In addition to these original orders, forty-seven Presidential orders were issued between 11 February 1956 and 19 February 1994, making various other provisions of the Constitution of India applicable to Jammu and Kashmir. All these orders were issued with the 'concurrence of the Government of the State' without any Constituent Assembly. Some of these Presidential orders were issued when the state was under President's rule and had "no Kashmir government at all", states Jill Cottrell. The concurrence in this instance was given by the Governor of the state, a nominee of the Union government. Such an interpretation was upheld by the Supreme Court of India in 1972.