Jurisprudence on Death Penalty: A Case Study of Justice Asif Saeed Khan Khosa’s Judgments

1. INTRODUCTION

The phrase “capital punishment”, literally meaning “punishment of the head”, is derived from the Latin word capitalis, from caput (head). It is a kind of punishment that leads to the death of the convict and is granted to an offender of a heinous offence by a competent court of law upon conviction of the heinous offence (Hood, 1998). It is also commonly referred to as the death penalty. In contemporary discourse, it is believed that the death sentence violates a person’s fundamental right to life (Turley, 2009).

Following the 1992 Geneva Convention, the United Nations Economic and Social Council (ECOSOC) also worked to safeguard the right to life of those on death row. The council committed to protecting the rights of such individuals and declared that none of its members would carry out executions, even in cases involving the vilest of crimes (United Nations, 1997). In 1997, the UN High Commission for Human Rights passed a resolution (E/CN.4/1997/60/Add.1) asserting that abolition of capital punishment enhances human dignity and protection of human rights.

This major shift took place with the idea that “states have no right to execute their citizens” (Bae, 2007). The trend became a global movement with the Rome Statute of the International Criminal Court. It became an obligation on states to abolish such punishments through legislation and practices. While approximately 70 percent of countries have either legally abolished or ceased the practice of the death penalty, Pakistan remains an exception. The death penalty has not been abolished by Pakistan, but it did impose a moratorium on executions in 2008. After the tragic event at the APS (Army Public School), the government of Pakistan withdrew the moratorium after 7–8 years. After six months of the removal of the moratorium, executions of convicted persons increased dramatically, and Pakistan became the third country with the highest ratio of executions (United Nations, 2015). The Human Rights Commission urged at that time that such executions would not create deterrence but rather compromise the basic rights of citizens and potentially fuel further violence and extremism. Consequently, it urged the government to revive the moratorium (United Nations, 2015).

Over the course of the past half-decade, the highest court in the land has developed a sophisticated legal doctrine via a multitude of verdicts, effectively reducing the range of applicability of capital punishment. A comprehensive investigation carried out by the Reprieve Foundation (2019) examined 310 judgments on capital punishment pronounced between 2010 and 2018. As a result of the analysis, a conclusion was drawn. The examination reveals that the Supreme Court of Pakistan is granting either acquittal or commutation in a substantial proportion (73%) of the cases pertaining to capital punishment that came before it. The rate of acquittal stands at 39%, implying that nearly 2 out of 5 individuals on death row in Pakistan have been subjected to erroneous verdicts and may have been wrongfully convicted. From 2015 to the end of 2018, there was a notable escalation to the extent of 83%. Notably, in 2018, the ultimate year on record, the Supreme Court upheld the death penalty in only 3% of its reported capital cases, with a staggering 97% of capital cases being overturned, with the death sentence either annulled or put under review (Reprieve, 2019). In 2017, Pakistan saw a 31% decrease in executions. In 2018, the Supreme Court of Pakistan affirmed the death penalty in only 3% of cases—a calculation based on its published judgments.

The proportion of cases resulting in acquittals relative to the total number of cases examined was determined to be 7:24. This finding suggests that, of the 72 cases scrutinized, 21 cases ended in acquittals.

The data analysis revealed that around 29.17% of the total cases investigated led to acquittals. This implies that, out of the 72 cases analyzed, 21 cases resulted in acquittals.

The ratio of cases receiving reduced sentences to the total number of cases examined was found to be 5:24. This indicates that, of the 72 cases studied, 15 cases were granted reduced sentences.

It was determined that approximately 20.83% of the total cases analyzed received reduced sentences. This indicates that, out of the 72 cases investigated, 15 cases were granted reduced sentences.

The ratio of appeals launched against acquittal that were not sustained was determined to be 0:11. Such a finding indicates that out of the 11 appeals scrutinized, none of them were upheld.

Upon conducting an analysis, it was ascertained that none of the appeals initiated against acquittal were sustained, resulting in a 0% success rate out of the total 11 appeals scrutinized. This means that in 100% of the appeals, the decisions of the high courts pertaining to acquittals were maintained and not interfered with by the Supreme Court.

The proportion of cases in which the convictions were upheld, in relation to the total number of cases scrutinized, was found to be 1:3. This implies that out of the 72 cases examined, 24 cases led to upheld convictions.

It was observed that approximately 33.33% of the total cases scrutinized resulted in upholding of convictions. This indicates that out of the 72 cases examined, 24 cases led to upheld convictions.

In the examination of 72 cases, it was ascertained that four cases resulted in the retention of a death sentence. The ratio of 1:18 demonstrates that in every 18 cases investigated, one case culminated in the sustenance of the death penalty. The comparatively diminished ratio indicates that the perpetuation of the ultimate punishment was not a prevalent consequence within the cases scrutinized. This discovery underscores the momentous nature and extraordinary circumstances encompassing the cases that occasioned the imposition and maintenance of the ultimate penalty.

The present study investigated the percentage of cases in which the death sentence was upheld. Analysis of the data collected from 72 cases revealed that only 5.56% of the cases ended with the ultimate punishment being upheld. The relatively low percentage of maintained death sentences raises important questions about the efficacy of capital punishment within the criminal justice system of Pakistan.

According to an article published in the Express Tribune, Pakistan has one of the highest death penalty rates globally. However, the Supreme Court of Pakistan has developed jurisprudence through which the scope of the death penalty has been minimized (Hasnat, 2020). Understanding this jurisprudence's exposition is crucial if one is to comprehend the rationale behind the commuted sentences or the reversal of convictions, particularly the guidelines for the reappraisal of evidence set forth by the Supreme Court, notably by Asif Saeed Khan Khosa. Hence, one of the primary objectives of this research is to analyze the jurisprudence developed by the honorable Justice ASK, to determine how the death penalty can be averted through judicial pronouncements even if the legislative framework is not particularly opposed to capital punishment.

The exoneration of the defendant by the Supreme Court was predicated on various considerations, notwithstanding the fact that the High Court had affirmed their capital punishment. In the subsequent passages, the study shall expound upon and scrutinize the diverse foundations or factors which culminated in the exoneration of the defendant, as laid down in Khosa’s judgments.

The established doctrine concerning the onus probandi necessitates no additional emphasis. It suffices to declare that within a national accusatorial legal system, the defendant enjoys the presumption of innocence until the prosecution establishes guilt beyond a reasonable doubt, and this primary burden of proof endures throughout the entire legal proceedings. This is based on the doctrine held in the case of Woolmington v. DPP (1935); it is patently clear that the burden of proof lies with the prosecution to demonstrate the culpability of the accused. If any semblance of reasonable doubt arises, whether emanating from the evidence provided by the prosecution or from the defense, concerning the intent of the accused in committing the alleged offense of murder, and in the absence of a successful prosecution, the accused is entitled to an acquittal.

Justice Asif Saeed Khan Khosa demonstrated instances where the accused have been acquitted, even in cases where the alleged incident took place within the defendant's residence. As the court held in Nasrullah alias Nasro v. The State (2017), if the entire case presented by the prosecution is discredited or deemed entirely implausible, the accused cannot be convicted solely on the grounds of not providing an explanation regarding the circumstances surrounding the loss of life of their spouse or a vulnerable dependent. These rulings have effectively rendered moot the principle which mandates the accused to elucidate the circumstances that culminated in the untimely demise of a vulnerable dependent residing with him.

When the original evidence fails to meet the necessary standard of reliability, a state of "reliability void" ensues (Cheema, 2015). To fill this void, corroborative evidence is employed in order to bolster the credibility and trustworthiness of the original evidence. However, it is important to note that corroboratory evidence is insufficient in transforming evidence that is intrinsically unreliable into one that is trustworthy. The Supreme Court recognized an insufficiency in reliability when the original evidence is not considered to be confidence-inspiring or is of doubtful character (Cheema, 2015). This principle is followed in cases of interested witnesses, chance witnesses, dying declarations, retracted confessions, and extra-judicial confessions. In instances of eyewitnesses, corroboration is always sought at least to confirm the witness's presence and the strength of his testimony. For this, reliance is always placed on medical evidence, as it is expert and independent evidence.

Witness Credibility in the Light of Medical Evidence

In the case of Nasrullah alias Nasro v. State (2017), the medical evidence contradicted the eye-witnesses insofar as PW1 testified before the trial court that the deceased had received a fire shot on her chest, while the medical evidence revealed that the firearm wound on the chest of the deceased was an exit wound. Similarly, PW5 testified before the trial court that both shots fired by the appellant had hit the deceased, but the medical evidence confirmed that only one fire shot had been received by the deceased, which had caused both an entry wound and an exit wound. Thus, contradiction in the ocular account and medical evidence means the latter will prevail. The presence of the eye witness is denied, as he failed to point out the direction of the fire shot. Moreover, the presence at the place of occurrence and hospital must tally with the MLR; as in the case Imtiaz alias Taj v. State (2018), the Medico-Legal Certificate did not reveal that the persons providing eyewitness account were in the company of the deceased, resulting in the court disbelieving their statement, as they failed to prove their presence. The presence is substantiated by the timely conducted post-mortem examination. As in the case titled Haroon Shafique v. The State (2018), an autopsy was performed around twelve hours after the demise of the individual. The court held that the findings of the medical examination reveal that considerable time had been consumed by the prosecution in order to secure eyewitnesses. The reason for their presence was invalidated due to an untimely conduct of the postmortem examination without any explanation. In light of the aforementioned case laws, it would be accurate to assert that medical evidence is the only evidence upon which the veracity of a witness's account can be assessed.

Confession is an admission made at any time by a person charged with a crime stating or suggesting the inference that he committed that crime (Madhana & Sreelatha, 2018). In Pakala Narayan Swami v. Emperor (1939), Lord Atkin observed: “A confession must either admit in terms the offence or at any rate substantially all the facts which constitute the offence. An admission of a gravely incriminating fact, even a conclusively incriminating fact, is not in itself a confession.”

Almost every confession is retracted; therefore, they must be corroborated for reliability. Independent corroboration must be of such nature which connects the accused with the alleged occurrence, as in the case Mir Zaman and 5 others v. State (2012), where the court held that mere recoveries in the shape of cash amount and weapon from both the accused do not connect them with the alleged occurrence, i.e., dacoity. In the case Muhammad Ashraf v. State (2016), it was a case of an unseen occurrence, confessed by the accused but corroborated as articles were recovered at the pointation of the accused; however, it was not relied upon as the recovery memo showed tampering on the date mentioned. Regarding the attribution of confession towards the accused, the court held that an application before the trial was considered sufficient to create doubt, stressing procedural informalities such as non-mentioning in the record, removal of handcuffs prior to recording confession, and presence of police inside the courtroom. It shows the approach of the court, how much stress is placed on procedural formalities, instead of bringing the evidence together and appraising it. The evaluation of evidence is done separately in light of procedural formalities, due to which reliance has not been made on such confession, resulting in acquittal of the accused.

Regarding the purported extra-judicial confession made during a public gathering, the Supreme Court made an observation in Mst Asia Bibi v. State (2019) that it cannot be considered as concrete evidence due to its ambiguous nature and lack of corroboration. Extra-judicial confession, its scope, and reliability are subjects of great fragility that require utmost care and caution while relying on such evidence. Due to the ease with which it may be concocted, such confessions are always looked at with doubt and suspicion.

“Legal worth of extra-judicial confession was almost equal to naught.”

An extra-judicial admission may be deemed as substantiating the accusation if, initially, it appears to be genuine and subsequently receives reinforcement from other evidence that is unquestionably reliable. In another case, Mohammad Ismail and others v. State (2017), the SC held that the extra-judicial confession must be natural in essence but also not made jointly by the accused, as the same is inadmissible in evidence. In the case Faisal Mehmood v. State (2016), the alleged admission of guilt by the accused to prosecution witness within residence 'A' has proven inadequate in establishing the purpose of his (prosecution witness) visit to the aforementioned place. Moreover, the failure to promptly alert the authorities about the confession, which had taken place two to three days prior, remains bereft of justification. Furthermore, a discrepancy has arisen about the arrest of the suspect, the testimony of the complainant, and the account provided by law enforcement pertaining to the arrest of the offender. Also, “A” was not produced by the prosecution, leading to adverse presumption.

The identification parade test is a valuable technique in criminal investigations, and if implemented correctly, it can be deemed admissible as corroborative evidence in a court of law (Sonthalia, 2021). One of the primary objectives of the identification parade test is to assess and reinforce the substantive evidence presented by the witness during the trial (Sonthalia, 2021). Justice Khosa, in the case Asfand Yar v. State (2018), where the appellant was sentenced to life imprisonment by the Lahore High Court, discussed the evidentiary value of IDP and also issued guidelines for conducting IDP. In Para 17, the court held that it is not a substantive piece of evidence, having no independent value, but it merely adds weight to other evidence. The main purpose is to determine whether the suspected person is the real accused or not.

Identification proceedings are not the testimony of a witness but the testimony of the senses of the witness. It is essentially a test of his power of observation and perception, a test of his power to recognize strangers, and a test of his memory. (Para. 17)

Such abilities are subjective and vary from person to person; even a truthful witness may be mistaken in identifying the accused. For these reasons, Justice Munir said: “the evidence as to identification ought in each case to be subjected to a close and careful scrutiny.” In the aforementioned case, the court laid down effective precautionary rules for IDP which basically determine its worth and value.

1. It should be held as early as possible, since memory tends to fade over time. Irrational delay in conducting IDP must be looked at with suspicion.
2. At first instance, the suspect must be produced before the magistrate, and he should not give custody to the police until IDP is held.
3. Prior to production before the magistrate, the suspect must be warned to muffle his face.
4. IDP should not be held inside the police station.
5. The magistrate should verify the time spent by the accused in police custody, if any, and mention it.
6. The recommended ratio between the accused individuals and the simulated representations is 1:9 or 10.
7. It is standard practice to perform individual identification lineups for each defendant.
8. Prior to participation in IDP, the witness should not be given opportunity to observe the suspected accused. After passing through it, the witness must be placed somewhere to rule out the possibility of contact with other witnesses.
9. The magistrate has a duty to create a comprehensive list of all individuals, commonly known as 'dummies', who make up the lineup during the parade. This list ought to contain relevant information regarding the parentage, occupation, and addresses of these individuals.
10. The magistrate must record any objection of the accused regarding identification.
11. If a witness identifies the accused, the magistrate must record the relation between the accused and the witness.
12. In case of failure to identify the accused, the magistrate must record it.

Lastly, he must mention in his report what kind of precautions have been taken by him. He will also give a certificate according to High Court rules.

The witness, while identifying, must specify the role played by the accused in the alleged occurrence. Moreover, identification before the trial court is not safe, as prior to this the witness has had numerous opportunities to see the accused. As it is not substantive evidence, failure to identify the accused is not always ruinous to the prosecution's case.

In the case titled Mir Zaman and 5 others v. State (2012), the accused were charged with dacoity and murder but were not nominated in the initial report and not properly portrayed. One accused was identified in IDP by the complainant without assigning him any role; the complainant acknowledged before the trial court that prior to IDP the police showed him all the accused. The natural witness (injured eye witness) was not associated to identify the suspects. In light of such conditions, it can be posited that the test identification parade has been rendered devoid of any evidentiary worth. In the case Gulfam and another v. State (2017), the court stressed the source of light, which the High Court presumed must exist at the medical store. The Supreme Court held that “The courts below need to realize that presumptions have very little scope in criminal law unless such presumption is allowed by the law to be raised.” Also, joint IDP is disapproved by courts.

The expression 'unnatural conduct of an eyewitness' lacks a generally accepted definition, hence making it subject to diverse interpretations contingent on contextual factors. Nonetheless, it typically indicates conduct or actions exhibited by an eyewitness that appear atypical, unconventional, or incongruent with prevailing norms in a particular scenario. This suggests that the conduct of the eyewitness may give rise to doubts about the accuracy or reliability of their testimony. In the case titled Irshad Ahmad v. State (2011), where the complainant and eye witness did not try to stop the appellant/accused from attacking the deceased even though he did not possess a firearm but a hatchet, this raises doubts about their presence at the place of occurrence. Similarly, in the case Nasrullah alias Nasro v. State (2017), non-transportation of the injured/deceased to the hospital by the complainant, even though the deceased was a relative, is an aberration from usual behavior and creates serious apprehensions about his presence.

The witnesses, purported to have observed some of the accused individuals discarding the deceased into a well on the ill-fated evening, exhibited peculiar or anomalous behavior. As per their own admission, subsequent to witnessing the disposal of the dead bodies into the well, the aforementioned witnesses had retired to their respective houses and slept throughout the night; upon their return to the relevant location on the following morning, the police officials had already arrived at the scene (Muhammad Ismail v. State, 2017).

Though any recovery at the pointation of the accused is acceptable in evidence, there are circumstances where the court did not consider it. As in Asad Khan v. State (2017), the reported discovery of a hatchet from the possession of the accused during the investigation was considered implausible as the aforementioned axe was reportedly found in an unfenced area of land owned by a third party, and the investigating officer had admitted before the court that at the time of its discovery, the hatchet was not stained with blood.

In Faisal Mehmood v. State (2016), as per the Memorandum of Recovery, it was apparent that the recovery in question was made from a cattle shed belonging to the complainant. This indicates that the recovery was not made from the sole custody of the appellant. It is evident that Section 103 of the Criminal Procedure Code (Cr.P.C.) was not adhered to in relation to the said recovery. Furthermore, it is noteworthy that after a period of approximately two years, it is scientifically implausible to determine the source of the blood due to the disintegration of human blood within a timeframe of three weeks. The court never relied on recovery if it is not made from the sole custody of the accused. It has been held that Section 103 Cr.P.C. is mandatory in nature; if an impartial witness is not associated with the recovery proceedings aforementioned, then it is a flagrant violation of the said section. The court, in the case of Muhammad Ashraf v. State (2016), discarded incriminatory articles as the date on the memo was tampered. In another case, Abdul Jabbar alias Jabbri v. State (2017), the court held such recovery of weapon is inconsequential as it has no matching report from the firearms expert. Also, sending empties along with the recovered weapon has no corroborative value; the same applies in the case of non-recovery of empties from the spot. It also loses its value if the same is not put to the accused under Section 342 Cr.P.C. (Imtiaz alias Taj v. State, 2018).

Grounds for Reduction of Sentence

In the case Nawab Ali v. State (2019), the inability of the prosecution to establish the alleged motive could potentially impact the sentencing determination and, under suitable circumstances, could lead to the commutation of capital punishment to life imprisonment to ensure the proper dispensation of justice. As in the case Nadeem Ramzan v. State (2018), it was held that in light of the lack of substantiation for the purported motive, the true impetus behind the incident has remained enigmatic and, as a result, prudence must be exercised in regards to the imposition of capital punishment upon the accused. In the present case, the motive established by the prosecution predominantly pertained to the co-accused, and the connection of the accused with the aforementioned motive was distant, which is a mitigating factor.

The courts adhere to certain principles of practice with regards to the principle of expectancy of life, as held in the case of Hassan and others v. State (2013):

1. In situations where a convict sentenced to death on a murder charge experiences delays in the final disposition of a legal remedy, and the duration of their incarceration is shorter than that of a life imprisonment term, the courts have abandoned the principle of utilizing the expectancy of life for the purpose of reducing the death sentence to imprisonment for life.
2. In the event that the State or the complainant party endeavors to augment a sentence of life imprisonment to that of capital punishment and if the convict has already served their entire sentence of life imprisonment or has not yet been released from incarceration during the pendency of such recourse, the principle of expectancy of life remains pertinent to preclude the elevation of the sentence of life imprisonment to that of capital punishment.
3. Article 13(a) of the Constitution may not be directly applicable to the aforementioned scenario, albeit the essence of the aforementioned Article could be taken into account as an element, in conjunction with other factors such as life expectancy, as well as the particulars and circumstances of the case, and the like. This consideration may lead to the decision of not augmenting the life imprisonment sentence to death, especially at a stage as advanced as the one mentioned.
4. In instances where a condemned individual who has been sentenced to capital punishment is subjected to a period of confinement that is equal to or exceeds the duration of a complete life imprisonment term while awaiting the adjudication of their appeal against their conviction and sentence of death, the concept of the life expectancy principle may be deemed a pertinent factor to be taken into account alongside other pertinent factors for the purpose of reducing their death sentence to one of life imprisonment.
5. The plea put forth was that, considering S. 367(5), Cr.P.C., “the normal sentence for a murder case is that of death”. The validity of this claim rests upon Section 302(b), P.P.C., which unambiguously outlines two possible sentences: death or life imprisonment. This provision does not stipulate that either of these sentences ought to be considered the normal.
6. When an appellate or revisional court deliberates on the appropriateness of a sentence imposed on a convicted individual, the provisions of Section 367(5), Cr.P.C. cannot be invoked. The said provision is relevant only to the trial court. This interpretation differs from previous cases.

In the legal matter of Khalid Iqbal v. Mirza Khan and another (2015), the court has pronounced that a lengthy imprisonment exceeding 18 years in the case of a death sentence may be grounds for commuting the sentence to life imprisonment. This may be applicable if there are other extenuating factors on record that suggest a reduction in the severity of the sentence.

In the case Naveed alias Needu and others v. State (2015), a person was killed in the occurrence, and two of the accused were sentenced to the death penalty as a result of the murder. The Supreme Court referred to the cross-examination, in which the doctor stated it cannot be ruled out that all of the wounds suffered by the deceased can be caused by a single weapon, upon which the death sentence was commuted.

In another case, the court held that the evidence presented by the doctor is significant as it unequivocally demonstrates that the appellant's intention was not to commit murder but solely to perpetrate rape against the victim. The medical evidence conclusively established that the victim's death was not the result of rape but rather due to shock. Furthermore, it was determined that the cause of death was not asphyxia but rather pressure applied to the victim's neck, which may have been an attempt by the appellant to silence her rather than an intention to kill.

The imposition of capital punishment may typically be suspended in instances where it remains uncertain from the available documentation as to which of the offenders was responsible for inflicting the deadly wound upon the deceased. The assertion rendered by the physician in question indicates that the deceased did not incur any specific injury that is to be deemed fatal for life. The withholding of a sentence of death was predicated upon the lack of clarity regarding the culpability of a specific defendant in the causation of death.

As per the prosecution's own argument, the complainant party had traveled to the location of the incident where the accused party was already present. Therefore, it is plausible that the incident was not premeditated on the part of the accused party. Instead, it could have occurred when the parties, who were otherwise hostile towards each other, encountered each other by chance. The present case, Hassan and others v. State (2013), is one in which the parties engaged in a confrontation that resulted in both parties resorting to firing. The court held that in cases where there is an absence of premeditated malice on the part of the accused party and where an incident occurs spontaneously, this Court, taking into account the specific circumstances of the case, typically approaches the matter of sentencing with a certain level of empathy and thoughtful consideration.

The present case, Muhammad Anwar v. State (2017), pertains to a singular discharge of a firearm, which was not subsequently repeated by the defendant. The court held: though the complainant was at the mercy of the accused, despite this, fire was not repeated. It shows he had no clear intention or premeditation to commit murder.

In the case Nadeem Ramzan v. State (2018), during the course of investigation a dagger was recovered from the accused and taken into possession by the police. It was accepted that the dagger found did not have traces of bloodstains, and therefore, was not related to the alleged occurrence. Moreover, in the absence of a serologist’s report, a mere recovery of a dagger does not connect the accused with the occurrence. Even in the case Nawab Ali v. State (2019), in which recovery was effected in the shape of the Kalashnikov (weapon of the offence) from the defendant during the investigation, it did not hold any legal significance, as the Kalashnikov and empties recovered were sent to the forensic laboratory on the same date. Though the FSL report is positive, it can be easily fabricated.

The impact of partial compromise may not necessarily have any bearing on the conviction of an accused person in a case of Ta'zir. However, in certain circumstances, it may hold some relevance to the question of sentence, as held in the case Muhammad Amin v. State (2016).

Conclusion

The issue of the death penalty holds great significance, as evidenced by the multitude of international documents that address it. Pakistan, being a signatory to some of these documents, has implemented various laws, e.g., the Juvenile Justice Act of 2018, which aim to decrease the utilization of the death penalty. Nevertheless, it is imperative to acknowledge that legislative measures are not the exclusive means of reducing the application of the death penalty; the judicial pronouncements of higher courts, as demonstrated by the approach of Justice Khosa, have also played a consequential role in its reduction. The judicial pronouncements of Justice Khosa have underscored the utmost significance of establishing guilt beyond a reasonable doubt and have meticulously scrutinized the credibility of evidentiary material proffered by the prosecution.

Overall, Justice Khosa's judgments are a testament to his dedication to justice, fairness, and the rights of the accused. His invaluable contributions to the legal field will continue to have a lasting impact on the criminal justice system in Pakistan.

Conflict of Interest

The author has no financial or non-financial conflict of interest in the subject matter or materials discussed in this manuscript.

Data Availability Statement

Data availability is not applicable as no new data was created.

Funding Details

No funding has been received for this study.

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