforms.

Global Property Transactions: International property transactions can be affected by adverse possession laws that vary from one jurisdiction to another. Companies operating globally may find themselves dealing with adverse possession claims in foreign countries, leading to legal complexities and potential disputes.

Changing Land Use Patterns: Adverse possession can impact land use patterns and urban development. As cities grow and evolve, disputes over land ownership and adverse possession can become more common, affecting urban planning and zoning.

Environmental Concerns: Adverse possession can have implications for environmental conservation. In cases where land is held by conservation organizations, adverse possession claims can disrupt conservation efforts and endanger fragile ecosystems.

Discusses the economic implications of ownership, emphasizing its role in incentivizing efficient resource allocation and management.[5]In a globalized economy, where borders are increasingly porous and transactions span international jurisdictions, adverse possession can introduce complex challenges to the traditional concepts of ownership and possession. Adverse possession laws vary significantly from one country to another, and this lack of uniformity can create uncertainty and legal disputes in international commerce. Companies operating globally may find themselves in situations where they unknowingly lose ownership or control of properties due to adverse possession claims in foreign jurisdictions. Conversely, they might encounter difficulties when attempting to assert their property rights in countries with different legal frameworks. Additionally, the rise of digital assets and virtual property in the global economy presents novel questions about adverse possession in the digital realm, where physical occupation is not as straightforward. Consequently, the application of adverse possession laws in the globalized economy requires careful consideration and harmonization to ensure the protection of property rights while accommodating the complexities of international business transactions.The effects of adverse possession on ownership and possession under a globalized economy can be significant. In a globalized economy, property is often owned by people who live in different countries. This can make it difficult for the owner to maintain continuous and uninterruptedpossession of the property. Additionally, the doctrine of adverse possession can be used by unscrupulous individuals to acquire property that they do not own.

One way to mitigate the effects of adverse possession in a globalized economy is to register property ownership. Property registration makes it easier for the owner to prove their ownership and to prevent adverse possession. Additionally, some countries have laws that limit the time period for adverse possession. This can help to protect property owners from losing their property through adverse possession.

 

Here are some specific examples of how adverse possession can affect ownership and possession in a globalized economy:

• A foreign investor buys a property in a developing country. The investor then leaves the country and does not return for many years. During this time, a local squatter moves onto the property and starts living there. If the squatter meets the requirements for adverse possession, they may be able to acquire ownership of the property, even though the investor is the legal owner.
• A company owns a factory in a foreign country. The company closes the factory and leaves the country. A few years later, a group of people start using the factory as a warehouse. If the group meets the requirements for adverse possession, they may be able to acquire ownership of the factory, even though the company is the legal owner.
• A person inherits a property in a foreign country. The person does not speak the language or know the local laws. They do not take any steps to register the property or maintain possession of it. A few years later, someone else starts claiming ownership of the property. If the person who inherited the property does not take action, they may lose their ownership rights through adverse possession.

These are just a few examples of how adverse possession can affect ownership and possession in a globalized economy. The effects of adverse possession can be significant, and it is important for property owners to be aware of the risks. By taking steps to protect their property,such as registering ownership and maintaining possession, property owners can help to mitigate the effects of adverse possession.

 

CONCLUSION

The concepts of ownership and possession are fundamental to the law of property. Ownership is the right to possess, use, and enjoy a thing. Possession is the actual control of a thing. While ownership and possession are often closely related, they are not the same thing.

 

In a globalized economy, where property is often owned by people who live in different countries, the concepts of ownership and possession can become even more complex. The doctrine of adverse possession can also play a role in this context, as it allows a person to acquire ownership of property through continuous, open, and notorious possession for a certain period of time.

 

In India, the law of adverse possession is governed by the Limitation Act, 1963. Under this Act, a person can acquire ownership of property through adverse possession if they have been in continuous, open, and notorious possession of the property for a period of 12 years in the case of private land and 30 years in the case of government land.

 

The doctrine of adverse possession has been used in India to resolve a number of disputes over property ownership. However, the doctrine has also been criticized for being unfair to the original owner of the property. In recent years, there has been a growing movement to reform the law of adverse possession in India.

 

One of the main arguments in favor of reforming the law of adverse possession is that it is unfair to the original owner of the property. The original owner may have been unaware of the adverse possession, or they may have been unable to take action to prevent it. Additionally, the original owner may have invested a significant amount of time, money, and effort into the property.

 

Another argument in favor of reforming the law of adverse possession is that it can lead to uncertainty in land ownership. This uncertainty can make it difficult for people to invest in property and can discourage economic development.

 

Here are some of the key considerations for reforming the law of adverse possession in India:

• The time period for adverse possession should be shortened. The current time period of 12 years for private land and 30 years for government land is too long, and it can be unfair to the original owner of the property.
• The requirements for adverse possession should be made more stringent. The current requirements for adverse possession are relatively easy to meet, and this can lead to abuse of the doctrine. For example, the requirement that the possession be "open and notorious" is often interpreted loosely, and this can allow squatters to acquire ownership of property without the knowledge or consent of the original owner.
• The law should be amended to allow the original owner of the property to challenge adverse possession even after the time period has expired. This would provide the original owner with a fair chance to protect their property rights.

Any reform to the law of adverse possession in India should be carefully considered to ensure that it is fair to all parties involved. The goal should be to strike a balance between the rights of the original owner of the property and the rights of the person who has been in adverse possession of the property.

 

In addition to the above, here are some other factors that should be considered when reforming the law of adverse possession in India:

• The impact of the reform on the economy. A reform that makes it more difficult to acquire property through adverse possession could discourage investment and economic development.
• The impact of the reform on the environment. A reform that allows squatters to acquire ownership of property could lead to environmental degradation.
• The impact of the reform on social justice. A reform that unfairly disadvantages the poor or marginalized could be seen as unjust.

 

The reform of the law of adverse possession in India is a complex and challenging issue. However, it is an important issue that deserves careful consideration. By carefully considering the various factors involved, it is possible to develop a reform that is fair to all parties involved and that promotes economic development and social justice.

 

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[1]Black’s Law Dictionary, 11th Edition (2019), p. 1284.

[2]Honoré, A.M. (1961), p. 493.

[3]Merrill, T.W., & Smith, H.E. (2001), p. 361.

[4] Smith, R.E. (2000), p. 449.

[5]Ellickson, R.C. (1998), p. 349.