I. ABSTRACT:

Alcohol at one time was luxury for the Indians but at the contemporary time, many citizens have been indulged into the consumption of alcohol resulting into few alcohol addicts. At the present time in India, alcohol as a subject comes under the State list entry 51 under the Schedule 7^th of the Indian constitution. This gives freedom to all the states for making their own laws for the current subject. This has led to widespread diversification resulting in different legal age in different states for liquor consumption. Certainly, some of the states have banned alcohol believing in the ideology of Gandhi. The supporters of alcohol worshipped the philosophy of liberty. The problem due to the ideology conflict among the states has led to a discriminatory law for liquor consumption as the states have created their own minimum legal drinking age rather accepting one national minimum legal drinking age. Every state having their own laws for the subject of alcohol is fair but to a very certain extent. The demerits have overpowered the merits of such laws. Uniformity is an essential element to control the extending scope of discrimination and other negative factors. Ideally, having uniform right to vote, the right to drive; right to liquor should also be fixed at the central level. Even if the minimum legal age is fixed at the central level for alcohol consumption, the question is what should be the minimum age. Certainly, after conducting the research, an age of 21 years has come forward in regard to minimum legal drinking age for India. Ultimately alcohol has become a need rather than luxury and it needs to be dealt with utmost importance.

II. INTRODUCTION:

Alcohol is the anaesthesia by which we endure the operation of life[1].

Alcohol is defined as the “colourless volatile flammable liquid which is produced by the natural fermentation of sugars and is the intoxicating constituent of wine, beer, spirits, and other drinks, and is also used as an industrial solvent and as fuel.”[2] Alcohol can be traced as old as different religions of the world and its use has always been a contentious issue. It always existed in the society either in the form of Madira in our traditional Indian society or in the form of finest beer of the modern world. While some countries favour a complete ban on the use of it for consumption purpose, other countries see the ban as against the principles of liberty and freedom of making choices. The debatable question of drinking it or not is based on the way it is perceived psychologically except the role it has to play on health. According to the Global status report on Alcohol and Health “the worldwide consumption of alcohol beverages in the year 2005 is equal to 6.13 litre of pure alcohol consumed by every person.”[3] Coming down to the national level, India is a constitutional democracy is facing the dilemma of either promoting liberty of an individual or to regulate the consumption of it in light of health, peaceful existence of society, and the sociocultural role it plays.

Almost 30% of the total population of India consumes alcohol out of which 5 to 13 percentages are daily drinkers. The dilemma mentioned above has been discussed thoroughly by the constitutional assembly in its debate[4] where arguments are advanced in support and opposition of banning it. Contemporary statistics show that India’s consumption level has increased by 55 % in the last five years[5] and it is continuously increasing at an unhesitating rate. Thus, there arises a need to strengthen the existing law and to increase awareness about it.

Article 47[6] of the Indian Constitution which was the result of constitution assembly debates is a directive principle of state policy is supremely fundamental for the governance of the country and it gives the state the complete discretionary privilege of consumption of liquor as a beverage as it is inherently dangerous to human health. State not only has the power to regulate consumption but it can also impose restrictions and limitations on the trade and business of liquor as a beverage.[7] Alcohol is such a commodity whose demand is constantly rising with time. Alcohol being a subject listed in state list lack the uniformity of law. Every state makes or changes law according to the requirement of its population, beliefs, sociocultural history etc. Having different age has resulted in a turmoil situation which can be effectively addressed only by having a uniform law. These loopholes have inspired the authors for digging deep into the problem. The authors through this article have tried to address the problem by suggesting measures to solve it.

III. WHY THERE IS NO UNIFORM LEGAL AGE FOR DRINKING IN INDIA?:

Consumption of Liquor has always been a boiling issue in India. India being a land of people believing in diverse culture, tradition, religion has different virtues and moral beliefs. It can be logically followed from the Cliché saying that “not everyone can fit into the same shoe” therefore India being a secular democratic nation never tried to fit its entire population into one frame of law. An appropriate example is the existence of different personal laws for people following different religion. India follows the principle of Unity in diversity. Therefore, every state in India has its own challenge. Considering the dissimilar needs of the different region the worthy constitution makers have put some items under the state list[8] on which the state has exclusive power to make laws according to their region specificity. The different regional needs are the reason why the liquor consumption law comes under the ambit of the state list.

a) CONFLICT IN HISTORY:

It has been seen in the 70 years history of Independent India that the different states make laws according to the requirement in their states. The topic of Liquor consumption is not welcomed in every state. In India, there are majorly three different ages i.e. 18, 21 and 25 which has been followed by the states and some states like Bihar and Gujarat has completely ban the sale. The states which have completely banned the consumption of liquor follow the ideology of Gandhi. Gandhi found alcohol against the moral beliefs and considered alcohol consumption no lesser than committing a sin. People of other states like Goa and Punjab find it essentially important part of their right to enjoyment. Gandhian ideologue states banned the complete use of alcohol for human consumption purpose in the light of article 47[9] of constitution of India but these states cannot completely negate the usefulness of alcohol on the grounds of morality since alcohol is an eminent source of revenue generation which somewhat contribute to the reduction of the poverty and employment generation. Hence, the liquor consumption has remained a contentious issue till date.

In the case of State of Bombay v. F. N. Balsara [10] the honourable supreme court of India laid down that that if the state government has enacted an act on the subject which it is constitutionally empowered to make, then it is legal. The doctrine of pith and substance played the determinant role while solving the dispute of whether liquor should be placed in Union list or State List Pith and this has been thoroughly discussed in the abovementioned case. The doctrine says “that where the question arises of determining whether a particular law relates to a particular subject (mentioned in one List or another), the court looks to the substance of the matter.”[11] Furthermore, the Supreme Court held on the same line that the state legislature has the complete power to prohibit the keeping, selling and intoxicating wine under entry 31 in the list II. There is, therefore no dispute regarding the jurisdiction of the state legislature and the central legislature. Hence, it can be inferred that having a single norm for a diversified country like India would have resulted in a conflict of interest of different states and thus chaos in Indian society. Therefore, the constitution makers did not make a single norm for its consumption and liquor was put under the state list so that each state according to the requirement would allow, disallow and restrict the age of consuming alcohol. The people who demand for a single uniform age for consuming alcohol mostly argue on the grounds that since most of the other modern developed economies have implemented a single age for consuming liquor India should follow on the same lines but the proponents of uniform law fail to consider that in a culturally diverse democracy, state action is a more effective method of controlling social behaviour.[12] Therefore for effective and efficient control, the onus has rested in the hands of the state legislature.

IV. NEED FOR UNIFORM LEGAL DRINKING AGE IN INDIA:

a) AWARENESS:

It is general research that citizens of a particular state are not aware of the legal drinking age in their respective states. Most of the people who suffer fine and prosecution do not have the intention to break laws but unfortunately are involved due to the lack of knowledge regarding that law. Different states have a different legal age for alcohol consumption and even in that, different products like Beer, liquor, Wine have their own certain minimum age to consume. For a prudent person, it turns out to be a difficult position to remember these minimum ages. Certainly, if a person somehow manages to remember the minimum legal age for all the products at least in their state, there are undoubtedly 7 Union territories and 28 other states that rules their own minimum drinking age. Now, the problem comes when the person travels from one state to another state. For an example, a person who is 19 years old from Rajasthan where the legal age for alcohol consumption is 18 year carries a bottle of Liquor to Delhi where the minimum legal age of drinking is 21 year. The problem occurs when he is not aware of such fact regarding the minimum legal age in Delhi. He could be prosecuted and a fine can be imposed of Rupees 10,000 on him.[13] It is humanly impractical to remember certain ages for different states. This is a bad law for the state as it is defeating the purpose for what the law was figured out. Primarily, a uniform age can seek out this problem. If there is a uniform age for drinking in all the states, such issues won’t hamper the functioning of law. It will be viable for a prudent person to ensure that he should respect the governing law and further needs to fulfil the obligation by keeping himself under the realm of law.[14]

In fact, in some cases, the different legal age in different states can be misused. People may travel interstate to consume alcohol. One state shares many borders with different states. In some of the cases, even one city touches 2-3 state borders. This creates an “interstate problem”.[15] This lack of uniformity among state laws provides teenagers with an incentive to drink and drive as they cross state borders in search of lower drinking age.[16] The result of every state having different minimum drinking age acts as a “crazy quilt of different States’ drinking laws and far too many blood borders where teens drive across to reach states with lower drinking ages.” Supposedly, Delhi and Haryana have adjacent borders and the legal drinking age at these places are 21 and 25 respectively. There is a very high probability that, a person who is less than 25 years and lives in Haryana will travel interstate to Delhi so that he could consume alcohol. In such cases, the whole social and economic purposes of different legal ages in different states stands defeated.

b) DISCRIMINATION BETWEEN THE PEOPLE OF DIFFERENT STATES:

As we know that the legal age of drinking is non-uniform and it varies from state to state. The issue is very genuine and needs to be highlighted. Certainly, all around the nation, a similar type of people live. There is variation between the economic and social factors but at large they all represent a single country.[17] The non-uniformity of the legal drinking age at the very first hand discriminates between the people. The current law means that an 18-year-old in Uttar Pradesh is more responsible than an 18-year-old in Delhi which is in reality not true. Under the article 14 of the India constitution, it is clearly mentioned that the State shall not deny to any person equality before the law or the equal protection of the laws within the territory of India Prohibition of discrimination on grounds of religion, race, caste, sex or place of birth[18]. Further, the only ground on which the discrimination can be done is that it should be positive discrimination which ascertains rational reason and intelligible differentia. In fact, when the right to vote and right to drive has a uniform legal age all over the country, why there is non-uniformity in case of alcohol?

The reasoning cannot be valid for the non-fixed case when other subjects which are of national importance have uniform age. Voting is a prudential subject for the nation as the whole political kingdom is selected through this system whereas driving is one of the important issues under the scope of national security. Ideally, if these two subjects that carry a lot more weightage than drinking, have a uniform age; the right to drinking itself should have a fixed legal age all over the country. John Stuart Mill said that, unless the action is self-regarding, minimum laws should be implemented on the subject and in case of alcohol for human consumption; it is a self-regarding subject unless it hinders the public morality or causes any other person a trouble. Eventually, after seeing the well-functioning of laws related to driving and voting that works on the principle of uniform drinking age, there will be no harm to the nation if alcohol consumption also applies the uniformity principle in the legal drinking age. The law is the same for all and calls for a fair and just decision universal throughout the country.

c) SMUGGLING AND BLACK MARKETING:

It is a general fact that, if a person is advised or restricted not to do anything, the probability of doing that thing highly increases. Same is the case of alcohol. Even banning the consumption of alcohol hasn’t proved a significant step in decreasing the consumption of alcohol. In fact, this has led to an increase in the smuggling rate of liquor. The high amount of liquor is smuggled at the borders of the state. In 2017, alcohol of Rs. 2 crores was confiscated by the Rajasthan police who was being taken to Gujarat.[19] 2,500 cartons of liquor from two trucks were found by the Dholpur police.[20] Certainly, this was not the only case that was reported of smuggling. If the law is unreasonable, society is sensible and intellect to break the laws. Liberty is a fundamental right for the survival of the human kind. This issue is not only for the states where the alcohol is banned but these issues are also reported in the areas where the legal age for drinking is high. Maharashtra has experienced such cases where the minimum age is set to 25.

In the era of diversification, it is impossible to restrict someone. When a person has an alternate medium to consume the things, he would obviously incline and will be dependent on that. It is on the nation to ensure that the loopholes of the law should be filled. Ideally, if the drinking age is uniform in all the states, there is less probability that the smuggling of liquor will take place. Respecting the states that have banned the consumption on the grounds of religious and state morality, there the police have to ensure the decline in smuggling rate. The uniformity of drinking age will be applicable in those states where at present there is a high variation of drinking ages.

In India itself, there are states where the legal age for drinking varies from 18years to 25 years and some of the places with an exception of 30 years. If the uniform drinking age is applied, it will automatically curb down the black marketing of the liquor because now the suppliers of the smuggled goods won’t get any benefit.

d) PUBLIC HEALTH SHOULD BE A NATIONAL SUBJECT:

As a basic human right, there is an obligation on the State to protect as well as ensure the promotion of rights that creates a favourable condition in society. Alcohol and consumption of liquor is a national issue. In an article of Indian express, it was mentioned that no amount of alcohol is good for anybody. Unfortunately, in India state has the juridical control of alcohol as it falls in the 2^nd list that ensures it to be a state subject. Public health care is a core area of concern for the National Human Rights Commission of India. The Commission has called upon the Government to adopt a rights-based approach to strengthen the public health infrastructure in the country. Regional public hearings organised by the National Human Rights Commission have shown that citizen’s right to health care is being violated on a significant scale. Hence there is a need to make the right to health care, which is one of the most basic of human rights, explicit, justiciable and operational. Given the fact that health is a State subject it tends to be a problem for any national action to be implemented in the states as they don’t implement such things.

V. PROPOSED UNIFORM DRINKING AGE IN INDIA:

After doing the exhaustive research, we came to the conclusion that the age for drinking should not be less or in another case not too high. Certainly, there is a middle path which is the median of both the extremes. If the age is too high or less, undoubtedly they have the highest chances of having defects in it.

a) PROBLEMS WITH 18 AS A UNIFORM AGE:

It has been reported that most of the crimes at the age of 18 have some of its roots lying in the over-consumption of alcohol. Alcohol as luxury can be harmful if it is over consumed. The brain after consuming alcohol starts losing its control over the body. The probability of committing a crime increases as the brain’s sensory part stops working potentially. According to the Centres for Disease Control and Prevention, or CDC, drinking by those under the age of 21 is a serious public health problem[21]. Also, the report says that most of the cases of domestic violence are directly related to alcohol. When a husband consumes alcohol more than his bodily limit, he tends to lose control of the body and does not know what his actions are. As soon as the alcohol is over consumed, the action changes from self-regarding to the other-regarding. According to Bentham, other-regarding means when your action directly or indirectly affects the action of another person. It means that the action is said to be immoral if it is an other-regarding action and hence it is not viable to make 18 as a fixed legal age for drinking.

The other demerit of 18 as a legal age would be that most of the people are at Schools or at colleges at this age. Majority of the people at this juncture are totally dependent on the money of their parents as they are not economically advanced to earn at their own. India as a developing country has a poor economic condition most of the parents cannot afford education for their students but somehow manages to provide them through loans or mortgaging their properties. Use of alcohol increases indebtedness and reduces the ability to pay for food and education, and can leave the family in destitution as funds for household expenditure are diverted to purchase alcohol. One of the researches carried out by Manipal University, it was found that out of the total alcohol consumers, 56% of consumers are under-graduate and 32% are graduates and only 12 % are Post-graduate. Current Indian Alcohol market is increasing because of the students who come in the under-graduate and graduate category as they have money to spend, time to party and likes experimenting and trying out new trends. Young alcohol consumers are quite regularly seen consuming alcohol and the purposes are several and varied. Youth often derive reasons to socialize from their favourite bottle of liquor. Hence this is the reason why alcohols are synonymous to the celebration of an occasion and having good times with peers.

If those persons who are studying start misusing the money given by parents, the economic condition of the family would be disturbed and would be highly influenced by the state of poverty. Proposing 18 as legal drinking age will indisputably disturb the socio and economic condition of India.

b) PROBLEMS WITH 25 AS A UNIFORM AGE:

In the case of 25, the effectiveness of the proposed law as a uniform age will be distressed. As per the report, 67% of the humans who consume alcohol in India are between the ages of 19 to 25[22]. The autonomy of the youngsters below 25 years of age would be neglected by the government by claiming them as incapable and irresponsible. Passing this age decision will lose the independence and respect as a responsible citizen of the country which is unacceptable.

This decision will reflect the paternalistic behaviour of the government as it will take control over the lifestyle of the younger section of the society by overseeing their interests and wishes. If at the age of 18 or 21 years, freedom to vote for the country, to marry, have children and fight for the country such responsibilities are given to the youngsters then this law would seem unreasonable in considering the 18 – 24 age people as negligent drinkers and taking away their rights by preventing them from drinks. The Government would be tagging this group of individuals as irresponsible and immature which is ethically wrong.

The 25 years age bar is not just feasible, it may also be counterproductive. Like many other unnecessary restrictions our legislators love to decorate our statute books with, this age barrier would merely drive the activity in question which in this case that the alcohol consumption by young people would be going underground. This will give upsurge the growth of alcohol and binge drinking, posing grave health risks.[23] Unreasonable laws also reinforce the culture of contempt for laws that have become widespread in our society. This law has the highest probability for opening the doors for the smuggled liquor. If the law is unjust, people have a thousand ways to break it.

c) WHY 21 YEARS IS A SUITABLE AGE FOR DRINKING?:

As per the reports carried out in the United States, it is found that in most of the road accidents involving drink and drive cases, people ranging from 18-20 years accrue the majority. The current data shows that, if the legal age is increased to 21 years, 28% decrease in automobile crashes can be achieved annually[24]. The target group of eighteen to twenty year has not been arbitrarily chosen. It has been shown through research that this age group is involved in a disproportionate number of fatal automobile crashes, which have been instigated in part, by the contemporary tendency of teenagers to drink frequently and to consume more alcohol during social gatherings. It has been observed all around the world that the key aim of the alcohol laws serves the purpose of delaying the minimum legal age for drinking. This reasoning is supported by the prudent facts that, at the very early age of drinking, people tend to get an addict if they have not achieved maturity. The lack of a matured approach during alcohol drinking for the first time can lead to severe addiction for the rest of the life. For example, the US Surgeon General’s Call to Action on underage drinking has found that; “approximately 40% of individuals who report drinking before age 15 also describe their behaviour and drinking at some point in their lives in ways consistent with a diagnosis for alcohol dependence. [25] This is four times as many as among those who do not drink before age 21 Similarly, the official UK guidance on alcohol consumption, which advice against any drinking before the age of 15 years, is supported by the statement that “early age of drinking onset is associated with an increased likelihood of developing alcohol abuse or dependence in adolescence and adulthood.

The total alcohol per capita consumption for drinkers (aged 15+) in India was 32.1 litres of pure alcohol in males and 10.6 litres of pure alcohol in females. Alcohol consumption has a direct effect on how a person behaves morally and socially. The maturity is required to handle the effect of alcohol. This does not mean that a matured man who is over drunk will not be affected. This means that the matured person will know his consumption limit in relation to the sensory control of his brain. A matured person has the ability to make informed decisions by acting quickly on its reflexes. Proposing the age of 21 as a fixed legal age will somehow decrease the immature decisions. With time and sensibility, maturity takes birth and 18-20 is such an age where the youth has just got the power and freedom. Till the time of 21, the majority of the people are termed as matured and it seems that 21 is the correct age for the minimum legal drinking age.

The minimum legal drinking age, 1984 act of the United States also worked on 21 as the minimum legal age for drinking. They didn’t come out with 21 randomly. They believed in the concept that a person converts into a complete adult at age 21 dates back centuries in English common law; 21 was the age at which an individual could, among other things, vote and become a knight. Since a person was an official adult at age 21, it seemed to make sense that they could drink then, too. Certainly, 21 as a minimum age have been turned out to be an effective decision. Till the time, more than 25,000 people are saved from road accidents or the accidents caused by over-drinking. The other report shows the 61 percent decrease in alcohol-related fatalities among motorists who are less than 21 years between 1982 and 1998.[26] If the country like the United States has relied on the 21 years as the legal age for drinking and in respect to other countries who have also relied on 21, the proposed legal age for the consumption of alcohol should also be 21. This has the highest probability of coming out as a success. In fact, this will help in controlling the number of addicts in India and it will ensure that the crime rate will attenuate.

VI. CONCLUSION:

India is one of the countries in which approximately 50% of the citizens are under 25 years. There is an immediate need to regulate liquor consumption with an effective national policy. Nation has its duty to safeguard the health of the public and to ensure that in no sense there is a violation of article 21 or any of the rights. Liquor has obvious side-effects and if the legislatures fail to draft a regulatory policy, the denizens of India would surely fall into an abyss. Alcohol, at present, is a state subject but there is an effective need of interference of the centre in this subject.

Uniform legal age for drinking is the need for an hour. As India flaunts its diversity, same needs to be protected and for that law which deals with the primary issues must be in control of centre for better and robust regulation like right to vote, right to drive, right to marry; right to liquor should also have a uniform age and in fact, there is also a need to a national policy dealing with all the laws relating to the alcohol.

At the very first level, it should be ensured that proper education should be given in regard to the harmful effects of consuming alcohol. Secondly, prohibition cannot be the correct step as it would only increase the rate of smuggled goods so the suitable step should be drafting a separate legislature. A national commission should be created to see the current scenario and to conduct and explanatory research between the two variables; Indians and alcohol. Further, with the exact result and the reports, the legislature should be drafted. The proposed age of 21 years can be one of the recommendations as the developed and many developing states have relied on this age. From the very beginning of human society, 21 years is considered as an age when the man finally becomes mature. In regard to this, 21 years as a uniform drinking age will help in improving the existing picture of the nation and will make sure progressive development.

[1] George Bernard Shaw.

[2] Oxford Online Dictionary.

[3] World Health Organisation , Global status report on alcohol and health ,p-16,  http://www.who.int/substance_abuse/publications/global_alcohol_report/msbgsruprofiles.pdf.

[4] Constituent Assembly Debates On 24 November, 1948, https://indiankanoon.org/doc/1945234/ .

[5] The Times Of India , Indians Drinking Alcohol up 55% in last 20 years , May 17^th 2015, https://timesofindia.indiatimes.com/india/Indians-drinking-alcohol-up-55-in 20years/articleshow/47313965.cms.

[6] Indian Constitution, Article 47.

[7] State of Kerala v. Kandath Distilleries, A.I.R 2013 S.C. 1812 (India).

[8] Indian Constitution, Schedule 12, State list.

[9] supra note 6.

[10] 1951 A.I.R. 318, 1951 S.C.R. 682 (India).

[11] P.M Bakshi, Concurrent Powers of Legislation under List III of the Constitution, Background paper, www.legalaffairs.gov.in.

[12] Kevin Kadlec , National Minimum Drinking Age Act of 1984: Once Again Congress Mails Home Another Fist, Cleveland State Law Review, 1986.

[13] IANS. “Underage Drinking Rampant in Delhi: Survey” INDIA TODAY, 1 Feb. 2009, www.indiatoday.in/latest-headlines/story/underage-drinking-rampant-in-delhi-survey-38621-2009-02-01.

[14] Liquor and Drinking Laws in India., LawRato.com, lawrato.com/indian-kanoon/criminal-law/liquor-and-drinking-laws-in-india-646.

[15] Shekhar, Kumar Shakti. Modi Must Either Ban Alcohol or Allow It in All States for Same Price,  DailyO – Opinion News & Analysis on Latest Breaking News India, Living Media India Limited, 25 Sept. 2015, www.dailyo.in/politics/liquor-ban-narendra-modi-make-in-india-licence-raj-gst-bootleggers/story/1/6453.html.

[16] Staff reporter “Haryana Border Turns into Haven for Liquor Smuggling.” , The Hindu, 4 Aug. 2014, www.thehindu.com/news/cities/Delhi/haryana-border-turns-into-haven-for-liquor-smuggling/article6279283.ece.

[17] Yoshimitsu Takie, et al. To Drink or Not To Drink: The Indian Adolescents’ Choice Between Friends and Family, vol. 27, JOURNAL OF AMERICAN INDIAN EDUCATION, v, pp. 1–9, 1988.

[18] Indian Constitution, Article 14.

[19] Correspondent, Special. Liquor Smugglers on the Wrong Track in Dry Bihar, The Hindu, The Hindu, 5 May 2018, www.thehindu.com/news/national/other-states/liquor-smugglers-on-the-wrong-track-in-dry-bihar/article23781018.ece.

[20] Dev Ankur Wadhwan, Rajasthan: Liquor Worth Rs 2 Crore Meant for Gujarat Seized from Dholpur, India Today, 11 Dec. 2017, www.indiatoday.in/india/story/rajasthan-liquor-worth-rs-2-crore-meant-for-gujarat-seized-dholpur-1105156-2017-12-11.

[21] The Legal Drinking Age: 18, 21, or 25?, Addiction Treatment | Elements | Drug Rehab Treatment Centres, 18 Apr. 2016, www.elementsbehavioralhealth.com/adolescent-issues/legal-drinking-age.

[22] Richa Banka., Delhi’s Drinking Age Too High? Court Will Decide, Hindustan Times, 25 May 2018, www.hindustantimes.com/delhi-news/delhi-s-drinking-age-too-high-court-will-decide/story-9neHq23a2Au9BxSDHfLguK.html.

[23] International Center for Alcohol Policies. Guide to Creating Integrative Policies. pdf , 2016 Apr 15, http://www.icap.org/ Portals/0/download/all_pdfs/Policy%20Tools/Guide%20to%20Creating%20 Integrative%20Policies.pdf.

[24] CDC. Alcohol-Related Disease Impact (ARDI) application. (2013), December 17, 2015, www.cdc.gov/ardi.

[25]ALCOHOL & HEALTH notes, U.S. Dept. of Health, Educ. and Welfare, Oct. 1973.

[26] Why Is the Drinking Age 21?, Mental Floss, 8 Apr. 2018, www.mentalfloss.com/article/19437/why-drinking-age-21.