In the realm of taxation, the South African Revenue Service has the power to set aside (or alter) certain transactions to curb impermissible tax avoidance or to give effect to the substance of a transaction over its form. Equally, in the insolvency realm, the Insolvency Act 24 of 1936 provides for certain instances where a transaction can be set aside if it falls within the ambit of impeachable dispositions. In this note, we consider the intersection between insolvency and tax avoidance with specific reference to the overlap between voidable preferences and impermissible tax avoidance arrangements, on the one hand, and substance over form and dispositions not made for value, on the other hand. This analysis highlights the significance of the timeline of events. We argue that SARS would only be able to benefit from both the avoidance mechanism and the setting side of the impeachable disposition when the tax avoidance remedy precedes the sequestration or liquidation order and the subsequent setting aside of the impeachable disposition.
{"title":"Notes: The intersection between insolvency and tax avoidance","authors":"T. Legwaila, C. Fritz","doi":"10.47348/salj/v139/i4a2","DOIUrl":"https://doi.org/10.47348/salj/v139/i4a2","url":null,"abstract":"In the realm of taxation, the South African Revenue Service has the power to set aside (or alter) certain transactions to curb impermissible tax avoidance or to give effect to the substance of a transaction over its form. Equally, in the insolvency realm, the Insolvency Act 24 of 1936 provides for certain instances where a transaction can be set aside if it falls within the ambit of impeachable dispositions. In this note, we consider the intersection between insolvency and tax avoidance with specific reference to the overlap between voidable preferences and impermissible tax avoidance arrangements, on the one hand, and substance over form and dispositions not made for value, on the other hand. This analysis highlights the significance of the timeline of events. We argue that SARS would only be able to benefit from both the avoidance mechanism and the setting side of the impeachable disposition when the tax avoidance remedy precedes the sequestration or liquidation order and the subsequent setting aside of the impeachable disposition.","PeriodicalId":39313,"journal":{"name":"South African law journal","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2022-01-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"70822938","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
In Wilsnach NO v TM 2021 (3) SA 568 (GP) the court radically reinterpreted the meaning of the term ‘parent’ for the purposes of intestate succession, thereby excluding an unmarried father from inheriting from his deceased child as a ‘parent’, and permitting the child’s grandmother to inherit as if she were the child’s ‘parent’. The court achieved this outcome by finding that the provisions of the Children’s Act 38 of 2005 must inform our understanding of who a ‘parent’ is for the purposes of the Intestate Succession Act 81 of 1987. The note critically evaluates this judgment in the light of the historical development of the rules of intestate succession and the history of the legislation, identifies problematic issues arising from the judgment, and suggests an alternative way in which the father’s perceived unsuitability as an heir may have been achieved.
在Wilsnach NO v TM 2021 (3) SA 568 (GP)一案中，法院为了无遗嘱继承的目的，从根本上重新解释了“父母”一词的含义，从而排除了未婚父亲以“父母”的身份继承其已故子女的遗产，并允许孩子的祖母以“父母”的身份继承。法院通过裁定2005年第38号《儿童法》的规定必须告知我们对1987年第81号《无遗嘱继承法》中“父母”是谁的理解，从而实现了这一结果。该说明根据无遗嘱继承规则的历史发展和立法的历史，对这一判决进行了批判性的评价，确定了该判决产生的问题，并提出了一种替代方法，即父亲被认为不适合作为继承人可能已经实现。
{"title":"Notes: Who is a ‘parent’ for the purposes of the Intestate Succession Act? Wilsnach NO v TM","authors":"M. Wood-Bodley","doi":"10.47348/salj/v139/i4a3","DOIUrl":"https://doi.org/10.47348/salj/v139/i4a3","url":null,"abstract":"In Wilsnach NO v TM 2021 (3) SA 568 (GP) the court radically reinterpreted the meaning of the term ‘parent’ for the purposes of intestate succession, thereby excluding an unmarried father from inheriting from his deceased child as a ‘parent’, and permitting the child’s grandmother to inherit as if she were the child’s ‘parent’. The court achieved this outcome by finding that the provisions of the Children’s Act 38 of 2005 must inform our understanding of who a ‘parent’ is for the purposes of the Intestate Succession Act 81 of 1987. The note critically evaluates this judgment in the light of the historical development of the rules of intestate succession and the history of the legislation, identifies problematic issues arising from the judgment, and suggests an alternative way in which the father’s perceived unsuitability as an heir may have been achieved.","PeriodicalId":39313,"journal":{"name":"South African law journal","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2022-01-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"70822987","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Some debate exists as to whether convicting an accused of both participating in and managing a criminal enterprise under chap 2 of the Prevention of Organised Crime Act 121 of 1998 constitutes an impermissible duplication of convictions. This note analyses the relevant provisions of the Act, and the concept of duplication of convictions, against two conflicting Supreme Court of Appeal judgments, namely S v Prinsloo 2016 (2) SACR 25 (SCA) and S v Tiry 2021 (1) SACR 349 (SCA). In these two cases the court reached diametrically opposite conclusions on the same legal question, creating uncertainty. Ultimately, the question whether a duplication of convictions has occurred depends on the facts of each case, and the extent to which managers-cum-participants have ‘dirtied their hands’ in the pursuit of the criminal enterprise. Foreign perspectives from United States constitutional jurisprudence will also be considered.
{"title":"Notes: Managing and participating in a criminal enterprise under POCA: Duplication of convictions? A discussion of the conflict between S v Prinsloo and S v Tiry","authors":"Delano Cole Van der Linde","doi":"10.47348/salj/v139/i3a3","DOIUrl":"https://doi.org/10.47348/salj/v139/i3a3","url":null,"abstract":"Some debate exists as to whether convicting an accused of both participating in and managing a criminal enterprise under chap 2 of the Prevention of Organised Crime Act 121 of 1998 constitutes an impermissible duplication of convictions. This note analyses the relevant provisions of the Act, and the concept of duplication of convictions, against two conflicting Supreme Court of Appeal judgments, namely S v Prinsloo 2016 (2) SACR 25 (SCA) and S v Tiry 2021 (1) SACR 349 (SCA). In these two cases the court reached diametrically opposite conclusions on the same legal question, creating uncertainty. Ultimately, the question whether a duplication of convictions has occurred depends on the facts of each case, and the extent to which managers-cum-participants have ‘dirtied their hands’ in the pursuit of the criminal enterprise. Foreign perspectives from United States constitutional jurisprudence will also be considered.","PeriodicalId":39313,"journal":{"name":"South African law journal","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2022-01-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"70823217","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
This note critically analyses the judgment in Miller v Natmed Defence (Pty) Ltd 2022 (2) SA 554 (GJ), in which the court ruled on the validity of the removal of a director by the company’s sole shareholder. Three issues were in contention: whether a shareholder must furnish the director with reasons for the proposed resolution to remove a director from office under s 71 of the Companies Act 71 of 2008; whether a shorter notice period for the shareholders’ meeting was legally acceptable; and whether the meeting that was held telephonically was valid. The court ruled that the director’s removal from office was valid and dismissed his request to be reinstated as a director. This note critically analyses the judgment and argues that the court misinterpreted some aspects of s 71 of the Act.
本文批判性地分析了Miller v Natmed Defence (Pty) Ltd 2022 (2) SA 554 (GJ)一案的判决，在该案中，法院裁定了公司唯一股东罢免董事的有效性。有三个问题存在争议:股东是否必须向董事提供根据2008年《公司法》第71条提出的罢免董事的决议的理由;缩短股东会通知期限是否在法律上可以接受;以及电话会议是否有效。法院裁定该董事的免职是有效的，并驳回了他重新担任董事的请求。本说明批判性地分析了判决，并认为法院误解了该法第71条的某些方面。
{"title":"Notes: Confusion in the removal of directors by shareholders under the Companies Act 71 of 2008: Miller v Natmed Defence (Pty) Ltd","authors":"Rehana Cassim","doi":"10.47348/salj/v139/i4a1","DOIUrl":"https://doi.org/10.47348/salj/v139/i4a1","url":null,"abstract":"This note critically analyses the judgment in Miller v Natmed Defence (Pty) Ltd 2022 (2) SA 554 (GJ), in which the court ruled on the validity of the removal of a director by the company’s sole shareholder. Three issues were in contention: whether a shareholder must furnish the director with reasons for the proposed resolution to remove a director from office under s 71 of the Companies Act 71 of 2008; whether a shorter notice period for the shareholders’ meeting was legally acceptable; and whether the meeting that was held telephonically was valid. The court ruled that the director’s removal from office was valid and dismissed his request to be reinstated as a director. This note critically analyses the judgment and argues that the court misinterpreted some aspects of s 71 of the Act.","PeriodicalId":39313,"journal":{"name":"South African law journal","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2022-01-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"70823322","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Whilst corporate political donations and expenditure is legally permissible in South Africa, and whilst some companies may be making such donations and incurring such expenditure for valid reasons, corporate political donations and expenditure is frequently associated with secrecy and poor corporate governance practices within companies. One strategy that some corporate-law jurisdictions have adopted to regulate corporate political donations and expenditure is to require company boards to disclose relevant information about such donations and expenditure directly to their shareholders. However, South African law currently does not require companies to disclose their political donations or expenditure directly to the shareholders, either in the annual financial statements, or in the directors’ report that must be included in the annual financial statements, or in the annual report. Following an examination of key policy considerations relevant to the disclosure of corporate political donations and expenditure to shareholders, and an examination of the legislative approach in the UK, the article argues for the effective disclosure of corporate political donations and expenditure to shareholders under the Companies Act 71 of 2008. It then makes detailed recommendations on how such disclosure requirements could be introduced and implemented in South Africa.
{"title":"Disclosure of corporate political donations and expenditure to shareholders: Why South Africa should follow the United Kingdom’s legislative approach","authors":"Vela Madlela","doi":"10.47348/salj/v139/i1a4","DOIUrl":"https://doi.org/10.47348/salj/v139/i1a4","url":null,"abstract":"Whilst corporate political donations and expenditure is legally permissible in South Africa, and whilst some companies may be making such donations and incurring such expenditure for valid reasons, corporate political donations and expenditure is frequently associated with secrecy and poor corporate governance practices within companies. One strategy that some corporate-law jurisdictions have adopted to regulate corporate political donations and expenditure is to require company boards to disclose relevant information about such donations and expenditure directly to their shareholders. However, South African law currently does not require companies to disclose their political donations or expenditure directly to the shareholders, either in the annual financial statements, or in the directors’ report that must be included in the annual financial statements, or in the annual report. Following an examination of key policy considerations relevant to the disclosure of corporate political donations and expenditure to shareholders, and an examination of the legislative approach in the UK, the article argues for the effective disclosure of corporate political donations and expenditure to shareholders under the Companies Act 71 of 2008. It then makes detailed recommendations on how such disclosure requirements could be introduced and implemented in South Africa.","PeriodicalId":39313,"journal":{"name":"South African law journal","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2022-01-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"70821940","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Patenting activity regarding new CRISPR (Clustered Regularly Interspaced Short Palindromic Repeats) genome editing technology has mushroomed to create a vast and complex patent landscape. However, because of South Africa’s current depository patent system, the South African CRISPR patent landscape contains foundational patents with overlapping claims, as highlighted by the ongoing litigation in the United States between the Broad Institute and the University of California. Both these parties were granted four patents in South Africa. Also, the South African landscape may contain multiple low-quality patents that have the potential to obstruct scientific research in South Africa. The solution in the South African context is threefold, but requires that the Intellectual Property Policy of South Africa: Phase I must first be operationalised to: (a) prioritise CRISPR patent applications for formal examination and substantive search and examination; (b) provide sufficient resources for extracurial patent opposition proceedings regarding all CRISPR patent applications and granted patents; and (c) create certainty by developing an obviousness standard with well-defined parameters. Although CRISPR is not yet advanced enough to fall within the class of life-saving technologies in the short-term, CRISPR may become critical in the treatment and eradication of priority diseases such as HIV/AIDS and tuberculosis. Accordingly, prioritising CRISPR-related patent applications serves the public interest in access to healthcare. By using (a), (b) and (c) in tandem, a triple layer of mechanisms will counter the problems of overlapping claims and of lowquality patents, and hence remove these potential obstructions to CRISPR research in South Africa.
关于CRISPR (Clustered Regularly Interspaced Short Palindromic Repeats)基因组编辑技术的专利活动如雨后春笋般涌现，创造了一个庞大而复杂的专利景观。然而，由于南非目前的存托专利制度，南非的CRISPR专利格局包含了重叠权利要求的基础专利，这一点在美国布罗德研究所和加州大学之间正在进行的诉讼中得到了突出体现。这两家公司都在南非获得了四项专利。此外，南非的环境可能包含多个低质量的专利，这些专利有可能阻碍南非的科学研究。南非的解决方案有三个方面，但需要南非的知识产权政策:第一阶段必须首先实施:(a)优先考虑CRISPR专利申请的正式审查和实质性检索和审查;(b)为所有CRISPR专利申请和授权专利的课外专利异议程序提供足够的资源;(c)通过制定具有良好定义参数的明显标准来创造确定性。虽然CRISPR技术还不够先进，在短期内还不足以成为挽救生命的技术，但CRISPR可能在治疗和根除艾滋病毒/艾滋病和结核病等重点疾病方面发挥关键作用。因此，优先考虑crispr相关的专利申请符合公众获得医疗保健的利益。通过串联使用(a)、(b)和(c)，一个三层机制将解决重叠权利要求和低质量专利的问题，从而消除在南非进行CRISPR研究的这些潜在障碍。
{"title":"Clearing the CRISPR patent landscape: Towards a solution for South Africa","authors":"M. Naidoo, D. Thaldar","doi":"10.47348/salj/v139/i2a6","DOIUrl":"https://doi.org/10.47348/salj/v139/i2a6","url":null,"abstract":"Patenting activity regarding new CRISPR (Clustered Regularly Interspaced Short Palindromic Repeats) genome editing technology has mushroomed to create a vast and complex patent landscape. However, because of South Africa’s current depository patent system, the South African CRISPR patent landscape contains foundational patents with overlapping claims, as highlighted by the ongoing litigation in the United States between the Broad Institute and the University of California. Both these parties were granted four patents in South Africa. Also, the South African landscape may contain multiple low-quality patents that have the potential to obstruct scientific research in South Africa. The solution in the South African context is threefold, but requires that the Intellectual Property Policy of South Africa: Phase I must first be operationalised to: (a) prioritise CRISPR patent applications for formal examination and substantive search and examination; (b) provide sufficient resources for extracurial patent opposition proceedings regarding all CRISPR patent applications and granted patents; and (c) create certainty by developing an obviousness standard with well-defined parameters. Although CRISPR is not yet advanced enough to fall within the class of life-saving technologies in the short-term, CRISPR may become critical in the treatment and eradication of priority diseases such as HIV/AIDS and tuberculosis. Accordingly, prioritising CRISPR-related patent applications serves the public interest in access to healthcare. By using (a), (b) and (c) in tandem, a triple layer of mechanisms will counter the problems of overlapping claims and of lowquality patents, and hence remove these potential obstructions to CRISPR research in South Africa.","PeriodicalId":39313,"journal":{"name":"South African law journal","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2022-01-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"70822561","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
In the scholarship on rights, one name is pre-eminent: Hohfeld. Despite this, there are two ways in which the Hohfeldian analysis of rights remains underappreciated. The first is that it is commonly assumed that the Hohfeldian analytic system applies only to private-law rights. The second is that South African lawyers remain mostly unfamiliar with the Hohfeldian analytic system. By providing a Hohfeldian analysis of the South African Bill of Rights, this article aims to set the record straight in both respects.
{"title":"A Hohfeldian analysis of the Bill of Rights","authors":"Q. du Plessis","doi":"10.47348/salj/v139/i3a5","DOIUrl":"https://doi.org/10.47348/salj/v139/i3a5","url":null,"abstract":"In the scholarship on rights, one name is pre-eminent: Hohfeld. Despite this, there are two ways in which the Hohfeldian analysis of rights remains underappreciated. The first is that it is commonly assumed that the Hohfeldian analytic system applies only to private-law rights. The second is that South African lawyers remain mostly unfamiliar with the Hohfeldian analytic system. By providing a Hohfeldian analysis of the South African Bill of Rights, this article aims to set the record straight in both respects.","PeriodicalId":39313,"journal":{"name":"South African law journal","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2022-01-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"70822880","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Animal welfare legislation in South Africa is deficient, especially in relation to farm animals reared for ingestion by human beings. That being so, this article analyses aspects of public international law, administrative law, constitutional law and interpretation of statutes that may contribute towards affording more legal protection to such animals. An overview of recent case law highlights that the Constitutional Court has mandated a shift away from the traditional laissez-faire legal attitude to human use of animals towards one that requires enhanced protection of their interests. To that end, extensive legislative reform is necessary to rectify the deficiencies of the present system.
{"title":"‘Miserable, laborious, and short’: The lives of animals","authors":"D. M. Pretorius","doi":"10.47348/salj/v139/i4a4","DOIUrl":"https://doi.org/10.47348/salj/v139/i4a4","url":null,"abstract":"Animal welfare legislation in South Africa is deficient, especially in relation to farm animals reared for ingestion by human beings. That being so, this article analyses aspects of public international law, administrative law, constitutional law and interpretation of statutes that may contribute towards affording more legal protection to such animals. An overview of recent case law highlights that the Constitutional Court has mandated a shift away from the traditional laissez-faire legal attitude to human use of animals towards one that requires enhanced protection of their interests. To that end, extensive legislative reform is necessary to rectify the deficiencies of the present system.","PeriodicalId":39313,"journal":{"name":"South African law journal","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2022-01-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"70823030","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
This article critically considers the legality of hyperlinking to copyright-protected material on the Internet. It considers the position with respect to standard hyperlinks, and attempts to provide a possible approach in light of the proposed introduction of two new exclusive rights, namely (i) the right of communication to the public; and (ii) the making-available right. These new exclusive rights appear to be an attempt to amend the South African Copyright Act in order to give effect to the 1996 WIPO Copyright Treaty, which sought to ‘digitise’ copyright law in light of the digital technology that had developed. The WIPO Copyright Treaty supplements, in particular, the rights granted to copyright owners under the Berne Convention, extending the right of communication to the public to include the making-available right. Use will be made of the case law of the Court of Justice of the European Union, which has given effect to the right of communication to the public (including the making-available right), following its inclusion in the WIPO Copyright Treaty of 1996. Through a more focused analysis of these exclusive rights, it is intended that this article can provide some guidance to South African lawyers and our courts when considering the application and scope of these exclusive rights.
{"title":"Hyperlinking and copyright","authors":"S. Karjiker","doi":"10.47348/salj/v139/i1a6","DOIUrl":"https://doi.org/10.47348/salj/v139/i1a6","url":null,"abstract":"This article critically considers the legality of hyperlinking to copyright-protected material on the Internet. It considers the position with respect to standard hyperlinks, and attempts to provide a possible approach in light of the proposed introduction of two new exclusive rights, namely (i) the right of communication to the public; and (ii) the making-available right. These new exclusive rights appear to be an attempt to amend the South African Copyright Act in order to give effect to the 1996 WIPO Copyright Treaty, which sought to ‘digitise’ copyright law in light of the digital technology that had developed. The WIPO Copyright Treaty supplements, in particular, the rights granted to copyright owners under the Berne Convention, extending the right of communication to the public to include the making-available right. Use will be made of the case law of the Court of Justice of the European Union, which has given effect to the right of communication to the public (including the making-available right), following its inclusion in the WIPO Copyright Treaty of 1996. Through a more focused analysis of these exclusive rights, it is intended that this article can provide some guidance to South African lawyers and our courts when considering the application and scope of these exclusive rights.","PeriodicalId":39313,"journal":{"name":"South African law journal","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2022-01-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"70821986","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
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