title: Necessary and Proper Clause

text: The clause, as justification for the creation of a national bank, was put to the test in 1819 during "McCulloch v. Maryland" in which Maryland had attempted to impede the operations of the Second Bank of the United States by imposing a prohibitive tax on out-of-state banks, the Second Bank of the United States being the only one. In the case, the Court ruled against Maryland in an opinion written by Chief Justice John Marshall, Hamilton's longtime Federalist ally. Marshall stated that the Constitution did not explicitly give permission to create a federal bank, but it conferred upon Congress an implied power to do so under the Necessary and Proper Clause so that Congress could realize or fulfill its express taxing and spending powers. The case reaffirmed Hamilton's view that legislation reasonably related to express powers was constitutional. Marshall wrote:


title: Necessary and Proper Clause

text: "McCulloch v. Maryland" held that federal laws could be necessary without being "absolutely necessary" and noted, "The clause is placed among the powers of Congress, not among the limitations on those powers." At the same time, the Court retained the power of judicial review established in "Marbury v. Madison" by declaring that it had the power to strike down laws that departed from those powers: "Should Congress, in the execution of its powers, adopt measures which are prohibited by the Constitution, or should Congress, under the pretext of executing its powers, pass laws for the accomplishment of objects not intrusted to the Government, it would become the painful duty of this tribunal, should a case requiring such a decision come before it, to say that such an act was not the law of the land."


title: Necessary and Proper Clause

text: As Marshall put it, the Necessary and Proper Clause "purport[s] to enlarge, not to diminish the powers vested in the government. It purports to be an additional power, not a restriction on those already granted." Without that clause, there would have been a dispute about whether the express powers imply incidental powers, but the clause resolved that dispute by making those incidental powers be expressed, instead of implied.


title: Necessary and Proper Clause

text: In a related case after the American Civil War, the clause was employed, in combination with other enumerated powers, to give the federal government virtually complete control over currency.


title: Necessary and Proper Clause

text: The clause has been paired with the Commerce Clause to provide the constitutional basis for a wide variety of federal laws. For instance, various reforms involved in the New Deal were found to be necessary and proper enactments of the objective of regulating interstate commerce.


title: Necessary and Proper Clause

text: Indeed, the influence of the Necessary and Proper Clause and its broader interpretation under "McCulloch v. Maryland" (1819) in American jurisprudence can be seen in cases generally to be thought to involve simply the Commerce Clause.


title: Necessary and Proper Clause

text: In "Wickard v. Filburn" (1942), the Supreme Court upheld a federal statute making it a crime for a farmer to produce more wheat than was allowed under price and production controls, even if the excess production was for the farmer's own personal consumption. The Necessary and Proper Clause was used to justify the regulation of production and consumption.


title: Necessary and Proper Clause

text: Also, in addition to both clauses being used to uphold federal laws that affect economic activity, they also were used to justify federal criminal laws as well. For example, Congress in the Federal Kidnapping Act (1932) made it a federal crime to transport a kidnapped person across state lines because the transportation would be an act of interstate activity over which the Congress has power. It has also provided justification for a wide range of criminal laws relating to interference with the federal government's rightful operation, including federal laws against assaulting or murdering federal employees.


title: Necessary and Proper Clause

text: In "National Federation of Independent Business v. Sebelius" (2012), the Supreme Court ruled that the individual mandate of the Patient Protection and Affordable Care Act cannot be upheld under the Necessary and Proper Clause. Chief Justice John Roberts ruled that the mandate cannot "be sustained under the Necessary and Proper Clause as an integral part of the Affordable Care Act's other reforms. Each of this Court's prior cases upholding laws under that Clause involved exercises of authority derivative of, and in service to, a granted power... The individual mandate, by contrast, vests Congress with the extraordinary ability to create the necessary predicate to the exercise of an enumerated power and draw within its regulatory scope those who would otherwise lie outside it. Even if the individual mandate is "necessary" to the Affordable Care Act's other reforms, such an expansion of federal power is not a "proper" means for making those reforms effective."


title: Necessary and Proper Clause

text: According to its proponents, the ruling returns the clause to its original interpretation, outlined by John Marshall in "McCulloch v. Maryland". According to David Kopel, the clause "simply restates the background principle that Congress can exercise powers which are merely 'incidental' to Congress's enumerated powers."


title: Necessary and Proper Clause

text: The specific term "Necessary and Proper Clause" was coined in 1926 by Associate Justice Louis Brandeis, writing for the majority in the Supreme Court decision in "Lambert v. Yellowley," 272 U.S. 581 (1926), which upheld a law restricting medicinal use of alcohol as a necessary and proper exercise of power under the 18th Amendment, which established Prohibition.


title: Necessary and Proper Clause

text: The phrase has become the label of choice for this constitutional clause. It was universally adopted by the courts and received Congress's imprimatur in Title 50 of the United States Code, Section 1541(b) (1994), in the purpose and policy of the War Powers Resolution.


title: EA Black Box

text: EA Black Box (formerly Black Box Games) was a video game developer based in Burnaby, British Columbia, Canada, founded in 1998 by former employees of Radical Entertainment and later acquired by Electronic Arts (EA). The developers are primarily known for the "Need for Speed" and "Skate" series. It was renamed Quicklime Games during the development of "", but after a series of restructures it was shut down in April 2013.


title: EA Black Box

text: Black Box Games had previously developed for game publishers such as Sega, Midway Games, and EA. In June 2002, during the development of "", the firm was acquired by EA and became an entirely owned subsidiary of EA Canada. As a result of the acquisition the studio's name was changed to EA Black Box. In March 2003, the firm lacked space for their current projects and as a solution the top four floors of an office tower in downtown Vancouver were used for expansion. In March 2005, EA Black Box became an independent studio from EA Canada, but still owned by EA.


title: EA Black Box

text: On December 19, 2008, EA announced that it would be shutting down EA Black Box's Vancouver studio location and relocating operations to EA Canada's Burnaby facilities, as part of EA's worldwide consolidation plans. Officials stressed that EA Black Box would remain open, and said they expected the move to be completed by June 2009. The studio remained a part of the EA Games label, and was independent of the EA Sports studio also located within the Burnaby facility.


title: EA Black Box

text: In February 2012, EA confirmed a number off lay-offs at EA Canada and EA Black Box, and that they were transforming the studios towards "high-growth digital formats, including online, social gaming and free-to-play". EA declined to comment on whether EA Black Box's brand would remain.


title: EA Black Box

text: In July 2012, EA Black Box was renamed Quicklime Games during the development of PC game "", under which name it operated until its closure in April 2013.


title: EA Black Box

text: The former employees of EA Black Box have spread around other game developers making racing games such as Ubisoft's "The Crew" and Slightly Mad Studios' "World of Speed".


title: Toyota Cresta

text: The is a mid-size car built by Toyota. It was launched in 1980 and shared the chassis with the Mark II/Cressida, sold at "Toyopet Store" dealerships in Japan. The goal of the Cresta was a higher level of luxury in comparison to the Mark II, while the Chaser was the performance-oriented version of the Mark II, but sold at different dealerships. Often available with two-tone paint and more interior convenience options, with the result ending up being more similar to the Cressida sold in export markets. The Cresta was produced for five generations, and production eventually ceased in 2001, when it was merged with the Chaser to form the short lived Verossa.


title: Toyota Cresta

text: The first Cresta was introduced April 1980 and was available exclusively at the renamed "Toyota Vista Store" (formerly Toyota Auto Store) sales channels across Japan, joining the X40 Chaser. The Cresta was positioned as a high-level luxury sedan just below the established, traditional luxury sedan, the Crown. The sales goal of the Cresta was to provide buyers with a luxury sedan, but not incur tax consequences for exceeding dimension regulations, the vehicle was limited to an engine size at 2000cc as well as dimensions under long, wide, and high, and allowing another Toyota dealership network to offer a luxury-sports oriented product originally exclusive to "Toyota Store" and "Toyopet Store" locations. The Cresta was introduced with halogen headlights to provide a modern European appearance, and was available with a full range of luxury amenities and conveniences. The SOHC 2.0 L M-EU engine was used with an automatic transmission only, which was shared with the Crown, as well as the 2.0L 1G-EU straight six engine, also used in the Crown. Trim levels used names meant to suggest luxury overtones, such as Super Lucent, Super Touring, Super Deluxe, Super Custom, and Custom, names that were similarly used on the Crown. Upper level trim levels used two-tone paint schemes to further the Cresta's elevated status towards a younger demographic. The Nissan competitor was the Laurel.


title: Toyota Cresta

text: This new luxury approach was well received with buyers. In August 1983, Toyota chairman Eiji Toyoda initiated the F1 project ("Flagship" and "No. 1 vehicle"; alternatively called the "Circle-F" project), a clandestine effort aimed at producing a world-class luxury sedan for international markets. This led to the creation of an all new, full size luxury sedan designed for export markets, called the Lexus LS.


title: Toyota Cresta

text: The X70 series was introduced March 8, 1984, with styling cues shared with the platform sharing Mark II, with the Cresta now offered as a 4-door, 4-window sedan (with window frames) while the X70 Mark II was offered as a 4-window hardtop bodystyle similar to the Chaser, alongside a 6-window style Mark II sedan. The Cresta has a distinct, creased rear windshield. The X70 series continued to enjoy the popularity enjoyed by the first generation Cresta. Power side view mirrors were now installed western style at the leading edge of the front doors instead of on the front fenders above the front wheels to provide a more modern appearance, and retracted electrically for confined parking spaces. The 2.2-litre diesel engine used in the first generation was upgraded to one with 2.4 litres displacement.


title: Toyota Cresta

text: Styling upgrades and engine changes were introduced in 1985. The twin turbo 1G-GTEU was introduced in October 1985, with the trim level designation GT Twin Turbo. As a result of the twin turbo introduction, the M-TEU engine was no longer offered. Foglights imbedded in the front bumper were made standard equipment, with another minor styling upgrade August 1986.


title: Toyota Cresta

text: The third generation was introduced March 8, 1988, with a transition away from straight edges previously used by Toyota products of the period and it was no longer a hardtop sedan. The top-of-the-line model, called the Super Lucent G included a supercharger equipped 1G-GZE engine. The 1JZ-GE and 1JZ-GTE were shared with the Chaser. Special anniversary trim levels were introduced May 1990, with a body refresh introduced later that year.


title: Toyota Cresta

text: The X90 Cresta debuted in 1992 with significant styling and mechanical changes over the X80. The car increased in size and gained some new trim levels similar to its sister cars, the Mark II and Chaser. Engines were carried over from the past generation albeit without the 7M or supercharged 1G I6's. Toyota also changed the front grille and taillight design in 1994. Under Japanese exterior dimension regulations, this series was no longer regarded as a "compact car".


title: Toyota Cresta

text: The X90 Cresta was offered in 4 primary trim levels throughout its run (the SC, Suffire, Super Lucent and Tourer), each with their own options and even more specific trim categorizations. All cars shared common longitudinal layout architecture as well as certain options standard, like automatic climate control and side-impact bars, not to mention driver-side airbags in 1995. The base trim level SC had very little in terms of options; it was powered by either a petrol or diesel engine mated to a 4-speed automatic. The next level Suffire had the same options available (or lack thereof) as the SC plus an optional 5-speed manual.


title: Toyota Cresta

text: The Super Lucent however was a much different story: this trim offered 3 different straight 6 engines from 2.0L-3.0L mated to an electronically controlled 4-speed automatic with options like a moon roof or a factory LSD. Further differentiating Super Lucent models was the G package, which featured ABS, 15" wheels, cruise control and a leather interior. Permanent 4WD was offered as an option in 1993. The various sized engine displacements gave Japanese buyers choices as to which annual road tax obligation they were willing to pay.


title: Toyota Cresta

text: The Tourer trim levels all featured a 2.5L 1JZ straight 6, but with a few differences. The Tourer S had a naturally aspirated engine and only a 4-speed automatic whereas the Tourer V's came with a pair of turbochargers and the option of a 5-speed manual. All Tourers had front- and rear-stabilizer bars but only the Tourer V's came with traction control, ABS and an LSD standard. Tourer V's were very popular amongst enthusiasts and drifters due to their stiff chassis and power-to-weight ratio.


title: Toyota Cresta

text: In 1996 the X100 series was released. Although dimension are extremely similar to the X90 series, the X100 series Cresta boasts an extra in weight, in part because of stricter safety regulations.


title: Toyota Cresta

text: Predecessor to the Toyota Verossa, the new Cresta X100 series started its differences from the X90 series with an updated front and rear end. The new generation Cresta also lost its previous generation's 1.8L 4S-FE I4 engine option.


title: Toyota Cresta

text: The Cresta, along with the Chaser, ceased production in 2001 (the Mark II saw one more generation, the X110, before production ceased in 2004) to make way for its replacement, the Toyota Verossa.


title: Toyota Cresta

text: The car is notable for featuring in the anime and manga "Great Teacher Onizuka", in which it is owned by Hiroshi Uchiyamada, whose car gets destroyed multiple times after a series of mishaps.


title: Mahasweta Devi

text: Mahasweta Devi (14 January 1926 – 28 July 2016) was an Indian writer in Bengali and an activist. Her notable literary works include "Hajar Churashir Maa", "Rudali", and "Aranyer Adhikar". She was a leftist who worked for the rights and empowerment of the tribal people ("Lodha" and "Shabar") of West Bengal, Bihar, Madhya Pradesh and Chhattisgarh states of India. She was honoured with various literary awards such as the Sahitya Akademi Award (in Bengali), Jnanpith Award and Ramon Magsaysay Award along with India's civilian awards Padma Shri and Padma Vibhushan.


title: Mahasweta Devi

text: Mahasweta Devi was born in a Brahmin family on 14 Jan 1926 in Dacca, British India (now Dhaka, Bangladesh). Her father, Manish Ghatak, was a poet and novelist of the Kallol movement, who used the pseudonym Jubanashwa (). Ghatak's brother was filmmaker Ritwik Ghatak. Devi's mother, Dharitri Devi, was also a writer and a social worker whose brothers include sculptor Sankha Chaudhury and the founder-editor of "Economic and Political Weekly" of India, Sachin Chaudhury.


title: Mahasweta Devi

text: Devi's first schooling was in Dhaka, Eden Montessori School (1930). After that, she moved to West Bengal (now in India). Then she studied in Midnapore Mission Girls High School (1935). After that she was admitted to Santiniketan (1936 to 1938). After that, she studied at Beltala Girls' School (1939-1941) where she finished her matriculation. Then in 1944 she got I.A. from Asutosh College. She attended Rabindranath Tagore-founded Visva-Bharati University and completed a B.A. (Hons) in English, and then finished an M.A. in English at Calcutta University.


title: Mahasweta Devi

text: Devi wrote over 100 novels and over 20 collections of short stories primarily written in Bengali but often translated to other languages. Her first novel, titled "Jhansir Rani", based on a biography of the Rani of Jhansi was published in 1956. She had toured the Jhansi region to record information and folk songs from the local people for the novel.


title: Mahasweta Devi

text: Mahasweta Devi's specialisation lay in the studies of Adivasi, Dalit and Marginalized citizens with a focus on their women. They were associated as protestor in the face of British colonialism, the Mahajanas and upper class corruption and injustice. She lived in the Adivasi villages in West Bengal, Bihar, Madhya Pradesh, Chhattisgarh years after years, befriending them and learning from them. She has embodied their struggles and sacrifices in her words and characters. She had claimed that her stories aren't her creation, they are the stories of the people of her country. Such an example is her work " Chotti Mundi Ebong Tar Tir"


title: Mahasweta Devi

text: In 1964, she began teaching at Vijaygarh Jyotish Ray College (an affiliated college of the University of Calcutta system). In those days Vijaygarh Jyotish Ray College was an institution for working-class women students. During that period she also worked—as a journalist and as a creative writer. She studied the "Lodhas" and "Shabars", the tribal communities of West Bengal, women and dalits. In her elaborate Bengali fiction, she often depicted the brutal oppression on the tribal people and untouchables by the powerful authoritarian upper-caste landlords, money-lenders, and venal government officials. She wrote of the source of her inspiration:


title: Mahasweta Devi

text: Postcolonial scholar Gayatri Chakravorty Spivak has translated Devi's short stories into English and published three books "Imaginary Maps" (1995, Routledge), "Old Woman" (1997, Seagull), "The Breast Stories" (1997, Seagull).


title: Mahasweta Devi

text: Mahasweta Devi raised her voice several times against the discrimination suffered by tribal people in India. Devi's 1977 novel "Aranyer Adhikar" (Right to the Forest) was about the life of Birsa Munda. And in June 2016, consequent to Devi's activism, the Jharkhand State Government finally saw to the removal of the manacles from the figure of Munda, which had been part of the commemorative sculpture of the notable young tribal leader due to its having been based on a photograph dating from the era of British rule.


title: Mahasweta Devi

text: Devi spearheaded the movement against the industrial policy of the earlier Communist Party of India (Marxist) government of West Bengal. Specifically, she stridently criticized confiscation from farmers of large tracts of fertile agricultural land by the government which then ceded it to industrial houses at throwaway prices. She supported the candidature of Mamata Banarjee in the 2011 West Bengal Legislative Assembly election which resulted in the end of the 34-year long rule of CPI(M). She had connected the policy to the commercialization of Santiniketan of Rabindranath Tagore, where she spent her formative years. Her lead in the Nandigram agitation resulted in a number of intellectuals, artists, writers and theatre workers joining in protest of the controversial policy and particularly its implementation in Singur and Nandigram.


title: Mahasweta Devi

text: She is known to have helped the noted writer Manoranjan Bypari to come into prominence as his initial writings were published in her journal and as prompted by her.


title: Mahasweta Devi

text: At the Frankfurt Book Fair 2006, when India was the first country to be the Fair's second time guest nation, she made an impassioned inaugural speech wherein she moved the audience to tears with her lines taken from the famous film song "Mera Joota Hai Japani" by Raj Kapoor.


title: Mahasweta Devi

text: In 1997, president Shankar Dayal Sharma commuted two death sentences after Devi led a petition campaign. In 2012, she was one of more than 215 signatories, along with Nandita Das, Aamir Bashir, and Anusha Rizvi, to a petition delivered to president Pranab Mukherjee that opposed the death penalty after the conviction of Ajmal Kasab following the 2008 Mumbai attacks and instead favored life imprisonment. The letter stated, "In the land of Buddha, Mahavira and Gandhiji, let it not be said there is no place in our hearts for mercy."


title: Mahasweta Devi

text: On 27 February 1947, she married renowned playwright Bijon Bhattacharya, who was one of the founding fathers of the Indian People's Theatre Association movement. In 1948, she gave birth to Nabarun Bhattacharya, who became a novelist and political critic. She worked in a post office but was fired for her communist leaning. She went on to do various jobs, such as selling soaps and writing letters in English for illiterate people. In 1962, she married author Asit Gupta after divorcing Bhattacharya. In 1976, the relationship with Gupta ended.


title: Mahasweta Devi

text: On 23 July 2016, Devi suffered a major heart attack and was admitted to Belle Vue Clinic, Kolkata. Devi died of multiple organ failure on 28 July 2016, aged 90. She had suffered from diabetes, sepsis and urinary infection.


title: Mahasweta Devi

text: On her death, Mamata Banerjee, Chief Minister of West Bengal tweeted "India has lost a great writer. Bengal has lost a glorious mother. I have lost a personal guide. Mahasweta Di rest in peace." Prime Minister Narendra Modi tweeted "Mahashweta Devi wonderfully illustrated the might of the pen. A voice of compassion, equality & justice, she leaves us deeply saddened. RIP."


title: Mahasweta Devi

text: "Mahananda," a Bengali film based on her life and works, directed by acclaimed director Arindam Sil was released in 2022. Gargi Roychowdhury essayed the titular role in the film.


title: Baby Esther

text: Esther Lee Jones (born , date of death unknown), known by her stage names "Baby Esther", "Little Esther", and other similar variations, was an American singer and child entertainer of the late 1920s, known for interpreting popular songs with a "mixture of seriousness and childish mischief". After gaining attention in her hometown of Chicago, she became an international celebrity before leaving the public spotlight as a teenager.


title: Baby Esther

text: In 1932, when singer Helen Kane sued Fleischer Studios, claiming that they had appropriated her persona for the voice of the cartoon character Betty Boop, the studios defended themselves by arguing that Kane's style of singing—characterized by her baby voice and use of the phrase "boop-boop-a-doop"—was not her own invention. Theatrical manager Lou Bolton testified during the "Kane v. Fleischer" trial that Kane saw Baby Esther's cabaret act in 1928, in which Esther used interpolated words such as "boo-boo-boo" and "doo-doo-doo". An early test sound film of Baby Esther's performance was used as evidence. Other evidence introduced at the trial included a recording by the Duncan Sisters and testimony from performers such as Bonnie Poe, Margie Hines, and Little Ann Little, who testified that she had been singing in a baby voice and using interpolations such as "bo-de-o-do" for several years. The court ruled against Kane.


title: Baby Esther

text: "Baby" Esther Lee Jones, originally billed as Little, Li'l or Lil' Esther, was a child entertainer who lived in Chicago, Illinois. She was initially managed by her parents, Gertrude and William Jones. Esther was a trained scat singer, dancer and acrobat who performed regularly at nightclubs in Harlem and all over the United States in the 1920s. In her act, "Baby Esther" danced, made funny faces, rolled her eyes, and—most famously—interpolated nonsense phrases such as "Boo-Boo-Boo", "Wha-Da-Da", and "Doo-Doo-Doo".


title: Baby Esther

text: By 1924, she was being managed by Lou Bolton. According to Bolton, Esther began using nonsense syllables in her singing between 1926 and her arrival in New York in 1928. In 1928, Tony Shayne, Jones' New York booking agent, also served as booking agent for Helen Kane. In the later "Kane v. Fleischer" court case, Bolton claimed that Kane first saw Esther perform in 1928, at which time Kane had a ringside seat with Shayne at the Everglades Club on Broadway.


title: Baby Esther

text: While touring Europe in 1930, Esther had already been honored, along with Josephine Hall, as representatives of both African-Americans and the United States of America.


title: Baby Esther

text: Baby Esther lived in the "colored" neighborhood of Chicago with her mother and father. Esther's career began in the 1920s when she won first prize at a Charleston contest in Chicago at the age of six. Russian-American theatrical manager Lou Bolton saw her performance and took her on, with her first performance purportedly being in a Chicago revue, "Opera Versus Charleston". Bolton went on to arrange engagements for Esther in Chicago, New York, Detroit, Toronto and other cities, after which he brought her to Europe. Esther Jones was rarely called Baby Esther while performing, most commonly going by the names "Li'l Esther" and "Little Esther." Originally she was billed "Farina's Kid Sister," but was later known as the "Miniature Florence Mills", as Esther had started her career impersonating Florence Mills. Florence Mills was noted for her "light, bright" voice and her use of wordless vocalizations such as "too-ty-tooty-too".


title: Baby Esther

text: The name "Farina's Kid Sister" derived from Allen "Farina" Hoskins, another African-American child star of the period. Apart from his ongoing role in "Our Gang" comedies, Hoskins was an expert Charleston dancer, performing along with his sister "Baby Jane." Lou Bolton, Esther's first manager, used Hoskins' fame to promote Esther in the early years of her career; the name formulation of Little (or Lil'/Li'l) Esther mimicked Hoskins' "Little Farina," a frequently-used nickname. While touring Spain, Esther was referenced as a member of "La Pandilla," the Spanish name for the "Our Gang" kids (taken from their alternate series name of "Hal Roach's Rascals"); at least once, she was specifically tagged as the performer of Farina, due to her past imitations of him.


title: Baby Esther

text: Esther performed briefly at a nightclub called the Everglades Club, where she would do imitations of Florence Mills, late at night. In June, Esther's father William Jones and manager Lou Bolton was charged for having a minor perform on stage; one write-up of the incident suggested that William Jones was not Esther's birth parent.


title: Baby Esther

text: In late 1928 Esther was signed for a talking short by Movietone, booked through William Morris for MGM. While the short was later listed variously as being in production or completed, it has not surfaced as of 2020.


title: Baby Esther

text: Harrison G. Smith, a business associate of Bolden Smith of New York, furnished Esther with several songs: "The Turtle Walk," "My Little Dixie Home," "I've Got the Blues for Dixieland," and "I Need a Man (Around My House)."


title: Baby Esther

text: Esther toured Europe in 1929, when her age was variously reported as seven or ten. An article in "The Chicago Defender" described her as the highest-paid child artist in the world.


title: Baby Esther

text: While touring Europe she delighted audiences including royalty. In Spain she played for King Alphonso and Queen Victoria Eugenie. In Sweden King Gustave and the Queen came to the theater especially to see her. In France, Germany, and other countries, Esther also gave private performances for the nobility and high society.


title: Baby Esther

text: Esther's travels around Europe were not entirely without fits and starts. After a dispute, Bolton was fired as the Jones family's manager and returned to the United States; Bolton blamed an Afro-French interpreter, cited in "Variety" as "Jacques Garnier," for the fracas; at first, Esther's return to the United States was announced. But Sidney Garner—evidently the same man first cited as "Jacques"—took over as the Joneses' manager forthwith, and the family stayed in Europe.


title: Baby Esther

text: Esther Jones first performed in France at the Moulin Rouge. In Paris, Esther was known as the "Miniature Josephine Baker." "Vu", a leading illustrated weekly, devoted the entire front cover to her picture and a full page in the interior. Esther was described as singing, dancing, doing the splits and generally carrying on to the great delight of her audiences, and was dubbed as being "too cute for words".


title: Baby Esther

text: The "London Sunday People" in its review of Paris plays said of Esther: "Thousands flock no longer to the Moulin Rouge to see Mistinguett herself or the clever American ballet girls, or the beautiful women of the chorus, but to applaud a little mite, 10-year-old, who has won fame and wealth within the space of a few weeks. We are living in an age of speed but this amazing little child has broken every record of sudden theatrical success."


title: Baby Esther

text: In Stockholm, Sweden in August, Esther was famously refused service at an American restaurant run by Branda Tomton, an immigrant from the United States. Swedish dignitaries and officials around the country spoke up in support of Esther and objected to Tomton's discrimination, railing against American "Jim Crowism" in Sweden, forcing the restaurant to close.


title: Baby Esther

text: Esther continued her success in South America. In Rio de Janeiro, Buenos Aires, São Paulo, and Montevideo she proved to be a sensation. In Rio de Janeiro, American Ambassador Morgan came to see her play and after her performance came backstage to congratulate her. He praised her ability to sing in different languages and invited her to perform for him at the American embassy. Accompanying Esther was Gordon Stretton, who was known as the Prince of Wales' favorite jazz entertainer. In the course of the evening, the president of Brazil expressed to Sidney Garner his great pleasure at seeing such capable black American artists in Brazil.


title: Baby Esther

text: Esther was interviewed in Rio de Janeiro by press who wanted to know how she had avoided the racists who lynched and burned black people in Texas and Alabama. Esther replied that she had so far escaped their wrath by staying out of the South.


title: Baby Esther

text: When Esther returned to the United States she purportedly continued touring and danced for Cab Calloway and his Orchestra as one of his Sepia Dancers at his club in New York. In 1934, Esther, billed as "The Sepia Dancing Doll", appeared with Helena Justa's "Harlem Maniacs" revue.


title: Baby Esther

text: In July 1934, Esther performed in Philadelphia at a midnight benefit performance for the NAACP, along with numerous other African-American stars. The Baltimore "Afro-American" commented that "Little Esther... had a bit too much art and finesse, born of her extensive travel and contacts, not to mention expert tutelage, for her to bring... spontaneous applause... But she had charm and grace—and—and—form! [Her] acrobatic dance number was very good." Esther made another Philadelphia appearance in September at a benefit for the Douglass Hospital, hosted by the famed dancer Bill "Bojangles" Robinson. Notably, Robinson also taught Helena Justa and Florence Mills.


title: Baby Esther

text: Esther has been verified as giving routine performances as late as September 1934, but her later activities are unknown. In 1934, she may have been 12 or 13 years old, as her age was reported as seven in June 1928 and in March 1929; or she may have been 15 or 16, as other articles from 1929 describe Esther as 10 years old; and an article during the week of August 22, 1931, seems to say that she was 12 then.


title: Baby Esther

text: In 1930, Fleischer Studios animator Grim Natwick introduced a caricature of Helen Kane—a singer known since 1923 for her baby voice and for replacing lyrics with noises, and later for her signature phrase "boop-oop-a-doop"—in the form of an anthropomorphic singing dog with droopy ears and a squeaky singing voice, in the Talkartoons cartoon "Dizzy Dishes". "Betty Boop", as the character was later dubbed, soon became popular and the star of her own cartoons. In 1932, Betty Boop was changed into a human, the long dog ears becoming hoop earrings.


title: Baby Esther

text: In May 1932, Kane filed a $250,000 lawsuit against Max Fleischer and Paramount Publix Corporation, for "exploiting her image", charging unfair competition and wrongful appropriation in the Betty Boop cartoons, contending that Betty Boop's "boop-oop-a-doop" style constituted a "deliberate caricature" that gave her "unfair competition".


title: Baby Esther

text: The trial opened that year in the New York State Supreme Court, with Kane and Betty Boop films being viewed only by the judge. No jury was called. Vocal performers Margie Hines, Little Ann Little, Kate Wright, Bonnie Poe, and most notably Mae Questel were all summoned to testify.


title: Baby Esther

text: Little Ann Little told the court how the "boop-oop-a-doop" phrase had started out as "ba-da inde-do", which developed into "bo do-de-o-do" and finally to "boop-oop-a-doop". Helen Kane's counsel asked Little, who spoke throughout the trial in a Betty Boop voice, "Oh, do you speak like that way at home?" Little responded to the court, "Yes, indeedy!"


title: Baby Esther

text: Testimony was given that Kane adopted her singing style after watching Baby Esther perform in a New York nightclub in April 1928. Esther's first manager, Lou Bolton, testified for the defense stating that in 1925, he coached a "young negro child" named Esther, teaching her how to interpolate her songs with scat lyrics such as "boo-did-do-doo" and "whad-da-da-da". Jones' manager testified that Kane had seen her act at the Everglades Restaurant in April 1928, before Kane opened her act at the New York Paramount Theatre. Kane had already testified that her first use of the phrase "boop-boop-a-doop" was during her engagement at the Paramount Theatre. Under cross-examination Bolton said that he had met with Kane at the club after Esther's performance, but could not say when she had walked in. Bolton also stated that Fleischer's lawyers had paid him $200 to come to New York. Bolton told the court that he had no idea where Esther was, and he thought that she was "probably still" in Paris. In fact, in May 1934 she was performing in Louisville. Esther herself did not testify at the trial.


title: Baby Esther

text: After a two-year legal struggle, Max Fleischer located a sound film made in 1928 of her performing, which was introduced as evidence. In the film she sings three songs that had earlier been popularized by Helen Kane – "Don't Be Like That", "Is There Anything Wrong with That?"" and "Wa-da-da" – which writer Mark Langer says "was hardly proof that Helen Kane derived her singing style from Baby Esther". According to jazz historian Robert O'Meally, this evidence might have been fabricated by the Fleischers to discredit Kane, whom they later admitted was their model for Betty Boop. O'Meally also questioned if there was some sort of deal between Fleischer Studios and Bolton, and questioned if Esther was ever paid for her presumed loss of revenue.


title: Baby Esther

text: Judge Edward J. McGoldrick ruled that "the vocables 'boop-boop-a-doop' and similar sounds had been used by other performers prior to the plaintiff" and that "the plaintiff has failed to sustain either cause of action by proof of sufficient probative force." In his opinion, based on the totality of the evidence presented in the trial, the "baby" technique of singing did not originate with Kane.


title: Baby Esther

text: Baby Esther is most associated today with her connection with the "Kane v. Fleischer" lawsuit. The film of Jones has been credited with convincing the judge in the case that Helen Kane had copied Baby Esther. Film scholar Mark Langer disputes this interpretation, which he says has become "conventional wisdom".


title: Baby Esther

text: Baby Esther shares her original name and original stage name with Little Esther Phillips, who was also known as Esther Mae Jones. Both singers used the names "Little Esther" and "Li'l Esther", but Esther Phillips was of a later generation, born in 1935.


title: Baby Esther

text: Photos of the model Olya Gussy costumed as Betty Boop, taken by Russian-based studio Retro Atelier in 2008, are regularly misidentified as Esther Jones.


title: Baby Esther

text: An older photo often purported to show Jones went viral when it was distributed by the official Betty Boop Checks website. The image was actually a James Van Der Zee photo of an unidentified woman.


title: Baby Esther

text: In 2021, a 2015 article by PBS, which had been used as "confirmation" of the "Baby Esther was the original Betty Boop" story by many people, was removed from the PBS website. PBS retracted the story, admitted that the "Baby Esther" portion of the article was never true, and apologized for spreading misinformation.


title: Anti-tank gun

text: An anti-tank gun is a form of artillery designed to destroy tanks and other armored fighting vehicles, normally from a static defensive position. The development of specialized anti-tank munitions and anti-tank guns was prompted by the appearance of tanks during World War I. To destroy hostile tanks, artillerymen often used field guns depressed to fire directly at their targets, but this practice expended too much valuable ammunition and was of increasingly limited effectiveness as tank armor became thicker. The first dedicated anti-tank artillery began appearing in the 1920s, and by World War II was a common appearance in many European armies. To penetrate armor, they fired specialized ammunition from longer barrels to achieve a higher muzzle velocity than field guns. Most anti-tank guns were developed in the 1930s as improvements in tanks were noted, and nearly every major arms manufacturer produced one type or another.


title: Anti-tank gun

text: Anti-tank guns deployed during World War II were often manned by specialist infantry rather than artillery crews, and issued to light infantry units accordingly. The anti-tank guns of the 1920s and 1930s were of small caliber; nearly all major armies possessing them used 37 mm ammunition (the British Army used the slightly larger 40mm 2-pounder gun). As World War II progressed, the appearance of heavier tanks rendered these weapons obsolete, and anti-tank guns likewise began firing larger and more effective armor-piercing shot. The development of the compact hollow charge projectile permanently altered anti-tank warfare, since this type of ammunition did not depend on a high muzzle velocity and could be fired from low-recoil, man-portable light weapons, such as the "Panzerfaust" and the American series of recoilless rifles.


title: Anti-tank gun

text: Although several large-caliber guns were developed during the war that were capable of knocking out the most heavily armored tanks, they proved expensive and difficult to conceal. The later generation of low-recoil anti-tank weapons, which allowed projectiles the size of an artillery shell to be fired from the shoulder, was considered a far more viable option for arming infantry. Recoilless rifles replaced most conventional anti-tank guns in the postwar period; nevertheless, the development of new anti-tank guns exhibiting similar low-recoil performance continued until the late 1950s in France, Belgium, and the Soviet Union. A few Soviet designs saw combat well into the 1980s. The People's Republic of China was still producing large-caliber anti-tank guns as late as 1988. In the 2000s, armies have increasingly preferred guided anti-tank missiles to guns.


title: Anti-tank gun

text: The first specialized anti-tank weaponry consisted of anti-tank rifles. These emerged from the mixed results of deploying field artillery against tanks during World War I, and the need to produce a more economical weapon to destroy them. Most anti-tank rifles were over 1.3 m in length, however, and difficult for infantrymen to operate in the confines of their trenches. They could penetrate a tank's armor at long range, but without explosive firepower, often failed to cause catastrophic damage, kill, or even seriously injure the crew, or disable the tank. A number of infantry support guns designed to defeat hard targets such as fortified machine gun emplacements were used as makeshift anti-tank weapons, including the French Canon d'Infanterie de 37 modèle 1916 TRP. The 3.7 cm Tankabwehrkanone 1918 im starrer Räder–lafette was probably the first dedicated anti-tank gun in service. However, its gun barrel was based on an earlier Hotchkiss 5- barrelled rotary-cannon. The 3.7 cm TAK 1918 was designed and built for the Imperial German Army in 1918. The 3.7 cm Pak 36 which first appeared in 1928 was probably the first purpose-built anti-tank gun. Weighing some 160 kg, the Pak 36 could inflict a catastrophic kill on a tank rather than merely penetrating its armor plate. Towed guns similar to the Pak 36 were the only anti-tank weapon issued to European armies during the 1930s, and a number of influential designs proliferated, such as the Böhler gun. By the late 1930s, anti-tank guns had been manufactured by companies in Germany, Austria, France, Czechoslovakia, Belgium, Great Britain, Denmark, and Sweden. A few countries, such as the Soviet Union, also manufactured foreign designs under license.


title: Anti-tank gun

text: At the outbreak of World War II, most armies were fielding light anti-tank guns firing 3.7-cm (37-mm) ammunition. The guns were usually mounted on two-wheeled carriages so they could be towed into position, then withdrawn and repositioned rapidly. Since they weighed only a few hundred pounds on average, they could also be manhandled into position. All fired high-explosive and solid armor-piercing shot effective at ranges up to roughly 500 m, and an increasing number were manufactured with protective gun shields in addition to a split rail mounting. They were able to destroy tanks fielded by both sides during the first two years of the war, but soon proved impotent against the heavier tank armor that debuted in 1940.


title: Anti-tank gun

text: French doctrine was for their infantry to let enemy tanks pass through then stop the accompanying enemy infantry leaving the unsupported tanks to be engaged by anti-tank guns deployed in three echelons. The issue of 58 guns per division provided 10 guns per kilometre of front which was expected to be able to deal with enemy tanks at a concentration of 50 tanks per kilometer. In practice the German invasion of France concentrated tanks in select divisions at up to 100 per kilometer.


title: Anti-tank gun

text: Introducing improved ammunition and increasing muzzle velocity initially helped compensate for their mediocre performance, but small-caliber anti-tank guns clearly would soon be overtaken by yet more heavily armored tanks. Medium-caliber guns in the 40- to 50-mm range began to appear, some of which simply used rebored 37-mm barrels. Although they, too, were soon approaching obsolescence, most remained in use with infantry units until the end of the war. Anti-tank guns remained ineffective against sloped armor, as demonstrated by an incident in 1941 when a single Soviet T-34 tank was hit more than 30 times by a battalion-sized contingent of German 37 and 50-mm anti-tank guns. The tank survived intact and was driven back to its own lines a few hours later. This helped earn the Pak 36 the moniker of "Panzeranklopfgerät" ("tank door knocker") because its crew simply revealed their presence and wasted their shells without damaging the T-34's armor. Anti-tank gunners began aiming at tank tracks, or vulnerable margins on the turret ring and gun mantlet, rather than testing their lighter cannon against bow and turret armor. These difficulties resulted in new types of ammunition being issued, namely high-explosive anti-tank (HEAT) and armor-piercing discarding sabot (APDS) projectiles.


title: Anti-tank gun

text: Towards the end of World War II, armor plating became still thicker, with tanks such as the Tiger II being fitted with armor over 100 mm in thickness, as compared to the 15 mm more typical in 1939. This prompted the development of a third generation of anti-tank guns, large-caliber pieces in the 57- to 100-mm range. The British Army adopted the Ordnance QF 6-pounder and Ordnance QF 17-pounder, which were then considered great advances in firepower, and the Wehrmacht fielded the even larger 7.5 cm Pak 41 and 8.8 cm Pak 43. While the early 37-mm anti-tank guns were easily concealed and moved, the large-caliber weapons available late in the war required equally large vehicles to tow them into place, and were difficult to conceal, dig in, withdraw, or reposition. By 1945, large anti-tank guns had become almost impractical in their role, and their size and weight were considered liabilities. They were also expensive to produce and although they were capable of defeating the most formidable of opponents, most tank units still consisted of less heavily armoured models that remained vulnerable to less expensive and more practical guns, as well. Many heavy anti-tank guns were issued, at least initially, on the divisional level, but gradually made their way to individual infantry battalions.


title: Anti-tank gun

text: Meanwhile, the effect of very compact hollow charge warheads was being noted, and a number of countries began producing man-portable anti-tank weapons using this ammunition. The development of man-portable, shoulder-fired, anti-tank rocket launchers began in 1941; most could be reloaded, but a few, such as the German Panzerfaust, were fired from disposable tubes. Unlike anti-tank guns, their light weight made them easily portable by individual infantrymen on the battlefield, and they offered similar degrees of firepower whilst being quicker and cheaper to produce.


title: Anti-tank gun

text: Towed anti-tank guns disappeared from most Western countries, such as the United States, after World War II, to be replaced by shoulder-fired rocket launchers, recoilless rifles, and eventually, guided anti-tank missiles.


title: Anti-tank gun

text: At the end of the war, German engineers had proposed a new, large-caliber anti-tank gun that used less propellant than a rocket or recoilless weapon, yet fired similar compact hollow-charge shells. German forces subsequently fielded the 8 cm PAW 600, which was an extremely lightweight, low-pressure weapon still able to fire the same ammunition types as higher-velocity anti-tank guns. In the 1950s, this idea was revived by a Belgian firm, Mecar, which subsequently improved on the concept and developed a low-pressure, smoothbore, 90-mm anti-tank gun. Because of its low recoil forces and light construction, the gun was particularly useful for being mounted on armored cars or small gun carriages. Its design inspired the lightly rifled French DEFA D921 anti-tank gun, which fired fin-stabilized shells and was available on a towed carriage or as a vehicle mount. It was later mated to the AML-90 and EBR series of French armored cars. The Soviet Union also adopted a similar design around the same time, the 100-mm T-12 anti-tank gun, which was smoothbore and fired fin-stabilized shells. Switzerland developed a postwar 90-mm anti-tank gun of its own, the Pak 50/57, firing shells with an even lower velocity than the Mecar or DEFA guns. Apart from the T-12, which used APDS rounds, these weapons could only use HEAT shells for armor-piercing purposes. France did introduce an APFSDS shell for the DEFA D921 at some point in the 1980s. The last country known to have produced a dedicated anti-tank gun was the People's Republic of China in 1988. The Chinese gun was known as the Norinco Type 86 and was probably manufactured as a replacement for the aging Soviet-sourced T-12.


title: Anti-tank gun

text: Anti-tank guns continued to be used in a number of conflicts around the world, such as the Six-Day War and the South African Border War. Soviet anti-tank guns in particular were exported to at least 18 other countries after being retired from service, and have continued to see action.


title: Anti-tank gun

text: Although still being drawn by horses or towed by trucks, towed anti-tank guns were initially much lighter and more portable than field guns, making them well-suited to infantry maneuvers. As their size and caliber increased, though, the guns likewise became increasingly heavy and cumbersome, restricting their role to static defense. In consequence, during World War II, both sides were compelled to make anti-tank guns self-propelled, which greatly increased their mobility.


title: Anti-tank gun

text: The first self-propelled anti-tank guns were merely belated attempts to make use of obsolete tanks, such as the Panzerjäger I, which was a Czech 4.7-cm Pak (t) gun mated to a Panzer I chassis. and were used in the Battle of France The trend continued with older tanks and captured vehicles, which were available in large numbers for conversions to self-propelled guns when they were replaced by heavier and better-armed (and armored) tanks. Although just a makeshift solution, these initial experiments proved so successful, they spawned an entire class of new vehicles: dedicated tank destroyers.


title: Anti-tank gun

text: The US Army's early self-propelled anti-tank guns were 75mm on M2 half-tracks (entering service in 1941) to complement towed artillery and M6 Gun Motor Carriage a 37mm on 4-wheel drive Dodge truck (1942). US Tank Destroyer doctrine emphasised mobility to place the tank destroyers into positions to ambush tank attacks.


title: Anti-tank gun

text: Tank destroyers offered some advantages over towed anti-tank guns, since a static gun emplacement sacrificed concealment and surprise after firing the first shot, but the same gun mounted on a tracked or wheeled chassis could open fire and throw a tank formation into substantial disarray before quickly withdrawing to repeat the same tactic elsewhere. The introduction of tank destroyers also put an end to the traditional tactic of suppressing anti-tank gun batteries with heavy artillery bombardments, as their crews were now well-protected under armor. They were not without their own series of disadvantages, however, namely presenting a much larger target than a towed gun, the added responsibilities of vehicle maintenance and logistical support, and the limited spaces in which the crew had to operate and stow all their available ammunition.


title: Anti-tank gun

text: By the end of the war, dedicated tank destroyers had been superseded by tanks, which were just as effective at destroying other tanks, and little incentive remained to continue their separate development. Nevertheless, much like towed anti-tank guns, they were widely exported and are still in service with some armies in the late 20th and early 21st century.


title: Suchomimus

text: Suchomimus (meaning "crocodile mimic") is a genus of spinosaurid dinosaur that lived between 125 and 112 million years ago in what is now Niger, during the Aptian to early Albian stages of the Early Cretaceous period. It was named and described by palaeontologist Paul Sereno and colleagues in 1998, based on a partial skeleton from the Elrhaz Formation. "Suchomimus"'s long and shallow skull, similar to that of a crocodile, earns it its generic name, while the specific name Suchomimus tenerensis alludes to the locality of its first remains, the Ténéré Desert.


title: Suchomimus

text: "Suchomimus" was a relatively large theropod, reaching in length and weighed . However, the age of the holotype specimen is uncertain, so it is unclear whether this size estimate would have been its maximum. The narrow skull of "Suchomimus" was perched on a short neck, and its forelimbs were powerfully built, bearing a giant claw on each thumb. Along the midline of the animal's back ran a low dorsal sail, built from the long neural spines of its vertebrae. Like other spinosaurids, it likely had a diet of fish and small prey animals.


title: Suchomimus

text: Some palaeontologists consider the genus to be an African species of the European spinosaurid "Baryonyx", "B. tenerensis". "Suchomimus" might also be a junior synonym of the contemporaneous spinosaurid "Cristatusaurus lapparenti", although the latter taxon is based on much more fragmentary remains. "Suchomimus" lived in a fluvial environment of vast floodplains alongside many other dinosaurs, in addition to pterosaurs, crocodylomorphs, fish, turtles, and bivalves.


title: Suchomimus

text: In 1997, American palaeontologist Paul Sereno and his team at Gadoufaoua discovered Fossils that represented about two-thirds of a large theropod dinosaur skeleton in Niger. The first find, a giant thumb claw, was made on 4 December 1997 by David Varricchio. In 1998, Sereno, Allison Beck, Didier Dutheil, Boubacar Gado, Hans Larsson, Gabrielle Lyon, Jonathan Marcot, Oliver Rauhut, Rudyard Sadleir, Christian Sidor, David Varricchio, Gregory Wilson and Jeffrey Wilson named and described the type species "Suchomimus tenerensis". The generic name "Suchomimus" ("crocodile mimic") is derived from the Ancient Greek σοῦχος, "souchos", the Greek name for the Egyptian crocodile god Sobek, and μῖμος, "mimos", "mimic", after the shape of the animal's head. The specific name "tenerensis" is after the Ténéré Desert where the animal was found.


title: Suchomimus

text: The holotype, MNN GDF500, was found in the Tegama Beds of the Elrhaz Formation. It consists of a partial skeleton lacking the skull. It contains three neck ribs, parts of fourteen dorsal (back) vertebrae, ten dorsal ribs, gastralia (or "belly ribs"), pieces of three sacral vertebrae, parts of twelve caudal (tail) vertebrae, chevrons (bones that form the underside of the tail), a scapula (shoulder blade), a coracoid, a partial forelimb, most of the pelvis (hip bone), and parts of a hindlimb. The spinal column was largely articulated, the remainder consisted of disarticulated bones. Parts of the skeleton had been exposed on the desert surface and had suffered erosion damage. Additionally, several specimens have been assigned as paratypes: MNN GDF 501 to 508 include a snout, a quadrate from the back of the skull, three dentaries (tooth-bearing bones of the lower jaw), an axis (second neck vertebra), a rear cervical vertebra, and a rear dorsal vertebra. MNN GDF 510 to MNN GDF 511 comprise two caudal vertebrae. All of the original "Suchomimus" fossils are housed in the palaeontological collection of the Musée National du Niger. The initial description of "Suchomimus" was preliminary. In 2007, the furcula (wishbone)—found during an expedition in 2000—was described in detail.


title: Suchomimus

text: "S". "tenerensis" is potentially a junior synonym of another spinosaurid from the Elrhaz Formation, "Cristatusaurus lapparenti", named the same year based on jaw fragments and vertebrae. The skull elements were considered indistinguishable from those of "Baryonyx walkeri" from the Barremian of England by British paleontologists Alan Charig and Angela Milner. In 1997 while describing "S". "tenerensis", Sereno and colleagues agreed with this assessment and concluded that "Cristatusaurus" was a dubious name. In 2002, the German palaeontologist Hans-Dieter Sues and colleagues concluded that "Suchomimus" was identical to "Cristatusaurus lapparenti", and despite "Cristatusaurus" having been named somewhat earlier than "Suchomimus", proposed them to represent a second species of "Baryonyx" called "Baryonyx tenerensis". In a 2003 analysis, German paleontologist Oliver Rauhut concurred with this.""


title: Suchomimus

text: The length of the type specimen of "Suchomimus", with undetermined age, reached in length and weighed . Therrein and Henderson proposed that a long "Suchomimus" would have weighed more than based on their ratio between skull length and body length; however, they noted that they might have overestimated the size of spinosaurids (i.e. "Suchomimus" and "Baryonyx"). The holotype of "Suchomimus" was considerably larger than that of "Baryonyx", but the ages of the two individuals are not known.


title: Suchomimus

text: Unlike most giant theropod dinosaurs, "Suchomimus" had a very crocodilian-like skull, with a long, low snout and narrow jaws formed by a forward expansion of the (frontmost snout bones) and the hind branch of the (main upper jaw bone). The premaxillae had an upward branch excluding the maxillae from the (bony nostrils). The jaws had about 122 conical teeth, pointed but not very sharp and curving slightly backwards, with fine serrations and wrinkled enamel. The tip of the snout was enlarged sideways and carried a "terminal rosette" of longer teeth, seven per side in the premaxillae and about the same number in the corresponding part of the lower jaw. Further back, there were at least 22 teeth per upper jaw side in the maxilla, while the entire lower jaw side carried 32 teeth in the dentary bone.


title: Suchomimus

text: The upper jaw had a prominent kink just behind the rosette, protruding downwards; this convexly curved part of the maxilla had the longest teeth of the entire skull. The internal bone shelves of the maxillae met each other in the midline of the skull over a long distance, forming a closed secondary palate that stiffened the snout, and setting off the internal nostrils and palatal complex (including the pterygoid, palatine and ectopterygoid) towards the back of the skull. The nostrils, unlike in most theropods, were retracted further back on the skull and behind the premaxillary teeth. The external nares were long, narrow and horizontally positioned; the same was true of the larger antorbital fenestrae, a pair of bony openings in front of the eyes. The rear of the skull is poorly known but for a short quadrate bone, which had broad condyles (round protrusions) away from the centre of attachment and—like in the spinosaurid "Baryonyx"—had a large foramen (opening) separating it from the quadratojugal bone. The lower jaws were greatly elongated and narrow, forming a rigid structure as their dentaries touched each other at the midline, reinforcing the mandible against torsional (bending and twisting) forces.


title: Suchomimus

text: The neck was relatively short but well-muscled as shown by strong epipophyses (processes to which neck muscles attached). There were about sixteen dorsal vertebrae. "Suchomimus" had significantly extended neural spines—blade-shaped upward extensions on the vertebrae—which were elongated at the rear back. Those of the five sacral vertebrae were the longest. The elongation of these structures continued until the middle of the tail. The spines may have held up some kind of low crest or sail of skin that was highest over its hips, lower and extending further to the back than that of "Spinosaurus", in which the sail reached its highest peak over the dorsal vertebrae. This condition was more reduced in "Baryonyx".


title: Suchomimus

text: The furcula was V-shaped and indicates a high and narrow trunk. The scapula had a rectangular acromion, or attachment site for clavicle (collarbone). The (upper arm bone) was very strongly built, only equaled in size among non-spinosaurid theropods by that of "Megalosaurus" and "Torvosaurus", with robust upper corners. The humerus had a boss (bone overgrowth) above the condyle that contacted its hook-shaped (forearm bone). Accordingly, the of the lower arm was well-developed with an enormous olecranon (upper process set-off from the shaft), an exceptional trait shared with "Baryonyx". The heavy arm musculature powered sizable hand claws, that of the first digit (or "thumb") being the largest with a length of . Only the third metacarpal (long bone of the hand) is known; showing a robust morphology (form). In the pelvis, the (main hip bone) was high. The (pubic bone) had a front surface that was wider than the side surface, and its forward-facing lower end was flattened and rectangular, with a brief flange along the midline, in contrast to the expanded boot shape it had in other theropods. The ischium (lower and rearmost hip bone) bore a low obturator flange. The (thighbone) was straight and robust, with a length of in the holotype. Its is markedly plate-like. In the ankle, the astralagus had an ascending process taller than that of "Allosaurus".


title: Suchomimus

text: The describers established some autapomorphies (unique derived traits) of "Suchomimus" to separate it from other theropods, including the expanded rear dorsal, sacral, and front caudal neural spines, the robust upper corners of the humerus, and the boss above the humerus' condyle that contacted its hook-shaped radius. Sereno and colleagues referred "Suchomimus" to the Spinosauridae and named two subfamilies within this clade, Baryonychinae (all spinosaurids more closely related to "Baryonyx") and Spinosaurinae (all spinosaurids closer to "Spinosaurus"). "Suchomimus" was a member of the subfamily Baryonychinae. Apart from its apparently taller sail, "Suchomimus" was very similar to the spinosaurid "Baryonyx" from the Barremian of England, and shared traits with it such as the reduced size and increased amount of teeth behind the snout tip in the mandible than spinosaurines, strong forelimbs, a huge sickle-curved claw on its "thumb", and strongly keeled front dorsal vertebrae. Spinosaurines are characterized by straight, unserrated and more widely spaced teeth, and the small size of their first premaxillary teeth. Sereno and colleagues pointed out that the more retracted nostrils in "Irritator" and the tall sail of "Spinosaurus" could also be unique traits of spinosaurines, though material from other taxa is needed to know for sure. As with "Suchomimus", the claw of "Baryonyx" had been the first discovered fossil of the animal. Sereno and colleagues in 1998 analyzed the distribution of forty-five traits to produce a cladogram that showed "Suchomimus" and "Baryonyx" to be distinct but closely related. Later, Barker and colleagues, in 2021, created a new tribe within Baryonychinae: Ceratosuchopsini, a clade that includes "Ceratosuchops", "Riparovenator" and "Suchomimus".


title: Suchomimus

text: Spinosaurids appear to have been widespread from the Barremian to the Cenomanian stages of the Cretaceous period, about 130 to 95 million years ago, while the oldest known spinosaurid remains date to the Middle Jurassic. They shared features such as long, narrow, crocodile-like skulls; sub-circular teeth, with fine to no serrations; the terminal rosette of the snout; and a secondary palate that made them more resistant to torsion. In contrast, the primitive and typical condition for theropods was a tall, narrow snout with blade-like (ziphodont) teeth with serrated carinae. The skull adaptations of spinosaurids converged with those of Crocodilians; early members of the latter group had skulls similar to typical theropods, later developing elongated snouts, conical teeth, and secondary palates. These adaptations may have been the result of a dietary change from terrestrial prey to fish. Unlike crocodiles, the post-cranial skeletons of baryonychine spinosaurids do not appear to have aquatic adaptations. Sereno and colleagues proposed in 1998 that the large thumb-claw and robust forelimbs of spinosaurids evolved in the Middle Jurassic, before the elongation of the skull and other adaptations related to fish-eating, since the former features are shared with their megalosaurid relatives. They also suggested that the spinosaurines and baryonychines diverged before the Barremian age of the Early Cretaceous.


title: Suchomimus

text: Several hypotheses have been proposed about the biogeography of the spinosaurids. Since "Suchomimus" was more closely related to "Baryonyx" (from Europe) than to "Spinosaurus"—although that genus also lived in Africa—the distribution of spinosaurids cannot be explained as vicariance resulting from continental rifting. Sereno and colleagues proposed that spinosaurids were initially distributed across the supercontinent Pangea, but split with the opening of the Tethys Sea. Spinosaurines would then have evolved in the south (Africa and South America: in Gondwana) and baryonychines in the north (Europe: in Laurasia), with "Suchomimus" the result of a single north-to-south dispersal event. Buffetaut and the Tunisian palaeontologist Mohamed Ouaja also suggested in 2002 that baryonychines could be the ancestors of spinosaurines, which appear to have replaced the former in Africa. Milner suggested in 2003 that spinosaurids originated in Laurasia during the Jurassic, and dispersed via the Iberian land bridge into Gondwana, where they radiated. In 2007, Buffetaut pointed out that palaeogeographical studies had demonstrated that Iberia was near northern Africa during the Early Cretaceous, which he found to confirm Milner's idea that the Iberian region was a stepping stone between Europe and Africa, which is supported by the presence of baryonychines in Iberia. The direction of the dispersal between Europe and Africa is still unknown, and subsequent discoveries of spinosaurid remains in Asia and possibly Australia indicate that it may have been complex. The findings of Barker "et al." (2021) are consistent with Milner's findings, where Spinosauridae arose in Europe and there were at least two migrations to Africa.


title: Suchomimus

text: Charig and Milner had proposed a piscivorous (fish-eating) diet for the closely related "Baryonyx" in 1986. This was later confirmed in 1997 with the discovery of partially digested fish scales found in the "Baryonyx" holotype. In 1998 Sereno and colleagues suggested the same dietary preference for "Suchomimus", based on its elongated jaws, spoon-shaped terminal rosette, and long teeth reminiscent of those of piscivorous crocodilians. American palaeontologist Thomas Holtz noted that spinosaurid teeth were adapted for grasping rather than slicing, hence their reduced serrations, which in most other theropods were more prominent. "Suchomimus"'s extensive secondary palate, which would have made the roof of the mouth more solid, allowed it to better resist twisting forces exerted by prey. The rest of "Suchomimus"'s body was not particularly adapted to the water. The discovery of "Suchomimus" revealed that spinosaurid skulls were significantly shallower, more elongated and narrow than previously thought.


title: Suchomimus

text: The use of the robust forelimbs and giant claws of spinosaurs remains a debated topic. Charig and Milner speculated in 1986 that "Baryonyx" may have crouched by the riverbank and used its claws to gaff fish out of the water, similarly to Grizzly bears. In 1987, British biologist Andrew Kitchener hypothesized a use in scavenging carcasses, though this has been critiqued by other researchers who pointed out that in most cases, a carcass would have already been largely emptied out by its initial predators. A 2005 study by Canadian paleontologist François Therrien and colleagues posited that spinosaur forelimbs were probably used for hunting larger prey items, given that their snouts could not resist the bending stress. In a 2017 review of the family, David Hone and Holtz also considered possible functions in digging for water sources or hard to reach prey, as well as burrowing into soil to construct nests.


title: Suchomimus

text: A 2022 study comparing the bone densities of "Suchomimus", "Baryonyx" and "Spinosaurus" reveals that spinosaurids had ecologically disparate lifestyles. "Suchomimus" itself was more adapted to a life hunting in shallow water due to its hollow bones, while "Baryonyx" and "Spinosaurus" were capable of fully submerging underwater and diving after prey. Courtesy of denser bones, the latter two spinosaurids could hunt underwater for prey and occupy a more derived lifestyle than "Suchomimus" could.


title: Suchomimus

text: The Elrhaz Formation, part of the Tegama Group, consists mainly of fluvial sandstones with low relief, much of which is obscured by sand dunes. The sediments are coarse- to medium-grained, with almost no fine-grained horizons. "Suchomimus" lived in what is now Niger, during the late Aptian to early Albian stages of the Early Cretaceous, 112 million years ago. The sediment layers of the formation have been interpreted as an inland habitat of extensive freshwater floodplains and fast-moving rivers, with a tropical climate that likely experienced seasonal dry periods.


title: Suchomimus

text: This environment was home to a variety of fauna including dinosaurs, pterosaurs, turtles, fish, hybodont sharks, and freshwater bivalves."" "Suchomimus" coexisted with other theropods like the abelisaurid "Kryptops palaios", the carcharodontosaurid "Eocarcharia dinops", and an unknown noasaurid. Herbivorous dinosaurs of the region included iguanodontians like "Ouranosaurus nigeriensis", "Elrhazosaurus nigeriensis, Lurdusaurus arenatus," and two sauropods: "Nigersaurus taqueti," and an unnamed titanosaur. Crocodylomorphs were abundant; represented by the giant pholidosaur species "Sarcosuchus imperator", as well as small notosuchians like "Anatosuchus minor," "Araripesuchus wegeneri", and "Stolokrosuchus lapparenti." The local flora probably consisted mainly of ferns, horsetails, and angiosperms, based on the dietary adaptations of the large diplodocoids that lived there.


title: Pioneer Football League

text: The Pioneer Football League (PFL) is a collegiate athletic conference which operates in the United States. The conference participates in the NCAA's Division I Football Championship Subdivision (FCS) as a football-only conference. It has member schools that range from New York, North Carolina, and Florida in the east to California in the west. It is headquartered in St. Louis, in the same complex that also contains the offices of the Missouri Valley Conference and Missouri Valley Football Conference. Unlike most other Division I FCS conferences, the Pioneer League consists of institutions that choose not to award athletic scholarships ("grants-in-aid") to football players.


title: Pioneer Football League

text: Most of the PFL's members are private schools. Morehead State University is currently the only public school in the conference.


title: Pioneer Football League

text: Following an NCAA rule change passed in January 1991, which required Division I schools to conduct all sports at the Division I level by 1993, the conference was formed by charter members Butler University, the University of Dayton, Drake University, the University of Evansville, and Valparaiso University. The University of San Diego joined in 1992, and the league played its first season in 1993. The six original schools which played in the 1993 season had previously sponsored football at the Division I, Division II and Division III levels.


title: Pioneer Football League

text: In 1997, the league reduced to five members when the University of Evansville downgraded football from Division I to club status; Evansville explored upgrading football back to Division I in 2007, but decided against it.


title: Pioneer Football League

text: In 2001, the conference nearly doubled in size and was reorganized with the five pre-2001 members forming the North Division, and newcomers Austin Peay State University, Davidson College, Jacksonville University and Morehead State University forming the South Division. The reorganization spawned a new championship system in which the best record holders from each division would play in a title game for the conference championship.


title: Pioneer Football League

text: On April 8, 2005, Austin Peay announced its departure from the league effective after the 2005 season; Austin Peay returned to scholarship-granting competition in 2007 as a member of the Ohio Valley Conference in which it competes in other sports. As a result, the conference reverted to round-robin play; the divisions and championship game were abolished. On April 7, 2006, Campbell University announced the reinstatement of football effective in 2008, and on December 5, 2007, accepted an invitation to the PFL. In February 2008, Marist College announced that it would join the PFL for the 2009 season, after the MAAC stopped sponsoring football. Although Campbell moved in 2011 from the Atlantic Sun Conference to the Big South Conference, which sponsors football, it did not join the Big South in football and remained in the PFL through the 2017 season.


title: Pioneer Football League

text: On June 13, 2011, Mercer University and Stetson University were announced as league members (effective 2013) bringing membership to 12 schools. In addition, as of 2013, the league has an automatic bid into the FCS division I playoffs. Soon after its PFL membership was announced, Mercer accepted an invitation to join the Southern Conference (scholarship-granting) effective July 1, 2014. During its one season in the league, Mercer set a Division I win–loss record for start-up programs; Mercer finished the 2013 season with an overall record of 10–2 including an undefeated 8–0 record at home, also a Division I record held jointly with Auburn University, which likewise went undefeated at home in 2013.


title: Pioneer Football League

text: On July 1, 2014, Mercer University joined the Southern Conference for all sports, including football.


title: Pioneer Football League

text: The next change in conference membership was announced on November 14, 2016, when Campbell announced it would transition to scholarship football and add that sport to its existing Big South membership effective with the 2018 season, temporarily reducing the PFL membership to 10. Barring any further changes to conference membership, the PFL would have returned to 11 members in 2021, following the November 20, 2017 announcement of Presbyterian College that it would join the conference starting with the 2021 season. Presbyterian remains in the Big South Conference for all other sports. While Presbyterian did not become a full conference member until July 2021, it began PFL play in the spring 2021 season, rescheduled from fall 2020 due to COVID-19. After two PFL members chose not to play in the 2020–21 school year, the conference entered into a scheduling agreement with Presbyterian that included it in the spring 2021 schedule. While PC was not eligible for the PFL title in that season, it was eligible for the league's individual awards and honors.


title: Pioneer Football League

text: On December 3, 2019 Jacksonville University announced that it discontinued its football program immediately.


title: Pioneer Football League

text: Presbyterian was joined as a new PFL member in 2021 by the University of St. Thomas, a Twin Cities school that had been expelled from its longtime Division III home of the Minnesota Intercollegiate Athletic Conference (MIAC) effective in 2021–22. Shortly after the MIAC announced St. Thomas' expulsion, the Summit League, a non-football Division I conference, offered the Tommies membership. The NCAA announced on July 15, 2020 that it had granted a waiver to allow St. Thomas to make the jump to D-I on a five-year schedule, instead of the four years used for moves from Division II. The Tommies will not be eligible for the FCS playoffs until the transition is completed in 2026.


title: Pioneer Football League

text: One in-state rivalry currently exists in the PFL. A second had existed before Jacksonville discontinued its football program.


title: Pioneer Football League

text: Butler and Valparaiso first played in 1927, and had nine meetings prior to 1951. That year, the two teams began playing every year, and in 2006 began playing for the Hoosier Helmet Trophy. Butler currently leads 47–24. The two schools had an all-sports rivalry as well when both were in the Horizon League together from 2007 to 2012.


title: Pioneer Football League

text: Jacksonville and Stetson had a football rivalry that ran from 2013, when Stetson began PFL play, to 2019, after which Jacksonville dropped football. The schools have been conference rivals in other sports since 1998, when Jacksonville joined the ASUN Conference, home to Stetson since 1985.


title: Pioneer Football League

text: Butler and Dayton also have a rivalry based on proximity to each other. The teams have met every year since 1977 with the exception of 1991 and 1992. Dayton leads 26–11–1.


title: Pioneer Football League

text: (*) Due to COVID-19, the Pioneer Football League suspended the fall 2020 football season. Dayton and Marist opted out of the spring season. Presbyterian played a full PFL schedule, but was ineligible for the conference title, and its games were not counted in PFL standings.


title: Pioneer Football League

text: The Pioneer Football League has had alliances with the Gridiron Classic and the Sports Network Cup. In addition, league members are allowed to accept at-large invitations to other college bowl games and teams are eligible to compete in the FCS playoffs.


title: Pioneer Football League

text: Through the 2012 season, the NCAA did not offer the league an automatic invite to the FCS playoffs and never offered an at-large bid to any of its teams, effectively barring the league from the tournament. Starting in 2013, the Pioneer League received an automatic bid to compete in the Division I Football Championship as the playoffs expanded from 20 teams to 24. The PFL won its first playoff game in 2016, as San Diego advanced past the first round of the playoffs.


title: Pioneer Football League

text: The PFL was a participant in the NCAA Division I FCS Consensus Mid-Major Football National Championship, along with the Northeast Conference and Metro Atlantic Athletic Conference, two other conferences without automatic playoff bids. The Consensus championship has since been discontinued; the NEC first earned an automatic postseason bid in 2010, while the MAAC no longer sponsors football.


title: Pioneer Football League

text: Below are postseason accomplishments by past and current members prior to the formation of the Pioneer Football League.


title: Pioneer Football League

text: From 2006 through 2009, the PFL and Northeast Conference (NEC) staged the Gridiron Classic, an exempted postseason football game that matched the champions of the two conferences which were technically members of Division I FCS, but which were not the recipients of automatic invitations to the football championship playoff at the time.


title: Pioneer Football League

text: Since 2013, the PFL champion has received an invite to the FCS playoffs; previously, PFL teams had to receive an at-large bid, which no team ever received.


title: Pioneer Football League

text: (*) - St. Thomas was the PFL champion in 2022; however, they were ineligible for postseason play due to still being in transition from Division III. Davidson, the runner-up, was awarded the auto-bid in their place.


title: Sanjiv Bhatt

text: Sanjiv Bhatt is a former Indian Police Service officer of the Gujarat-cadre. He is known for his role in filing an affidavit in the Supreme Court of India against the then Chief Minister of the Government of Gujarat, Narendra Modi, concerning Modi's alleged role in the 2002 Gujarat riots. He claimed to have attended a meeting, during which Modi allegedly asked top police officials to let Hindus vent their anger against the Muslims. However, the Special Investigation Team appointed by the Supreme Court of India concluded that Bhatt did not attend any such meeting, and dismissed his allegations.


title: Sanjiv Bhatt

text: In 2015, Bhatt was removed from the police service, on the grounds of "unauthorised absence". In October 2015, the Supreme Court quashed Bhatt's plea for constituting a special investigation team (SIT) for cases filed against him by Gujarat Government. The court lifted a stay on his trial in these cases and asked him to face prosecution. The court observed that, "Bhatt was in active touch with leaders of rival political parties, was being tutored by NGOs, was involved in politics and activism of creating pressure, even upon 3-judge bench of this court, amicus and many others".. On 20 June 2019, he was sentenced to life imprisonment by the Sessions Court of Jamnagar District in the state of Gujarat in a 1990 custodial death case.


title: Sanjiv Bhatt

text: Bhatt is a Kashmiri Pandit. He earned an MTech degree from the Indian Institute of Technology, Bombay in 1985. He is married to Shweta Bhatt.


title: Sanjiv Bhatt

text: Bhatt joined the Indian Police Service (IPS) in 1988, and was allotted the Gujarat cadre. In 1990, as the Additional Superintendent of Police, he detained 150 people in order to control a riot in Jamnagar district. Prabhudas Vaishnani, one of the detainees, died of kidney failure a few days later, after being hospitalised. His brother lodged an FIR against Bhatt and six other policemen, alleging that he had been tortured in police custody. Another man, Vijaysinh Bhatti, alleged that he had been beaten up by Bhatt.


title: Sanjiv Bhatt

text: In 1996, as the Superintendent of Police (SP) of Banaskantha district, he was accused of falsely framing a Rajasthan-based lawyer in a narcotics case. It was alleged that Bhatt maliciously filed nearly 40 petitions in the high courts of Rajasthan and Gujarat as well as before the apex court to delay action against him. The Bar association members have alleged that Bhatt got himself appointed the Gujarat government's officer in-charge for the special appeal petition pending in the SC. They pointed out that Bhatt is using the Gujarat government as a shield to save himself but is also misusing the public money to fight the crimes he committed.


title: Sanjiv Bhatt

text: From December 1999 to September 2002, he worked as Deputy Commissioner of Intelligence in the state Intelligence Bureau (India) at Gandhinagar. He was responsible for looking after the state's internal security, border and coastal security, and security of vital installations. He was also responsible for the Chief Minister Narendra Modi's security. During this period, the Godhra train burning and the subsequent Hindu-Muslim riots led to over a thousand deaths in February–March 2002.


title: Sanjiv Bhatt

text: On 9 September 2002, Narendra Modi allegedly mocked the high Muslim birth rates during a speech at Bahucharaji. Though Modi denied making such remarks, the National Commission for Minorities (NCM) sought a report from the State Government. Modi's Principal Secretary P K Mishra told "The Indian Express" that the State Government had no recordings or transcripts of the speech, and therefore, could not send these to the NCM. However, the State Intelligence Bureau provided the NCM a copy of Modi's speech, which had been recorded as part of routine procedure. Subsequently, the Modi government transferred the Bureau's senior officials on 'punishment postings'. The officers transferred included Sanjiv Bhatt, R. B. Sreekumar and E. Radhakrishnan. Bhatt was posted as principal of the State Reserve Police Training College.


title: Sanjiv Bhatt

text: In 2003, Bhatt was posted as the superintendent of Sabarmati central jail. There, he became very popular among the prisoners. He introduced desserts like gajar ka halwa on the jail menu. He also posted undertrials in Godhra train burning case on a jail committee. Two months after his appointment, he was transferred for being too friendly with the prisoners and bestowing favours upon them. On 18 November 2003, nearly half of the 4000 prisoners went on a hunger strike to protest his transfer. Six convicts slashed their wrists in protest.


title: Sanjiv Bhatt

text: By 2007, Bhatt's colleagues from the 1988 batch had been promoted to the rank of Inspector-general of police (IGP). However, Bhatt had stayed at the SP level for a decade without any promotion, because of the pending criminal cases and departmental inquiries against him.


title: Sanjiv Bhatt

text: After the 2002 riots, a group of social activists had formed the "Concerned Citizens Tribunal" to analyze the riots. Gujarat's home minister Haren Pandya allegedly told this tribunal that Modi had organised a meeting at the Chief Minister's residence on 27 February 2002, after the Godhra train burning, in which over 63 Hindu pilgrims were killed. According to Pandya, in this meeting, Modi had asked the police officials not to come in the way of "the Hindu backlash". Pandya had named several police officials who attended this meeting; Bhatt was not among these. Pandya was later assassinated by unidentified men.


title: Sanjiv Bhatt

text: On 14 April 2011, 9 years after the riots, Bhatt filed an affidavit in the Supreme Court of India, making similar allegations. According to Bhatt, at this meeting on 27 February 2002, Modi asked top police officials to let Hindus "vent out their anger" against the Muslims. He said that the meeting determined to bring the bodies of the Hindu pilgrims to Ahmedabad before cremation and that he had cautioned against this, fearing religious violence. According to him, Modi's Bharatiya Janata Party (BJP) and the Hindu nationalist Bajarang Dal were stirring tensions in the city, and the Vishwa Hindu Parishad (VHP) had proposed a bandh (an illegal general strike). Bhatt claimed that the then Director General of Police, K. Chakravarthi, and the city Police Commissioner, P. C. Pandey, had raised concerns regarding the manpower available to deal with this, and both men advised that it was not wise for the bodies to be taken to Ahmedabad. Bhatt also says that he sent some fax messages to major officials soon after the meeting ended and that these referred to the meeting itself, the decision regarding the bodies of the dead and the growing activity of the BJP and Bajrang Dal. Subsequently, riots occurred in which around 1000 people died, three-quarters of whom were Muslim. Described as a whistleblower both by some of the Indian media and some pressure groups, Bhatt has since referred to the events as "state-sponsored riots" and has alleged both that Modi told his officials to be "indifferent" towards rioters and said that Muslims needed to be "taught a lesson".


title: Sanjiv Bhatt

text: In his affidavit, Bhatt mentioned six witnesses, who could testify his presence in the alleged meeting held at Modi's residence. He claimed that he had travelled to Modi's residence in the official car of K. Chakravarthi, which was being driven by Tarachand Yadav; Bhatt's driver Constable KD Panth followed them in Bhatt's official car. Bhatt's affidavit was signed by KD Panth, whose statement supported Bhatt's presence at the alleged meeting. On 24 June 2011, Panth filed an FIR against Bhatt, alleging that Bhatt had threatened him and forced him to sign a false affidavit. Panth alleged that Bhatt took him to the residence of Arjun Modhwadia, the state president of the opposition party, Indian National Congress. He further alleged that Modhwadia asked him to obey Bhatt. Panth claimed that he was on leave in February 2002, when the riots broke out, and had already told this to the Supreme Court-appointed Special Investigation Team (SIT). Chakravarthi also denied that Bhatt was present in the meeting.


title: Sanjiv Bhatt

text: However, Tarachand Yadav supported Bhatt, stating that he had driven Bhatt to Modi's bungalow, and that Panth had been with them. He also supported Bhatt's claim that he travelled there with Chakravarthy.


title: Sanjiv Bhatt

text: When questioned why he had not made these revelations earlier, Bhatt stated that in 2004, he "started sending out feelers" that he wanted to be cross-examined by the Nanavati Commission, but the commission had not called him. In May 2011, Bhatt repeated the allegations made in his affidavit when he was called to give evidence to the NMC. Before this appearance and to support the statements that he would make during it, Bhatt had attempted to obtain documents as evidence from the police and the State Intelligence Bureau, as well as from the SIT hearing. He again requested this information in December 2011, claiming that it was needed so that it could be placed on the official record. These requests for information failed, and Bhatt alleged that this was because the Modi government opposed them because it was involved in a "cover-up". In 2012, he alleged that the NMC had consistently refused to demand production of the documents, despite Bhatt's belief that it has the legal powers to do so.


title: Sanjiv Bhatt

text: Bhatt's ex-boss R. B. Sreekumar stated that Bhatt had never told him about his presence at the meeting during these nine years. But he told the Nanavati Commission that in 2002, the Modi government had asked the State Intelligence Bureau to tap Haren Pandya's phone to confirm that he was the minister who talked to the "Concerned Citizens Tribunal".


title: Sanjiv Bhatt

text: In March 2008, the Supreme Court had appointed a Special Investigation Team (SIT), headed by former Central Bureau of Investigation chief R. K. Raghavan, to investigate cases relating to the various incidents that had occurred during the 2002 riots. One of those who died in the Gulbarg Society massacre that formed a part of the riots was Ehsan Jaffri, the former Indian National Congress Member of Parliament. His widow, Zakia Jaffri, subsequently became concerned about the involvement of senior officials in allegedly aiding and abetting the rioters and by the lack of legal action against them by the police. She petitioned the Court, alleging criminal conspiracy, a "deliberate and intentional failure" to protect life and property, and failure to fulfil their constitutional duty. In 2009, the Court responded by directing the SIT to investigate the actions of Modi and 62 other people, including Pandey and some VHP leaders. Bhatt presented evidence to this particular SIT investigation in 2009.


title: Sanjiv Bhatt

text: In his 2011 affidavit, Bhatt accused the SIT of trying to "hide the truth behind the riots". Bhatt alleged that a mole in SIT leaked information to the Modi Government, through Gujarat's additional advocate general Tushar Mehta. Mehta and Bhatt were good friends since the 1980s, until 2010. Bhatt claimed that he happened to access Mehta's account to book two vacations for their families: one to Goa in September 2009 and another to the US in May–June 2010. At that time, he claims, he saw emails from SIT in Mehta's inbox. Mehta alleged that their friendship ended because of something that happened during their 2010 vacation in the US; he refused to go into details calling it a personal affair. In August 2011, Mehta lodged a complaint against Bhatt, accusing him of hacking into his email account. Bhatt's wife Shweta denied the accusation, stating that her husband only helped Mehta because the latter was not good with computers.


title: Sanjiv Bhatt

text: The Court had previously appointed Raju Ramachandran to act as "amicus curiae" (friend of the court). Ramachandran had reviewed the original confidential SIT report that had been submitted in November 2010. His report was also confidential but prompted the Court to order the SIT to conduct a self-review. That self-review had been submitted in April 2011 and the Court referred this for consideration by Ramachandran in May, which was also when it refused to accept Bhatt's affidavit.


title: Sanjiv Bhatt

text: In June 2011, Bhatt filed a Public-interest litigation (PIL) in the Supreme Court, calling for an independent agency to investigate the riots or, alternatively, for the case to be transferred outside Gujarat. Bhatt also alleged that his emails had been hacked and filed a complaint against the state alleging that they had been leaked from the SIT.


title: Sanjiv Bhatt

text: On 13 October 2015, a bench comprising Supreme Court Chief Justice H L Dattu and Justice Arun Mishra ruled Bhatt's allegations against the SIT as totally "false and baseless". It further rebuked Bhatt, ruling that "He had exchanged e-mails with rival political party leaders and was being tutored by the lawyer of an NGO and its activist... The petitioner has even sent e-mails to influence the judicial proceedings of a 3-Judge Bench of this court and has tried to influence the amicus curiae."


title: Sanjiv Bhatt

text: On 8 August 2011, the Gujarat government suspended Bhatt, accusing him of unauthorised absence from duty, not appearing before an inquiry committee and using his official car while not on duty.


title: Sanjiv Bhatt

text: Bhatt claimed that he was unable to report for work because he was required to attend various legal and investigatory hearings, including those of Nanavati-Mehta commission (NMC) – originally known as the Nanavati-Shah Commission – which had been established by the government of Gujarat.


title: Sanjiv Bhatt

text: The Gujarat government had originally appealed the court to drop charges against Bhatt and other policemen in the 1990 custodial death case. However, after Bhatt's affidavit against Modi, the Government withdrew its application, and the court initiated criminal proceedings against the policemen. On 18 September 2011, the Gujarat Home Ministry chargesheeted Bhatt in the 1990 police atrocity case. On 27 September 2011, Bhatt appeared before the Gujarat High Court in the police atrocity case against him in Jamnagar district. During the hearing, he told the Court that Narendra Modi and his former Home Minister Amit Shah had pressurised him to destroy crucial evidence in the Haren Pandya murder case.


title: Sanjiv Bhatt

text: In a fresh affidavit, Bhatt made detailed allegations against Modi and Shah. He claimed that while posted as Superintendent of the Sabarmati Jail in 2003, he had met Asgar Ali, an accused in the Haren Pandya murder case. Ali allegedly told him that Pandya had been killed by Tulsiram Prajapati (who was later killed in a fake encounter in 2006). Bhatt claimed that he had immediately informed Home Minister Amit Shah about this revelation, but Shah asked him to destroy all documentary evidence related to this matter. He claimed that he had been removed as the Jail Superintendent because he had refused to obey Shah.


title: Sanjiv Bhatt

text: On 30 September 2011, Bhatt was arrested, following an investigation into KD Panth's FIR. Bhatt alleged that Panth was following "diktats" from the Modi government, an allegation denied by Panth. Bhatt's arrest was condemned by the Congress leaders and human rights activists, who accused the Modi government of persecuting Bhatt. The arrest gave rise to protests at places such as Ahmedabad, Delhi and Bangalore. The Gujarat IPS Officers Association also expressed their support for Bhatt and his family, although this was far from being unanimous and was downplayed by various senior officers. Bhatt has referred to being harassed by members of the Gujarat police.


title: Sanjiv Bhatt

text: On 17 October 2011, Bhatt was granted bail by a local court in Ahmedabad, on condition that he continue to cooperate with investigations into the allegations laid against him. His bail application had been opposed by the Modi government. The Supreme Court suspended the case in April 2012, with Bhatt arguing that the arrest was "politically motivated".


title: Sanjiv Bhatt

text: Bhatt was among those who refused to accept an award offered by the Maulana Muhammad Ali Jauhar Academy in 2011. This was because one of the co-awardees, Jagdish Tytler, is alleged to have been involved in the 1984 anti-Sikh riots.


title: Sanjiv Bhatt

text: In November 2012, Bhatt and six other policemen were charged with murder in the 1990 custodial death case of Prabhudas Vaishnani. On 20 June 2019, he was sentenced to life in relation to this case.


title: Sanjiv Bhatt

text: A former BBC journalist, Shubhranshu Choudhary, filed an affidavit in November 2011 that supported the claim that Bhatt was present at the 2002 meeting. In the same month, he requested that the SIT allow his testimony to be recorded in the presence of a magistrate as he believed that his earlier statements to it had been distorted. He made several similar requests thereafter.


title: Sanjiv Bhatt

text: In January 2012, the SIT demanded the original copy of the fax messages that Bhatt claimed to have sent after the 2002 meeting and which, according to Bhatt, substantiated his presence at the meeting. Bhatt said that he had already provided the evidence in 2009 and again in 2011. He also noted that the SIT could get the information from the SIB records, and he claimed that the SIT was failing to interview police officials who could testify to his movements on the night in question. This was not the first occasion that he had alleged the SIT was reluctant to examine key witnesses who could verify his whereabouts at the time of the meeting.


title: Sanjiv Bhatt

text: Bhatt has produced evidence of police inaction to SIT chairman along with a letter which had details of deployment of police, SRP and RAF in the state, areas under curfew, types of crimes committed during the riots, etc. In that letter he also alleged delayed deployment of army. He insisted that those documents were intended for the sole purpose of ensuring that crucial evidence is not disregarded or concealed by the SIT with a view to screen powerful and influential offenders from legal punishment". Bhatt in a letter written to SIT alleged that the probe team didn't exhume the bodies from well of Naroday Patia despite strong evidences catered by him to support his claim. He also complained that Ahmedabad police commissioner P. C. Pandey was alerted on the same.