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Legalizing gambling in India: Tackling match-fixing by the regulation of sports-betting by Mayank Samuel

About the Author: Mayank Samuel is a Law Student at NALSAR University of Law, Hyderabad

INTRODUCTION

“Sometimes a 3-1 favourite loses. That’s why they call it gambling, and that’s why they keep flipping over the cards.”[i]

                                                                                                                        -Richard Roeper

It has always been the desire of the man to get rich overnight which led to a search for different ways and means, one of which is gambling. Gambling, one of the oldest industries in the world, is regarded by some as a vice and sinful activity and by others as a harmless form of entertainment. On the other hand, gambling has played a considerable role in the American history with the usage of lotteries by the First Continental Congress to finance the Revolutionary War and the founding fathers such as Benjamin Franklin and George Washington sponsoring private lotteries.[ii]

Three key elements of gambling:-

  1. Something valuable is being put at risk
  2. The outcome of the game is determined by chance
  3. Irreversible nature

All forms of gambling require three elements, namely prize, chance and consideration and a person gambles when he takes the chance of losing his money or belongings.[iii] People choose to gamble to win money in order to overcome their financial hardships, to socialize or just as a source of excitement. While gambling was once illegal and viewed as a disreputable activity, it is increasingly becoming a popular recreational activity. Gambling is not only associated with casinos and racetracks but also other innumerable activities such as Bingo, betting on games of skill such as golf and Internet gambling (sites such as bet365.com) making it a multi-billion dollar industry with continual growth and giving birth to  resort cities such as Las Vegas, the Gambling Capital of the world.

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ADVANTAGES OF LEGALIZED GAMBLING

Negative perceptions about gambling in the Indian society with the media and the government calling it a social evil has restricted the growth potential of the industry though gambling is merely a ‘chance’ activity with a monetary value attached to it.[iv] All of us in our daily lives are involved in some form of ‘chance’ activity though we don’t attach any monetary value to our predictions but merely attaching monetary value to such predictions doesn’t make it illegal or immoral.

Economic Acceleration

South-east Asian nations such as Thailand having lesser number of tourist spots attract more international tourists than India and therefore tourism-related revenue as they promote tourism with the help of gambling-related activities. India, in order to attract more foreign tourists and therefore, earn valuable foreign exchange should amend suitably the outdated local and national laws and set up a national level Gambling Regulatory Authority on the lines of UK Gambling Commission so that hotels in the important tourist centres of India are allowed to operate casinos and thus provide the currently missing ‘fun’ part of a tourist activity. A regulated gambling industry in the country with young population, robust economy and superpower status in the IT sector would have a positive multiplier effect on other sectors in the supply chain such as real estate, advertising, banking and hotel industry. The policy makers of the country by providing the right legal framework to legalize gambling in a regulated manner in India would see thousands of billions of rupees of black money involved in illegal gambling coming to the legal economy for the benefit of citizens of the country not only filling the Exchequer but also providing employment negating the effects of economic slowdown. This resulting increase in the tax revenue would also lower the tax burden on other sources and, therefore, would be welcomed by other citizens of the country.[v]

Curbing Corruption in Sports

Former International Cricket Council (ICC) chief, Ehsan Mani, urging the ICC and Board of Control for Cricket in India (BCCI) to pressurize the Indian government to legalize betting said that match fixing can’t be stopped until and unless the betting industry is regulated in India calling India as the epicentre of cricket betting.[vi] He further added that betting should be legalized and regulated in India in order to monitor the conduct of the bookies also reducing the risk of corrupting players around the world who are lured into match fixing and spot fixing due to the huge money involved in the business.[vii] Such cricket-fixing allegations which are detrimental to the country’s reputation projecting India as a corrupt nation can be eliminated by legalizing gambling in India benefitting not only nation’s economy but also its pride.

Entertainment value

Gambling, made illegal in India with the intention of strengthening Indian economy by Public Gambling Act, 1867 took into account moral and financial arguments though the legislation was unsuccessful in stemming gambling as when a population is asked not to gamble, it’s the first thing they’d do, driving gambling underground. Mahatma Gandhi also spoke out against gambling giving moral arguments to support his stance calling it a morally corrupt activity.[viii] All such arguments didn’t take into account the enjoyment that is derived from low-stakes betting for entertainment purposes with the evil aspects of gambling reduced by legislation. The lawmakers, not ready to consider the entertainment aspect of gambling are unwilling to legalize gambling despite the economic and social advantages fearing an attack from media and rival political parties.

Bridging Class gaps in Society

Another social advantage of legal gambling in India such as horse racing, increasingly becoming popular in the country, is the interaction of ordinary people with the richest people of society which is a rare sight in India, infamous for its ever-expanding inequalities.

Increasing employment rate

Lottery stalls, found all over India, provide jobs for the people that print the tickets, sell them and increasing the newspaper sales in which the lottery results are published, providing employment to a large number of people in the chain.

Putting Taxpayers’ money to better use

A large amount of money and time of the government which is spent in tracking down the criminals involved in illegal gambling could be put for better use such as improving the infrastructure of the country as such people do not provide any imminent threat to the public. Such a thing would also, on the other hand, ensure that the money made in illegal betting doesn’t fund terrorism and other forms of criminal activities posing a danger to the society.

Reduction in the profits of crime-lords

Another argument advanced in favour of legalizing gambling is that it is impossible to enforce laws against gambling with the only effect of such laws being an increase in the price of gambling and therefore, an increase in the profits of the criminal elements.

Case study: Sikkim’s PlayWin lottery and Goa’s floating casinos

The transformation of Sikkim from a small, sleepy Himalayan state to one of the major hubs of Indian gambling industry is one of the pronounced effects of legalized gambling due to a large amount of investment which has brought economic power in Sikkim. Sikkim’s economic progress has been remarkable due to legalized gambling such as PlayWin lottery the first national lottery of India.[ix] Another such example is Panjim in Goa, previously neglected by the tourism industry in favour of beach resorts, which has seen an economic boom with thriving businesses due to the tourism brought in by the gambling industry, pulling in gambling fans from all over Asia to Mandovi river, home to India’s largest casinos floating on large ferries.[x]

DISADVANTAGES OF LEGALIZED GAMBLING

“Gambling: The sure way of getting nothing for something.”[xi]

                                                                                                                        -Wilson Mizner

Addiction to Gambling

The lure of “getting something for nothing” has attracted the individual towards gambling and, therefore, the biggest impact of legalizing gambling has been seen in people’s homes where individuals tend to over-gamble, spending all their earnings on the table leading to severe problems in the households. One of the significant drawbacks of legalizing gambling industry has been increasing its accessibility to people with about 130 million people visiting casinos in USA which is about double the attendance at major league baseball games.[xii]

Financial concerns

Legalizing gambling would be detrimental to the financial position of the citizens with people choosing to gamble to make quick money instead of investing it wisely.  The casinos, with so much money at stake, analyse the situation which makes a gambler stay longer on the table and lose as much money as possible disappointing the gamblers who come to casinos with the intention of winning money.

Increase in Crime rates

Due to lack of self-restraint of the gamblers, various problems such as loss of money, neglecting the duties and responsibilities, getting into trouble with gambling cartels due to their attempts to dupe casinos through illegal means and indulging in over-drinking arise which increases the crime rate in a region with illicit activities such as money laundering, and counterfeit money taking place. Atlantic City in US is one example where legalizing gambling saw a phenomenal 320% rise in the crime rate and a 100% rise in cases of rape, muggings and burglary.[xiii] Another observation is an increase in the suicide rates in the areas where gambling has been legalized as compulsive gambling leads to suicide.[xiv]

Small Businesses suffer

Even though the tourism industry on the whole would prosper, other small business establishments providing recreation and establishment will suffer with most people visiting only the casinos, and therefore, such growth rate would be uneven.[xv]

Loss of National income

Nobel Prize-winning economist Paul Samuelson described gambling as sterile transfers of money and goods between individuals creating no new money for goods while absorbing time and resources which if pursued beyond a certain limit of recreation would subtract from the national income.[xvi] Further, the revenue boosts from legalized gambling are short-lived generating gambling dependence and failing to maintain a city through recession.

Social evil

Gambling is a social evil not only causing an erosion of one’s ethics but also leading to irresponsibility amongst the youths of the country who initially start off by spending little amounts but later, end up wasting their earnings, becoming irresponsible citizens of the society and the country setting a wrong example for the younger generations. Therefore, the financial benefits provided by gambling are dwarfed by the social and cultural risks posed by addiction to gambling.

“If you think legalizing games of chance starves out the criminals, look at Las Vegas, where the games are legal, yet the hoods still deal themselves in and related vices flourish.”[xvii]

                                                                                    -Late J. Edgar Hoover, Director, FBI

Revenue generation is an illusion

Senator Alexander Wiley of Wisconsin while urging the state of Alaska not to legalize gambling said that the idea of increasing revenue through gambling is an illusion as every dollar raised would mean five dollars spent in “higher police costs, higher court costs, higher penitentiary costs and higher relief costs.”[xviii]

Sheer waste of time

Another disadvantage of legalizing gambling is the extraordinary waste of time involved while neglecting their family and work, especially when gambling becomes an addiction.[xix] The late Elder Richard L. Evans of the Council of Twelve aptly described it in the following statement:-

“The spirit of gambling is a progressive thing. Usually it begins modestly; and then like many hazardous habits, it often grows beyond control. At best it wastes time and produces nothing. At worst it becomes a ruinous obsession and fosters false living by encouraging the futile belief that we can continually get something for nothing.”[xx]

HISTORY OF GAMBLING IN INDIA

Gambling has been an integral part of the Indian culture with texts dating back to 2000 BC making reference to gambling as a pastime of Indian rulers and chieftains. Mahabharata presents the most famous gambling story where Yudhishthira, ended up gambling his entire kingdom, his brothers, his wife Draupadi and eventually himself to king Shakuni.[xxi] By the 15th century, gambling houses were legalized with a share of the profit going to the king leading to a boom in the gambling which took a toll on the society and, therefore, forcing the British Empire in the 19th century to declare gambling an illegal activity in the country under the Public Gambling Act 1867 despite the tax gains.

LEGAL POSITION OF GAMBLING IN INDIA

Legal Definition of gambling

The term ‘Gambling’ includes any activity or undertaking whose determination is influenced by chance or accident and an activity or undertaking which is entered into or undertaken with consciousness of the risk of winning or losing a prize competition or a wagering contract, as defined under List II Entry 34 of the Constitution of India.[xxii]

  1. Public Gambling Act 1867- The legislation making gambling in India illegal

Public Gambling Act 1867 outlawed all forms of gambling in India except Horse Racing, Rummy and Lotteries.[xxiii] Under Section 3 of the Public Gambling Act, 1867 which lays down penalty for owning or keeping, or having charge of a gaming-house, “Whoever, being the owner or occupier, or having the use, of any house, walled enclosure, room or place situated within the limits to which this Act applies, opens, keeps or uses the same as a common gaming-house; and whoever being the owner of such place knowingly or wilfully permits the same to be opened, occupied, used or kept by any other person as a common gaming-house; and whoever has the care or management of, or in any manner assists in conducting, the business of any house, walled enclosure, room or place as aforesaid, knowingly  or wilfully permits the same to be opened, occupied, used or kept by any other person as a common gaming-house; and whoever has the care or management of, or in any manner assists in conducting, the business of any house, walled enclosure, room or place as aforesaid, opened, occupied, used or kept for the purpose aforesaid; and whoever advances or furnishes money for the purpose of gaming with persons frequenting such house, walled enclosure, room or place shall be liable to a fine not exceeding two hundred rupees, or to imprisonment of either description, as defined in the Indian Penal Code for any term not exceeding three months.[xxiv] The act not only declares gambling done as a business to earn profits illegal but also visiting gaming-house without an active participation a crime with mere presence being enough.[xxv] Under this act, the police have been given full authority to search, enter, arrest all the occupants and seize all the gambling instruments.[xxvi] Though the Public Gambling Act 1867 makes gambling illegal, section 12 has kept certain activities requiring skill whenever played out of its purview.[xxvii] Bona-fide business transactions valid under the contracts of indemnity, share market, purchase or sale of securities in future also doesn’t come under the purview of gambling.

 

  1. Indian Contract Act 1872- Agreements by way of wager void

Section 30 of the Act prevents a person from recovering any winnings on an agreement based on a future event wherein the loss of one party is the gain of another party as agreements by way of wager are void.[xxviii] It may be legal to buy a lottery ticket in India but the winner of such lottery will’ve no remedy against the lottery agency if it refuses to pay the winnings. The MP High Court reiterated a similar position in Subhash Kumar Manwani v. State of MP wherein the Court dismissing the appeal under Section 96 of the Code of Civil Procedure held that the promise to pay prize in a lottery cannot be enforced by civil suit due to prohibition contained in Section 30 of the Indian Contract Act.[xxix]

Case Laws

The argument that skill based games wherever played are not illegal was reiterated in MJ Sivani v. State of Karnataka where the SC ruled that games where the element of chance is predominant fall under the category of gamble.[xxx] In S.P. Nathan v. State of Tamil Nadu, the Madras HC held that unregulated video game operators not only pose danger to public peace and safety but also the vulnerable public suffer losses while playing in games of chance and therefore the prohibition of video games based on pure chance or mixed chance are not violative of Article 21 nor is the procedure established by law unjust or unreasonable.[xxxi] The legal position in India on poker as a skill or a chance based game continues to be uncertain with the SC in State of Andhra Pradesh v. K Satyanarayana while answering the question of rummy being a game of chance or skill held that the game of rummy is not entirely a game of chance and does require skill of memorizing and discarding cards.[xxxii]

GAMBLING LAWS IN UNITED KINGDOM AND UNITED STATES OF AMERICA

United Kingdom

UK’s obsession with gambling is driven by the number of sporting events held across the country with nearly 73% of UK adults participating in some form of gambling in 2010.[xxxiii] Under the UK Gambling Act 2005 which regulates commercial gambling in Britain, betting means ‘the making or accepting of a bet on the outcome of a race, competition or other event; the likelihood of anything occurring or not occurring; or whether anything is or is not true.’[xxxiv] Under the Act, betting in UK is regulated by the Gambling Commission which aims to keep gambling crime free, ensure transparency and protect children and vulnerable adults on behalf of the UK government’s Department for Culture, Media and Sport (DCMS) which govern the government policy relating to horse-racing, greyhound racing and lottery.[xxxv] The UK gambling industry generated revenues worth 82 billion pounds and gave employment to 120,665 people in 2012-13 with the growth rate at 5.8%and the annual growth during the five-year period 2008-13 at 2.2% with a total of 1,243 businesses.[xxxvi]  The Act aimed at creating a modern gaming industry in Britain capable of making a positive contribution to the development of the leisure economy by boosting employment during economic downturn and promoting the welfare of the customers.[xxxvii] Neighbouring European countries such as France and Italy are in the process of drafting laws which allow online gambling in order to curb unemployment and generate revenues.[xxxviii]

The act, though, commercialized the gambling industry in UK was failed by the taxation policies of the government which failed to tax all regulated forms of gambling under one fair regime with some forms of gambling facing the brunt of heavy taxes whereas online gambling remained untouched.[xxxix] All UK bookmakers, such as William Hill, shifted their online businesses to gambling-friendly tax havens such as Gibraltar in order to avoid taxation by the government and maximize their profits.[xl] The legislature, addressing this loophole, made changes in the gambling laws taxing the offshore operators with an idea of broadening the tax base by taxing the wagers on a point-of-consumption basis and providing a fair competition between UK and overseas remote gambling operators imposing a 15 % duty on online gambling profits generated in the country.[xli]

United States of America

Gambling, deeply rooted in the American culture has shaped the history of America since the pre-colonial times where the proceeds from lotteries authorized by the ruling English monarchy were used to subsidize explorations of the New World.[xlii] The first era of gambling where government and private lotteries were common in the colonial America ended with the spread of Jacksonian morality in the country and numerous publicized scandals.[xliii] Post-Civil war reconstruction introduced a second era of gambling where lotteries were employed as a form of voluntary taxation to rebuild the war-torn South.[xliv] This era ended by a scandal involving the Louisiana lottery with the federal legislation  banning the state-run lotteries and other forms of a gambling in 1890.[xlv] The United States, in the 21st century, is in the midst of a third era of widespread legalized gambling which began in 1931 with the state of Nevada re-legalizing casinos.[xlvi] Initially, off-track betting and back room casino games were treated as organized crimes by law-enforcement agencies with legal gambling opportunities limited to Nevada casinos, charitable bingo and horse-racing though gambling expanded greatly after New Hampshire initiated the first modern state lottery signifying a change in traditional, social and moral barriers.[xlvii] Slow economic growth, cuts in federal funding and growth in public needs during the late 1980’s and early 1990’s forced the state governments to explore additional sources of revenue with states turning to lotteries and casino gambling which further led to an increase in tourism, employment and tax revenues. The New Jersey Casino Control Act 1977 stated that legalized casino gambling has been approved by the New Jersey citizens as a tool of urban re-development of the city.[xlviii] The Congress passed the Indian Gaming Regulatory Act 1988 allowing the tribes to operate any form of legalized gambling in their resident state.[xlix] According to the data provided by National Opinion Research Centre, 1999, some form of gambling has been legalized in  all but three states of USA and lotteries in 37 states.[l] Casino gambling continues to be illegal in most of the states though Colorado, Illinois and Indiana have legalized casino gambling to provide employment to citizens and improve their economy. Internet Gambling Regulation, Consumer Protection and Enforcement Act 2013, introduced in the US Congress bringing the regulation of online gambling and betting under the Federal Department of Treasury would allow a comprehensive system regulating all forms of online gambling while also bringing in an element of flexibility allowing the state to either participate in the internet gaming licensing system or prohibit such system in their state.[li]

The attention-grabbing findings of the American Gaming Association (AGA) of casinos generating one percent of the US’s GDP in 2010 of $14.5 trillion with 566 casinos in 22 states of US providing 820,000 jobs and taking $49.7 billion from tourists show that gambling industry propped the US economy during and after the 2008 Financial crisis.[lii] According to a national economic impact study released by the AGA, the national commercial casino industry grossed second-largest gaming revenues ever in 2012 after three consecutive years of escalating growth when it reached its highest levels of gross gaming revenues since prior to the 2008 recession.[liii] The report also stated that an overwhelming majority of 85% of American adults view casino gaming as acceptable for themselves representing the highest acceptability level in the last decade.[liv]

 

CONCLUSION

“Luck is a very thin wire between survival and disaster, and not many people can keep their      balance on it.”[lv]

                                                                                                            – Hunter S. Thompson

The effects of legalization of gambling in a country would depend on the self-discipline of the citizens and the magnitude on which the gambling  industry is welcomed in a region. Legalizing gambling and betting may or may not serve the purpose depending on the favour or opposition of the same based on the arguments mentioned above as a person influenced by either side of the arguments will take a stand to favour or oppose the legalization of betting. The advantages and disadvantages are observed by the residents of cities that host casinos and therefore, while gambling can prove to be extremely beneficial bringing in economic stability and prosperity in some areas, in other areas it can destroy lives as well.

Gambling would continue to be prevalent in India regardless of whether it is legalized or not due to their popularity though legal forms of gambling have had beneficial effects on both local and national economies and illegal forms of gambling continue to fund terrorist organizations and crime lords which not only damages the country’s economy but also the pride and reputation of the country.  A number of countries have legalized gambling in a regulated and safe manner and India could set up a national level Gambling Regulatory Authority on the lines of UK Gambling Commission. India, before legalizing gambling in the country should see that the advantages significantly outnumber the disadvantages in a particular region because if they can bring in the ‘fun’ part, they can at the same time, bring in irresponsibility and criminality adversely affecting the poorer, uneducated Indians who may gamble their life’s savings.[lvi]

ENDNOTES

[i]Richard Roeper, available at https://www.searchquotes.com/quotation/Sometimes_a_3- 1_favorite_ loses._That’s_why_they_call_it_gambling,_and_that’s_why_they_keep_flipping_/198080/.

[ii] History of Gambling in the United States, available at https://www.library.ca.gov/crb/97/03/ chapt2.html.

[iii] Prof. I. Nelson Rose, GAMBLING AND THE LAW, Gambling and the Law, https://www.gambling andthelaw.com /index.php/8-information/information/1-qgambling-and-the-law-rq.

[iv]Kamini Mathai, Gambling addiction growing but few admit to it, The Times Of India, June 1, 2013, https://articles.timesofindia.indiatimes.com/2013-06-01/india/39674076_1_gambling-problem-gambling-addiction-psychiatrist.

[v] Rahul Thadani, Legalized Gambling Pros and Cons, Buzzle, https://www.buzzle.com/articles/legalized-gambling-pros-and-cons.html.

[vi] AFP, Ex-ICC chief says India is illegal betting hub, Mar. 20, 2012, https://tribune.com.pk/story/352542/ex-icc-chief-says-india-is-illegal-betting-hub/.

[vii]id.

[viii] Prof. Dr. Yogendra Yadav, Gambling and Mahatma Gandhi, The Gandhi-King Community, https://gandhiking.ning.com/profiles/blogs/gambling-and-mahatma-gandhi.

[ix]George Oborne, Why Gambling In India Needs To Be Legalized, IndiaBet,  https://www.indiabet.com/indian-betting/495110/why-gambling-in-india-needs-to-be-legalised.

[x] Sambuddha Mitra Mustafi, Poke Me: Why India should legalise casinos, Oct 16, 2013,  https://articles. economictimes.indiatimes.com/2013-10-16/news/43107322_1_casinos-gambling-american-gaming-association.

[xi]Wilson Mizner, available at https://www.brainyquote.com/quotes/quotes/w/wilsonmizn125526.html.

[xii] Should Gambling Be Legalized?, StudyMode, https://www.studymode.com/essays/Should-Gambling-Be-Legalized-1189.html.

[xiii] Pp. 21-22, Legalized Gambling: For and Against, Rod L. Evans and Mark Hance (eds.), (Open Court Publishing, 1998).

[xiv]id. at P. 210.

[xv] id. at Pp. 213-214.

[xvi] Pp. 99-99, Gambling in America: An Encyclopaedia of History, Issues, and Society, William Norman Thompson, (ABC-CLIO, 2001).

[xvii] Dallin H. Oaks, The Evils of Gambling, THE CHURCH OF JESUS CHRIST OF LATTER-DAY SAINTS, https://www.lds.org/ldsorg/v/index.jsp?vgnextoid=2354fccf2b7db010VgnVCM1000004d82620aRCRD&locale=0&sourceId=c4650b2e72c1c010VgnVCM1000004d82620a____&hideNav=1.

[xviii] P. 232, Christians and the Gambling Mania, Lycurgus M. Starkey, (New York: Harper and Row, 1967).

[xix] supra. note xvii.

[xx]P. 5, Elder Dallin H. Oaks, Gambling—Morally Wrong and Politically Unwise,https://stoppredatorygambling. org/wp-content/uploads/2012/12/Dallin-Oakes-of-LDS-Church-Predatory-Gambling-is-Wrong-and-Politically-Unwise.pdf.

[xxi] Sports and Games in Ancient India, available at https://veda.wikidot.com/info:origin-of-games.

[xxii] P.1080, V.N. Shukla’s Constitution of India, Mahendra P. Singh, (Lucknow: Eastern Book Company, 2012).

[xxiii] The Public Gambling Act 1867, available at https://indiankanoon.org/doc/1824663/.

[xxiv] Section 3 – Penalty for owning or keeping, or having charge of a gaming-house, The Public Gambling Act 1867, available at https://www.manupatrafast.in/Search/dispsearch.aspx?nActCompID=59797&iPage=1&h Text= .

[xxv]Section 4 – Penalty for being found in gaming-house, The Public Gambling Act 1867, available at https://www.manupatrafast.in/Search/dispsearch.aspx?nActCompID=59798&iPage=1&hText=.

[xxvi] Section 5 – Powers to enter and authorise police to enter and search, The Public Gambling Act 1867, available at https://www.manupatrafast.in/Search/dispsearch.aspx?nActCompID=59799&iPage=1&hText=.

[xxvii] Section 12 – Act not to apply to certain games, The Public Gambling Act 1867, available at https://www.manupatrafast.in/Search/dispsearch.aspx?nActCompID=59806&iPage=1&hText=.

[xxviii] Section 30 – Agreements by way of wager void, The Indian Contract Act 1872, available at https://www.manupatrafast.in/Search/dispsearch.aspx?nActCompID=15358&iPage=1&hText=.

[xxix] AIR 2000 MP 109

[xxx] AIR 1995 SC 1770

[xxxi] AIR 2001 Mad 159

[xxxii] AIR 1968 SC 825

[xxxiii] Heather Wardle and Alison Moody, Don’t bet on it!: Why what you think you know about gambling is probably wrong, GamCare, Spring 2011, https://www.gamcare.org.uk/pages/dont_bet_on_it.html.

[xxxiv] P. 18. Gambling Act 2005, https://www.legislation.gov.uk/ukpga/2005/19/pdfs/ukpga_20050019_en.pdf.

[xxxv] id. at P. 23.

[xxxvi] Gambling & Betting Activities in the UK: Market Research Report, IBIS World, https://www.ibisworld. co.uk/ market-research/gambling-betting-activities.html?partnerid=prweb.

[xxxvii] Ian Burke, With betting industry taxes, the Government is gambling with economic growth, Jan 08 2012, https://www.telegraph.co.uk/finance/comment/9001143/With-betting-industry-taxes-the-Government-is- gambling-with-economic-growth.html.

[xxxviii] The latest news from Europe – debates about national gambling laws continue, OLSWANG, https://www.olswang.com/articles/2011/02/the-latest-news-from-europe-debates-about-national-gambling-laws-continue/.

[xxxix] supra. note xxxvii.

[xl] Nathalie Thomas, William Hill prepares to challenge UK online gaming tax, Jul 30 2012, https://www.telegraph.co.uk/finance/newsbysector/retailandconsumer/leisure/9436762/William-Hill-prepares-to-challenge-UK-online-gaming-tax.html.

[xli]id.

[xlii]P. 19, Pathological Gambling: A Critical Review,National Research Council, (Washington, DC: The National Academies Press, 1999).

[xliii]id.

[xliv]id.

[xlv]id.

[xlvi]id.

[xlvii] id. at Pp. 19-20.

[xlviii] The State of New Jersey v. Trump Hotels and Casino Resorts Inc. (734 A.2d 1160 (1999)), available at https://www.leagle.com/decision/19991894734A2d1160_11869.

[xlix] NATIVE AMERICAN GAMING, NATIONAL GAMBLING IMPACT STUDY COMMISSION, https://govinfo.library.unt.edu/ngisc/research/nagaming.html.

[l] Gambling in the United States, available at https://www.library.ca.gov/crb/97/03/chapt1.html.

[li] Online Gambling, American Gaming Association, https://www.americangaming.org/government-affairs/key-issues/online-gambling.

[lii] Pp. 1-2, Coleman Bazelon, Kevin Neels & Pallavi Seth,  Beyond the Casino Floor: Economic Impacts of the Commercial Casino Industry, American Gaming Association, https://www.americangaming.org/sites/default/files /uploads/docs/final_final_brattle_study_2-3-12.pdf.

[liii] Brian Lehman, 2013 Report Shows Commercial Casino Industry’s Highest Growth Rates Since Recession, American Gaming Association, https://www.americangaming.org/newsroom/press-releases/2013-report-shows-commercial-casino-industry%E2%80%99s-highest-growth-rates-since.

[liv]id.

[lv] Hunter S. Thompson, available at https://www.brainyquote.com/quotes/quotes/h/huntersth588334.html.

[lvi] Rama Lakshmi, India considers legalizing sports gambling as way to curb match-fixing, June 25, 2013, https://www.washingtonpost.com/blogs/worldviews/wp/2013/06/25/india-considers-legalizing-sports-gambling-as-way-to-curb-match-fixing/.

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