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Shri P. Babulu Reddy Foundation Lecture victims of Crime - the unseen side†
by Dr. Justice A.S. Anand, Judge, Supreme Court of India

Cite as : (1998) 1 SCC (Jour) 3

I am grateful to the Trustees of Shri P. Babulu Reddy Foundation for inviting me to deliver the Foundation Lecture for the year 1997.

I have not had the pleasure of meeting Shri P. Babulu Reddy personally but from many who knew him well, I have learnt that he was a colossus of the legal profession for over a period of three decades and commanded the respect of the Bench, esteem of the Bar and confidence of the clientele in an unsurpassed measure. He was a brilliant advocate with an equally brilliant academic record. Mr Babulu Reddy was enrolled as an advocate in 1948 in the High Court of the composite Madras State and got trained in the chambers of Shri P. Chandra Reddy. When Shri Chandra Reddy was elevated to the Bench, Shri Babulu Reddy set up independent practice and very soon established a good practice. When Andhra State was formed, he moved to Guntur and from Guntur to Hyderabad. He had the reputation for hard work and high degree of forensic skill. He was clear-headed. I am told that he had a remarkable ability to outsmart his opponent with a torrent of facts laced with legal principles in a confident, deliberate and assertive manner of advocacy which at the same time did not produce any animosity in the opponent or unpleasant comments from the Bench. The legal fraternity showered their admiration and affection on Shri Babulu Reddy immensely. He was President of the High Court Advocate's Association. He was also elected to the Rajya Sabha from Andhra Pradesh in 1982. I have been greatly impressed by what I have learnt about him and therefore take pleasure to deliver the Foundation Lecture for 1997 in his memory.

I now come to the subject of the lecture today.

VICTIMS OF CRIME - THE UNSEEN SIDE

The history of crime is as old as mankind itself. This evil has existed since the dawn of civilization. The primitive societies had some basic customs and taboos which were respected by all members of the society. The respect for the customs and taboos was actuated by the belief that anyone who violated the custom would be punished by God. "A tooth for tooth" and "eye for an eye" - the theory of retaliation - which often led to bloodshed was also prevalent in some primitive societies. As civilization advanced, new ideas regarding the individual's rights and his duty towards his fellow human beings developed and crime was no longer considered an offence against an individual but a revolt against the whole society and an attack on the civilization of the day. Soon the State took upon itself the right to punish the offender. Crime began to be classified and penal laws were enacted to deal with criminals. However, the rising crime rate in the post-independence era and the inadequacy of the law in balancing individual's liberty and State's duty to ensure protection of life and liberty has made the criminal justice system a subject of heated debates but despite the concern over the shortcomings of the system to check the growing crime rate, we are still unable to check the rise in crime. But what appears to be certain is that more police, more prisons, more laws, more courts will not achieve the object of bringing about reform in the system of criminal justice and check the growing crime rate. Giving the victim of crime his rightful place and taking a serious note of his existence, his feelings and his rights with a view to offer redress to him for his "injuries" may in the long run help check the rising graph of crime. One of the basic criticism against the present system of criminal justice is that it has failed in its essential purpose of protecting the society by deterring crime and, therefore, the system needs to be given a second look and when we do give that second look, let us see how the victim of crime is to be treated by the society and by the courts, so as to become an active participant in the justice delivery system. Who is a victim of crime? Generally speaking, the society as a whole and talking specifically, the injured individual himself or his family and sometimes a group or even unidentified or unborn persons. In the scheme of the present justice delivery system, does the law render any help to him to provide a restitutive content to his suffering.

Victims are unfortunately the forgotten people in the criminal justice delivery system. Our criminal justice system, like all such systems, stemming from the Anglo-Saxon pattern, tends to take the victim for granted and is more concerned with the offender, his activities, his rights and his correctional needs. Only recently, long after the Second World War, as a result of the activities of certain progressive thinkers and activists in various advanced countries, like the UK, Canada, USA, Australia and New Zealand, the focus has marginally shifted towards the unfortunate victim, who generally is the most injured party in the crime and also the party who naturally deserves redress but often does not get it. Canada-Monitoba enacted the Justice for Victims of Crime Act, 1986. New Zealand has also enacted Victim of Offences Act, 1987. In the United Kingdom, Criminal Justice Act, 1988 has made fresh provisions for payment of compensation by the Criminal Injuries Compensation Board. Australia has also enacted a legislation based on the U.N. Declaration of 1985. Victims of Crime Act became a part of Federal Law in the United States in 1984.

The rights of an accused or a convict, which are well safeguarded both by the Constitution and other laws of the country have often been discussed and debated at various conferences and seminars, but in all these there has been hardly any reference to the "rights" of the victims of crime. Should the victim of crime continue to be also victim of law's myopia? Does he not matter? Is he irrelevant in the scheme of justice delivery system? Can his "recognition" help in checking the rising crime rate? These are some of the questions which have prompted me to choose this topic for today's lecture.

The term victim is lacking descriptive precision. It implies more than the mere existence of an injured party, in that innocence or blamelessness is suggested as well as a moral claim to a compassionate response from others. The term victim is defined in Oxford English Dictionary as:

"Victim is a person who is put to death or subjected to misfortune by another; one who suffers severely in body or property through cruel or oppressive treatment; one who is destined to suffer under some oppressive or destructive agency; one who perishes or suffers in health etc., from some enterprise or pursuit voluntarily undertaken."

As per Collins English Dictionary,

" 'victim' means a person or thing that suffers harm, death, etc. from another or from some adverse act, circumstance, etc.,;"

and it is defined in the Black's Law Dictionary as:

"the person who is the object of a crime or tort, as the victim of a robbery is the person robbed".

According to New Webster's Dictionary, victim means:

"a person destroyed, sacrificed, or injured by another, or by some condition or agency; one who is cheated or duped; a living being sacrificed to some deity, or in the performance of a religious rite."

Every crime has a victim and ignoring him and not making any attempt to provide him solace or restitution, would be a challenge to protection of his human rights also.

The present criminal system of justice is loaded heavily in favour of the accused because under the accusatorial system an accused is presumed to be innocent till proved guilty and the burden of proof always rests on the prosecution.

The presumption of innocence gives right to various constitutional and legal rights insofar as an offender is concerned. His right not to be arrested except in accordance with the law, right to be produced before the Magistrate within 24 hours of his arrest, right to know the grounds of his arrest, right to be represented by a counsel, right to legal aid in respect of certain cases, right to bail, right to public trial, right to test evidence by cross-examining, right to be heard about the sentence, immunity from compulsory testimony and so on and so forth.

Thus, the criminal justice system today is basically concerned with criminals, whether it is their conviction, treatment, reformation or rehabilitation. The purpose of criminal justice system appears, at present, to be confined to the simple object of ascertaining guilt or innocence and use the victim only as a witness. Since, the central object of legal process is to promote and maintain public confidence in the administration of justice, therefore there is an urgent need for giving a well-defined status to the victim under the criminal law. His interest in getting the offender punished cannot be ignored or completely subordinated to the interest of the State. Otherwise, the victim will remain discontended and may develop a tendency to take the law into his own hands in order to seek revenge.

A victim of crime or his heirs after suffering at the hands of the offender have the choice to either move a court of law or go to the police station to seek redressal of the grievance. For him unfortunately neither of the two is an attractive proposition. If he is hesitant to approach the police station for the reasons which are by no means unknown, his reluctance to approach the court is also not without reason.

If he opts for the first which is understandably less expensive and less arduous his expectations are not always met because what the law provides is not always practised and the police in this country with exceptions here and there has unfortunately failed to inspire confidence in the minds of the society. There are complaints of police indifference when they go to report crime which not only discourages him but also makes him an object of ridicule. The Tamil Nadu Police Commission found and it is a matter of record that when a person goes to a police station with a complaint no one listens to him willingly or patiently. May be it is because of the fact that police today is overburdened, it has a variety of roles to perform and the investigation of cases therefore receives a poor priority. Under the existing criminal laws in our country the victim is not having any right to ensure that the crime is properly and effectively investigated by the police. It will be in the interest of justice to recognise the right of the victim in cognizable offences to know about the progress in the investigation as well as an opportunity to provide relevant evidence apart from making the statement. If the police is going to file a final report before the magistrate, the victim (or the first informant) must be heard. No final report of closure of a case should be accepted by the Magistrate without notice to the de facto complainant and providing him with an opportunity of having his say. The Supreme Court in Bhagwant Singh v. Commr. of Police1 (followed in Union Public Service Commission v. S. Papaiah2) has read into the requirements of Section 173 CrPC, the necessity to issue such a notice. This Court said: (SCC pp. 542-43, para 4)

"There can, therefore, be no doubt that when, on a consideration of the report made by the officer in charge of a police station under sub-section (2)(i) of Section 173, the Magistrate is not inclined to take cognizance of the offence and issue process, the informant must be given an opportunity of being heard so that he can make his submissions to persuade the Magistrate to take cognizance of the offence and issue process. We are accordingly of the view that in a case where the Magistrate to whom a report is forwarded under sub-section (2)(i) of Section 173 decides not to take cognizance of the offence and to drop the proceeding or takes the view that there is no sufficient ground for proceeding against some of the persons mentioned in the first information report, the Magistrate must give notice to the informant and provide him an opportunity to be heard at the time of consideration of the report." (emphasis supplied)

So far as the second option is concerned, i.e., to go to the court, apart from the expense involved, the obligation to appear on every date of hearing is quite a deterrent.

In the present system of criminal justice, speaking generally, offences registered by the police are treated as offences against the State which gets an offence investigated by its agency, moves the court for trial of the offender and prosecutes him in a court of law. Right to bail is regarded as a right of the accused but there is no corresponding right available to the victim or his heirs to oppose bail. It is left to the State only to oppose or not to oppose the grant of bail. Neither at the stage of the framing of a charge or passing an order of discharge are the views of the victim ascertained, let alone considered. He is not to be consulted. Even after the case ends up in a conviction, it is the State which defends the judgment of the trial court in appeal, if any, filed against the conviction and sentence. The victim of crime has hardly any role to play in the whole proceedings except that he may, if alive, be examined by the prosecution as a witness. Under the CrPC, a victim of crime has got a very limited right of revision and that too under exceptional circumstances. An accused has the statutory right to be heard on the question of quantum of sentence after conviction is recorded, but unfortunately a victim of the crime is not so heard. It is strange that in spite of the fact that a victim of crime, who suffers at the hands of the accused and moves the State through the police or the courts to seek justice, is given the impression that after having lodged the report or the complaint, he is a "Mr Nobody". Even where he engages a counsel, during the trial of a case, instituted on a police challan or at the hearing of the appeal, his counsel is treated only as a "counsel by sufferance" and may or may not be heard by the court depending upon the attitude of the State counsel. He can at the best assist the public prosecutor but that also in case the public prosecutor really wants to be assisted by him. A victim of crime is, thus, a mute witness to the whole drama. If alive, he may appear as a witness and there again the provision of Evidence Act of relevancy of facts notwithstanding, he is subjected to continual questioning, with the court almost silently watching. Expressing concern about the treatment of victims of sexual offences in the courts during their cross-examination, in State of Punjab v. Gurmit Singh3 I emphasised: (SCC pp. 403-04, para 22)

"22. There has been lately, lot of criticism of the treatment of the victims of sexual assault in the court during their cross-examination. The provisions of Evidence Act regarding relevancy of facts notwithstanding, some defence counsel adopt the strategy of continual questioning of the prosecutrix as to the details of the rape. The victim is required to repeat again and again the details of the rape incident not so much as to bring out the facts on record or to test her credibility but to test her story for inconsistencies with a view to attempt to twist the interpretation of events given by her so as to make them appear inconsistent with her allegations. The court, therefore, should not sit as a silent spectator while the victim of crime is being cross-examined by the defence. It must effectively control the recording of evidence in the court. While every latitude should be given to the accused to test the veracity of the prosecutrix and the credibility of her version through cross-examination, the court must also ensure that cross-examination is not made a means of harassment or causing humiliation to the victim of crime. A victim of rape, it must be remembered, has already undergone a traumatic experience and if she is made to repeat again and again, in unfamiliar surroundings what she had been subjected to, she may be too ashamed and even nervous or confused to speak and her silence or a confused stray sentence may be wrongly interpreted as 'discrepancies and contradictions' in her evidence."

After the evidence is recorded and arguments heard comes the verdict of the accused being guilty or not guilty - a matter of great concern to the victim of crime.

It humiliates and frustrates a victim of crime when the offender goes unpunished or is let off with a relatively minor punishment as the present system pays no attention to his injured feelings. Imposition of appropriate punishment on the criminal is the response of the courts to the society's cry for justice. Indifference to the rights of the victim of crime is fast eroding the faith of the society in general and the victim of crime in particular in the criminal justice system and this has already given rise to the incidents of crime and lawlessness, in the form of terrorism, which is raising its ugly head to settle private and political scores over the adversary with the barrel of gun.

Dealing with the object of sentencing, in the case of Bheru Singh v. State of Rajasthan4, where the appellant had murdered his wife and five children, the Court observed: (SCC p. 481, para 28)

"The object of sentencing should be to see that the crime does not go unpunished and the victim of crime as also the society has the satisfaction that justice has been done to it. In imposing sentences in the absence of specific legislation, judges must consider variety of factors and after considering all those factors and taking an overall view of the situation, impose sentence which they consider to be an appropriate one. Aggravating factors cannot be ignored and similarly mitigating circumstances have also to be taken into consideration.

In our opinion, the measure of punishment in a given case must depend upon the atrocity of the crime; the conduct of the criminal and the defenceless and unprotected state of the victim. Imposition of appropriate punishment is the manner in which the courts respond to the society's cry for justice against the criminals. Justice demands that courts should impose punishment befitting the crime so that the courts reflect public abhorrence of the crime. The courts must not only keep in view the rights of the criminal but also the rights of the victim of crime and the society at large while considering imposition of appropriate punishment."

In ancient times victimized person himself used to choose the offender's punishment and, if possible, inflict it. In early societies the relationship of criminal and victim basically reflected a raw struggle for power and survival and the right of the individual victim to take vengeance was of paramount importance. With the development of society this right of victim to take vengeance was transformed from individual to the group by considering any act of aggression against a member of the group as aggression against the whole group. With the occurrence of the barter economy the society accepted money or goods as symbolic compensation and restitution of crime in place of punishment or along with punishment.

Victims of war and accidents have the right to claim compensation under the statute. But there is no such right available to other victims, though compensation has been awarded in a few cases, at the discretion of the court and some statutory provisions have also been enacted in the Criminal Procedure Code.

A victim of crime has hardly any guaranteed right except may be of getting some assistance by way of payment of compensation, but even here the statutory provisions are grossly inadequate. These provisions suffer from inherent limitations also about the extent of fine, capacity of the criminal to pay and the like. Award of fair and reasonable compensation to the victim might act as a balm on his wound, and may also deter to whatever little extent, the criminal but there is no such statute in this country which takes care of it.

Under the Probation of Offenders Act, 1958 while releasing an accused on probation or with admonition, the Court may order the offender to pay compensation and cost to the victim under Section 5 of the Act. Similarly, Section 250 (compensation for accusation without reasonable cause), Section 357 (order to pay compensation out of fine or even without a sentence of fine), Section 358 (compensation up to Rs 100 to persons groundlessly arrested) and Section 359 (order to pay cost in non-cognizable cases) of Criminal Procedure Code, 1973, provide for payment of compensation and costs to the victims of crime under different circumstances.

Section 357 empowers the Court imposing the sentence to order the whole or part of the fine, if any, imposed to be applied in the payment to any person of compensation for any loss or injury caused by the offence, provided such compensation is recoverable in a civil court. Similarly, compensation may be paid at the sentencing stage to persons who are, under the Fatal Accidents Act (13 of 1855), entitled to recover damages from the convict.

Section 358 of the Code, provides for a small compensation payable to an illegally arrested person by any other person who causes a police officer to arrest him. What is noteworthy is that a prosecution is the sine qua non for an order of compensation.

Thus, if there is no prosecution or no sentence, there can be no compensation.

Emotional assistance or charity has its own limitations. A permanent mode of compensation has to be worked out. It may be worth considering as to whether the State which fails to protect the life and property of the citizen should not be made to pay compensation to the victim of the crime because provisions for payment of compensation, out of the fine imposed, with all its limitations, are rather illusory, of course, reserving the right of the State to reimbursement from the guilty. Setting up of a fund for payment of compensation to victims of crime as is in vogue in Canada, Australia, New Zealand, United Kingdom, under the control of a Board for awarding compensation to victims of crime would be a positive and a welcome step to assure the victims of crime that "We care".

In a number of cases, the Supreme Court has laid down some guidelines with regard to assessment of just and reasonable compensation to be paid to the victims of accidents. Though in some hard cases, either no compensation was paid or inadequate compensation was paid, yet it is generally found that the courts and tribunals have been liberal in granting compensation to such victims in accordance with the observations made by the Supreme Court.

In Hari Singh v. Sukhbir Singh5 the Court said:

"Section 357(2) is an important provision but courts have seldom invoked it. Perhaps due to ignorance of the object of it. It empowers the court to award compensation to victims while passing judgment of conviction. In addition to conviction, the court may order the accused to pay some amount by way of compensation to the victim who has suffered by the action of the accused. It may be noted that this power of courts to award compensation is not ancillary to other sentences but it is in addition thereto. This power was intended to do something to reassure the victim that he or she is not forgotten in the criminal justice system. It is a measure of responding appropriately to crime as well as reconciling the victim with the offender. It is, to some extent, a constructive approach to the crimes. It is indeed a step forward in our criminal justice system."

When sovereign functions are purportedly done by bosses and minions of Government and the citizens are damnified, sovereign immunity is often invoked. When a soldier shoots at a citizen without any justification or a police officer tortures an innocent citizen in his custody, no democracy which honours human rights can vaccinate the Republic against liability for criminal or wrongful conduct. Such immunization negates the rule of law and discriminates unjustly in favour of the sovereign.

The Supreme Court in Nilabati Behera v. State of Orissa6 held that the concept of sovereign immunity is not applicable to the cases of violation of the right to life and liberty guaranteed by Article 21 of the Constitution. The Court observed: (SCC pp. 762-63, para 17)

"[A] claim in public law for compensation for contravention of human rights and fundamental freedoms, the protection of which is guaranteed in the Constitution, is an acknowledged remedy for enforcement and protection of such rights, and such a claim based on strict liability made by resorting to a constitutional remedy provided for the enforcement of a fundamental right is 'distinct from, and in addition to, the remedy in private law for damages for the tort' resulting from the contravention of the fundamental right. The defence of sovereign immunity being inapplicable, and alien to the concept of guarantee of fundamental rights, there can be no question of such a defence being available in the constitutional remedy. It is this principle which justifies award of monetary compensation for contravention of fundamental rights guaranteed by the Constitution, when that is the only practicable mode of redress available for the contravention made by the State or its servants in the purported exercise of their powers, and enforcement of the fundamental right is claimed by resort to the remedy in public law under the Constitution by recourse to Articles 32 and 226 of the Constitution."

The Court went on to say: (SCC p. 764, para 21)

"Anyone who has been the victim of unlawful arrest or detention shall have an enforceable right to compensation."

And then observed: (SCC p. 768, para 33)

"The old doctrine of only relegating the aggrieved to the remedies available in civil law limits the role of the courts too much as protector and guarantor of the indefeasible rights of the citizens. The courts have the obligation to satisfy the social aspirations of the citizens because the courts and the law are for the people and expected to respond to their aspirations."

It was further opined: (SCC p. 768, para 32)

"No one can suppose that the executive will never be guilty of the sins that are common to all of us. You may be sure that they will sometimes do things which they ought not to do; and will not do things that they ought to do. But if and when wrongs are thereby suffered by any of us what is the remedy? Our procedure for securing our personal freedom is efficient, our procedure for preventing the abuse of power is not. Just as the pick and shovel is no longer suitable for the winning of coal, so also the procedures of mandamus, certiorari, and actions on the case are not suitable for the winning of freedom in the new age. They must be replaced by new and up-to-date machinery by declarations, injunctions and actions for negligence.... This is not the task for Parliament ... the courts must do this. Of all the great tasks that lie ahead, this is the greatest. Properly exercised, the new powers of the executive lead to the Welfare State; but abused they lead to a totalitarian State. None such must ever be allowed in this country."

The Court dealing with the relief of granting compensation as "exemplary damages" said: (SCC pp. 768-69, para 34)

"Therefore, when the court moulds the relief by granting 'compensation' in proceedings under Article 32 or 226 of the Constitution seeking enforcement or protection of fundamental rights, it does so under the public law by way of penalising the wrongdoer and fixing the liability for the public wrong on the State which has failed in its public duty to protect the fundamental rights of the citizen. The payment of compensation in such cases is not to be understood as it is generally understood in a civil action for damages under the private law but in the broader sense of providing relief by an order of making 'monetary amends' under the public law for the wrong done due to breach of public duty of not protecting the fundamental rights of the citizen. The compensation is in the nature of 'exemplary damages' awarded against the wrongdoer for the breach of its public law duty and is independent of the rights available to the aggrieved party to claim compensation under the private law in an action based on tort, through a suit instituted in a court of competent jurisdiction or/and prosecute the offender under the penal law."

The Supreme Court in State of M.P. v. Shyamsunder Trivedi7 found that the victim died in police custody as a result of extensive beating given to him. The Sub-Inspector of Police was sentenced to pay a fine of Rs 50,000 and other accused sentenced to pay Rs 20,000 each and the entire amount of fine on realisation was directed to be paid to the heirs of the deceased.

The existing procedure for getting compensation is also time-consuming and creates many problems for the victim as he has to first go through a criminal trial to establish the culpability of the offender and then go through a civil trial for getting proper compensation as the compensation under Section 357(2) CrPC is almost illusory. This should be put to an end in the new victimologically-oriented jurisprudence by providing that both the trials, i.e., the trial for finding culpability of the offender and for award of compensation to the victim should be synthesized into one trial so that both the objectives can be achieved within the same period. The court trying the accused, may at the stage of consideration of award of appropriate sentence call upon the de facto complainant to establish his case for award of proper compensation and while delivering the final verdict of sentence also award compensation as a "decree of the civil court". This will considerably mitigate the problems of the victim in getting compensation and avoid further litigation and suffering and would be less expensive also.

The United Nations General Assembly in November 1985, adopted the declaration of "Basic Principles of Justice for Victims of Crime and Abuse of Power". This declaration is the magna carta of the Rights of Victims globally. The declaration has made certain suggestions for dealing with the problems of victims of crime including victims of abuse of power. Some of the suggestions which deserve a special note are:

(a) Victims should be treated with compassion and respect for their dignity. They are entitled to access to the mechanisms of justice and to promote redress, as provided for by national legislation, for the harm that they have suffered.

(b) Judicial and administrative mechanisms should be established and strengthened where necessary to enable victims to obtain redress through formal or informal procedures that are expeditious, fair, inexpensive and accessible. Victims should be informed of their rights in seeking redress through such mechanisms.

(c) Informing victims of their role and the scope, timing and progress of the proceedings and of the disposition of their cases, especially where serious crimes are involved and where they have requested such information.

(d) Allowing the views and concerns of victims to be presented and considered at appropriate stages of the proceedings where their personal interests are affected without prejudice to the accused and consistent with the relevant national criminal justice system.

(e) Providing proper assistance to victims throughout the legal process.

(f) Taking measures to minimize inconvenience to victims, protect their privacy where necessary, and ensure their safety, as well as that of their families and witnesses on their behalf, from intimidation and retaliation. Avoiding unnecessary delay in the disposition of cases and the execution of orders or decrees granting awards to victims.

It is therefore, high time that rights of the victim of crime are recognised in this country - it may in the longer run help in checking the rise in the crime rate and also bring credibility to the criminal justice system. A beginning can be made by bringing about a model legislation based on the U.N. Declaration of 1985 and by setting up a fund for payment of compensation to the victims of crime under an independent Board for Awarding Compensation to the Victims of Crime. The State which creates the fund should be entitled to complete reimbursement from the offender or the guilty party in the same manner as a decree-holder, the manner of reimbursement in cash or kind being left to the State to be decided on the facts of each case and the capacity of the individual. It may be treated as a charge on the estate of the offender or the guilty party. It is necessary that due notice is paid to the victim of crime to assure him that the society cares and feels for him. He needs justice and the society is obliged to give him justice and not merely lip service. Let us make a beginning. Ladies and Gentlemen, I take your leave and thank you for a patient hearing.

† Delivered at Hyderabad on 28th of September 1997 Return to Text

1. (1985) 2 SCC 537 : 1985 SCC (Cri) 267 Return to Text
2. (1997) 7 SCC 614 : 1997 SCC (Cri) 1112 Return to Text
3. (1996) 2 SCC 384 : 1996 SCC (Cri) 316 Return to Text
4. (1994) 2 SCC 467 : 1994 SCC (Cri) 555 Return to Text
5. (1988) 4 SCC 551 : 1988 SCC (Cri) 984 Return to Text
6. (1993) 2 SCC 746 : 1993 SCC (Cri) 527 Return to Text
7. (1995) 4 SCC 262 : 1995 SCC (Cri) 715 Return to Text