Federalism

Why this chapter matters for UPSC: Chapter 7 of Indian Constitution at Work is the core source for GS Paper 2 questions on Centre-State relations, the three legislative lists, emergency provisions, Finance Commission, and the evolving concept of cooperative federalism. The Seventh Schedule lists, Article 356 and the Bommai case, GST as cooperative federalism, NITI Aayog, and the recommendations of the Sarkaria and Punchhi Commissions are among the most consistently tested topics. UPSC Mains has repeatedly asked questions on whether India is "federal" or "unitary" — a conceptual question this chapter directly addresses.

Contemporary hook (for Mains introductions): India's federal structure is in permanent creative tension. Designed to hold together a diverse continental nation, the Constitution tilts towards the Centre — in legislative competence, in financial resources, in emergency powers, and in the appointment of Governors. Yet states are not mere administrative units; they are independent constitutional polities with elected governments, legislative assemblies, and constitutional protections. The last three decades of coalition politics, economic liberalisation, and the GST transformation have shifted the discourse from competitive federalism (states competing for central favour) to cooperative federalism (Centre and States as genuine partners in governance). This chapter is fundamentally about the architecture of that partnership.

PART 1 — Prelims Fast Reference

The Seventh Schedule — Legislative Lists

42nd Amendment (1976) transferred five subjects from State List to Concurrent List: Education, Forests, Weights and Measures, Protection of Wild Animals and Birds, and Administration of Justice (organisation of courts below HC).

Residuary powers (Article 248): Subjects not enumerated in any of the three lists vest with Parliament (Union). This contrasts with the USA and Australia, where residuary powers rest with states.

Key Articles — Federalism

Centre-State Tensions — Emergency Articles

National Emergency (Article 352) — 44th Amendment Safeguards

S.R. Bommai Case (1994) — Article 356 Safeguards

Finance Commission — Key Facts

Commissions on Centre-State Relations

Federal vs Unitary Features of the Indian Constitution

UPSC Traps — Federalism

PART 2 — NCERT Chapter Notes (Mains Depth)

1. What is Federalism? Why Does India Need It?

Federalism is a system of government in which power is constitutionally divided between a central authority and constituent units (states, provinces). Both levels of government derive their powers directly from the Constitution — neither is merely a creation of the other.

Why federalism for India? India inherited a continental landmass with extraordinary diversity — in language, religion, culture, geography, and economic conditions. The framers faced a challenge that no other constitutional democracy had faced in quite the same form: how to hold together an enormously diverse polity that had never previously been a single state in the modern sense.

The solution was a federal structure with significant central features. The Constitution was designed, as K.C. Wheare observed, to be "quasi-federal" — federal in form but unitary in tendency. The framers — informed by the Partition tragedy and the experience of provincial separatism — chose to make the Centre strong enough to hold the country together while giving states sufficient autonomy to administer their diverse populations.

2. The Seventh Schedule — Division of Legislative Powers

The heart of Indian federalism lies in Articles 245–246 and the Seventh Schedule, which distribute legislative competence among three lists.

Union List (List I): Subjects of national importance requiring uniform legislation across India — defence, foreign policy, currency, atomic energy, banking, communications, railways, inter-state rivers. Parliament has exclusive jurisdiction. Currently 100 subjects.

State List (List II): Subjects of local or regional importance — land, law and order, local self-government, agriculture, public health, market regulation, water supply. State Legislatures have exclusive jurisdiction in ordinary circumstances. Currently 61 subjects (down from original 66 after the 42nd Amendment transferred 5 subjects to the Concurrent List).

Concurrent List (List III): Subjects where uniform law is desirable but local variation is acceptable — criminal law, family law, contracts, labour law, education, environment protection. Both Parliament and State Legislatures can legislate. In case of conflict, the parliamentary law prevails (Article 254) — unless the state law was reserved for Presidential assent and received it.

Residuary powers (Article 248): All subjects not enumerated in any list vest exclusively with Parliament. This is diametrically opposite to the US constitutional model, where residuary powers rest with the states. India's choice reflects the framers' concern that unforeseen new subjects (such as cyberspace, biotechnology) should fall under central control.

3. Why Indian Federalism Is Called "Quasi-Federal"

Constitutional scholars such as K.C. Wheare have described India as "quasi-federal" — not purely federal, not purely unitary, but a federation with strong unitary features. Both the federal and unitary characterisations have textual and institutional support.

Arguments for the federal character:

The Constitution establishes a dual polity — the Union government and state governments derive their powers independently from the Constitution. States are not administrative subdivisions of the Union; they are constitutional polities with their own legislatures, executives, high courts, and financial institutions. The Supreme Court in S.R. Bommai (1994) explicitly held that federalism is part of the basic structure of the Constitution — meaning even Parliament cannot destroy it through constitutional amendment.

Arguments for the quasi-federal/unitary character:

Several constitutional provisions tilt the balance strongly towards the Centre:

Single citizenship: India has only Union citizenship, not state citizenship as in the United States. Citizens have the same rights across states.

Integrated judiciary: Unlike the US, India has a single judicial hierarchy with the Supreme Court at the apex. There are no separate state and federal court systems.

Strong Centre in legislative competence: The Union List is the largest list; residuary powers vest with Parliament; Parliament can legislate on the State List under Articles 249, 250, 252, and 253; and in case of conflict on Concurrent List subjects, central law prevails.

Governor as Centre's agent: The Governor is appointed by the President, holds office at the pleasure of the President, can reserve state bills for Presidential consideration, can recommend President's Rule, and can act without ministerial advice in certain circumstances. Critics argue the Governor functions more as a Centre's representative than as a constitutional head of state.

Parliament's power over state territories: Article 3 allows Parliament, by simple majority, to change the boundaries, names, or areas of states. While the concerned state legislature's view is sought, it is not binding. This is fundamentally different from genuine federations where states cannot have their boundaries altered without their consent.

All India Services: The IAS (Indian Administrative Service), IPS (Indian Police Service), and IFoS (Indian Forest Service) are recruited and ultimately controlled by the Centre but serve in state governments. Senior administrative positions in states are thus filled by officers whose career advancement depends on the Centre.

Dr B.R. Ambedkar, responding to this critique in the Constituent Assembly, characterised India as a "Union of States" rather than a federation — the word "federation" does not appear in the Constitution. He argued this was a deliberate choice: India's unity could not be compromised by giving states the right to secede or by fragmenting fundamental institutions.

4. Centre-State Legislative Relations

Articles 245–255 govern the distribution of legislative powers.

Territorial extent (Article 245): Parliament can make laws for the whole or any part of India. State Legislatures can only make laws for the state or any part thereof.

Subject-matter competence (Article 246): The Seventh Schedule three-list distribution is the operative mechanism. When a State Legislature legislates on a Concurrent List subject and Parliament subsequently legislates on the same subject, the central law prevails — unless the state law was reserved for Presidential assent and received it (Article 254(2)).

Parliament's power to legislate on State List (exceptional circumstances):

• Article 249: Rajya Sabha can, by a resolution passed by 2/3 of members present and voting, declare it necessary in the national interest for Parliament to legislate on a State List matter. Parliament can then do so for 1 year (extendable).
• Article 250: During National Emergency (Article 352), Parliament can legislate on State List subjects.
• Article 252: If two or more states pass resolutions requesting Parliament to legislate on a State List subject, Parliament may do so; the resulting law applies only to those states (unless other states adopt it).
• Article 253: Parliament can legislate on any subject — including State List — to implement international treaties, agreements, or conventions.

These provisions mean states can never fully rely on the exclusivity of the State List against determined central legislative action.

5. Centre-State Administrative Relations

Even where states have legislative competence, the Centre has significant administrative reach:

All India Services: IAS and IPS officers are recruited by the Centre (UPSC) and allocated to state cadres, but their ultimate career decisions (empanelment for central deputation, promotions, disciplinary action) involve the Centre. This gives the Centre leverage over state administration at the senior levels.

Directions to states: The Centre can give directions to states on certain matters (Article 256 — conforming to central laws; Article 257 — maintaining means of communication of national importance). If states do not comply, President's Rule can follow.

Article 365: If a state fails to comply with directions of the Centre, it becomes lawful for the President to hold that the government of the state cannot be carried on in accordance with the Constitution — a trigger for Article 356.

6. Article 356 — President's Rule

Article 356 empowers the President to impose "President's Rule" in a state if satisfied — on the Governor's report or otherwise — that the constitutional machinery in the state has broken down. During President's Rule:

• The state government is dismissed and the Governor administers the state in the name of the President
• The state legislature is prorogued or dissolved
• Parliament exercises the legislative powers of the state

Historical misuse: Article 356 was invoked over 100 times between 1950 and 1994 — frequently for partisan political reasons, dismissing Opposition-party state governments. The Emergency period (1975–77) and its aftermath saw the most egregious misuse.

S.R. Bommai case (1994): A nine-judge bench of the Supreme Court fundamentally reshaped Article 356 in this landmark judgment:

• The floor of the Assembly is the sole test of majority — the Governor cannot dismiss a government based on his subjective assessment
• Presidential Proclamation under Article 356 is subject to judicial review — courts can examine whether the President had material before him to reach his satisfaction
• The Council of Ministers cannot advise dissolution of the Assembly immediately on proclamation — there is a window for judicial review
• Secularism is part of basic structure; a government flouting it can be removed

44th Amendment safeguards (1978):

• The proclamation lapses unless approved by both Houses of Parliament within 1 month (by special majority)
• Maximum duration is 3 years (six-month extensions require fresh parliamentary approval; beyond 1 year requires proclamation of national emergency or an Election Commission certificate that elections in the state are not possible)

7. Financial Relations — Finance Commission and Fiscal Federalism

The fiscal asymmetry: The Indian Constitution created a fiscal imbalance by design — the most buoyant tax sources (income tax, corporation tax, customs, central excise/GST) are assigned to the Centre, while the most expenditure-intensive responsibilities (public health, education, law and order, local government) rest with states. The Finance Commission and grants-in-aid are the constitutional mechanisms for correcting this vertical imbalance.

Finance Commission (Article 280): Constituted by the President every five years (or earlier), the Finance Commission recommends:

• The share of central tax revenues to be distributed to states (the divisible pool)
• The allocation of the states' share among individual states (the horizontal distribution formula — based on criteria such as population, area, fiscal capacity, demographic performance)
• Grants-in-aid to states whose revenues are insufficient to meet their needs
• Measures to supplement resources of Panchayats and Municipalities

The 16th Finance Commission (constituted 2023, chaired by Dr Arvind Panagariya) covers the award period 2026–2031, having submitted its report in October 2025.

Evolution of tax devolution: The 14th Finance Commission (2015–20) recommended increasing the states' share of the divisible pool to 42% (from 32% under the 13th FC) — the largest ever vertical devolution. The 15th FC recommended 41% (adjusting for the newly created Union Territories of J&K and Ladakh absorbing some share). The 16th FC's recommendations will shape Centre-State finances until 2031.

8. GST and Cooperative Federalism

The Goods and Services Tax, introduced through the 101st Constitutional Amendment Act, 2016, is one of the most significant fiscal reforms in India's post-independence history and a landmark in cooperative federalism.

Constitutional changes: The 101st Amendment inserted three new articles:

• Article 246A: Both Parliament and State Legislatures have concurrent power to make laws with respect to GST. Parliament has exclusive power over GST on inter-state trade.
• Article 269A: GST on inter-state supplies is levied and collected by the Centre, and divided between Centre and States as Parliament prescribes by law.
• Article 279A: Established the GST Council — comprising the Union Finance Minister (Chairperson), Union Minister of State for Finance, and the Finance Ministers of all States. The GST Council decides tax rates, exemptions, and other GST-related matters.

Why GST represents cooperative federalism:

• States voluntarily surrendered their exclusive power to tax goods (State List entry 54 — taxation on sale/purchase of goods) in exchange for a share of a larger, more efficient tax base
• The GST Council operates by weighted voting — Union has 1/3 weight, all States together have 2/3 weight; decisions require 3/4 supermajority — meaning neither Centre nor States can ram through decisions alone
• The Supreme Court described the 101st Amendment as a "watershed moment in the evolution of cooperative federalism" (2022)

9. Cooperative Federalism vs Competitive Federalism

Planning Commission era (pre-2015): The Planning Commission — a powerful extra-constitutional body with no explicit constitutional status — effectively directed state development plans by controlling discretionary central grants and plan approvals. States had to negotiate with the Planning Commission for resources, which critics argued made states supplicants of the Centre rather than co-equal partners.

NITI Aayog (from January 1, 2015): The Planning Commission was replaced by NITI Aayog (National Institution for Transforming India) through a Cabinet resolution. Key differences in the federal dimension:

• All State Chief Ministers and Lieutenant Governors of UTs are members of NITI Aayog's Governing Council — institutionalising state participation in national policy
• The top-down "one-size-fits-all" central planning model was replaced by a "bottom-up" approach where state governments are partners in designing development strategies
• NITI Aayog functions as a think-tank and facilitator rather than a fund-controlling authority

Competitive federalism: The concept — promoted particularly through rankings such as the Ease of Doing Business State Rank, NITI Aayog's SDG India Index, and the NFSA Performance Index — encourages states to compete with each other in improving governance quality, attracting investment, and achieving development outcomes. It is premised on the idea that inter-state competition spurs better governance.

Tensions in cooperative federalism:

• GST compensation: States were promised compensation for revenue losses for 5 years post-GST (2017–22). Disputes over compensation payments — especially during COVID-19 when Centre borrowed on states' behalf — strained Centre-State fiscal relations.
• Centrally Sponsored Schemes: Central government's shift to funding states through CSS (where states must match central grants) reduces state fiscal autonomy as states must align priorities with central schemes.
• Governor controversies: Delays in giving assent to state bills passed by legislatures, dismissal of state governments on political grounds, and the role of Governors in government formation during hung assemblies have been recurring friction points.

10. Inter-State Council and Zonal Councils

Inter-State Council (Article 263): The Constitution empowers the President to establish an Inter-State Council "if at any time it appears to the President that the public interests would be served" by doing so. The ISC was established by a Presidential Order of May 28, 1990 — following the Sarkaria Commission's recommendation. It is chaired by the Prime Minister and includes all Chief Ministers, Administrators of UTs, and six Cabinet Ministers of the Union.

Functions: Investigating and discussing subjects in which some or all states or the Union and states have a common interest; making recommendations for better coordination of policy; discussing other matters of general interest.

The ISC is an advisory body — its recommendations are not binding. Critics argue it has met infrequently and its decisions are not always implemented, limiting its effectiveness as a forum for genuine federal dialogue.

Zonal Councils: Five Zonal Councils were established under Part III of the States Reorganisation Act, 1956 (a statutory body, not a constitutional one) at Pandit Nehru's initiative:

• Northern Zonal Council
• Central Zonal Council
• Eastern Zonal Council
• Western Zonal Council
• Southern Zonal Council

(Note: The North-Eastern Council, covering the eight north-eastern states, is a separate statutory body.)

The Union Home Minister is the common chairman of all five Zonal Councils. They discuss matters of common interest among member states — border disputes, inter-state transportation, development of interstate infrastructure. Like the ISC, they are advisory in nature.

11. Sarkaria Commission (1983) and Punchhi Commission (2007)

Sarkaria Commission: Set up in 1983, chaired by Justice R.S. Sarkaria (retired Supreme Court judge), to examine Centre-State relations. Submitted its 1600-page report in 1988 with 247 specific recommendations. Key recommendations:

• Article 356 should be used only as a last resort when constitutional machinery has genuinely broken down — not for political reasons
• The ISC under Article 263 should be made permanent and effective
• Governors should be appointed from outside the state, be non-partisan, and should not be given the office of profit after retirement
• The All India Services should be retained and strengthened
• Residuary powers of taxation should remain with Parliament; other residuary matters (non-taxation) should go to the Concurrent List
• Prior consultation with states on concurrent matters

In January 1999, the ISC endorsed 124 of Sarkaria's recommendations for implementation.

Punchhi Commission: Established in April 2007, chaired by Justice M.M. Punchhi (former Chief Justice of India), to re-examine Centre-State relations in light of changes since 1988. Submitted its report in March 2010 in 7 volumes with 273 recommendations. Key recommendations:

• "Localise" emergency provisions — central forces should not be deployed in a state against its wishes for more than a week without post-facto approval
• Governors should not be selected from the ranks of active politicians; should be removed only on the advice of the Chief Minister
• Article 355 (duty of Centre to protect states from external aggression and internal disturbance) should be invoked before resorting to Article 356 — a graduated response
• The ISC should be activated as a permanent working body, meeting at least 3 times a year
• Strengthen financial autonomy of states; rationalise centrally sponsored schemes

PART 3 — Mains Answer Frameworks

Framework 1: "Critically examine the federal features and unitary tendencies of the Indian Constitution." (15 marks)

Introduction (~60 words): The Indian Constitution is frequently described as "quasi-federal" — federal in structure but unitary in tendency. This characterisation, first offered by K.C. Wheare, captures a deliberate design choice: a constitution that divides power between the Union and States while retaining strong central mechanisms to ensure national cohesion in a diverse and newly independent democracy. The truth is more nuanced — India is federal by structure, unitary by necessity.

Body — Organise under two clear heads:

Federal features: The Constitution creates a dual polity — Union and States draw their authority directly from the Constitution, not from each other. The Seventh Schedule distributes legislative competence across three lists; states have exclusive jurisdiction over 61 State List subjects. The Finance Commission (Article 280) institutionalises resource sharing. The Supreme Court is the arbiter of federal disputes (Article 131). S.R. Bommai (1994) confirmed federalism as basic structure — Parliament cannot destroy it. The GST Council (Article 279A) represents genuine joint decision-making. Bicameralism (Rajya Sabha as a state-representing upper house) provides a federal check.

Unitary tendencies: Five structural features create strong centripetal forces: (1) Residuary powers vest with Parliament (Article 248); (2) Parliament can legislate on State List under Articles 249, 250, 252, 253; (3) Parliament can alter state boundaries without state consent (Article 3); (4) Article 356 allows Centre to take over state governance; (5) The Governor, appointed by the President, gives the Centre an agent in every state. Single citizenship, integrated judiciary, and All India Services further centralise power. K.C. Wheare noted that the distribution of powers in India decidedly favours the Centre.

Assessment: India's quasi-federal character was not an accident but a reasoned response to circumstances — the Partition trauma, the challenge of integration of princely states, and the need for uniform economic planning in the early decades. As India has matured — with strong regional parties governing states, coalition politics at the Centre reducing Delhi's dominance, and GST requiring genuine Centre-State cooperation — the federal character has strengthened in practice even where constitutional text favours the Centre.

Conclusion: India's Constitution is best understood not as a fixed federal or unitary structure but as a flexible architecture that can accommodate the needs of national unity and state autonomy simultaneously. The balance has shifted over time — the 1970s saw aggressive centralisation; the post-1990s era has seen re-federalisation through coalition politics and fiscal reforms. The Constitution's design, for all its centrist tilt, has proved resilient enough to sustain this evolution.

Framework 2: "Examine Article 356 of the Indian Constitution in light of the S.R. Bommai judgment." (10 marks)

Introduction: Article 356 — the provision for President's Rule in states — has been called the most dangerous provision in the Indian Constitution. Invoked over 100 times between 1950 and 1994, it was frequently misused to dismiss politically inconvenient Opposition-party state governments. The S.R. Bommai judgment (1994) of a nine-judge Supreme Court bench transformed Article 356 from a tool of political centralism into a provision tightly hedged by constitutional and judicial safeguards.

Body:

The problem: Articles 356's trigger — "failure of constitutional machinery" — is inherently subjective. A sympathetic Governor, writing a partisan report to the Centre, could provide the pretext for dismissing a state government. Between 1967 and 1994, Article 356 was invoked to dismiss state governments of parties opposed to the ruling party at the Centre — most egregiously after the Emergency (1977) and in the early 1990s (Babri Masjid demolition fallout).

Bommai's holdings: The nine-judge bench (1994) established: (1) Floor of the Assembly is the only legitimate test of majority; (2) Presidential Proclamation is justiciable — courts can examine whether the President had material before him; (3) Before imposing President's Rule, the state legislature should be given an opportunity to demonstrate majority; (4) Secularism as basic structure — governments flouting secularism can be dismissed; (5) Once promulgated, the state legislature cannot be dissolved until Parliament approves the proclamation.

44th Amendment safeguards: Parliamentary approval within 1 month by special majority; maximum duration of 3 years with 6-month extensions; Lok Sabha can revoke by simple majority.

Contemporary relevance: Post-Bommai, Article 356 is invoked far less frequently and courts have become more willing to examine the constitutional basis for its imposition. However, the Governor's role in recommending President's Rule and in government formation during hung assemblies remains a contested area — the Bommai doctrine applies after imposition, not to the Governor's report that triggers it.

Conclusion: The Bommai judgment represents the Supreme Court's most significant intervention in Centre-State relations. By making Article 356 justiciable and affirming federalism as basic structure, the Court reshaped the balance of power between Centre and States in a way that even constitutional amendment cannot undo.

Framework 3: "Cooperative federalism — an aspiration or a reality in India?" (10 marks)

Introduction: Cooperative federalism — the principle that Centre and States are partners in governance rather than competitors in a zero-sum game — has become a central theme in India's developmental discourse. The replacement of the Planning Commission with NITI Aayog (2015), the creation of the GST Council (2016), and the Finance Commission's enhanced devolution to states all reflect a genuine shift. Yet structural tensions — in fiscal relations, Governor controversies, and the proliferation of centrally sponsored schemes — reveal that cooperative federalism remains an aspiration as much as a reality.

Body:

Evidence of cooperative federalism in practice: The 14th Finance Commission's recommendation of 42% devolution of the divisible pool to states gave states unprecedented fiscal resources to pursue their own priorities. The GST Council — where states together hold 2/3 of voting weight — is a constitutionally embedded cooperative institution. NITI Aayog's Governing Council (all CMs as members) institutionalises state participation in national planning. The SDG India Index and similar state-ranking exercises encourage healthy inter-state learning and competition.

Persistent tensions: Centrally Sponsored Schemes — where states must match central grants for centrally designed programmes — reduce state fiscal autonomy by tying state expenditure to central priorities. State Finance Commissions (for Panchayats and Municipalities) have not functioned with the same vigour as the Union Finance Commission, weakening local self-governance. Governor controversies — delays in assenting to state bills, partisan recommendations on government formation — remain friction points. GST compensation disputes (2020–22) exposed the vulnerability of cooperative arrangements when fiscal stress hits.

Structural constraints: True cooperative federalism requires approximate fiscal equality between levels of government. India's constitutional assignment — most buoyant taxes with the Centre, most expenditure responsibilities with States — creates a vertical imbalance that no Finance Commission can fully correct. States that are fiscally dependent on central transfers are structurally weakened as equal partners.

Conclusion: Cooperative federalism in India is a direction of travel, not an achieved destination. The institutional infrastructure — GST Council, NITI Aayog, Finance Commission — is in place. The political culture of Centre-State relations has improved from the confrontational centralisation of the 1970s. But structural fiscal asymmetry, the proliferation of central schemes, and the recurring controversy over Governors' roles mean that genuine fiscal and administrative federalism remains work in progress.

Exam Strategy

For Prelims:

• Memorise the three lists and their current subject counts: Union List (100), State List (61), Concurrent List (52) — the 42nd Amendment reduced State List from 66 to 61
• Article 248 = residuary with Parliament (not states — this is a common trap)
• Finance Commission = Article 280; constituted every 5 years; 16th FC covers 2026–2031
• Inter-State Council established May 28, 1990 (Presidential Order); Article 263 is the constitutional basis
• Zonal Councils = 5 in number; statutory (States Reorganisation Act 1956); chairman = Union Home Minister
• S.R. Bommai case = 1994, 9-judge bench, floor test is the majority test
• GST = 101st Constitutional Amendment, 2016; added Article 246A (concurrent GST power)
• NITI Aayog replaced Planning Commission from January 1, 2015 (Cabinet Resolution — no constitutional basis)
• Article 360 (Financial Emergency) has never been declared in India

For Mains:

• The "Is India truly federal?" question requires a structured two-sided argument — always list specific constitutional provisions under each head, not just generalities
• Article 356 questions must include: the misuse history, the Bommai judgment's specific holdings, and 44th Amendment safeguards
• Cooperative federalism questions should cover GST Council, Finance Commission, NITI Aayog, AND identify the tensions/limitations — avoid one-sided cheerleading
• Sarkaria and Punchhi Commission questions: quote the year, chairman, and at least 3–4 specific recommendations
• The keyword "basic structure + federalism" connects to S.R. Bommai (1994) — always cite this case when discussing the constitutional status of federalism

Current Affairs Link: Track: 16th Finance Commission recommendations (released 2025–26); GST Council meetings and rate changes; Governor controversies in various states; debates on delimitation and its federal implications; Centre-State disputes over welfare schemes. Visit Ujiyari.com for current affairs linked to this chapter.