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The Court held that although the IP rights and other related rights of tobacco companies may be restricted as a result of the plain packaging laws, the restriction imposed by this law does not involve the accrual of a benefit of a proprietary character to the Commonwealth which would constitute an acquisition .[5] Legal arguments against plain packaging laws have been raised on the grounds that it violates Art 20 of TRIPS, 1994

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By the 1970s, there was a further upswing in the volume of anti-smoking material and also a change in its design and approach