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It was found to be more fundamental than the other laws. It should therefore be the first law, but at that time, renumbering all the laws was deemed impractical, since the terms "First Law" and "Second Law" were already well-established.

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Q: Why Zeroth law of thermodynamics is not called as 3 Rd law of thermodynamics though it was discovered after 1 and 2 law?
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