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Question: What are the three subsets into which the parameter space V is divided?

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Context 1: Paper Info

Title: An CUSUM Test with Observation-Adjusted Control Limits in Change Detection
Publish Date: March 9, 2023
Author List: Fuquan Tang (from Department of Statistics, Shanghai Jiao Tong University), Dong Han (from Department of Statistics, Shanghai Jiao Tong University)

Figure

exp{−cg(µ)(θ − x Hv (θ) + o(1))} for 1 ≤ k ≤ ac − 1, bc ≤ n ≤ m, where Zi = −g ′ (µ)(Z i − µ)/a and Hv (θ) = ln hv (θ) + ( ac k − 1) ln ĥv (θ), ĥv (θ) = E v (e θ Zi ) 
i < cg(µ)(1 + o(1))) exp{−cg(µ)θ * v (1 + o(1))} (A  5) for ac ≤ k ≤ bc − 1, bc ≤ n ≤ m,andP v (
i + g ′ (µ)a −1 Tc(g)−1 i=Tc(g)−ac (Z i − µ)] −→ µas c → ∞ By the uniform integrability of {T c (g)/c} and using Theorem A 1 1 in Gut's book(1988), we haveE v (T c (g)) = (1 + o(1)) cg(µ) µfor a large c This completes the proof of Theorem 2 Proof of Theorem 4  Since g(x) < 0 for x > a * , a * ≤ µ * and µ * ≥ 0, it follows thatP v m Ẑm < cg( Ẑm ), Ẑm > a * ≤ P v ( Ẑm < µ * )andP v (T c (g) > m) = P v n i=n−k+1 Z i < cg( Ẑn ), 1 ≤ k ≤ n, 1 ≤ n ≤ m ≤ P v m Ẑm < cg( Ẑm ) = P v m Ẑm < cg( Ẑm ), Ẑm ≤ a * + P v m Ẑm < cg( Ẑm ), Ẑm > a * ≤ 2P v ( Ẑm < µ * ) Furthermore,P v ( Ẑm < µ * ) = P v ( m i −Z i > −mµ * ) = P v ( m i (µ − Z i ) > m(µ − µ * )) = P v (e θ m i (µ−Z i ) > e θm(µ−µ * ) ) ≤ e −m[θ(µ−µ * )−ln M (θ)] ,whereM(θ) = E v (e θ(µ−Z 1 )) and the last inequality follows from Chebychev's inequality Note thath(θ) = θ(µ − µ * ) − ln M(θ) attains its maximum value h(θ * ) = θ * (µ − µ * ) − ln M(θ * ) > 0 at θ = θ * > 0, where h ′ (θ * ) = 0  So, E v (T c (g)) = 1 + ∞ m=1 P v (T c (g) > m) ≤ 1 + m=1 −m[θ * (µ−µ * )−ln M (θ * )] = e θ * (µ−µ * )−ln M (θ * ) + 1 e θ * (µ−µ * )−ln M (θ * ) − Let k > 1 It follows that E vk (T c (g) − k + 1) + = ∞ m=1 P vk (T c (g) > m + k − 1, T c (g) > k − 1) ≤ (a 0 + 1)(k − 1)P 0 (T c (g) > k − 1) + ∞ m≥(a 0 +1)(k−1) P vk (T c (g) > m + k − 1) Similarly, we haveP vk (T c (g) > m + k − 1) = P vk n i=n−k+1 Z i < cg( Ẑn ), 1 ≤ k ≤ n, 1 ≤ n ≤ m + k − 1 ≤ 2P vk ( Ẑm+k−1 < µ * ) − Z i ) > m(µ − µ * ) + (k − 1)(µ 0 − µ * ) ≤ 2 exp{−m θ * (µ − µ * ) − ln M(θ * ) + k − 1 m [µ 0 − µ * − ln M 0 (θ * )] } ≤ e −mb for m ≥ (a 0 + 1)(k − 1), since θ * (µ − µ * ) − ln M(θ * ) + k − 1 m [µ 0 − µ * − ln M 0 (θ * )] ≥ b for m ≥ (a 0 + 1)(k−1) Thus, E vk (T c (g) − k + 1) + ≤ (a 0 + 1)(k − 1)P 0 (T c (g) ≥ k) + m≥(a 0 +1)(k−1) e −mb ≤ (a 0 + 1)(k − 1)P 0 (T c (g) >≥ k) + 2e −(a 0 +1)(k−1)b 1 − e −b  
Simulation of E τ i ,v and J ACE for detecting two mean shifts v = 0 1, v = 1 The parameters for T * M are k1=1, k2=150, r 1 = 5 2 * 10 −5 , r 2 = 1 1 * 10 −5 , and the expectation and standard deviation in both cases are 1717 06with 13459 80 and 3918 33 with 16893 25,respectively 

abstract

In this paper, we not only propose an new optimal sequential test of sum of logarithmic likelihood ratio (SLR) but also present the CUSUM sequential test (control chart, stopping time) with the observation-adjusted control limits (CUSUM-OAL) for monitoring quickly and adaptively the change in distribution of a sequential observations 
Two limiting relationships between the optimal test and a series of the CUSUM-OAL tests are established  Moreover, we give the estimation of the in-control and the out-of-control average run lengths (ARLs) of the CUSUM-OAL test  The theoretical results are illustrated by numerical simulations in detecting mean shifts of the observations sequence 

INTRODUCTION

In order to quickly detect a change in distribution of observations sequence without exceeding a certain false alarm rate, a great variety of sequential tests have been proposed, developed and applied to various fields since proposed a control chart method, see, for example, , , One of popular used sequential tests is the following upper-sided CUSUM test which was proposed by  
where c > 0 is a constant control limit, Z i = log[p v 1 (X i )/p v 0 (X i )], p v 0 (x) and p v 1 (x) are prechange and post-change probability density functions respectively for a sequence of mutually independent observations {X i , i ≥ 1}, that is, there is a unknown change-point τ ≥ 1 such that X 1 ,    , X τ −1 have the probability density function p v 0 , whereas, X τ , X τ +1 ,     have the probability density function p v 1  
By the renewal property of the CUSUM test T C we have , where E 1 (T C ) is the out-of-control average run length (ARL 1 ), P k and E k denote the probability and expectation respectively when the change from p v 0 to p v 1 occurs at the change-point τ = k for k ≥ 1  Though we know that the CUSUM test is optimal under Lorden's measure (see Moustakides 1986 and Ritov 1990), the out-of-control ARL 1 of the CUSUM test is not small, especially in detecting small mean shifts ( see Table in Section 4) 
In other words, the CUSUM test is insensitive in detecting small mean shifts  Then, how to increase the sensitivity of the CUSUM test ? Note that the control limit in the CUSUM test is a constant c which does not depend on the observation samples  Intuitively, if the control limit of the CUSUM test can become low as the samples mean of the observation sequence increases, then the alarm time of detecting the increasing mean shifts will be greatly shortened 
Based on this idea, by selecting a decreasing function g(x) we may define the ( upper-sided ) CUSUM chart T C (cg) with the observation-adjusted control limits cg( Ẑn ) ( abbreviated to the CUSUM-OAL chart ) in the following where c > 0 is a constant and Ẑn = n i=1 Z i /n  In other words, the control limits cg( Ẑn ) of the CUSUM-OAL test can be adjusted adaptively according to the observation information { Ẑn } 
Note that the control limits cg( Ẑn ) may be negative  In the special case, the CUSUM-OAL chart T C (cg) becomes into the conventional CUSUM chart T C (c) in (1) when g ≡ 1  Similarly, we can define a down-sided CUSUM-OAL test  In this paper, we consider only the upper-sided CUSUM-OAL test since the properties of the down-sided CUSUM-OAL test can be obtained by the similar method 
The main purpose of the present paper is to show the good detection performance of the CUSUM-OAL test and to give the estimation of its the in-control and out-of-control ARLs  The paper is organized as follows  In Section 2, we first present an optimal SLR sequential test, then define two sequences of the CUSUM-OAL tests and prove that one of the two sequences of CUSUM-OAL tests converges to the optimal test, another sequences of CUSUM-OAL tests converges to a combination of the optimal test and the CUSUM test 
The estimation of the in-control and out-of-control ARLs of the CUSUM-OAL tests and their comparison are given in Section 3  The detection performances of the three CUSUM-OAL tests and the conventional CUSUM test are illustrated in Section 4 by comparing their numerical out-ofcontrol ARLs  Section 5 provides some concluding remarks 
Proofs of the theorems are given in the Appendix 

AN OPTIMAL SLR TEST, TWO CUSUM-OAL TESTS AND THEIR LIMITING RELATIONSHIPS

Let P 0 and E 0 denote the probability and the expectation respectively with the probability density p v 0 when there is no change for all the time  It is known that It follows from Proposition 2 38 in and (5 8)-(5 9) in Chow et al, P 108) that the following sequence test of sum of logarithmic likelihood ratio (SLR)
for B > 1, is optimal in the following sense min for P 0 (T SLR < ∞) = α, where c = log B and 0 < α < 1  In particular, if P 0 is the standard normal distribution with mean shift µ > 0 after changepoint, we have Z j − µ 0 = µX j , where µ 0 = −µ 2 /2  It follows from proposition 4 in that the SLR test T SLR in (4) is also optimal (minimal ARL 1 ) with the same false alarm probability P 0 (T < τ ) 
It can be seen that the in-control average run length of T SLR is infinite, that is, ARL 0 = E 0 (T SLR ) = ∞  However, the minimal ARL 1 with finite ARL 0 is a widely used optimality criterion in statistical quality control (see ) and detection of abrupt changes (see   In order to get finite ARL 0 for T SLR , we replace the constant control limit c of T SLR in (3) or (4) with the dynamic control limit n(µ 0 − r) and obtain a modified SLR test T SLR (r) in the following
for r ≥ 0  For comparison, the in-control ARL 0 of all candidate sequential tests are constrained to be equal to the same desired level of type I error, the test with the lowest out-of-control ARL v has the highest power or the fastest monitoring (detection) speed  In the following example 1, the numerical simulations of the out-of-control ARLs of the CUSUM-OAL tests T C (cg u,0 ) in detecting the mean shifts of observations with normal distribution will be compared with that of the SLR tests T * (r) and T * (0), and that of the CUSUM-SLR test T C (c) ∧ T * (0) := min{T C (c), T * (0)} in the following Table  
These comparisons lead us to guess that there are some limiting relationships between T C (cg u,r ) and T * (r), and T C (c g u ) and T C (c) ∧ T * (0), respectively  Example 1  Let X 1 , X 2 ,      be mutually independent following the normal distribution N(0, 1) if there is no change  After the change-point τ = 1, the mean E µ (X k ) ( k ≥ 1 ) will change from v 0 = 0 to v = 0 1, 0 25, 0 5, 0 75, 1, 1 25, 1 5, 3  Here, we let
, where v 1 = 1 is a given reference value which for the CUSUM test is the magnitude of a shift in the process mean to be detected quickly  We conducted the numerical simulation based on 1,000,000 repetitions  The following Table lists the simulation results of the ARLs of the tests T C (c), T C (c g u ) for u = 1, 10, 10 2 , 10 3 , 10 4 , T * (0 0007), T C (c) ∧ T * (0) and T * (0) for detecting the mean shifts, where the mean shift 0 0 means that there is no change which corresponds to the in-control ARL 0 and all tests have the common ARL 0 ≈ 1000 except the test T * (0) which has ARL 0 = ∞ 
The values in the parameters are the standard deviations of the tests  From the last row in Table , it's a little surprising that though the ARL 0 of T * (0) is infinite, that is, E 0 (T * (0)) = ∞, the detection speed of T * (0) is faster than that of the CUSUM chart T C for all mean shifts, in particular, for detecting the small mean shift 0 1, the speed of T * (0) is only 7 47 which is very faster than the speed, 439, of the CUSUM test 
Moreover, both control charts T * (0 0007) and T C (11 9271) ∧ T * (0) not only have the nearly same detection performance as T * (0) but also can have the finite in-control ARL 0   Note particularly that when the number u in g u is taken from 0 to 1, 10, 10 2 , 10 3 , 10 4 , the detection speed of T C (c g u ) is getting faster and faster, approaching to that of T C (c) ∧ T * (0) 
This inspires us to prove the following theoretic results  Let τ = 1 and {X k , k ≥ 1} be an i i d  observations sequence with Theorem 2 shows that when the constant control limit c of the CUSUM test T C (c) is replaced with the observation-adjusted control limits {cg u,r ( Ẑn )} and {c g u ( Ẑn )} respectively, the corresponding two CUSUM-OAL tests {T C (cg u,r )} and {T C (c g u )} will converge to the optimal SLR test T * (r) and the CUSUM-SLR test T C (c) ∧ T * (0) as u → ∞, respectively 
In other words, the fastest alarm times that {T C (cg u,r )} and {T C (c g u )} can be reached are T * (r) and T C (c) ∧ T * (0), respectively  u ≥ 0} can be seen as two "long bridges" connecting T C (c) and T * (r), and T C (c) and T C (c) ∧ T * (0), respectively 

ESTIMATION AND COMPARISON OF ARL OF THE CUSUM-OAL TEST

In this section we will give an estimation of the ARLs of the following CUSUM-OAL test that can be written as where g( ) is a decreasing function, Ẑn (ac x] denotes the smallest integer greater than or equal to x  Here Ẑn (ac) is a sliding average of the statistics, Next we discuss on the the post-change probability distribution in order to estimate the ARLs of T C (cg) 
Usually we rarely know the post-change probability distribution P v of the observation process before it is detected  But the possible change domain and its boundary (including the size and form of the boundary) about v may be determined by engineering knowledge, practical experience or statistical data 
So we may assume that the region of parameter space V and a probability distribution Q on V are known  If we have no prior knowledge of the possible value of v after the change time τ , we may assume that v occurs equally on V , that is, the probability distribution Q is an equal probability distribution (or uniform distribution ) on V  
For example, let P v be the normal distribution and v = (µ, σ), where µ and σ denote the mean and standard deviation respectively, we can take the set V = {(µ, σ) : and Q is subject to the uniform distribution U(V ) on V if v occurs equally on V , where the numbers µ 1 , µ 2 , σ 1 and σ 2 are known  It means that we know the domain of the possible post-change distributions, P v , v ∈ V , i e , the boundary ∂V of the parameter space V is known 
Next we shall divide the parameter space V into three subsets V + , V 0 and V − by the Kullback-Leibler information distance  Let and are two Kullblak-Leibler information distances between P v , P v 0 and P v , P v 1   Since I(p|q) = 0 if and only if p = q, where p and q are two probability measures, it follows that
, it means that P v is closer to P v 0 than to P v 1 according to the Kullblak-Leibler information distance  There is a similar explanation for v ∈ V + or ∈ V 0   Suppose the post-change distribution P v and the function g(x) satisfy the following conditions: (I) The probability P v is not a point mass at E v (Z 1 ) and P v (Z 1 > 0) > 0 
(II) The moment-generating function h v (θ) = E v (e θZ 1 ) satisfies h v (θ) < ∞ for some θ > 0  (III) The function g(x) is decreasing, its second order derivative function g ′′ (x) is continuous and bounded, and there is a positive number x * such that g(x * ) = 0  ) and and therefore, Θ ′ (θ(u)) = −H(θ(u)) = −H(θ * v ) = 0, Θ ′ (θ(1/x)) > 0 for x > 1/u and Θ ′ (θ(1/x)) < 0 for x > 1/u 
Hence, there exists a positive number b defined in (??)  It can be seen, the main part of ARL v (T c (g)) will be an exponential function, square function, and linear function of c when the process {Z k : k ≥ 0} has no change or a "small change", a "medium change" and a "large change" from P v 0 to P v , respectively 
Here, the "small change" (v ∈ V − ) means that P v is closer to P v 0 than to P v 1 , i e , I(P v |P v 0 ) < I(P v |P v 1 ), and the "large change" is just the opposite  The "medium change" (v ∈ V 0 ) corresponds to In this paper, we will use another method to prove Theorem 3 since Wald's identity and the martingale method do not hold or can not work for showing the ARLs estimation of the test T c (g) when g is not constant 
Next we compare the detection performance of the CUSUM-OAL test (ARL v (T c ′ (g))) with that of the CUSUM test (ARL v (T C (c))) by using (??) in Theorem 4 1  ) when µ 0 < µ < 0 and for θ * v 0 > g(µ)/g(µ 0 ) when µ ≥ 0  This means that ARL v (T c (g)) can be smaller than ARL v (T C (c)) as long as g(µ)/g(µ 0 ) is small for all µ > µ 0  

NUMERICAL SIMULATION AND A REAL EX-AMPLE ILLUSTRATION

4 1 Numerical Simulation of ARLs for τ ≥ 1 By the simulation results of ARLs in Table , we see that the detection performance of T * (r), T C (c)∧T * (0), T * (0) and T C (c g u ) for large u is much better than that of the conventional CUSUM test T C for τ = 1  The following Table illustrates the simulation values of E τ i ,v and J ACE of nine tests in detecting two mean shifts v = 0 1 and v = 1 after six change-points, τ i , 1 ≤ i ≤ 6 with ARL 0 (T ) = E 0 (T ) ≈ 500 
Note that H v (θ) is a convex function and H ′ v (0) = µ < 0  This means that there is a unique positive number   It follows from (A 9) that for a large c  Taking θ ց θ * v and u ′ ց u, we have for a large c  Thus, by (A 11) we have as c → ∞  By the properties of exponential distribution, we have for a large c 
To prove the downward inequality of (A 10), let where b is defined in (??) and without loss of generality, we assume that b > a  Obviously, Let k = xcg(µ)  By Chebyshev's inequality, we have Since Hv (θ) and H v (θ) are two convex functions and Let m = tcg(µ)θ * v /bc for t > 0  By (A 13), (A 14), (A 15) and Theorem 5 1 in Esary, Proschan and Walkup (1967) we have
Finally, as c → +∞, where θ 0 > 0 satisfies h v (θ 0 ) = 1  Thus as c → ∞  This implies that for a large c  This completes the proof of (A 10)  Let v ∈ V 0   Let m 1 = (cg(0)) 2 /σ 2   It follows that Note that for a large c, where A = |g ′ (0)|/a, and , where Φ( ) is the standard normal distribution  Let m 2 = (cg(0)) 2 /(8σ 2 ln c) 
Note that as c → ∞, where the third inequality comes from Theorem 5 1 in Esary, Proschan and Walkup (1967)  Thus, we have Let v ∈ V + and let The uniform integrability of {T c (g)/c} for c ≥ 1, follows from the well-known uniform integrability of {T 0 /c} (see Gut (1988)) 
Context 2: Ghousul Waqt, Mufti-e-Azam-e-Hind (radi Allahu anhu) was born on Monday, 22nd of Zil Hijjah 1310 AH (18 July 1892) in the most beautiful city of Bareilly Shareef, India  It was in this very city that his illustrious father, the Mujaddid (Reviver) of Islam, Imam-e-Ahle Sunnat, A'la Hazrat, Ash Shah Imam Ahmed Raza Khan Al Qaderi (radi Allahu anhu) was born (1856 - 1921) 
At the time of the birth of Ghousul Waqt, Mufti-e-Azam-e-Hind (radi Allahu anhu), his distinguished father, was in Mahrerah Shareef, one of the great spiritual centers of the Sunni World  On that very night, Sayyiduna A'la Hazrat (radi Allahu anhu) dreamt that he had been blessed with a son and in his dream he named his son "Aale Rahmaan"  Hazrat Makhdoom Shah Abul Hussain Ahmadi Noori (radi Allahu anhu), one of the great personalities of Mahrerah Shareef, named the child "Abul Barkaat Muhiy'yuddeen Jilani" 
Mufti-e-Azam-e-Hind (radi Allahu anhu) was later named "Mustapha Raza Khan"  His Aqiqa was done on the name of "Muhammad", which was the tradition of the family 
Upon the birth of Ghousul Waqt, Mufti-e-Azam-e-Hind (radi Allahu anhu) Sayyiduna Shah Abul Hussain Ahmadi Noori (radi Allahu anhu) told A'la Hazrat (radi Allahu anhu), "Maulana! When I come to Bareilly Shareef, then I will definitely see this child  He is a very blessed child "
As promised, when Sayyiduna Abul Hussain Ahmadi Noori (radi Allahu anhu) went to Bareilly Shareef, he immediately summoned to see Mufti-e-Azam-e-Hind (radi Allahu anhu) who was only six (6) months old  Sayyiduna Noori Mia (radi Allahu anhu), as he was also famously known, congratulated A'la Hazrat (radi Allahu anhu) and said, "This child will be of great assistance to the Deen and through him the servants of Almighty Allah will gain great benefit  This child is a Wali  From his blessed sight thousands of stray Muslims will become firm on the Deen  He is a sea of blessings "
On saying this, Sayyiduna Noori Mia (radi Allahu anhu) placed his blessed finger into the mouth of Mufti-e-Azam-e-Hind (radi Allahu anhu) and made him a Mureed  He also blessed him with I'jaazat and Khilafat at the same time  (Mufti Azam Hind Number, pg  341)  Not only did he receive Khilafat in the Qaderi Silsila (Order), but also in the Chishti, Nakshbandi, Suharwardi, and Madaari Orders  Mufti-e-Azam-e-Hind (radi Allahu anhu) also received Khilafat from his blessed father, A'la Hazrat, Ash Shah Imam Ahmed Raza Khan Al Qaderi (radi Allahu anhu) 
Ghousul Waqt, Mufti-e-Azam-e-Hind (radi Allahu anhu) attained most of his early education from his illustrious family - from his father, A'la Hazrat, Ash Shah Imam Ahmed Raza Khan Al Qaderi (radi Allahu anhu) the Mujaddid of Islam, whose status and position even at that time cannot be explained in these few lines  He also studied Kitaabs under the guidance of Hazrat Moulana Haamid Raza Khan (his elder brother), Maulana Shah Rahm Ilahi Maglori and Maulana Sayed Basheer Ahmad Aligarhi and Maulana Zahurul Hussain Rampuri (radi Allahu anhum)  He studied various branches of knowledge under the guidance of his most learned and blessed father, A'la Hazrat (radi Allahu anhu)  He gained proficiency in the many branches of Islamic knowledge from among which are: Tafseer; Hadith; Fiqh; Laws of Jurisprudence; Sarf; Nahw; Tajweed; Conduct of Language; Philosophy; Logistics; Mathematics; History etc ; Arithmetic; Aqaid (Belief); Taasawwaf; Poetry; Debating; Sciences; etc 
Mufti-e-Azam-e-Hind, Moulana Mustapha Raza Khan (radi Allahu anhu's) brilliance as an Islamic Scholar manifested itself when he was a still a youth, but overflowing with knowledge and wisdom  He wrote his first historical Fatawa (Islamic Ruling) when he was only 13 years old  It dealt with the topic of "Raza'at" - affinity between persons breast fed by the same woman  The following has been recorded with regards to this occasion 
Hazrat Maulana Zafrud'deen and Hazrat Maulana Sayed Abdur Rasheed (radi Allahu anhum) were at the Darul Ifta (Fatawa Department) at this stage  One day, Mufti-e-Azam-e-Hind (radi Allahu anhu) walked into the Darul Ifta and noticed that Hazrat Maulana Zafrud'deen (radi Allahu anhu) was writing a certain Fatawa  He was taking "Fatawa Razvia" from the shelf as his reference  On seeing this, Mufti-e-Azam-e-Hind (radi Allahu anhu) said, "Are you relying on Fatawa Razvia to write an answer?" Maulana Zafrud'deen (radi Allahu anhu) replied, "Alright then, why don't you write the answer without looking " Mufti-e-Azam-e-Hind (radi Allahu anhu) then wrote a powerful answer without any problem  This was the Fatawa concerning "Raza'at" - the very first Fatawa which he had written 
Sayyiduna A'la Hazrat (radi Allahu anhu) then signed the Fatawa  He also commanded Hafiz Yaqeenudeen (radi Allahu anhu) to make a stamp for Mufti-e-Azam-e-Hind (radi Allahu anhu) as a gift and said that it should read as follows: "Abul Barkaat Muhiy'yuddeen Jilani Aale Rahmaan urf Mustapha Raza Khan "
This incident took place in 1328 AH  After this incident Mufti-e-Azam-e-Hind, Moulana Mustapha Raza Khan (radi Allahu anhu) spent another 12 years writing Fatawas at the feet of A'la Hazrat (radi Allahu anhu)  He was given this immense responsibility of issuing Fatawas even while A'la Hazrat (radi Allahu anhu) was in this physical world  He continued this trend until his last breath  The stamp which was given to him was mislaid during his second Hajj when his bags were lost 
Mufti-e-Azam-e-Hind (radi Allahu anhu) married the blessed daughter of his paternal uncle, Hazrat Muhammad Raza Khan (radi Allahu anhu)  He had 6 daughters and one son, Hazrat Anwaar Raza (radi Allahu anhu), who passed away during childhood 
"Khuda Kheyr se Laaye Wo Din Bhi Noori, Madine ki Galiya Buhara Karoo me"
Tajedaare Ahle Sunnah, Taaje Wilayat Wa Karaamat, Mufti-e-Azam-e-Hind, Moulana Mustapha Raza Khan (radi Allahu anhu) went twice for Hajj - in 1905 and 1945  He performed his third Hajj in 1971 
Mufti-e-Azam-e-Hind, Moulana Mustapha Raza Khan (radi Allahu anhu) was the first person to go for Hajj without a photograph in his passport  He refused to take a photograph  Mufti-e-Azam-e-Hind (radi Allahu anhu) was allowed to go for Hajj without a photograph in his passport and without taking any vaccinations 
During his trip to Makkatul Mukarramah, Mufti-e-Azam-e-Hind (radi Allahu anhu), also had the opportunity of meeting those Ulema whom his father, Sayidduna A'la Hazrat (radi Allahu anhu), met during his visit to Haramain Sharifain  These great Ulema were from amongst the students of Sayed Yahya Almaan (radi Allahu anhu)  A few of the Ulema that he met were Allamah Sayed Ameen Qutbi; Allamah Sayed Abbas Alawi and Allamah Sayed Noor Muhammad (radi Allahu anhum) - to mention just a few  They narrated many incidents which had taken place during Sayyiduna A'la Hazrat (radi Allahu anhu's) visit to Haramain Sharifain  They then requested Khilafat from Mufti-e-Azam-e-Hind, (radi Allahu anhu) which he bestowed upon them 
Tajedaare Ahle Sunnah, Taaje Wilayat Wa Karaamat, Mufti-e-Azam-e-Hind, Moulana Mustapha Raza Khan (radi Allahu anhu) was aware of the actual time of his Wisaal 
On the 6th of Muharram (1981) he said, "All those who intended to become my Mureed but for some reason or the other could not come to me, I have made all of them Mureed and I have given their hands into the hand of Sayidduna Ghousul Azam (radi Allahu anhu) "
On the 12th of Muharram (1981) Hazrat said, "All those who asked me to make Dua for them, I have made Dua for their Jaiz (permissible) intentions to be fulfilled  May Allah accept this Dua " On this day he asked those that were present concerning date  They told him that it was the 12th of Muharram  On hearing this he became silent 
On the 13th of Muharram, he again asked concerning the date and the Mureedeen present said that it was Wednesday, the 13th of Muharram  On hearing this Mufti-e-Azam-e-Hind (radi Allahu anhu) said, "Namaaz will be held at Nau Mahla Musjid"  Those present did not understand what he meant, but remained silent out of respect  After some time again Mufti-e-Azam-e-Hind (radi Allahu anhu) said, "Did anybody tell you about the Namaaz  I will read Jumma Namaaz in Nau Mahla Masjid " After some time Hazrat said, "Did anybody say anything about the Fatiha " Those present just gazed at each others faces and remained silent  Only later did they realise what Mufti-e-Azam-e-Hind (radi Allahu anhu) was implying  Hazrat was spiritally present for Jummah at the Nau Mahla Masjid! Mufti-e-Azam-e-Hind (radi Allahu anhu) was not only giving hope to the Mureedeen but also informing them of his Wisaal 
The shining star of A'la Hazrat, Ash Shah Imam Ahmed Raza Khan (radi Allahu anhu), the glitter and the hope for the hearts of millions throughout the world, the Mujaddid of the 15th Century, the Imam of his time, Huzoor Sayyidi Sarkaar Mufti-e- Azam-e-Hind (radi Allahu anhu) left the Aalame Duniya to Journey towards the Aalame Aakhira  It was 1 40 p m  on the eve of the 14th of Muharram 1402 AH (1981) 
"Chal diye tum Aankho me ashko ka darya chor kar, har jigar me dard apna meetha meetha chor kar"
Rawa Aankho se he Ashko ke Dhaare Mufti-e-Azam, Kaha Ho Be Saharo Ka Sahara Mufti-e-Azam"
On Friday, the 15th of Muharram, at 8  00 a m  the Ghusl of Mufti-e-Azam-e-Hind (radi Allahu anhu) took place  His nephew, Hazrat Maulana Rehan Raza Khan (radi Allahu anhu) performed the Wudhu  Hazrat Allamah Mufti Mohammed Akhtar Raza Khan Azhari performed the Ghusl  Sultan Ashraf Sahib used the jug to pour water  The following persons were present during the Ghusl : Hazrat Maulana Rehan Raza Khan (radi Allahu anhu), Hazrat Allamah Mufti Mohammed Akhtar Raza Khan, Sayed Mustaaq Ali, Maulana Sayed Muhammad Husain, Sayed Chaif Sahib, Maulana Naeemullah Khan Sahib Qibla, Maulana Abdul Hamid Palmer Razvi, Muhammad Esa of Mauritius, Ali Husain Sahib, Hajji Abdul Ghaffar, Qari Amaanat Rasool Sahib and a few other Mureeds and family members 
Hazrat Allamah Mufti Mohammed Akhtar Raza Khan Azhari and Hazrat Maulana Rehan Raza Khan (radi Allahu anhu) have stated that at the time of the Ghusl Shareef of Mufti-e-Azam-e-Hind (radi Allahu anhu) the Chaadar mistakenly moved a little  Immediately, Mufti-e-Azam-e-Hind (radi Allahu anhu) held the Chaadar between his two fingers and covered the area that the Chaadar exposed  Those present thought that the Chaadar had just got caught between Mufti-e-Azam-e-Hind (radi Allahu anhu's) fingers  They tried to remove the Chaadar from between his fingers but it would not move  The first person to notice this Karaamat was Hazrat Allamah Mohammed Akhtar Raza Khan Azhari  He showed this to everyone  Mufti-e-Azam-e-Hind (radi Allahu anhu's) fingers did not move until the area was properly covered 
"Zinda hojate he jo marte he haq ke Naam par, Allah, Allah Maut ko kis ne Masiha Kardiya"
"Janaaze se utha kar haath Pakri Chaadare Aqdas, He too Zinda He ye Zinda Karaamat Mufti e Azam"
As he had wished, the Janaza Salaah of Mufti-e-Azam-e-Hind (radi Allahu anhu) was performed by Maulana Sayed Mukhtar Ashraf Jilani at the Islamia Inter College grounds in Bareilly Shareef  Two and a half million (2 500 000) Muslims attended his Janazah Salaah  Mufti-e-Azam-e-Hind (radi Allahu anhu) is buried on the left-hand-side of Sayyiduna A'la Hazrat (radi Allahu anhu)  Those who lowered Mufti-e-Azam-e-Hind (radi Allahu anhu) in his Qabr Shareef have stated that they were continously wiping out perspiration from the forehead of Mufti-e-Azam-e-Hind (radi Allahu anhu) right up to the last minute 
"Maangne Waala sub kuch paaye rota aaye hasta Jaaye", "Ye He Unki Adna Karamat Mufti Azam Zinda Baad"
Wealth, presidency, minister ship, worldly satisfaction and happiness can be given to a person by anyone, but such people do not have the spiritual insight to give tranquility to a disturbed heart and they cannot put a smile onto the face of a depressed person  But Tajedaare Ahle Sunnah, Taaje Wilayat Wa Karaamat, Mufti-e-Azam-e-Hind, Moulana Mustapha Raza Khan (radi Allahu anhu) gave both the treasures of the physical world and the spiritual worlds to those in need  To be his servant was not less than kingship  Every day hundreds and thousands of people in need of spiritual, physical and academic needs would come to him and each one of them returned with complete satisfaction 
"Jhuki Hai Gardane Dar Par Tumhare, Taaj Waalo Ki, Mere Aqa Mere Maula Wo Taajul Auliyah Tum Ho"
Mufti-e-Azam-e-Hind, Moulana Mustapha Raza Khan (radi Allahu anhu) is that light of such an illustrious family whose radiance reflected itself in his character and manners that he displayed - such qualities that very few would be able to reach perfection  His character was the true embodiment of the Sunnah of Sayyiduna Rasulullah (sallal laahu alaihi wasallam)  He shone like a star in the darkness of the night 
Mufti-e-Azam-e-Hind, Moulana Mustapha Raza Khan (radi Allahu anhu) possessed great heights of good character, moral standards, kindness, sincerity, love and humbleness  He never refused the invitation of any poor Muslim  He always stayed away from those who were very wealthy and lavish  He was the possessor of great moral and ethical values 
It is stated that once Akbar Ali Khan, a Governor of U P , came to visit Mufti-e-Azam-e-Hind (radi Allahu anhu)  Mufti-e-Azam-e-Hind (radi Allahu anhu) did not meet him but left to a place called Puraana Shahar (Old City) to visit a poor Sunni Muslim who was very ill and at the doorstep of death 
In another occasion, Fakhruddeen Ali Ahmad, the President of a Political Party, came to visit Mufti-e-Azam-e-Hind (radi Allahu anhu) but was refused this opportunity  Many other proud ministers had also come to meet Mufti-e-Azam-e-Hind (radi Allahu anhu) but met with the same fate  This was due to his extreme dislike for politics and involvement in worldly affairs 
Mufti-e-Azam-e-Hind (radi Allahu anhu) never fell short in entertaining those who came to visit him  When he was physically fit he used go into the Visitors Section and ask each person whether they had eaten or not  He used to ask them if they partook in tea or not  He used to continuously enquire as to whether they were experiencing any difficulties or not  It was often seen that he would personally carry the dishes into the house for the visitors! He was definitely blessed with the characters of the "Salfe Saliheen" or The Pious Servants of Allah 
Mufti-e-Azam-e-Hind, Moulana Mustapha Raza Khan (radi Allahu anhu) was a pillar of hospitality and humbleness  If he reprimanded a certain person for doing something un-Islamic or if he became displeased with anyone for some reason or the other, he used to also explain to the person in a very nice way and also try to cheer that person  He would then make Dua in abundance for such a person  His Mureeds (Disciples), on many ocassions, used to recite Manqabats (Poetry) in his praise  On hearing such Manqabats he would say, "I am not worthy of such praise  May Allah make me worthy "
Many people came to him for his blessings  Others would come for Ta'weez  He never refused anyone  It is also not known how many homes were being supported through the kindness and hospitality of Mufti-e-Azam-e-Hind, Moulana Mustapha Raza Khan (radi Allahu anhu)  He always entertained those who came from far and near to the best of his means  He used to even give most of his visitors train and bus fares to travel  In winter, he would give warm clothes, warm sheets and blankets to the poor and the needy 
Mufti-e-Azam-e-Hind, Moulana Mustapha Raza Khan (radi Allahu anhu) gave Khilafat to many Ulema-e-Ikraam and personally tied the Amaama (Turban) on their heads  He gave cloaks, turbans and hats to many people  Once, during winter, a few of the Khaadims were present with Mufti-e-Azam-e-Hind (radi Allahu anhu)  He was lying on his bed and covered with a shawl  A certain Maulana Abu Sufyaan touched Mufti-e-Azam-e-Hind (radi Allahu anhu's) shawl and commented as to how beautiful it was  Mufti-e-Azam-e-Hind (radi Allahu anhu) immediately removed the shawl and presented it to him  Although the Moulana refused to accept it Mufti-e-Azam-e-Hind (radi Allahu anhu) gave it to him forcefully 
All of his Mehfils were full of knowledge and Barkah  Many questions on Tassawuf were easily answered by him  It seemed as if the rains of mercy and rays of Noor were spread all over his Mehfils 
Mufti-e-Azam-e-Hind, Moulana Mustapha Raza Khan (radi Allahu anhu) always wanted to see a Muslim's inner and outer personality  He always advised them to mould their lives according to the principles and the commands of Islam  He always showed discomfort to those who did not have beards, those who wore hats and to those who wore ultra-western clothes  He used to warn such Muslims  Mufti-e-Azam-e-Hind, Moulana Mustapha Raza Khan (radi Allahu anhu) used to show his displeasure towards those who wore ties  He used to tug at their ties and commanded them to abstain from wearing a tie  He also asked them to make Tauba from such acts 
Mufti-e-Azam-e-Hind, Moulana Mustapha Raza Khan (radi Allahu anhu) always commanded Muslims to give or take anything with their right hand  He stopped the Muslims from calling the governments as their "Sarkaar" or leaders  He never kept any ordinary Kitaab on the books of Tafseer or Hadith  Whenever he sat in a Meelad-un-Nabi (sallal laahu alaihi wasallam) or Mehfil-e-Zikr, he always sat with utmost respect until the very end 
Mufti-e-Azam-e-Hind, Moulana Mustapha Raza Khan (radi Allahu anhu) never spat towards the Qibla  He never stretched his legs in the direction of the Qibla  Whenever he entered the cemetery, he never used his entire feet to walk on the ground  He always walked on his toes  At times, he would stand on his toes for about half an hour in the graveyard making Dua-e- Maghfirat!
He always stopped Muslims from doing any false fortune telling  If any death or loss took place in the house of a Muslim, Mufti-e-Azam-e-Hind, Moulana Mustapha Raza Khan (radi Allahu anhu) would go to comfort the people of that house but he would never eat there  He always advised those in sorrow to make Sabr and remember Almighty Allah  He always respected Ulema-e-Ikraam  He respected the Sayeds in such a manner as a slave will respect his King  He prohibited Muslims from keeping un-Islamic names  He preferred such names as Abdullah, Abdur Rahmaan, Muhammad and Ahmad 
Mufti-e-Azam-e-Hind, Moulana Mustapha Raza Khan (radi Allahu anhu) always performed his Salaah in Jamaah whether he was on journey or not  The moment he put his foot out of his house to go towards the Masjid, he used to be surrounded by his Mureeds (disciples) and well-wishers who would follow him till the Masjid door which was just a few feet away from his house  While some would be kissing his blessed hands, others tried to talk with him  He would reply to all those who made Salaam to him  On entering the Masjid, he would immediately recite the dua prescribed 
Mufti-e-Azam-e-Hind, Moulana Mustapha Raza Khan (radi Allahu anhu) would then remove his Amaama and then sit down to perform Wudhu  He would wash all the parts thoroughly so that the Sunnahs were accomplished  He would perform his Salaah with great sincerity and used to be lost in the worship of his Creator  The person who looked at him from a distance would have instantly understood that Mufti-e-Azam-e-Hind (radi Allahu anhu) had left all the worldly desires and was intent upon pleasing his Creator 
Once, while Mufti-e-Azam-e-Hind (radi Allahu anhu) was traveling from Nagpur, it was time for Maghrib Salaah  He immediately disembarked from the train  The people told Mufti-e-Azam-e-Hind (radi Allahu anhu) that the train was about to leave, but he was intent on performing his Salaah  His companions also disembarked with him  They had just performed their Wudhu and were making Niyyah for Salaah when the train left the station  All of Mufti-e-Azam-e-Hind (radi Allahu anhu's) and his companions luggages' were left on the train  A few un-Islamic people who were there said "the Mias train had left him"  Mufti-e-Azam-e-Hind (radi Allahu anhu) was still in Salaah 
When they all had completed their Salaah, they noticed that the station platform was empty  They became a little worried since all their luggage had gone with the train, but still Mufti-e-Azam-e-Hind (radi Allahu anhu) looked undisturbed  His companions were busy talking about the luggage when they noticed the station guard, followed by a group of travellers, running towards them  The guard came up to Mufti-e-Azam-e-Hind (radi Allahu anhu) and said, "Huzoor! The train is stuck!" Mufti-e-Azam-e-Hind (radi Allahu anhu) said, "The engine is damaged " The train was brought back and Mufti-e-Azam-e-Hind (radi Allahu anhu) and his companions sat in the train  After some repairs the train left with him and his companions seated in it!
Mufti-e-Azam-e-Hind, Moulana Mustapha Raza Khan (radi Allahu anhu) was drowned in the love for the Holy Prophet, Sayyiduna Rasulullah (sallal laahu alaihi wasallam)  Everything he did was for the pleasure of Almighty Allah and Sayyiduna Rasulullah (sallal laahu alaihi wasallam)  All that he had gained was due to the intense love which he possessed for the Holy Prophet (sallal laahu alaihi wasallam) 
His extreme and intense love for the Holy Prophet (sallal laahu alaihi wasallam) can be understood by the fact that during the latter stages of his life, even though he was very ill, he would sit for hours with great respect in the Naath Mehfils and would shed tears in his love for Sayyiduna Rasulullah (sallal laahu alaihi wasallam)  He used to celebrate the Meelad-un-Nabi (sallal laahu alaihi wasallam) each year with great splendour  The programme used to begin on the eve of the 12th of Rabi-ul-Awwal and used to continue till the next day just before lunch  The invitation was open to all Muslims and they all used to be fed 
Even after examining the Naath Shareefs written by Mufti-e-Azam-e-Hind (radi Allahu anhu) one would see that every word written dislayed his measureless love for the Holy Prophet (sallal laahu alaihi wasallam) 
In the world of poetry, Mufti-e-Azam-e-Hind, Moulana Mustapha Raza Khan (radi Allahu anhu) was a Giant of his time  Most of his poems were in the form of Humd (Praise of Allah), Naath Shareef, Qasidas and Manqabats compiled in the Arabic, Urdu, Persian and Hindi languages  All these poems were compiled into a book which is famously known as "Samaane Bakhshish" which is still available toady  Samaane Bakhshsish is a treasure chest which flows with pearls of love for Sayyiduna Rasoolullah (sallal laahu alaihi wasallam)  The compilation of Samaane Bakhshish is through the blessings of Sayyiduna Rasoolullah (sallal laahu alaihi wasallam) 
"Ye Dil Ye Jigr Hai Ye Aankhe Ye Sar Hai, Jaha Chaaho Rakho Qadam Ghause Azam"
"Once a very young descendant of Sayyiduna Sheikh Abdul Qaadir Jilani (radi Allahu anhu), Hazrat Peer Taahir Ala'uddeen (radi Allahu anhu), visited Bareilly Shareef  The respect and honour that Mufti-e-Azam-e-Hind (radi Allahu anhu) showed towards him was out of this world  Mufti-e-Azam-e-Hind (radi Allahu anhu) used to walk bare feet behind him with great respect "
The great Ulema of the time have stated that Mufti-e-Azam-e-Hind (radi Allahu anhu) was lost to such an extent in the love for Sayyiduna Ghousul Azam, Sheikh Abdul Qaadir Jilani (radi Allahu anhu) that even physically he began to resemble Sheikh Abdul Qaadir Jilani (radi Allahu anhu) 
"Dekh Kar Shakle Mufti Azam, Ghause Azam ki Yaad Aayi he"
Ghousul Waqt, Mufti-e-Azam-e-Hind (radi Allahu anhu) had great respect and love for the Ulema and for Sayeds (Descendants of Sayyiduna Rasulullah sallal laahu alaihi wasallam)  The respect which he showed towards them is beyond explanation 
One day, in 1979, a lady came with her little child to ask for Ta'weez  It was a very hot day and she was informed that Mufti-e-Azam-e-Hind (radi Allahu anhu) was resting  The lady, however, was in great need for the particular Ta'weez  She asked someone to see if Mufti-e-Azam-e-Hind (radi Allahu anhu) was awake but nobody had the nerve of going near him while he was resting as they considered this to be disrespectful  Taking her child she commented, "What did we know that the words of Sayeds will not be heard in this place" 
It is not known how Mufti-e-Azam-e-Hind (radi Allahu anhu) heard this, but he immediately summoned one of the Mureeds  He instructed him to call the lady and not give her grief  The woman then sent her child to Mufti-e-Azam-e-Hind (radi Allahu anhu)  He asked the child's name and showed great love and respect towards this young child  With great affection, he placed his hand on the child's head  He even asked someone to bring an apple for the child  From behind the curtain, he spoke to the lady concerning her problem and immediately wrote a Ta'weez for her 
Mufti-e-Azam-e-Hind (radi Allahu anhu) then sent a message to his family requesting that the mother and child should only be allowed to leave after the heat became less intense; that they should be well entertained and that no shortage should be spared in entertaining these Sayeds 
When Allamah Sadru Shariah Maulana Amjad Ali Al Qadri (radi Allahu anhu), the author of the famous "Bahare Shariah," used to come to Bareilly Shareef for the Urs Shareef of Sayyiduna A'la Hazrat (radi Allahu anhu), Mufti-e-Azam-e-Hind (radi Allahu anhu) used to go to the railway station to welcome him and showed great respect towards this Scholar of Islam  He also showed great respect towards Sayyidi Hafiz-e-Millat and Hazrat Maulana Hasmat Ali Khan Sahib (radi Allahu anhum)  He also showed respect towards his own Mureeds and Khalifas who were Alims 
"Hawa he Gotand wa Tez lekin Chiraagh Apna Jala Raha he, Wo Marde Durwesh jis ko Haq ne diye the Andaze Khusrawana"
The sign of a true Mo'min is that he never submits himself before an enemy  In the worst of circumstances a Mo'min announces that which is the truth  Sayyiduna Rasulullah (sallal laahu alaihi wasallam) said, "To speak the truth before a tyrant King is a great Jihad " So imagine the excellence of a person who always spoke the truth at all times, a person who always raised the flag of truth and honesty, and a person who never left the path of truth in his entire life!
Mufti-e-Azam-e-Hind, Moulana Mustapha Raza Khan (radi Allahu anhu) was one such person  He is one of the greatest leaders of the Sunnis  His boldness and fearlessness is difficult to explain  His entire life was spent speaking against Deobandis, Wahabis and all the other misleading sects, whether is was against the West, Qadianism, or Najdism he always challenged them right till the very end  He always propagated the true Deen and the Path of the Ahle Sunnah Wa Jamaah  With his Fatawas, he helped protect the Imaan of not only the Muslims in India and Pakistan, but of Muslims throughout the world 
He attacked the enemies of Islam through his writings, sayings, actions, etc  He did everything in his capacity to challenge the enemies of Islam  No person in his presence could say or do anything against Shariah  No person could speak against that which was the truth  It is stated by one of Mufti-e-Azam-e-Hind (radi Allahu anhu's) Khaadim's, who accompanied him on a journey by train, that there were some people in the train who were consuming alcohol  When Mufti-e-Azam-e-Hind (radi Allahu anhu) saw them, he reprimanded them and told them to desist from such a Haraam act  They did not listen to his advise so he scolded the leader of the group who was a young and well-built person  He gave the young person a hard slap which caused the bottle of alcohol to fall far from his hand  The Khaadim expected the person to retaliate but, who had the nerve to retaliate against this Lion of Islam! They became afraid and sat down quietly  Later some of them came up to Mufti-e-Azam-e-Hind (radi Allahu anhu) and begged for forgiveness for their shameful behavior 
"Tassawuf, Philsafa, Tafseer ki fiqhi Masa'il, Subhi kahte hai ke Aqida Kusha he Mufti Azam"
Mufti-e-Azam-e-Hind, Moulana Mustapha Raza Khan (radi Allahu anhu), who after writing his first Fatawa while still a student at "Darul Uloom Manzare Islam", was given the status of Mufti due to his immense knowledge  When the Muslim World began to see his knowledge and Fatawas brightenening the world, they began calling him "Mufti-e-Azam" or The Most Exalted Mufti of the Time  This title alone became the name he was recognised by  Whenever the name "Mufti Azam Hind" was mentioned, it referred to none other than his exalted personality 
Remember that he or she only is exalted who has been blessed with this excellence by Almighty Allah and His Beloved Rasool (sallal laahu alaihi wasallam)  Mufti-e-Azam-e-Hind, Moulana Mustapha Raza Khan (radi Allahu anhu) was a personality free from pride, lavishness and self- fame  His status was bestowed upon him by Almighty Allah and His Beloved Rasool (sallal laahu alaihi wasallam)  That person to whom Almighty Allah and His Rasool (sallal laahu alaihi wasallam) grants such excellence, then such excellence cannot be understood by ordinary mortals  This is one of the reasons why the entire world was brightened and received the benefits of his knowledge of Fiqh 
There came a stage when Mufti-e-Azam-e-Hind (radi Allahu anhu) was not only known as "Mufti-e-Azam-e-Hind" but he was also known as "Mufti-e-Azam-e-Alam" or The Grand Mufti of the World 
It is recorded that on his trip to the Haramain Sharifain the Ulema of the Hejaz (Arabia), Syria, Egypt, Iraq, and from many other countries came to him to solve Fiqh Mas'alas  Many became his Mureeds  This is how his Faiz of Shariah and Tariqah spread its rays throughout the world  While in the Hejaz Shareef, he also had to deal with many Fatawas that poured in from various countries, such as, Africa, Mauritius, United Kingdom, America, Sri Lanka, Pakistan, Malaysia, Bangladesh, and many other places  He answered every single one of them in a very dedicated and professional manner 
During the reign of General Ayub Khan a "Rooyat Hilal Committee" was formed in Pakistan for the purpose of sighting the moon for every Islamic Month, and more importantly, for Eid-ul-Fitr and Eid-ul-Adha  An aeroplane was flown up to a certain height and the moon would be sighted from there  This form of Shahaadah (Confirmation) of the sighting of the moon via an aeroplane was readily accepted by the Pakistani Government  In this manner, Eid was celebrated 
On a specific occasion, on the 29th of Ramadaan, an aero plane was flown from the East to the West of Pakistan and the moon was reported to be sighted  This sighting was announced by the Hilaal Committee, but the Sunni Ulema of Pakistan did not accept this confirmation  The Ulema of Pakistan sent questionnaires to the Ulema throughout the world for clarification and one such questionnaire was sent to Mufti-e-Azam-e-Hind (radi Allahu anhu)  Many Ulema replied that the confirmation had to be accepted and that it was permissible, but Mufti-e-Azam-e-Hind (radi Allahu anhu) clearly replied that this was not permissible  His Fatawa read as follows:" The Command of Shariah is to sight the Moon and fast or celebrate Eid  Where the Moon is not sighted the Qazi should give an Islamic decision in connection with a confirmation  The moon must be sighted from the ground level or any place attached to the ground  With regards to the matter of using the plane - to sight the moon via a plane is wrong because the moon sets and does not perish  This is why it is sometimes sighted on the 29th and sometimes on the 30th  If to fly in a plane to sight the moon is a condition, then by increasing altitude the moon will be sighted even on the 27th and 28th  In this case, will the sighting be confirmed for the 27th or 28th? No person in his right sense will accept this  Thus under these circumstances, how would it be proper to sight the moon on the 29th?"
This Fatawa of Mufti-e-Azam-e-Hind, Moulana Mustapha Raza Khan (radi Allahu anhu) appeared in every newspaper in Pakistan as "Headline News" 
The following month, on the 27th and the 28th, the Pakistan Government sent an aeroplane at a higher altitude and found that the moon was visible on these days  The Government of Pakistan then accepted the Fatawa of Mufti-e-Azam-e-Hind (radi Allahu anhu) and the Hilaal Committee of Pakistan was disbanded 
Mufti-e-Azam-e-Hind (radi Allahu anhu) wrote more or less 50 000 Fatawas in his lifetime  His word was accepted by great Ulema  Shamsul Ulema, Hazrat Maulana Shamsud'deen Ja'fari (radi Allahu anhu) stated: "In this era, there is no greater expert in Fiqha than Huzoor Mufti-e-Azam-e-Hind (radi Allahu anhu)  Whenever I present myself in his high court I always sit with my head bowed and I listen to his words in silence  I do not have the audacity to talk in abundance to him "
"Amaanat Hind-o-Paak he is baat ke Shaahid, Ke badal deti he minto me Huqumat Mufti-e-Azam"
The year 1976 was a very difficult period for the Muslims in India  Certain Ulema, bought of by the Saudi Riyals and American Dollars, passed the Fatawa making Vasectomy (male sterilization to prevent birth of children) permissible  The Indian Government made Vasectomy necessary for every male in India at that time 
Muslims of India were in search of a Saviour to prevent such a law from being passed as this would mean them not having any more children  They were looking for someone who would stand and fight for their religious rights  All the Muslims looked towards the city of Bareilly Shareef, the city of light and truth, for an answer to this controversy  All of a sudden that Mujahhid of Islam rose with the torch of knowledge and light against the winds of enmity and destruction - Mufti-e-Azam-e-Hind (radi Allahu anhu)  He immediately issued the true Fatawa on vasectomy and said, "Vasectomy is Haraam, Haraam, Haraam " This news spread throughout India  Through the Dua and firmness of Mufti-e-Azam-e-Hind (radi Allahu anhu) on this issue, the Government that wished to pass this law had lost power, and a new government came into power  The law on Vasectomy was abolished!
Once, Maulana Abdul Hadi Al Qaderi and Soofi Iqbal Sahib asked Ghousul Waqt, Mufti-e-Azam-e-Hind (radi Allahu anhu) the following question: "Huzoor! Can one remember his Sheikh in Namaaz?" Mufti-e-Azam-e-Hind (radi Allahu anhu) answered by saying, "If you need to remember anyone in Namaaz then you should remember Tajedare Do Aalam, Habbibe Khuda (sallal laahu alaihi wasallam)  Yes, just as people tend to gaze here and there in Namaaz - if, in this way, the thought of one's Peer comes into the mind, then there is no hindrance"  Subhan-Allah! Such caution is in this answer! This answer has also contradicted the Deobandi belief  By looking at the life of Mufti-e-Azam-e-Hind (radi Allahu anhu) and reading his Fatawas, one would see his status and excellence in the spiritual domain  His spiritual life was according to that of his renowned and distinguished father, Sayyiduna A'la Hazrat (radi Allahu anhu) 
When the Americans were announcing there journey to the moon, a few Ulema were present with Mufti-e-Azam-e-Hind, Moulana Mustapha Raza Khan (radi Allahu anhu)  Amongst these Ulema were Shamsul Ulema Hazrat Maulana Shamsud'deen and Allamah Ghulam Jilani Mirati (radi Allahu anhum)  They were discussing the concepts concerning the sun and the moon  Mufti-e-Azam-e- Hind (radi Allahu anhu) said that the sky and the earth are both stationary and that the moon and the sun are in motion  On hearing this Allama Ghulam Jilani Mirati (radi Allahu anhu) said, "In the Holy Quran it is said, 'Wash Shamsu Tajri Li Mustaqaril'laha'  In other words, the sun is in motion in its fixed abode  From the word 'Tajri', it is obvious that the sun is in motion and from the word 'Mustaqaril'laha' it is obvious that it is stationary in one place  How can both these concepts be right?"
In answer to this, Mufti-e-Azam-e-Hind, Moulana Mustapha Raza Khan (radi Allahu anhu) immediately said, "It was commanded to Hazrat Adam (alaihis salaam) and Hazrat Hawa (radi Allahu anha) (as follows): 'Walakum fil Ardi Mustaqar'  Does this mean that they were stationary in only one portion of the earth? Did they not walk around (on the earth)? To be Mustaqar means to be stationary in your surrounding, not to come out of your boundaries  To move but to move within your boundaries of movement " On hearing this Allama Mirati Sahib (radi Allahu anhu) became silent 
Hazrat Muhaddith-e-Azam-e-Hind (radi Allahu anhu) said: "IN THIS TIME, THAT PERSONALITY WHOSE TAQWA (PIETY) IS MORE THAN HIS FATAWA, IS NONE OTHER THAN THE SON OF SAYYIDI A'LA HAZRAT (RADI ALLAHU ANHU) WHOSE BEAUTIFUL NAME IS MUSTAPHA RAZA AND THIS NAME COMES ON MY TONGUE WITHOUT PROBLEM AND IT ALLOWS ME TO GAIN GREAT BLESSINGS " Once Hazrat Muhaddith-e-Azam (radi Allahu anhu) wrote the following words on the Fatawa of Mufti-e-Azam-e-Hind (radi Allahu anhu): "THIS IS THE SAYING OF SUCH AN AALIM WHOM TO FOLLOW IS COMPULSORY "
Huzoor Sayyidi Hafiz-e-Millat (radi Allahu anhu) stated, "A PERSON DOES NOT GET PROPER RESPECT AND ACCEPTANCE IN HIS OWN TOWN, BUT THE ACCEPTANCE AND RESPECT THAT HUZOOR MUFTI AZAM HAS GAINED IN HIS TOWN CANNOT BE FOUND ANYWHERE ELSE  THIS IS OPEN PROOF OF HIS KARAMAAT AND WILAYAT"  He then said, "MUFTI AZAM IS A KING, HE IS A KING"  (Which means that he should be respected and treated as a King) 
Huzoor Mujjahid-e-Millat (radi Allahu anhu) said, "IN THIS TIME, THE PERSONALITY OF HUZOOR MUFTI AZM HIND (RADI ALLAHU ANHU) IS A UNIQUE ONE, ESPECIALLY IN THE FIELD OF IFTA, BUT ALSO IN HIS DAILY CONVERSATIONS - THE MANNER IN WHICH HE SPOKE AND EXPLAINED CAN BE UNDERSTOOD BY ONLY THE PEOPLE OF KNOWLEDGE "
The "Imam Ghazzali" of his time, Allama Saeed Ahmad Kazmi Shah Sahib (radi Allahu anhu) says, "THE STATUS OF SAYYIDI MUFTI AZAM HIND (RADI ALLAHU ANHU) CAN BE UNDERSTOOD FROM THIS THAT HE IS THE SON AND THE BELOVED OF MUJJADIDE DEEN-O-MILLAT, IMAM AHLE SUNNAT, ASH SHAH IMAM AHMAD RAZA KHAN (RADI ALLAHU ANHU) "
Hazrat Qari Maslihud'deen (radi Allahu anhu) says, "AFTER THE WISAAL OF MY MURSHAD, THE CENTRAL POINT OF MY FOCUS WAS THE PERSONALITY OF HUZOOR MUFTI AZAM HIND (RADI ALLAHU ANHU) AND NOT ONLYWAS HE THE POINT OF MY FOCUS, BUT ALSO THAT OF THE ENTIRE SUNNI POPULATION "
One of the greatest Karamats of a Mo'min is for him to be always steadfast on Shariat-e-Mustapha and Sunnat-e-Mustapha (sallal laahu alaihi wasallam)  A Mo'min must be prepared to accept all the difficulties and calamities of life  When faced by any calamity he should always make Shukr to Allah Almighty 
These outstanding qualities can be found in the life of Mufti-e-Azam-e-Hind (radi Allahu anhu)  He was always steadfast and firm on Shariat-e-Mustapha (sallal laahu alaihi wasallam)  It is said that it is impossible to move a mountain from its place but it was not possible to move Mufti-e-Azam-e-Hind (radi Allahu anhu) from the Shariat-e-Mustapha (sallal laahu alaihi wasallam)  Every second in the life of Mufti-e-Azam-e-Hind (radi Allahu anhu) was a Karaamat  Volumes can be written about the Karaamats of Mufti-e-Azam-e-Hind (radi Allahu anhu)  He himself is a living Karaamat!
"Kaha tak Raaz likhoge karaamat Mufti-e-Azam, Sarapa hi Sarapa he karaamat Mufti-e-Azam"
For the purpose of Fuyooz-o-barkaat we will quote one such Karaamat 
Once Hazrat went for the Urs of Hazrat Mahboob-e-Ilahi, Kwaja Nizaamud'deen Awliyah (radi Allahu anhu) to Delhi  He stayed at a place called 'Koocha Jilan' with Ashfaaq Ahmad Sahib  At this place, a certain Wahabi Maulvi began arguing with Hazrat concerning the Ilme Ghaib (Knowledge of the Unseen) of Huzoor Anwar (sallal laahu alaihi wasallam)  Ashfaaq Ahmad Sahib asked Hazrat not to argue with this person as it would not make any difference to him  Hazrat said, "Let him speak  I will listen to him and all those who are present should also listen attentively  The reason why nothing makes a difference to Maulvi Sahib is because nobody listens to him properly  So let him say that which he wishes " Maulvi Saeedud'deen then spoke for approximately 15 minutes explaining how Rasoolullah (sallal laahu alaihi wasallam) did not possess Ilme Ghaib  He spoke for some time and then became silent 
Hazrat then said, "If you have forgotten anything concerning your argument then please try to remember " The Maulvi Sahib spent another half an hour trying to prove that Huzoor (sallal laahu alaihi wasallam) did not possess Ilme Ghaib 
After listening to his arguments Hazrat said, "You should immediately repent from your false belief  Allah has definitely blessed Huzoor (sallal laahu alaihi wasallam) with Ilme Ghaib and you have tried to contradict it in every way you could  If you do not mind, then also listen to my argument" 
Then very sarcastically Hazrat said, "What is the responsibility of a son towards his widowed mother?" Maulvi Sahib in answer said, "I will not answer this as it is not relevant to the topic of discussion" 
Hazrat then said, "I did not mind when you questioned me, but in any case just listen to my questions  There is no need to answer them" 
The second question Hazrat asked was, "How is it to take a loan from someone and then hide from him? Can you become weary of your crippled son and leave him to beg? To make Hajj Badal from    "
This question was not yet completed when the Wahabi Maulvi fell at the feet of Mufti-e-Azam-e-Hind (radi Allahu anhu) and said, "Hazrat! It is enough  The problem has been solved  Today I have realised that Huzoor (sallal laahu alaihi wasallam) has Ilme Ghaib  If not by now the Munaafiqeen would have destroyed the Islamic Missions  If Almighty Allah has shown you those things about me which nobody else here knows about, then I cannot imagine all that which He has informed Rasoolullah (sallal laahu alaihi wasallam) of" 
The Wahabi Maulvi immediately repented and became Mureed of Mufti-e-Azam-e-Hind (radi Allahu anhu) 
Each year, Mufti-e-Azam-e-Hind (radi Allahu anhu) used to go to Calcutta for missionary work  The Pope used to also visit Calcutta and although he received good coverage in the media, very few Christians turned up to meet the Pope  The Christians of Calcutta became very jealous whenever Mufti-e-Azam-e-Hind (radi Allahu anhu) visited that city as, without any news coverage, he attracted thousands of people who came to see him 
The Christians decided to insult Huzoor Mufti-e-Azam-e-Hind (radi Allahu anhu) and lower his personality in the eyes of the people  They trained three Christians to approach Huzoor Mufti-e-Azam-e-Hind (radi Allahu anhu) with the pretence that they were going to become his Mureeds  This was their plan: Whenever Hazrat was going to make any person his Mureed, he would ask the person to say, "Say that you have given your hand into the hands of Ghous-e-Azam (radi Allahu anhu) " The Christians where then going to say that Hazrat is a liar (Allah forbid) since that was not the hand of Ghous-e-Azam (radi Allahu anhu)!
The three Christians, now disguised as Muslims went to Huzoor Mufti-e-Azam (radi Allahu anhu) with the pretence of becoming his Mureed  When two of the Christians saw Hazrat's noorani face they became afraid of carrying out their plans, but the third Christian, who was very stubborn, decided to carry out the plan 
He sat in front of Huzoor Mufti-e-Azam-e-Hind (radi Allahu anhu) and Hazrat proceeded with making him a Mureed  When Hazrat said, "Say that you have given your hand into the hands of Ghous-e-Azam (radi Allahu anhu)," he said, "I am giving my hand in the hand of Mufti-e-Azam " He was implying that Hazrat was asking him to lie when he was made to say a moment ago that he is not going to lie 
Huzoor Mufti-e-Azam-e-Hind (radi Allahu anhu) again commanded him to say, "Say that you have given your hand into the hands of Ghous-e-Azam (radi Allahu anhu) " He again said, "I am giving my hand in the hand of Mufti-e-Azam "
Huzoor Mufti-e-Azam-e-Hind (radi Allahu anhu) came into a Jalaal (Spiritual Anger) state and said, "Say that you are giving your hands into the hands of Ghous-e-Azam (radi Allahu anhu) " To the surprise of many, the Christian began continuously saying, "I have given my hands into the hands of Ghous-e-Azam, I have my given hands into the hands of Ghous-e-Azam (radi Allahu anhu)       "
When asked about his behavior, the Christian said that as Huzoor Mufti-Azam-e-Hind (radi Allahu anhu) commanded him for the final time to say that he has given his hands into the hands of Ghous-e-Azam (radi Allahu anhu), he actually saw two bright hands emerging from Hazrat's hands and the Christian says that he is sure that these hands were none other the mubarak hands of Ghous-e-Azam (radi Allahu anhu) 
That Christian then asked Huzoor Mufti-e-Azam-e-Hind (radi Allahu anhu) for forgiveness and explained to him what his true intentions were  He immediately accepted Islam and became a Mureed  The news of this Karaamat spread far and wide and thousands of Christians accepted Islam at Hazrat's hands  Subhan-Allah! This incident was narrated by Hazrat Moulana Abdul Hamid Palmer Noori Razvi, a close Khalifa of Huzoor Mufti-e-Azam-e-Hind (radi Allahu anhu) 
Huzoor Sayyidi Sarkaar Mufti-e-Azam-e-Hind (radi Allahu anhu's) Mazaar Shareef is situated in Mohalla Saudagran, Bareilly Shareef  Every year thousands of Mureeds and lovers of Huzoor Mufti-e-Azam-e-Hind (radi Allahu anhu) present themselves at Bareilly Shareef for his Urs Mubaarak 
Mufti-e-Azam-e-Hind (radi Allahu anhu's) Mureedeen were not only ordinary people but his Mureeds also consisted of great Ulema, Muftis, Mufassirs, Poets, Philosophers, Professors, Doctors, etc  It is said that he has millions of Mureedeen 
In India - Mufas'sire Azam Hind Hazrat Ibrahim Raza (radi Allahu anhu); Hazrat Maulana Tahseen Raza Khan; Hazrat Maulana Rehan Raza Khan (radi Allahu anhu); Hazrat Allamah Mufti Mohammed Akhtar Raza Khan Azhari; Muhadithe Kabeer Hazrat Maulana Mufti Zia Ul Mustapaha Sahib; Hazrat Maulana Arshadul Qaadri Sahib 
His Eminence, Shaikh Mufti Mohammad Akhtar Raza Khan Azhari Al-Qaderi, was born on the 25th of Safar in the year 1942 in Bareilly, the citadel of spirituality and learning  He is the great grandson of A'la Hazrat, Shaikh Imam Ahmed Raza Fazil-e Barelvi (rahmatullahi alaih), the Mujaddid (Reviver) of Islam in the 14th Century Hijri 
Under the tutorship of renowned Ulama, he attained the degree of Fazile Deeniyat (Graduation in Islamic Theology) from Darul Uloom Manzare Islam, Bareilly  After spending three years (1963 - 1966) at the Al Azhar University in Cairo, Egypt, his Eminence post-graduated in Arabic Literature and Deeniyat with specialization in Ahadith (Prophetic Tradition) and Tafseer (Quranic Exegesis) with high distinctions 
On his return home, he joined Darul Uloom Manzare Islam, Bareilly Shareef  Thereafter, he left the Darul Uloom and established his own Darul-Ifta with the permission of his maternal grandfather, Huzoor Mufti-e-Azam Hind, Shaikh Mufti Muhammad Mustapha Raza Khan (rahmatullahi alaih)  His Eminence, Mufti-e-Azam Hind (rahmatullahi alaih) declared him his Ja'Nashin (Successor) while the great Shaikh was present in this world 
His Eminence inherited the skill in the issuing of Fatawa (Legal Islamic Rulings) and in tackling the complex issues relating to Fiqh (Islamic Jurisprudence) directly from Mufti-e-Azam (radi Allahu anhu) who inherited it directly from Mujaddid-e-Deen-o-Millat, Ash Shah Imam Ahmed Raza Bareilvi (rahmatullahi alaih) 
He is not only the Successor and a trustworthy custodian of Fatawa writing of Shaikh Mufti-e-Azam Hind (rahmatullahi alaih), but also the custodian of learning, knowledge, sanctity and saintliness, of his grandfather, Hujjatul Islam, Moulana Muhammad Haamid Raza Khan (rahmatullahi alaihi) 
His father, Moulana Muhammad Ibrahim Raza Khan Jilaani Mia (rahmatullahi alaih), was a great Aalim and Saint  He was well-versed in the commentary of the Holy Quran and so was given the title of Mufassir-e-Azam-e-Hind or Great Commentator of the Holy Quran in India 
His Eminence, Mufti Akhtar Raza Khan Azhari, travels extensively propagating the Deen and is a world-renowned preacher and a spiritual guide  Thousands of Muslims in India and abroad are attached with his Silsila  His Eminence has many Khulafa  He was also given the title of Taajush Shari'ah 
Besides being a great Mufti and Aalim, he is also a poet and an academic writer  His Diwan (Collection of Poems) was published for the first time entitled Naghmat-e-Akhtar  Later, it was published entitled Safina-e-Bakhshish in 1986, a chrono-grammical name, derived by Dr  Abdun Naim Azizi  Safina-e-Bakhshish includes Mufti Akhtar Raza Khan's Urdu and Arabic poems and was compiled and published by Dr  Abdun Naim Azizi  Many of Allama Mohammad Akhtar Raza's Naaths and Manqabats have not been published as yet 
Amongst his academic works, a few are as follows: (1) Taswiron Ka Hukm, (2) T V  aur Video ka Operation, (3) Difae Kanzul Imaan, (4) Sharhe-Hadise Niyat, (5) Al-Haqqul Mobeen (Arabic), (6) Difa Kanzul Imaan Part I & II (7) Mer-atun-Najdi'ah (Arabic) (8) Hazrat Ibrahim ke Waalid Tariq ya Azar, etc 
His Darul-Ifta is now the central Darul Ifta of not only Bareilly Shareef, but of the Sunni world and he has continued the prestige of Fatawa writing of his grand-father and great grand-father  To date, he has written more than 5 000 Fatawa Besides being well-versed in Arabic, Persian, and Urdu he has also a good knowledge of English  He has written many Fatawa in the English Language  The original book, Few English Fatawa, was first published by Edara Sunni Duniya, 82 Saudagran, Bareilly Shareef by his Eminence  Allama Mufti Naseem Ashraf Habibi, who is the Head Advisor and Mufti of the Imam Ahmed Raza Academy and of Sunni Ulama Council included a few more unpublished Fatawas, which was also written or orally dictated in English by Hazrat Azhari Sahib 
May Almighty Allah keep Hazrat Allama Mufti Mohammad Akhtar Raza Khan Azhari firm on Maslak-e-A'la Hazrat and serve as a beacon of guidance  May He grant his Eminence good health and long life  Aameen 
Context 3: South Dakota v  Wayfair, Inc  - Harvard Law Review
Fourth Circuit Invalidates Maryland Statute Regulating Price Gouging in the Sale of Generic Drugs 
South Dakota Supreme Court Holds Unconstitutional State Law Requiring Internet Retailers Without In-State Physical Presence to Remit Sales Tax 
Judicial junk, the Court has long thought, is easier to scrap when the erroneous precedent cannot be fixed by Congress, as in constitutional cases 1× 1  See Burnet v  Coronado Oil & Gas Co , 285 U S  393, 405–10 (1932) (Brandeis, J , dissenting); Lee Epstein, William M  Landes & Adam Liptak, The Decision to Depart (or Not) from Constitutional Precedent: An Empirical Study of the Roberts Court, 90 N Y U  L  Rev  1115, 1116 (2015) (“[Justice Brandeis’s] dissenting opinion       now has the status of black letter law ”)  On the flip side, whenever a bad precedent can be corrected by Congress, stare decisis applies with “special force ”2× 2  See Patterson v  McLean Credit Union, 491 U S  164, 172–73 (1989)  The Court, following Justice Brandeis, usually articulates the rule as distinguishing between “constitutional” and “statutory” precedents  See, e g , id  But the distinction is occasionally said to be between “constitutional” and “nonconstitutional cases ” See, e g , Glidden Co  v  Zdanok, 370 U S  530, 543 (1962) (plurality opinion)  Nomenclature aside, the Court has — until now — adhered to Justice Brandeis’s key insight that the important factor is whether or not the mistake may be legislatively corrected  Last Term, in South Dakota v  Wayfair, Inc ,3× 3  138 S  Ct  2080 (2018)  the Court tinkered with this thinking in overruling an outdated dormant commerce clause precedent  Dormant commerce clause decisions technically produce constitutional holdings, but Congress may override them at will 4× 4  See Prudential Ins  Co  v  Benjamin, 328 U S  408, 421–27 (1946)  Under the usual logic of stare decisis, it should take special force to dislodge such precedents  But Wayfair applied the weakened stare decisis of constitutional cases, asserting that the Court must “address a false constitutional premise         whether or not Congress can or will act ”5× 5  Wayfair, 138 S  Ct  at 2096–97 
Emerging from Wayfair is an odd and ominous development in stare decisis doctrine  Odd, because it turns on a formal classification instead of on Congress’s practical ability to fix the problem  Ominous, because the Court’s logic leads far past the dormant commerce clause  Wayfair grants only feeble stare decisis to precedents that set a “constitutional default rule,”6× 6  Id  at 2096 (“While       Congress has the authority to change the physical presence rule, Congress cannot change the constitutional default rule ”)  meaning constitutional decisions that allow for legislative adjustment or override  This new stare decisis analysis makes other precedents setting constitutional default rules more vulnerable — including, perhaps, mainstays of criminal procedure like Miranda v  Arizona7× 7  384 U S  436 (1966)  and Mapp v  Ohio 8× 8  367 U S  643 (1961) 
Since its 1967 decision in National Bellas Hess, Inc  v  Department of Revenue,9× 9  386 U S  753 (1967)  the Court has held that, under the “dormant” or “negative” implication of the Commerce Clause,10× 10  The dormant or negative commerce clause is a judicial derivation from the Commerce Clause “prohibiting States from discriminating against or imposing excessive burdens on interstate commerce without congressional approval,” which “strikes at one of the chief evils that led to the adoption of the Constitution, namely, state tariffs and other laws that burdened interstate commerce ” Comptroller of the Treasury of Md  v  Wynne, 135 S  Ct  1787, 1794 (2015)  states may not compel remote sellers with no physical presence in the state to collect and remit sales taxes 11× 11  See Bellas Hess, 386 U S  at 759–60  In Quill Corp  v  North Dakota,12× 12  504 U S  298 (1992)  the Court refused to overrule the “bright-line, physical-presence requirement” of Bellas Hess, leaning heavily on stare decisis 13× 13  Id  at 317–18  Three Justices joined a concurrence explaining that their decision rested solely “on the basis of stare decisis ” Id  at 320 (Scalia, J , concurring in part and concurring in the judgment)  So the physical presence test remained the law of the land while the internet conquered the earth  Justice Kennedy had joined the Quill majority and Justice Scalia’s concurring opinion emphasizing stare decisis, but by 2015 he had second thoughts  Writing separately in Direct Marketing Ass’n v  Brohl,14× 14  135 S  Ct  1124 (2015)  Justice Kennedy acknowledged that “[t]he Internet has caused far-reaching systemic and structural changes in the economy” and therefore “Quill now harms States to a degree far greater than could have been anticipated earlier ”15× 15  Id  at 1135 (Kennedy, J , concurring)  He concluded with the wish that “[t]he legal system should find an appropriate case for this Court to reexamine Quill and Bellas Hess ”16× 16  Id 
Seldom has a concurring opinion signed by a lone Justice prompted a state to officially declare an emergency  Yet in 2016, in response to Justice Kennedy’s overture, the South Dakota legislature passed a law, S B  106, “to provide for the collection of sales taxes from certain remote sellers       and to declare an emergency ”17× 17  2016 S D  Sess  Laws ch  70 pmbl  217 (codified at S D  Codified Laws § 10-64 (2017))  It required every remote seller to collect and remit sales tax if the seller’s business in South Dakota comprised either a “gross revenue” greater than $100,000 or at least 200 “separate transactions” within one calendar year 18× 18  Id  § 1  Significantly, the law did not apply retroactively 19× 19  Id  § 5  The “emergency” declaration was necessary to give the law immediate effect, for the purpose of “permitting the most expeditious possible review of the constitutionality of this law” by the U S  Supreme Court 20× 20  Id  § 8(8)  As Justice Alito put it, the “South Dakota law [was] obviously a test case ”21× 21  Transcript of Oral Argument at 27, Wayfair, 138 S  Ct  2080 (No  17-494), https://www supremecourt gov/oral_arguments/argument_transcripts/2017/17-494_7lho pdf [https://perma cc/8HYH-VU8N] 
Expeditiously, a group of remote sellers challenged the law  After being sued by South Dakota for refusing to register for the newly required sales tax license, Wayfair, Inc , Overstock com, Inc , and Newegg, Inc  moved for summary judgment in South Dakota circuit court on the grounds that S B  106 was unconstitutional under Quill and Bellas Hess — a point South Dakota conceded, indicating that it was seeking review by the U S  Supreme Court to overturn Quill 22× 22  State v  Wayfair Inc , 2017 SD 56, ¶¶ 9–11, 901 N W 2d 754, 759–60  Accordingly, the South Dakota circuit court granted the motion for summary judgment and South Dakota appealed to the state’s highest court 23× 23  Id  ¶ 12, 901 N W 2d at 760  The South Dakota Supreme Court unanimously affirmed, recognizing that South Dakota’s “arguments on the merits” may be “persuasive” but “Quill remains the controlling precedent ”24× 24  Id  ¶ 18, 901 N W 2d at 761  See generally Recent Case, State v  Wayfair Inc , 2017 SD 56, 901 N W 2d 754 (S D  2017), 131 Harv  L  Rev  2089 (2018) 
The U S  Supreme Court vacated and remanded 25× 25  Wayfair, 138 S  Ct  at 2100  Writing for the Court one last time, Justice Kennedy26× 26  Justices Thomas, Ginsburg, Alito, and Gorsuch joined Justice Kennedy’s opinion  pilloried Quill’s physical presence rule as “arbitrary, formalistic,” “anachronistic,” and “unfair and unjust” to both states and brick-and-mortar retailers 27× 27  Wayfair, 138 S  Ct  at 2092, 2095  After all, the rationale of Quill was that remote sellers lacked a sufficiently “substantial nexus” with the state to justify imposing a duty of tax collection 28× 28  Quill Corp  v  North Dakota, 504 U S  298, 311 (1992) (quoting Complete Auto Transit, Inc  v  Brady, 430 U S  274, 279 (1977))  This was wrong even in the mail-order catalog days of 1967 and 1992, but “the Internet revolution has made [Quill’s] earlier error all the more egregious and harmful ”29× 29  Wayfair, 138 S  Ct  at 2097; see also id  at 2092  The rule deprived the states of billions of dollars, since they could not force remote sellers to collect the tax and consumers hardly ever paid it on their own 30× 30  Id  at 2088 (“[C]onsumer compliance rates are notoriously low ”)  Quill “serve[d] as a judicially created tax shelter” for remote retailers who do a great deal of business online 31× 31  Id  at 2094 
Satisfied that Bellas Hess and Quill were wrongly decided, the Court then jumped the hurdle of stare decisis  The Quill Court had feared upsetting reliance interests 32× 32  Quill, 504 U S  at 317 (“Bellas Hess       has engendered substantial reliance and has become part of the basic framework of a sizable industry ”)  Wayfair shrugged off this concern, noting that “stare decisis accommodates only ‘legitimate reliance interest[s]’”; by contrast, reliance on the physical presence rule was largely due to consumers evading their use-tax obligations 33× 33  Wayfair, 138 S  Ct  at 2098 (alteration in original) (quoting United States v  Ross, 456 U S  798, 824 (1982))  Quill had also appealed to Congress’s ultimate authority over interstate commerce as a reason to abide by a precedent, even if wrongly decided 34× 34  See Quill, 504 U S  at 318–19; id  at 320 (Scalia, J , concurring in part and concurring in the judgment) (“Congress       can change the rule of Bellas Hess by simply saying so ”)  But Wayfair denied that Congress’s ability to change the law was a proper consideration:
While it can be conceded that Congress has the authority to change the physical presence rule, Congress cannot change the constitutional default rule  It is inconsistent with the Court’s proper role to ask Congress to address a false constitutional premise of this Court’s own creation  Courts have acted as the front line of review in this limited sphere; and hence it is important that their principles be accurate and logical, whether or not Congress can or will act in response 35× 35  Wayfair, 138 S  Ct  at 2096–97 
Having dispensed with the physical presence rule, the Court remanded the case to the South Dakota courts to determine in the first instance “whether some other principle in the Court’s Commerce Clause doctrine might invalidate the Act ”36× 36  Id  at 2099  But the Court listed “several features [of South Dakota law] that appear[ed] designed to prevent discrimination against or undue burdens upon interstate commerce ” Id 
Justices Thomas and Gorsuch each filed concurring opinions  Justice Thomas wistfully likened himself to Justice White — who voted for Bellas Hess but against Quill a quarter-century later — and confessed that he “should have joined [Justice White’s dissenting] opinion ”37× 37  Id  at 2100 (Thomas, J , concurring)  Justice Thomas added that the “Court’s entire negative Commerce Clause jurisprudence” is wrong and should be abandoned 38× 38  Id  Justice Gorsuch also wrote separately to express skepticism of the Court’s dormant commerce clause jurisprudence, raising “questions for another day” of whether the doctrine “can be squared with the text of the Commerce Clause, justified by stare decisis, or defended as misbranded products of federalism or antidiscrimination imperatives flowing from Article IV’s Privileges and Immunities Clause ”39× 39  Id  at 2100–01 (Gorsuch, J , concurring) 
Chief Justice Roberts dissented 40× 40  Justices Breyer, Sotomayor, and Kagan joined the Chief Justice’s dissent  Surprisingly, the dissenting Justices “agree[d] that Bellas Hess was wrongly decided, for many of the reasons given by the Court ”41× 41  Wayfair, 138 S  Ct  at 2101 (Roberts, C J , dissenting)  The dispute between the majority and the dissent turned entirely on the principles and application of stare decisis  Chief Justice Roberts argued that whether or how to reverse Quill should be left to Congress, which “has the flexibility to address these questions in a wide variety of ways” and “can focus directly on current policy concerns rather than past legal mistakes ”42× 42  Id  at 2104  He also pointed to the “baffling” burdens of compliance with the idiosyncratic tax codes of “[o]ver 10,000 jurisdictions,” particularly for small businesses, and doubted that new “software” — the majority’s proposed solution to this mess43× 43  Id  at 2098 (majority opinion) (“Eventually, software that is available at a reasonable cost may make it easier for small businesses to cope with these problems ”)  — would soon solve the problem 44× 44  Id  at 2103–04 (Roberts, C J , dissenting)  In Bellas Hess, the Court reasoned that the dormant commerce clause protects interstate business from being “entangle[d]       in a virtual welter of complicated obligations to local jurisdictions ” Nat’l Bellas Hess, Inc  v  Dep’t of Revenue, 386 U S  753, 759–60 (1967)  The dissent replied that the Court “vastly underestimate[d] the skill of contemporary man and his machines ” Id  at 766 (Fortas, J , dissenting)  The dispute in Wayfair over whether software is up to the task effectively reprised the old debate from Bellas Hess, only this time couched as part of the stare decisis inquiry’s concern for reliance interests rather than as a matter of dormant commerce clause doctrine  While Wayfair acknowledged that “[c]omplex state tax systems could have the effect of discriminating against interstate commerce,” 138 S  Ct  at 2099, the Court remarked that “[t]he physical presence rule is a poor proxy” for an inquiry into any actual burdens imposed on interstate commerce, id  at 2093 
Chief Justice Roberts emphasized that a “heightened form of stare decisis”45× 45  Wayfair, 138 S  Ct  at 2102 (Roberts, C J , dissenting)  applies when “Congress       can, if it wishes, override this Court’s decisions with contrary legislation ”46× 46  Id  at 2101 (first citing Michigan v  Bay Mills Indian Cmty , 134 S  Ct  2024, 2036 (2014) (tribal sovereign immunity); then citing Kimble v  Marvel Entm’t, LLC, 135 S  Ct  2401, 2409 (2015) (statutory interpretation); and then citing Halliburton Co  v  Erica P  John Fund, Inc , 134 S  Ct  2398, 2411 (2014) (judicially created doctrine implementing a judicially created cause of action))  In Quill, the Chief Justice noted, the Court had taken to heart that “Congress may be better qualified” and “has the ultimate power to resolve” the question47× 47  Id  at 2102 (quoting Quill Corp  v  North Dakota, 504 U S  279, 318 (1992))  while Justice Scalia had “recogniz[ed] that stare decisis has ‘special force’ in the dormant Commerce Clause context due to Congress’s ‘final say over regulation of interstate commerce ’”48× 48  Id  (quoting Quill, 504 U S  at 320 (Scalia, J , concurring in part and concurring in the judgment))  Moreover, “[i]f stare decisis applied with special force in Quill, it should be an even greater impediment” afterward since Quill effectively “tossed [the ball] into Congress’s court ”49× 49  Id  (alteration in original) (quoting Kimble, 135 S  Ct  at 2409); cf  Bay Mills, 134 S  Ct  at 2039 n 12 (“When we inform Congress that it has primary responsibility over a sphere of law, and invite Congress to consider a specific issue within that sphere, we cannot deem irrelevant how Congress responds ”)  Because the Court invited Congress to act and then “suddenly chang[ed] the ground rules, the Court may have waylaid Congress’s consideration of the issue ”50× 50  Wayfair, 138 S  Ct  at 2102–03 (Roberts, C J , dissenting) 
In Wayfair, the Court applied the flimsier form of stare decisis to a precedent that could have been overruled by Congress  It did so in the context of a dormant commerce clause case, but Wayfair’s logic extends to all constitutional default rules — that is, constitutional decisions that Congress remains free to change  Not only does Wayfair deviate from the Court’s decades-old stare decisis analysis, it also imperils other precedents that set constitutional default rules 
The Court’s reasoning in Wayfair departs from its prior stare decisis analysis  In 1932, Justice Brandeis posited that stare decisis must bend “in cases involving the Federal Constitution, where correction through legislative action is practically impossible ”51× 51  Burnet v  Coronado Oil & Gas Co , 285 U S  393, 406–07 (1932) (Brandeis, J , dissenting)  The Court has long since adopted his argument,52× 52  See, e g , Smith v  Allwright, 321 U S  649, 665 (1944)  as well as its corollary — that stare decisis commands “special force in the area of statutory interpretation” where “Congress remains free to alter what [the Court has] done ”53× 53  Patterson v  McLean Credit Union, 491 U S  164, 172–73 (1989)  For normative evaluations of heightened stare decisis for statutory precedents, see generally Einer Elhauge, Statutory Default Rules: How to Interpret Unclear Legislation 211–23 (2008); and William N  Eskridge, Jr , Overruling Statutory Precedents, 76 Geo  L J  1361, 1364–1409 (1988)  Justice Brandeis’s logic demands that dormant commerce clause cases, where Congress is free to act, be granted the weightier stare decisis 54× 54  Scholars have noted the curious fact that Justice Brandeis included many dormant commerce clause cases as examples of overruled constitutional precedents  See, e g , Earl M  Maltz, Commentary, Some Thoughts on the Death of Stare Decisis in Constitutional Law, 1980 Wis  L  Rev  467, 468–469, 469 n 11  One explanation for this is that Justice Brandeis sought the authority of Chief Justice Taney’s dictum that the Court’s “opinion upon the construction of the Constitution is always open to discussion” — which referred to the dormant commerce clause  See Burnet, 285 U S  at 408 n 3 (Brandeis, J , dissenting) (quoting The Passenger Cases, 48 U S  (7 How ) 283, 470 (1849) (Taney, C J , dissenting))  In Chief Justice Taney’s time, it was thought that Congress could not override the Court’s dormant commerce clause decisions, see Cooley v  Bd  of Wardens, 53 U S  (12 How ) 299, 321 (1852), so the context of Chief Justice Taney’s dictum does not conflict with Justice Brandeis’s theory of stare decisis  The Court applied this reasoning in Quill, as Chief Justice Roberts underscored 55× 55  Wayfair, 138 S  Ct  at 2102 (Roberts, C J , dissenting) 
Yet the Wayfair majority refused to consider Congress’s authority to legislate as a relevant factor for stare decisis 56× 56  Even Justice Kennedy’s earlier opinion in Direct Marketing contemplated judicially overruling Quill, conspicuously neglecting a possible legislative solution  See supra p  278  The Court even insisted that to do so “is inconsistent with the Court’s proper role,” since Quill embodied “a false constitutional premise of th[e] Court’s own creation ”57× 57  Wayfair, 138 S  Ct  at 2096 (emphasis added)  This refusal breaks from the practical Brandeisian wisdom that has guided the Court’s treatment of precedent for the better part of a century  The point is not that stare decisis should have ultimately propped up Bellas Hess yet again, as Wayfair’s dissenting Justices maintained  After all, a realistic approach that is alert to each branch’s institutional capacities might have led to the conclusion that Congress was actually ill-equipped to overrule Quill  In this vein, the Court could have sensibly pointed out that Congress is unlikely to stick its neck out with a tax hike (or a look-alike) from which only the states would benefit 58× 58  For two practical arguments to this effect, see Brian Galle, Essay, Kill Quill, Keep the Dormant Commerce Clause: History’s Lessons on Congressional Control of State Taxation, 70 Stan  L  Rev  Online 158, 160–62 (2018), https://review law stanford edu/wp-content/uploads/sites/3/2018/03/70-Stan -L -Rev -Online-158-Galle pdf [https://perma cc/22YP-P4V5]; Edward A  Zelinsky, The Political Process Argument for Overruling Quill, 82 Brook  L  Rev  1177, 1191–92 (2017)  Indeed, South Dakota advanced such practical arguments in its brief 59× 59  See Petitioner’s Brief at 54, Wayfair, 138 S  Ct  2080 (No  17-494) (“Congress has little incentive to act here because it would be (or appear to be) authorizing new or greater tax collections from its constituents, while receiving none of the revenue in return ”)  More generally, the Court might have discussed the limits of the states’ influence in the federal system as a reason not to wait for congressional intervention, a topic it has debated on other occasions 60× 60  See Richard H  Pildes, Institutional Formalism and Realism in Constitutional and Public Law, 2013 Sup  Ct  Rev  1, 30–32; see also Galle, supra note 58, at 159 (“Congress is not a trustworthy guardian of state fiscal power, making continuing judicial involvement a more appealing prospect ”)  Or it could have argued that new facts on the ground — namely, the blast of e-commerce that hit like a comet after Quill — overpowered stare decisis of any force, special or plain 61× 61  Two recent studies of stare decisis highlighted the physical presence rule as exemplifying a precedent that may reasonably be overruled due to changed facts  See Bryan A  Garner et al , The Law of Judicial Precedent 364–65 (2016); Randy J  Kozel, Settled Versus Right: A Theory of Precedent 112–13 (2017)  It should be noted that the authors of The Law of Judicial Precedent classify the physical presence rule as a constitutional precedent for stare decisis purposes, thus anticipating the Court’s misstep in Wayfair  Garner et al , supra, at 354–65  Because even statutory precedents may sometimes be overruled,62× 62  See Patterson v  McLean Credit Union, 491 U S  164, 173–74 (1989) (discussing justifications for overruling statutory precedents)  Contra Lawrence C  Marshall, “Let Congress Do It”: The Case for an Absolute Rule of Statutory Stare Decisis, 88 Mich  L  Rev  177 (1989)  the Court could have killed Quill without first planting its constitutional kiss of death 63× 63  Cf  Thomas R  Lee, Stare Decisis in Historical Perspective: From the Founding Era to the Rehnquist Court, 52 Vand  L  Rev  647, 704 (1999) (“Justice Brandeis’       memorable prose has since become a mandatory part of the burial rite for any constitutional precedent ”) 
The Court resisted such arguments  Instead, Wayfair reasoned that Congress’s total ability to correct an erroneous decision counts for nothing when the Court gets the Constitution wrong  That such a theory sprouts from a case like Wayfair, which repudiated a “formalistic distinction,”64× 64  Wayfair, 138 S  Ct  at 2092  is ironic  Wayfair’s stare decisis analysis resorts to the formalism of making constitutional a “magic” word65× 65  See Transcript of Oral Argument, supra note 21, at 12  rather than asking whether Congress can step in 
Moreover, the Court’s new thinking on stare decisis threatens other constitutional default rules  Wayfair now stands for the proposition that a “constitutional default rule” — a term the Court apparently lifted from South Dakota’s reply brief on the merits66× 66  Reply Brief at 22, Wayfair, 138 S  Ct  2080 (No  17-494) (“Congress is polarized, which makes it critical       to get the constitutional default rule right ”)  — gets only weakened stare decisis  To appreciate why this holding matters, it is worth exploring the concept and scope of constitutional default rules  Contract theory describes default rules as legal rules that the parties may “contract around ”67× 67  See, e g , Ian Ayres & Robert Gertner, Filling Gaps in Incomplete Contracts: An Economic Theory of Default Rules, 99 Yale L J  87, 87 (1989)  Although “constitutional default rule” could be read broadly to include a variety of actors and contracting mechanisms,68× 68  See John Ferejohn & Barry Friedman, Toward a Political Theory of Constitutional Default Rules, 33 Fla  St  U  L  Rev  825, 826 (2006) (“When we speak of default rules in constitutional law, we typically are talking about specifications of ways the government can act (or modify its behavior) to get around a constitutional prohibition ”)  the Court’s use of the term for purposes of stare decisis may be narrowly defined as judicial precedents of constitutional law that “are ultimately subject to congressional control ”69× 69  Gillian E  Metzger, Congress, Article IV, and Interstate Relations, 120 Harv  L  Rev  1468, 1525 (2007) (describing judicially enforceable “constitutional default rules imposing obligations on the states in the name of union [that] are ultimately subject to congressional control”)  The dormant commerce clause is a paradigmatic constitutional default rule because what the Court does today Congress may undo tomorrow  Justice Scalia declared this fact “[t]he clearest sign that the negative Commerce Clause is a judicial fraud,” for “[h]ow could congressional consent lift a constitutional prohibition?”70× 70  Comptroller of the Treasury of Md  v  Wynne, 135 S  Ct  1787, 1808 (2015) (Scalia, J , dissenting)  But that’s what a constitutional default rule is  The Court has allowed Congress to overturn its dormant commerce clause cases since 1891 71× 71  See In re Rahrer, 140 U S  545, 560–62 (1891) 
Dormant commerce clause cases are not the only constitutional default rules  Professor Laurence Tribe’s treatise identifies two others 72× 72  1 Laurence H  Tribe, American Constitutional Law § 6-35 (3d ed  2000)  And in a groundbreaking article, Professor Henry Monaghan revealed “a substructure of substantive, procedural, and remedial rules” forming “a constitutional common law subject to amendment, modification, or even reversal by Congress ”73× 73  Henry P  Monaghan, The Supreme Court, 1974 Term — Foreword: Constitutional Common Law, 89 Harv  L  Rev  1, 2–3 (1975); see also Susan R  Klein, Identifying and (Re)Formulating Prophylactic Rules, Safe Harbors, and Incidental Rights in Constitutional Criminal Procedure, 99 Mich  L  Rev  1030 (2001) (further developing Monaghan’s theory in criminal procedure context)  What follows is a list of six lines of cases beyond the dormant commerce clause that may be fairly described as constitutional default rules  The first two are drawn from Tribe’s treatise while the next four are found in Monaghan’s article:
(1) State Taxation of Federal Instrumentalities: States may not tax instrumentalities of the federal government74× 74  McCulloch v  Maryland, 17 U S  (4 Wheat ) 316, 436 (1819)  — unless Congress consents 75× 75  See, e g , Helvering v  Gerhardt, 304 U S  405, 411 n 1 (1938) (“Congress may curtail an immunity which might otherwise be implied or enlarge it beyond the point where, Congress being silent, the Court would set its limits ” (citations omitted))  One court has described such judicial decisions as setting a “constitutional default rule ” United States v  Delaware, 958 F 2d 555, 560 n 9 (3d Cir  1992) (“[W]e must decide the constitutional default rule for this type of tax, fully aware that Congress could decide at any time to reverse our decision statutorily ”)  (2) Article I, Section 10 Cases: Article I, Section 10 provides that certain prohibitions on the states may be waived by Congress 76× 76  See U S  Const  art  I, § 10, cls  2–3  The Court has taken note of this when considering whether to overrule, for instance, an Import-Export Clause precedent 77× 77  See Hooven & Allison Co  v  Evatt, 324 U S  652, 668 (1945) (“In view of the fact that the Constitution gives Congress authority to consent to state taxation of imports and hence to lay down its own test for determining when the immunity ends, we see no convincing practical reason for abandoning the test which has been applied for more than a century        ”), overruled on other grounds by Limbach v  Hooven & Allison Co , 466 U S  353 (1984)  In Michelin Tire Corp  v  Wages, 423 U S  276 (1976), the Court left open the question whether “Congress may authorize, under the Import-Export Clause, an exaction that it could not directly impose under the Tax Clause ” Id  at 301 n 13  Metzger, however, argues that the Import-Export Clause is free of other clauses’ limits on congressional power  See Metzger, supra note 69, at 1500 & n 120  (3) Bivens Cases: In Bivens v  Six Unknown Named Agents of Federal Bureau of Narcotics,78× 78  403 U S  388 (1971)  the Court held that a violation of the Fourth Amendment gives rise to a right to sue for damages 79× 79  Id  at 397  But the Court has also held that “[s]uch a cause of action may be defeated       when       Congress has provided an alternative remedy which it explicitly declared to be a substitute for recovery directly under the Constitution and viewed as equally effective ”80× 80  Carlson v  Green, 446 U S  14, 18–19 (1980)  (4) Miranda Cases: The Miranda Court famously “encourage[d]” Congress and the states to explore alternative “procedures which are at least as effective in apprising accused persons of their right of silence and in assuring a continuous opportunity to exercise it ”81× 81  Miranda v  Arizona, 384 U S  436, 467 (1966)  In Dickerson v  United States, 530 U S  428 (2000), the Court struck down a congressional attempt to effectively abolish Miranda, holding that “Miranda announced a constitutional rule that Congress may not supersede legislatively ” Id  at 444  But Dickerson also stood by Miranda’s “invitation for legislative action” to replace Miranda with an adequate substitute  Id  at 440; see also Michael C  Dorf & Barry Friedman, Shared Constitutional Interpretation, 2000 Sup  Ct  Rev  61 (discussing legislative alternatives to Miranda)  (5) The Police Lineup Case: In United States v  Wade,82× 82  388 U S  218 (1967)  the Court created an exclusionary rule for evidence obtained from a police lineup in violation of the Sixth Amendment right to counsel but acknowledged that it could be replaced by “[l]egislative or other regulations       which eliminate the risks of abuse ”83× 83  Id  at 239  (6) The Exclusionary Rule Cases: Mapp v  Ohio made the Fourth Amendment “exclusionary rule” binding on the states,84× 84  367 U S  643, 655 (1961)  yet Congress is thought to have the power to replace it 85× 85  See Bivens v  Six Unknown Named Agents of Fed  Bureau of Narcotics, 403 U S  388, 422–24 (1971) (Burger, C J , dissenting) (inviting Congress to replace the Fourth Amendment exclusionary rule); Harold J  Krent, How to Move Beyond the Exclusionary Rule: Structuring Judicial Response to Legislative Reform Efforts, 26 Pepp  L  Rev  855, 864–71 (1999) 
All of the above are arguably constitutional default rules set by the Court that remain, to one degree or another, open to congressional revision  The list could be longer or shorter, depending on which default rules the Court will view as constitutional86× 86  A shorter list could be produced by whittling away at the constitutional status of the cases identified by Monaghan  While the Court has held that Miranda is a constitutional decision, Dickerson, 530 U S  at 444, some of the other cases may be viewed as nonconstitutional  See, e g , Collins v  Virginia, 138 S  Ct  1663, 1675–80 (2018) (Thomas, J , concurring) (arguing that Mapp is “nonconstitutional,” id  at 1678 n 5); Richard H  Fallon, Jr  et al , Hart and Wechsler’s The Federal Courts and the Federal System 775–77 (7th ed  2015) (discussing whether Bivens is constitutionally required)  Conversely, a longer list might include any constitutional right that can be waived by a party  See, e g , Daniel A  Farber, Another View of the Quagmire: Unconstitutional Conditions and Contract Theory, 33 Fla  St  U  L  Rev  913, 918 (2006) (describing the Eleventh Amendment as “just a contractual default rule that the states are free to barter away”)  Such a list might also include various constitutionally inspired judicial presumptions  See, e g , Jack Goldsmith & John F  Manning, The President’s Completion Power, 115 Yale L J  2280, 2299 (2006) (describing the Chevron presumption of delegated interpretive power to administrative agencies as “a constitutionally inspired default rule”); Nicholas Quinn Rosenkranz, Federal Rules of Statutory Interpretation, 115 Harv  L  Rev  2085, 2097–98 (2002) (describing clear statement rules as “constitutional default rules” reversible by Congress)  Many other decisions could likely be characterized as constitutional default rules; the list above is only an initial stab  and on how it will answer open questions about congressional authority over certain constitutional provisions 87× 87  See, e g , Thomas v  Wash  Gas Light Co , 448 U S  261, 272 n 18 (1980) (plurality opinion) (leaving unresolved whether Congress may limit constitutional full faith and credit obligations); White v  Mass  Council of Constr  Emp’rs, Inc , 460 U S  204, 215 n 1 (1983) (Blackmun, J , concurring in part and dissenting in part) (leaving unresolved “whether Congress may authorize       what otherwise would be a violation” of the Privileges and Immunities Clause); 1 Tribe, supra note 72, § 6-35, at 1243–44 (arguing that Congress cannot override judicial constructions of the Privileges and Immunities Clause); Metzger, supra note 69, at 1486–89 (arguing the opposite)  But the takeaway is clear: weaker stare decisis for constitutional default rules  Pre-Wayfair, one would have thought that stare decisis applies with special force to such precedents, given congressional power to set them straight  Not anymore  Why? Because it is improper to “ask Congress to address a false constitutional premise of th[e] Court’s own creation ”88× 88  Wayfair, 138 S  Ct  at 2096  The Latin for Wayfair’s doctrine is not stare decisis, which should reflect a realistic, working relationship between the legislative and judicial branches  It is mea culpa 
In its zeal to update the Constitution for “the Cyber Age,”89× 89  Id  at 2097  the Court deleted Congress from stare decisis doctrine in constitutional cases  The Court had better options  It could have left Quill on Congress’s doorstep, as the dissent argued  Or it could have justified overruling Quill notwithstanding the special force of stare decisis  Instead, the Court reasoned that it doesn’t matter whether Congress is willing and able to do the job: a constitutional mess calls for a judicial clean-up crew  For constitutional default rules — a category of decisions embracing the dormant commerce clause and sweeping far beyond — Wayfair’s new theory of stare decisis makes the Court’s precedents less sticky and Congress less relevant 



ground_truth: The three subsets are V+, V0, and V-, determined by the Kullback-Leibler information distance.

prompt_front: Now, answer the following question based on the text below, only give me the answer and do not output any other words.

Question: Which orders did Mufti-e-Azam-e-Hind receive Khilafat from?

Read the following text and answer briefly.

Context 4: Sir Simon William English  (born 30 December 1961) is a New Zealand former National Party politician who served as the 39th prime minister of New Zealand from 2016 to 2017  He had previously served as the 17th deputy prime minister of New Zealand and minister of finance from 2008 to 2016 under John Key and the Fifth National Government 

A farmer and public servant before entering politics, English was elected to the New Zealand Parliament in  as the National Party's candidate in the Wallace electorate  He was elevated to Cabinet in 1996 and in 1999 was made minister of finance, although he served for less than a year due to his party's loss at the 1999 general election  In October 2001, English replaced Jenny Shipley as the leader of the National Party (and consequently as Leader of the Opposition)  He led the party to its worst defeat at the 2002 general election, and as a consequence, in October 2003 he was replaced as leader by Don Brash 

In November 2006, after Brash's resignation, English became deputy leader under John Key  After National's victory at the 2008 general election, he became deputy prime minister and was also made minister of finance for the second time  Under English's direction New Zealand's economy maintained steady growth during National's three terms of government  He became a list-only MP after stepping down as an electorate MP at the 2014 general election 

John Key resigned as leader of the National Party and prime minister in December 2016  English won the resulting leadership election unopposed and was sworn in as prime minister on 12 December 2016  His tenure was only ten months, and included a three-month election campaign  In the 2017 general election, National won the largest number of seats but fell short of a majority  The parties holding the balance of power declined to support the existing government, and English was subsequently replaced as prime minister by Jacinda Ardern, leader of the Labour Party  English initially continued on as Leader of the Opposition, but resigned as leader of the National Party on 27 February 2018 and left parliament two weeks later 

Early life
English was born on 30 December 1961 at Lumsden Maternity Centre in Lumsden  He is the eleventh of twelve children of Mervyn English and Norah (née O'Brien) English  His parents purchased Rosedale, a mixed sheep and cropping farm in Dipton, Southland from Mervyn's uncle, Vincent English, a bachelor, in 1944  English was born in the maternity unit at Lumsden 

English attended St Thomas's School in Winton, then boarded at St  Patrick's College in Upper Hutt, where he became head boy  He played in the first XV of the school's rugby team  English went on to study commerce at the University of Otago, where he was a resident at Selwyn College, and then completed an honours degree in English literature at Victoria University of Wellington 

After finishing his studies, English returned to Dipton and farmed for a few years  From 1987 to 1989, he worked in Wellington as a policy analyst for the New Zealand Treasury, at a time when the free market policies favoured by Labour's finance minister Roger Douglas (known collectively as "Rogernomics") were being implemented 

English joined the National Party in 1980, while at Victoria University  He served for a period as chairman of the Southland branch of the Young Nationals, and became a member of the Wallace electorate committee  After moving to Wellington, he served for periods on the Island Bay and Miramar electorate committees, respectively 

Fourth National Government (1990–1999)

At the 1990 general election, English stood as the National candidate in Wallace, replacing the retiring Derek Angus, and was elected with a large majority  He would hold this seat, renamed Clutha-Southland in 1996, until 2014  He and three other newly elected National MPs (Tony Ryall, Nick Smith, and Roger Sowry) were soon identified as rising stars in New Zealand politics, and at various points were dubbed the "brat pack", the "gang of four", and the "young Turks"  In his first term in parliament, English chaired a select committee into social services  He was made a parliamentary under-secretary in 1993, serving under the Minister of Health 

First period in cabinet (1996–1999)
In early 1996, English was elevated to cabinet by Prime Minister Jim Bolger, becoming the Minister for Crown Health Enterprises and Associate Minister of Education (to Wyatt Creech)  He was 34 at the time, becoming the cabinet's youngest member  After the 1996 general election, the National Party was forced into a coalition with New Zealand First to retain government  In the resulting cabinet reshuffle, English emerged as Minister of Health  However, as a condition of the coalition agreement, NZ First's Neil Kirton (a first-term MP) was made Associate Minister of Health, effectively becoming English's deputy  This arrangement was described in the press as a "shotgun marriage", and there were frequent differences of opinion between the two ministers  After their relationship became unworkable, Kirton was sacked from the role in August 1997, with the agreement of NZ First leader Winston Peters 

As Minister of Health, English was responsible for continuing the reforms to the public health system that National had begun after the 1990 general election  The reforms were unpopular, and health was perceived as one of the government's weaknesses, with the health portfolio consequently being viewed as a challenge  English believed that the unpopularity of the reforms was in part due to a failure in messaging, and encouraged his National colleagues to avoid bureaucratic and money-focused language (such as references to "balance sheets" and "user charges") and instead talk about the improvements to services the government's reforms would bring  He also rejected the idea that public hospitals could be run as commercial enterprises, a view which some of his colleagues had previously promoted 

By early 1997, as dissatisfaction with Bolger's leadership began to grow, English was being touted as a potential successor, along with Jenny Shipley and Doug Graham  His age (35) was viewed as the main impediment to a successful leadership run  National's leadership troubles were resolved in December 1997, when Bolger resigned and Shipley was elected to the leadership unopposed  English had been a supporter of Bolger as leader, but Shipley reappointed him Minister of Health in her new cabinet 

English was promoted to Minister of Finance in a reshuffle in January 1999, a position which was at the time subordinate to the Treasurer, Bill Birch  After a few months, the pair switched positions as part of Birch's transition to retirement, with English assuming the senior portfolio  In early interviews, he emphasised his wish to be seen as a pragmatist rather than an ideologue, and said that the initiatives of some of his predecessors (Roger Douglas's "Rogernomics" and Ruth Richardson's "Ruthanasia") had focused on "fruitless, theoretical debates" when "people just want to see problems solved" 

Opposition (1999–2008)

After the National Party lost the 1999 election to Helen Clark's Labour Party, English continued on in the shadow cabinet as National's spokesperson for finance  He was elected deputy leader of the party in February 2001, following the resignation of Wyatt Creech, with Gerry Brownlee being his unsuccessful opponent 

Leader of the Opposition
In October 2001, after months of speculation, Jenny Shipley resigned as leader of the National Party after being told she no longer had the support of the party caucus  English was elected as her replacement unopposed (with Roger Sowry as his deputy), and consequently became Leader of the Opposition  However, he did not openly organise against Shipley, and according to The Southland Times "there was almost an element of 'aw, shucks, I'll do it then' about Mr English's ascension" 

Aged 39 when he was elected, English became the second-youngest leader in the National Party's history, after Jim McLay (who was 38 when elected in 1984)  He also became only the third Southlander to lead a major New Zealand political party, after Joseph Ward and Adam Hamilton  However, English failed to improve the party's performance  In the 2002 election, National suffered its worst electoral defeat ever, gaining barely more than twenty percent of the vote  English described it as "the worst day of my political life"  Both party insiders and the general public were split as to how much to blame him for the loss, but most of the party believed that English would be able to rebuild National's support 

By late 2003, however, National's performance in opinion polls remained poor  The party had briefly increased its popularity in the year following the election, but by October its support had fallen to levels only slightly better than what it achieved in the last ballot  English also appeared in a boxing match for a charity against entertainer Ted Clarke  This did not boost his polling or that of the National party either, with suggestions that it devalued his image as a serious politician  Don Brash, former governor of the Reserve Bank and a relative newcomer to politics, began to build up support to replace English  On 28 October, Brash gained sufficient backing in Caucus to defeat English in a leadership contest 

Shadow cabinet roles and deputy leader
On 2 November 2003, when Brash changed responsibilities for certain MPs, English became National's spokesman for education, ranked at fifth place in the party's parliamentary hierarchy  He remained in parliament after the 2005 election  In his new shadow education portfolio, English performed strongly, and remained a party favourite despite his election defeat as leader in 2002, eventually being returned to the finance portfolio in August 2004 as deputy spokesman (while still retaining responsibility for education) 

In November 2006, Brash resigned as leader  English was considered as a potential replacement leader (running against John Key) or deputy leader (against incumbent Gerry Brownlee) in the ensuing leadership election  However, a contest was avoided when the MPs agreed a Key/English ticket would run unopposed in a display of party unity  English took over the deputy leadership and the finance portfolio in the Key shadow cabinet 

Fifth National Government (2008–2017)

Deputy Prime Minister and Minister of Finance (2008–2016)

At the 2008 election, English was re-elected by his electorate, winning by a margin of about 15,500 votes  He became Deputy Prime Minister of New Zealand and Minister of Finance in the fifth National Government, being sworn into office on 19 November 2008 and continued to serve in those roles until becoming Prime Minister on 12 December 2014  He was also made Minister of Infrastructure in National's first term of government and Minister responsible for Housing New Zealand Corporation and minister responsible for the New Zealand flag consideration process in its third 

He was comfortably re-elected in Clutha-Southland in the 2011 election but opted to run as a party-list candidate in 2014  

The pairing of John Key as leader of the National Party and English as his deputy has been compared to that of Bob Hawke and Paul Keating (in Australia) and Tony Blair and Gordon Brown (in the UK)



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Question: What did Justice Kennedy argue about Quill in Direct Marketing Ass'n v. Brohl?

Read the following text and answer briefly.

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English acceded to the role of Finance Minister in the continuing wake of the financial crisis  In response to New Zealand's rising debt, English made budget deficit-reduction his main priority  His first budget outlined three focuses in New Zealand's financial recovery: "improving the business environment and removing roadblocks to growth; investment in productive infrastructure; and improving the way government works"  One of his first acts was creating the National Infrastructure Unit, charged with formulating a plan for infrastructure projects and investments  He commissioned a government-wide spending review, with an aim to reducing government expenditure—with the exceptions of a two-year stimulus package and long-term increases on infrastructure spending 

In April 2011, the Opposition criticised English for suggesting that New Zealand businesses could use New Zealand's low wages to help it compete with Australia  The National Government campaigned for re-election in 2011 on its economic record  The Government boasted growth for five consecutive quarters up to mid-2010, totalling 1 6% of real GDP 

Strong growth resulted in a surplus of $473 million for the 2015/16 financial year, projected to rise to $8 5 billion by 2020/21  In his 2016 Economic and Fiscal Update address, English stated that reducing debt and tackling the costs of the 2016 Kaikōura earthquake were higher priorities than reducing rates of tax 

Allowances issue
In 2009, the media, including TVNZ and TV3 revealed that English was receiving about NZ$900 a week as part of a living allowance for ministers, to live in his own NZ$1 2 million Wellington home  At the time, English also received $276,200 in his annual salary as Deputy Prime Minister  It was also revealed other ministers with homes in the capital city were also claiming accommodation allowances  On 3 August 2009, Prime Minister John Key started a review of the housing allowances claimed by cabinet ministers  English subsequently paid back $12,000 and only claimed about $24,000 a year in living allowances  The Auditor-General's office said in September 2009 that they were making "preliminary enquiries" into parliamentary housing expenses in response to a letter of complaint from Progressive party leader Jim Anderton  Two days later English stated that he would no longer take up any housing allowance and had paid back all the allowance he had received since the November 2008 election 

Prime Minister (2016–2017)

John Key resigned on 12 December, and endorsed English as his successor in the resulting leadership election  Following the drop-out of both Judith Collins and Jonathan Coleman from the leadership election, English was sworn in as the 39th Prime Minister of New Zealand on 12 December 2016 

English appointed his first cabinet on 18 December  In a reshuffle, he appointed Steven Joyce to succeed him as Finance Minister, while most ministerial portfolios remained the same 

In February 2017, English did not attend Waitangi Day commemorations at the historic treaty grounds, reportedly in response to the Ngāpuhi iwi's decision to stop the Prime Minister from speaking at the marae  Ngāpuhi have protested the Government's negotiation of the Trans Pacific Partnership Agreement (TPPA), which the iwi believe infringes upon Māori sovereignty, and thus does not adhere to the Treaty of Waitangi  English had been invited to attend in an official capacity; his non-attendance was criticised by a Ngāpuhi elder and Opposition leader Andrew Little 

In his first overseas trip as Prime Minister, English travelled to Europe to discuss trade ties, including a prospective New Zealand–European Union free trade agreement  He first travelled to London on 13 January 2017 to meet British Prime Minister Theresa May  Discussing trade relations, English said the two nations were "natural partners" and would "continue to forge ties" after the UK's withdrawal from the EU  He also arranged to meet with London Mayor Sadiq Khan, Belgian Prime Minister Charles Michel and German Chancellor Angela Merkel   In a meeting with Merkel, English received crucial backing from Germany for a trade deal with the EU  On 16 January, English stated that his government would continue to promote TPPA, despite the United States' decision to withdraw from the agreement  He explained that Southeast Asian countries would now be treated as a priority in negotiations—he also asserted that the United States was ceding influence to China by its rejection of the trade pact 

At a press conference at the Beehive on 1 February 2017, English announced that the 2017 general election would be held on 23 September  The Prime Minister later confirmed that his party would approach ACT, United Future and the Māori Party if confidence and supply agreements were required to form a government following the election  In his second cabinet reshuffle on 24 April, English appointed Gerry Brownlee as his new Foreign Affairs Minister; he also promoted Nikki Kaye to the portfolio of Education Minister, and moved Mark Mitchell into the cabinet to become Defence Minister  The reshuffle was perceived as an election preparation 

On 13 February 2017, English welcomed Australian Prime Minister Malcolm Turnbull to Wellington  The two leaders reaffirmed their shared trade agenda, and discussed changes to the Australian citizenship pathway which will affect permanent residents originating from New Zealand 

On 19 June, it was reported that Todd Barclay, who succeeded English as MP for Clutha-Southland, had clandestinely recorded one of his employee's conversations the previous year, and that John Key's leaders' budget was used to pay a confidential settlement after the employee resigned  English admitted that he had been aware of the illegal recording and the settlement, and thus implicated in the scandal 

During the 2017 National campaign launch, English introduced a $379 million social investment package including digital learning academies for high school students, more resources for mathematics, and boosting support for teaching second languages in schools, and maintaining National Standards in the school curriculum  Prime Minister English also sought to defend National's financial management and economic track record and claimed that the opposition Labour Party would raise taxes  Early opinion polling had forecast a poor showing in the election for the Labour Party, but in early August 37-year-old Jacinda Ardern took over as Labour leader and seemingly energised younger voters 

At the 2017 general election, National won the largest share of the party vote (44 4%) and the largest number of seats (56) in the House Representatives  However, National lacked enough seats to govern alone due to two of the party's support partners, the Māori Party and United Future, losing their parliamentary seats  In response, English stated that the party would be entering into talks to form a coalition with New Zealand First  Following talks with the two largest parties, New Zealand First entered a coalition arrangement with the Labour Party  English was succeeded as prime minister by Jacinda Ardern on 26 October 

Opposition (2017–2018)

Leader of the Opposition
English was re-elected as National Party leader on 24 October 2017  At the time of his re-election, English announced his intention to stay on as leader until the next general election  On 13 February 2018, however, he stood down as National Party leader due to personal reasons, and instructed the party to put into motion the processes to elect a new leader  He also retired from Parliament  English's resignation followed weeks of speculation that he would step aside for a new leader  On 27 February, he was succeeded as party leader by Simon Bridges as the result of the leadership election held that day 

Post-premiership 
In 2018, English joined the board of Australian conglomerate, Wesfarmers  English serves in Chairmanships of Mount Cook Alpine Salmon, Impact Lab Ltd and Manawanui Support Ltd  He is also a director of The Instillery, Centre for Independent Studies and The Todd Corporation Limited, and is a member of the Impact Advisory Group of Macquarie Infrastructure and Real Assets 

Political and social views

English is regarded as more socially conservative than his predecessor, John Key  He has stated his opposition to voluntary euthanasia and physician-assisted suicide, same-sex civil unions, and the decriminalisation of prostitution  As Prime Minister he opposed any "liberalisation" of abortion law 

In 2004, English voted against a bill to establish civil unions for both same-sex and opposite-sex couples  In 2005, he voted for the Marriage (Gender Clarification) Amendment Bill, which would have amended the Marriage Act to define marriage as only between a man and a woman  English voted against the Marriage (Definition of Marriage) Amendment Bill, a bill that legalised same-sex marriage in New Zealand  However, in December 2016 he stated, "I'd probably vote differently now on the gay marriage issue  I don't think that gay marriage is a threat to anyone else's marriage" 

In 2009, English voted against the Misuse of Drugs (Medicinal Cannabis) Amendment Bill, a bill aimed at amending the Misuse of Drugs Act so that cannabis could be used for medical purposes 

Personal life 
English met his future wife, Mary Scanlon, at university  She was studying medicine at the time, and became a general practitioner  Both her parents were immigrants, her father being Samoan and her mother Italian, born on the island of Stromboli  They have six children: a daughter and five sons 

English is a practising Roman Catholic, but has stated that he considers his religious beliefs personal and thus separate from politics 

In June 2002, English took part in TV3's Fight For Life, a celebrity boxing fundraiser to raise money for the Yellow Ribbon anti-youth-suicide campaign, influenced by the death of a teenage nephew in 1997  He lost a split decision to former university colleague Ted Clarke 

Honours
In the 2018 Queen's Birthday Honours, English was appointed a Knight Companion of the New Zealand Order of Merit, for services of over 27 years to the State 

See also

List of New Zealand governments
Politics of New Zealand

References

External links

Profile at National Party 
Profile on Parliament nz
Releases and speeches at Beehive govt nz

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1961 births
21st-century New Zealand politicians
Candidates in the 2017 New Zealand general election
Deputy Prime Ministers of New Zealand
Leaders of the Opposition (New Zealand)
Living people
Members of the Cabinet of New Zealand
Members of the New Zealand House of Representatives
New Zealand farmers
New Zealand finance ministers
New Zealand list MPs
New Zealand MPs for South Island electorates
New Zealand National Party MPs
New Zealand National Party leaders
New Zealand Roman Catholics
New Zealand people of Irish descent
People educated at St  Patrick's College, Silverstream
People from Dipton, New Zealand
People from Lumsden, New Zealand
Prime Ministers of New Zealand
University of Otago alumni
Victoria University of Wellington alumni
Knights Companion of the New Zealand Order of Merit
New Zealand politicians awarded knighthoods



ground_truth: Quill harmed states more than anticipated due to the Internet.