Central University of South Bihar

School of Law & Governance

Project Topic: Assault and Criminal Force

Under the supervision of: Dr. Pawan Kumar Mishra

(Faculty, Law of Crimes – 1, School of Law & Governance)

Submitted by: Nishant Kumar

Course: BA LLB (Hon.)

Semester: 3rd

Enrolment Number: CUSB1713125025

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Acknowledgement
I would like to express my gratitude to my professor Dr. Pawan Kumar Mishra for providing
me invaluable guidance, comments and suggestions throughout the course of the project and
for constantly motivating me to work hard. I am very thankful to him for giving me this
golden opportunity to do this wonderful project on the topic Criminal Force and Assault and
I came to know about so many new things while doing this project. I really am very thankful
to her.

The success and final outcome of this assignment required a lot of guidance and I am
extremely fortunate to have got this all along the completion of this project work and could
not forget to thank her. Whatever I have done is only due to such guidance and assistance.

Thanks..!

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Index
Contents Page no.
1. Acknowledgement 2
2. Introduction 4
3. Criminal Force 5
4. Assault 8
i. Essential Ingredients 8
ii. Difference between Assault and Criminal Force 9
iii. Punishment for Assault 10
5. Aggravated forms of Assault or Criminal Force 11
i. To Deter a Public Servant 11
ii. To Woman to Outrage her Modesty 12
iii. To Dishonour a Person 15
iv. To Commit Theft 15
v. To Confine a Person 15-16
vi. Assault on Grave & Sudden Provocation 16
6. Conclusion 17
7. Reference 18

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Introduction

Criminal force is equivalent to ‘battery’ in English law, which means the intentional infliction of
force by one person upon another against latter’s consent. Force can also be put in a positive or
good use. For instance, pulling a person away from fire, so as to save him from being burnt, or
pushing or dragging a person so as to prevent him from being run down by a vehicle are some of
examples of force put to good use. But when the force is used to hurt someone intentionally then
it becomes ‘criminal force’.
When a person show some gestures or our hand movements which clearly indicates that he is
going to use criminal force against some other person then it is called ‘assault’. Assault,
according to English law is a threat of violence exhibiting an intention to use criminal force, and
intention to carry out the threat into execution. There must in all cases be the means to carry out
the threat into effect.

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Criminal Force
For understanding criminal force we will need to know what ‘force’ itself is. Section 349 of the
Indian Penal Code, 1860 explains what amounts to force.

Section 349. Force- A person is said to use force to another if he causes motion, change of
motion, or cessation of motion to that other, or if he causes to any substance such motion or
change of motion, or cessation of motion as brings that substance into contact with any part of
that other’s body, or with anything which that other is wearing or carrying, or with anything so
situated that such contact affects that other’s sense of feeling:

Provided that the person causing the motion, or change of motion, or cessation of motion,
because that motion, or change of motion, or cessation of motion in one of the three ways
hereinafter described:

First – By his own bodily power.

Secondly – By disposing any substance in such a manner that the motion, or change of
motion, or cessation of motion takes place without any further act on his part, or on the part
of any other person.
Thirdly – By inducing any animal to move, to change its motion, or to cease to move.
The term force can be defined as the exertion of energy or strength producing a movement or
change in the external world. The force is here used by a human being on another human being.
Thus a motion or change of motion or cessation of motion caused to property without affecting a
human being is not the ‘use of force to another’ within the meaning of this section.

The force defined in this section becomes criminal force when (i) it is used in order to the
committing of the offence and is used without consent and (ii) when it is intentionally used to
cause injury, fear or annoyance to some other person. Criminal force is defined in the section
350 of the Indian Penal Code, 1860.

Section 350. Criminal Force- Whoever intentionally uses force to any person, without that
person's consent, in order to the committing of any offence, or intending by the use of such force
to cause or knowing it to be likely that by the use of such force he will cause injury, fear or
annoyance to the person to whom the force is used, is said to use criminal force to that other.

Illustrations

(a) Z is sitting in a moored boat on a river. A unfastens the moorings, and thus intentionally
causes the boat to drift down the stream. Here A intentionally causes motion to Z, and he
does this by disposing substances in such manner that the motion is produced without any
other act on any part. A has therefore intentionally used force to Z; and if he has done so
without Z's consent, in order to the committing of any offence, or intending or knowing it
to be likely that this use of force will cause injury, fear or annoyance to Z, A has used
criminal force to Z.

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(b) Z is riding in a chariot. A lashes Z's horses, and thereby causes them to quicken their
pace. Here A has caused change of motion to Z by inducing the animals to change their
motion. A has therefore used force to Z, and if A has done this without Z's consent,
intending or knowing it to be likely that he may thereby injure, frighten or annoy Z, A has
used criminal force to Z.
(c) Z is riding in a palanquin. A, intending to rob Z, seizes the pole and stops the palanquin.
Here A has caused cessation of motion to Z, and he has done this by his own bodily
power. A has therefore used force to Z, and as A has acted thus intentionally without Z's
consent, in order to the commission of an offence, A has used criminal force to Z
(d) A intentionally pushes against Z in the street. Here A has by his own bodily power moved
his own person so as to bring it into contact with Z. He has, therefore, intentionally used
force to Z; and if he has done so without Z's consent, intending or knowing it to be likely
that he may there by injure, frighten or annoy Z, he has used criminal force to Z.
(e) A throws a stone, intending or knowing it to be likely that the stone will be us brought
into contact with Z, or with Z’s clothes, or with something carried by Z, or that it will
strike water, and dash up the water against Z’s clothes or something carried by Z. Here, if
the throwing of the stone produces the effect of causing any substance to come into
contact with Z, or Z’s clothes, A has used force to Z; and if he did so without Z's consent,
intending thereby to injure, frighten or annoy Z, he has used criminal force to Z.
(f) A intentionally pulls up a woman's veil. Here A intentionally uses force to her, and if he
does so without her consent, intending or knowing it to be likely that he may thereby
injure, frighten or annoy her, he has used criminal force to her.
(g) Z is bathing. A pours into the bath water which he knows to be boiling. Here A
intentionally by his own bodily power causes such motion in the boiling water as brings
that water into contact with Z, or with other water so situated that such contact must
affect Z's sense of feeling. A has therefore intentionally used force to Z; and if he has
done this without Z's consent, intending or knowing it to be likely that he may thereby
cause injury, fear
or annoyance to Z, A has used criminal force.
(h) A incites a dog to spring upon Z, without Z's consent. Here, if A intends to cause injury,
fear or annoyance to Z, he uses criminal force to Z.

Criminal force is equivalent to ‘battery’ in English law, which means the intentional infliction
of force by one person upon another against latter’s consent. The essential ingredients of the
section are:

(a) There must be use of force as defined by section 349;

(b) Such force should be used intentionally against any person;
(c) It should have been used without the consent of the person against whom it is used;
(d) Force is used to commit an offence.

Force can also be put in a positive or good use. For instance, pulling a person away from fire,
so as to save him from being burnt, or pushing or dragging a person so as to prevent him from
being run down by a vehicle are some of examples of force put to good use. Force becomes
‘criminal force’, only when it satisfies all the essential ingredients set out in section 350.
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Thus, the use of force which causes motion, change of motion or cessation of motion to
another person, done without the consent of such person, in order to commit an offence, or
cause injury, fear or annoyance to the said person, will amount to criminal force. No bodily
injury or hurt need be caused.

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Assault
Assault is defined in section 351 of the IPC as consisting of an overt act, or making gestures,
or a preparation intending, or knowing it to be likely that such gestures or preparation, are
with reference to the use of criminal force against the person. Assault, according to English
law is a threat of violence exhibiting an intention to use criminal force, and intention to carry
out the threat into execution. There must in all cases be the means to carry out the threat into
effect.

Section 351. Assault- Whoever makes any gesture, or any preparation intending or knowing
it to be likely that such gesture or preparation will cause any person present to apprehend that
he who makes that gesture or preparation is about to use criminal force to that person is said
to commit an assault.

Explanation: Mere words do not amount to an assault. But the words which a person uses
may give to his gestures or preparation such a meaning as may make those gestures or
preparations amount to an assault.

Illustrations

(a) A shakes his fist at Z, intending or knowing it to be likely that he may thereby cause Z
to believe that A is about to strike Z. A has committed an assault.
(b) A begins to unloose the muzzle of a ferocious dog, intending or knowing it to be
likely that he may thereby cause Z to believe that he is about to cause the dog to
attack Z. A has committed an assault upon Z.
(c) A takes up a stick, saying to Z, "I will give you a beating". Here, though the words
used by A could in no case amount to an assault, and though the mere gesture,
unaccompanied by any other circumstances, might not amount to an assault, the
gesture explained by the words may amount to an assault.

Causing of some actual hurt is not necessary for constituting assault. Mere threat may
constitute assault.1 The essence of the offence lies in the effect which threat creates in the
mind of the victim. In the view of explanation mere words do not constitute assault. There
must be use of word accompanied with such gestures or preparation that may cause another
to apprehend that criminal force is about to be used against him amounts to assault. Thus
there must be some threatening physical act done by the accused by which he causes another
to apprehend that criminal force is about to be used against him. The person threatening must
be in a position to carry his threat into effect.

Essential ingredients of Assault

The following are the essential ingredients of this section:

i. The accused should make a gesture or preparation to use criminal force;

1
Rupabati v. Shyama, A.I.R. 1958 Cut. 710.
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 ii. Such gesture or preparation should be made in the presence of the person in respect
of whom it is made;
iii. There should be intention or knowledge on the part of the accused that such gesture or
preparation would cause apprehension in the mind of the victim that criminal force
would be used against him, and
iv. Such gesture or preparation has actually caused apprehension in the mind of the
victim, of use of criminal force against him.

Cases- Mere utterance of threatening words does not amount to assault. In a case a person
took a lathi and shouted that he will break the head of a police officer if he insists upon
taking his thumb impression. He was not guilty of assault.2 But where a person shouts that he
would be coming back and teach a lesson to the police officer and accordingly he comes back
with lathi, moves close to the police officer raising a reasonable apprehension that he was
about to use criminal force, the accused would be guilty under this section.3

Difference between Assault and Criminal Force

The difference between an assault and criminal force under Indian law is the same as in
English law between assault and battery. The offence is battery as soon as there is anything
more than an attempt to do a corporal hurt to another, however small the injury caused might
be. A threat to throw boiling water on a man amounts to an assault and when it touches the
body, it amounts to battery (i.e. hurt).

The code has classified infliction of bodily pain into three categories, viz., (i) Assault (ii)
Criminal force and (iii) Hurt.

Touching another in anger, spitting on the face of a man, etc., are less than a hurt, but more
than assault. These may be instances of criminal force, but in English Law it is battery.
Mere utterance of threat with no gesture or preparation indicating an intention to use force
does not constitute an offence under section 351.4 A mere menace of future injury is not
assault, but the words of menace may give such character to the gesture or preparation of
the speaker as to show an intention to use immediate violence. For instance, pointing a gun
at a person, lifting a lathi to hit another, or throwing of brick bats which causes the
apprehension that criminal force is about to be used against him amounts to an assault.
Every use of criminal force includes assault but in assault there is merely apprehension of
use of force and no use of actual force.

Punishment for Assault

Section 352 provides punishment for assault or criminal force. The punishment for assault
or criminal force, otherwise than on grave and sudden provocation with imprisonment of
either description for three months, or with fine which may extend to five hundred rupees,
or with both.

2
Birbal Khalifa, (1902) I.L.R. 30 Cal. 97.
3
Ram Singh, A.I.R. 1935 Pat. 214.
4
Kailash Chandra v. Emperor, (1939) 43 CWN 756.
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Section 352. . Punishment for assault or criminal force otherwise than on grave
provocation- Whoever assaults or uses criminal force to any person otherwise than on grave
and sudden provocation given by that person, shall be punished with imprisonment of either
description for a term which may extend to three months, or with fine which may extend to
five hundred rupees, or with both.

Explanation: Grave and sudden provocation will not mitigate the punishment for an offence
under this section, if the provocation is sought or voluntarily provoked by the offender as an
excuse for the offence, or

if the provocation is given by anything done in obedience to the law, or by a public servant,
in the lawful exercise of the powers of such public servant, or

Provocation is given by anything done in the lawful exercise of the right of private defence.

Whether the provocation was grave and sudden enough to mitigate the offence is a question
of fact.

For punishment under this section it must be proved that all the essential ingredients of
assault exist there. The offence is non-cognizable, bailable, compoundable and triable by
any magistrate.

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Aggravated forms of Assault or Criminal Force
Sections 353 to 357, IPC provide for severe punishment in case of aggravated form of assault
or use of criminal force. Aggravated assault occurs when a weapon is used, when assault
occurs during another crime, or when increased force is used. In some states, the victim must
suffer physical injuries before an assault can be considered aggravated.

Assault or Criminal Force to Deter Public Servant

Section 353 punishes assault or use of criminal force to a public servant acting in the
discharge of a duty imposed by law on him.

Section 353. Assault or criminal force to deter public servant from discharge of his duty-
Whoever assaults or uses criminal force to any person being a public servant in execution of
his duty as such public servant, or with intent to prevent or deter that person from discharging
his duty as such public servant, or in consequences of anything done or attempted to be done
by such person in lawful discharge of his duty as such public servant, shall be punished with
imprisonment of either description for a term which may extend to two years, or with fine, or
with both.

A public servant is often exposed to considerable risks in the discharge of his official duties,
and law therefore throws round him a special protection by prescribing specially deterrent
sentences to those who offend against the majesty of law, of which he is a minister.

But only an officer engaged compulsorily in the discharge of official duties is entitled to
protection. So also, a commissioner attempting to give possession under a time-expired
warrant has no authority to go upon land in the possession of the party who resists the
execution. Persons offering resistance are not guilty under this section. A public servant,
when acting under an illegal order of his superior, although unaware of the illegality, cannot
invoke section 353.

Ingredients:

1) The person assaulted must be a public servant;

2) The public servant was acting in the exercise of his duties;
3) That the assault or criminal force used against such public servant:
a) Was intended to prevent or deter him from discharging his duty as a public servant, or
b) Was used as a consequence of anything done or attempted to be done by the said
public servant in lawful exercise of his duties as such public servant.

The offence is cognizable, bailable, non-compoundable and triable by any magistrate.

Punishment includes imprisonment that may extend up to two years either rigorous or simple
or fine, or with both.

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In the case of P Rama Rao v. State,5 the Andhra Pradesh High Court that the essence of s 353
lies in the assault directed towards a public servant to deter him. The accused was asked by a
sub-inspector to stop his car. While pretending to stop the car he sped away and in the
process hit the mudguard of the motorcycle carrying the sub-inspector. The court ruled that
the facts of the case did not warrant s 353 of the IPC. It is not essential that the assault should
be caused to the public servant while he is actually discharging his official duty. Section 353
can come into play even if hurt is caused to him ‘in consequence’ of anything done by him in
the discharge of his duties as public servant.

Assault or Criminal Force to Woman to Outrage her Modesty

Section 354. Assault or criminal force to woman with intent to outrage her modesty-
Whoever assaults or uses criminal force to any woman, intending to outrage or knowing it to
be likely that he will thereby outrage her modesty, shall be punished with imprisonment of
either description for a term which may shall not be less than one year but which may extend
to five years, and shall also be liable to fine.

Assault to a woman- Section 354, IPC was added in a view to protect a woman against
incident assault as well as to safeguard public morality and decent behaviour. The section
punishes an assault, or use of criminal force to any woman with the intention or knowledge
that the woman’s modesty will be outraged.

Ingredients:

1) A woman was assaulted or criminal force was used against her.

2) The accused intended to outrage her modesty or knew that her modesty was likely to
be outraged.

The offence is cognizable, bailable, non-compoundable and triable by any magistrate.

Punishment includes imprisonment of either description up to two years, or fine, or with both.

Pandurang Mahale v. State of Maharashtra6

The Supreme Court held that the essence of a woman's modesty is her sex. The culpable
intention of the accused is the crux of the matter. The reaction of the woman is very relevant,
but its absence is not always decisive. Modesty in this section is an attribute associated with
female human beings as a class. It is a virtue which attaches to a female owing to her sex.
The act of pulling a woman, removing her saree, coupled with a request for sexual
intercourse, is such as would be an outrage to the modesty of a woman; and knowledge, that
modesty is likely to be outraged, is sufficient to constitute the offence without any deliberate
intention having such outrage alone for its object.

The scope of the section is wide enough to include a female of any age, young or old, as
defined under section 10 of the Indian Penal Code. Thus, an assault can be committed on any
woman irrespective of her age.

5
(1984) Cr LJ 27 (AP)
6
AIR 2004 SC 1677
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Modesty is the quality of being modest which means, as regards women, decent in manner
and conduct, scrupulously chaste, shrinking from indecency. Decency means propriety of
behaviour, what is required by good taste or delicacy, avoidance of obscene language and
gesture and of undue exposure of person, and respectability. Decorum means propriety of
speech, manner, etc., and dignity.

‘Intention’ is the gist of the offence- It is not every act that is criminal. To bring an assault
within section 354, IPC the act must be done with the intention or knowledge that it is likely
to outrage the modesty of the person with reference to whom the act is done. In Ram Das v.
State of West Bengal,7 the accused was charged for having committed offence under section
354, IPC. The accused boarded at night in a railway compartment in which two females were
seated along with their male escorts. He took off his trousers under which he was wearing an
under Thereupon there developed a heated exchange of words and quarrel between that group
and the accused, in the course of which he gave a push to one of those or women.

No inference of a criminal intention to outrage a woman’s modesty can be drawn from a

man’s act of removing his trousers at night before lying down on his berth, since it is a
natural preparatory act to becoming comfortable on a journey. Similarly, in the absence of
any evidence as to any gesture made by the accused the evidence that he was (staring)
looking at the ladies with lustful eyes' had to be discarded as giving any indication to his
intention, because such an impression is more psychological than factual

Held, it was not established that the accused acted with the intention to outrage e ladies
modesty, or with the knowledge that it was likely that he would thereby outrage their
modesty.

Types of Assault to Women

 Sexual Harassment

Section 354 A- Sexual harassment and punishment for sexual harassment-

1. A man committing any of the following acts—

i. physical contact and advances involving unwelcome and explicit sexual overtures;
or
ii. a demand or request for sexual favours; or
iii. showing pornography against the will of a woman; or
iv. making sexually coloured remarks, shall be guilty of the offence of sexual
harassment.
2. Any man who commits the offence specified in clause (i) or clause (ii) or clause (iii) of
sub-section (1) shall be punished with rigorous imprisonment for a term which may
extend to three years, or with fine, or with both.
3. Any man who commits the offence specified in clause (iv) of sub-section (1) shall be
punished with imprisonment of either description for a term which may extend to one
year, or with fine, or with both.
7
AIR 1954 SC 711
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 Disrobing a Woman
Section 354 B- Assault or use of criminal force to woman with intent to disrobe
Any man who assaults or uses criminal force to any woman or abets such act with the
intention of disrobing1 or compelling her to be naked, shall be punished with
imprisonment of either description for a term which shall not be less than three years but
which may extend to seven years, and shall also be liable to fine.
 Voyeurism
Section 354 C- Voyeurism
Any man who watches, or captures the image of a woman engaging in a private act in
circumstances where she would usually have the expectation of not being observed either
by the perpetrator or by any other person at the behest of the perpetrator or disseminates
such image1 shall be punished on first conviction with imprisonment of either description
for a term which shall not be less than one year, but which may extend to three years, and
shall also be liable to fine, and be punished on a second or subsequent conviction, with
imprisonment of either description for a term which shall not be less than three years, but
which may extend to seven years, and shall also be liable to fine.

Explanation 1: For the purpose of this section, “private act” includes an act of watching
carried out in a place which, in the circumstances, would reasonably be expected to
provide privacy and where the victim’s genitals, posterior or breasts are exposed or
covered only in underwear; or the victim is using a lavatory; or the victim is doing a
sexual act that is not of a kind ordinarily done in public.
Explanation 2: Where the victim consents to the capture of the images or any act, but not
to their dissemination to third persons and where such image or act is disseminated, such
dissemination shall be considered an offence under this section.
 Stalking a Woman
Section 354 D- Stalking
(1) Any man who—
i. follows a woman and contacts, or attempts to contact such woman to foster
personal interaction repeatedly despite a clear indication of disinterest by such
woman; or
ii. monitors the use by a woman of the internet, email or any other form of
electronic communication,
commits the offence of stalking:
PROVIDED that such conduct shall not amount to stalking if the man who pursued it
proves that—
i. it was pursued for the purpose of preventing or detecting crime and the man
accused of stalking had been entrusted with the responsibility of prevention and
detection of crime by the State; or
ii. it was pursued under any law or to comply with any condition or requirement
imposed by any person under any law; or
iii. in the particular circumstances such conduct was reasonable and justified.

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 (2) Whoever commits the offence of stalking shall be punished on first conviction with
imprisonment of either description for a term which may extend to three years, and
shall also be liable to fine; and be punished on a second or subsequent conviction,
with imprisonment of either description for a term which may extend to five years,
and shall also be liable to fine.

Assault to Dishonour a Person

Section 355. Assault or criminal force with intent to dishonour person, otherwise than on
grave provocation- Whoever assaults or uses criminal force to any person, intending thereby
to dishonour that person, otherwise than on grave and sudden provocation given by that
person, shall be punished with imprisonment of either description for a term which may
extend to two years, or with fine, or with both.

The essential ingredients of this section are

i. The accused assaulted or used criminal force;

ii. The accused intended thereby to dishonour the person assaulted, or against whom
criminal force was used; and
iii. The accused did so otherwise than on sudden and grave provocation.

The intention to dishonour may be supposed to exist when the assault or criminal force is by
means of gross insult. For e.g., an accused while under trial, struck a police sub-inspector
who was giving evidence against him, he would be guilty under this section.

Punishment under this section includes imprisonment of either description up to two years, or
fine, or both.

Assault to Commit Theft

Section 356. Assault or criminal force in attempt to commit theft of property carried by a
person- Whoever assaults or uses criminal force to any person, in attempting to commit theft
on any property which that person is then wearing or carrying shall be punished with
imprisonment of either description for a term which may extend to two years, or with fine, or
with both.

This section punishes assault or use of criminal force in attempting to commit theft to
property which the person is wearing or carrying, such as articles of jewellery or purse, etc.,
usually in a crowded place. The offence under this section will be complete as soon as the
person attempting to steal touches the person to be robbed.

The essential ingredients of this section are

i. The accused assaulted or used criminal force to another person;

ii. The other person was wearing or carrying the property attempted to be stolen;
iii. The accused committed assault in attempting to steal such property.

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The offence is cognizable, bailable, non-compoundable and triable by any magistrate.
Punishment includes imprisonment of either description up to two years, or fine, or with both.

Assault to Confine a Person

Section 357. Assault or criminal force in attempt wrongfully to confine a person- Whoever
assaults or uses criminal force to any person, in attempting wrongfully to confine that person,
shall be punished with imprisonment of either description for a term which may extend to one
year, or with fine which may extend to one thousand rupees, or with both.

This section punishes an assault or use of criminal force in attempting to wrongfully confine
a person. The offence is cognizable, bailable, non-compoundable and triable by any
magistrate. Punishment includes imprisonment of either description up to one year, or fine
which may extend to one thousand rupees, or both.

Assault on Grave and Sudden Provocation

Section 358. Assault or criminal force on grave provocation- Whoever assaults or uses
criminal force to any person on grave and sudden provocation given by that person, shall be
punished with simple imprisonment for a term which may extend to one month, or with fine
which may extend to two hundred rupees, or with both.

This section punishes assault or use of criminal force on grave and sudden provocation as
against section 352, IPC, which punishes assault or criminal force otherwise than on grave
and sudden provocation.

The offence is cognizable, bailable, non-compoundable and triable by any magistrate.

Punishment includes imprisonment of either description up to one year, or fine which may
extend to one thousand rupees, or both.

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 Conclusion
Criminal force is equivalent to ‘battery’ in English law, which means the intentional infliction of
force by one person upon another against latter’s consent. Force can also be put in a positive or
good use. For instance, pulling a person away from fire, so as to save him from being burnt, or
pushing or dragging a person so as to prevent him from being run down by a vehicle are some of
examples of force put to good use. Force becomes criminal force only when - it is used without
consent and in order of committing offence, when it is used to cause injury, fear or annoyance to
another to whom the force is used.
Assault is defined as consisting of an overt act, or making gestures, or a preparation intending,
or knowing it to be likely that such gestures or preparation, are with reference to the use of
criminal force against the person. Assault, according to English law is a threat of violence
exhibiting an intention to use criminal force, and intention to carry out the threat into execution.
There must in all cases be the means to carry out the threat into effect. Assaults are of various
types as discussed above under sections 353 to 357.
Assault is the gesture and preparation to apprehend the victim that the offender will use criminal
force. But criminal force is intentional use of force to the victim without his consent. Criminal
force includes assault. But assault may not include criminal force.
An assault is something less than the use of criminal force, the force being cut short before the
blow actually falls. But criminal force is something more than the assault; the force is actually
used criminally crossing the limit of gesture and preparation.

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References
Books

1. K D Gaur, Textbook on Indian Penal Code, (Universal Law Publishing Co., New
Delhi, 6th Edn. 2016, Reprint 2017)
2. S.N. Mishra, The Indian Penal Code, (Central Law Publication, Allahabad, 20th Edn.
2016)
3. K. I. Vibhuti, P.S.A. Pillai’s Criminal Law (Lexis Nexis, Wadhwa, 11th Edn. 2012)

Websites

1. https://www.slideshare.net/simranjalhotra/criminal-force-47730267

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