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To contribute to the limited work in this field, much of which has been conducted in the United States 2,7,17-21 , data were collected in four countries: Australia, China, India, and the United Kingdom (UK)

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The counsel further contended that despite police certification of destruction of the seized stock, but considering magnitude on which the counterfeit manufacturing was going on, it was likely that vast stockpiles remained, and as the manufacturing unit was in the vicinity of the Mumbai city, it was possible that the counterfeit cigarettes were available for sale and distribution within the jurisdiction of this Court