“CRIMINAL MISAPPROPRIATION OF PROPERTY AND

RAFALE DEAL”

A Project submitted in partial fulfilment of the course CRIMINAL LAW-I,

3rd SEMESTER during the Academic Year 2019-2020

SUBMITTED BY:
KUMAR SHASWAT
Roll No. – 1929
B.A. LL.B.(Hons.)

SUBMITTED TO:
DR.FR. PETER LADIS FRANCIS
FACULTY OF CRIMINAL LAW-I

SEPTEMBER, 2019
CHANAKYA NATIONAL LAW UNIVERSITY, NAYAYA NAGAR,
MITHAPUR, PATNA-800001

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 DECLARATION BY THE CANDIDATE

I hereby declare that the work reported in the B.A. LL.B (Hons.) Project Report Entitled
“CRIMINAL MISAPPROPRIATION OF PROPERTY AND RAFALE DEAL” submitted at
Chanakya National Law University, Patna is an authentic record of my work carried out
under the supervision of Dr. Fr Peter Ladis Francis. I have not submitted this work elsewhere
for any other degree or diploma. I am fully responsible for the contents of my Project Report.

(Signature of the Candidate)

KUMAR SHASWAT
Chanakya National Law University, Patna

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 ACKNOWLEDGEMENT

Firstly, I would like to thank my faculty of Criminal Law-I Dr Fr Peter LadisFrancis for
providing me an opportunity to make my project on such an interesting topic which is also a
contemporary issue as for now.
Secondly, I would like to thank all my colleagues and friends for helping me out in arranging
of the accumulated collected study material.
Lastly, special thanks to my parents for guiding me in giving the final touch to this project
and helping me out throughout this project.

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TABLE OF CONTENT

I. Historical background of Rafale deal………………….............................

II. Section 403 and 404 of IPC,1860……………………….............................

III. Judicial interventions on criminal misappropriation of property……...

IV. Conclusion, criticism and suggestions……………………………………

Bibliography…….……………………………………………………………………...

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 AIMS AND OBJECTIVES

1. To understand the section 402 and 404 of the Indian Penal Code,1860
2. To understand what is dishonest misappropriation in context of section 403,404 of
IPC,1860
3. To understand various sections relating to criminal misappropriation of property and
its punishment
4. To study the controversial Rafale deal in relation of criminal misappropriation of
property

HYPOTHESIS

1.The researcher presumes the person committing the act of criminal misappropriation of
other’s property will be held liable

2. The government servants also can commit the offence of criminal misappropriation of
property

3.Rafale deal is criminal misappropriation.

RESEARCH METHODOLOGY

The method of this research work is doctrinal in nature

SOURCES

1.Primary sources: Enactments, rules, regulations, convention, etc.

2.Secondary sources: Reference books, commentaries, and treaties, works of

interpretation, textbooks, abstract

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 LIMITATION OF STUDY

The researcher will confine the research to the city of Patna , Bihar due to constraints the
researcher will include library work.

SCOPE

The scope of project extends to study of criminal misappropriation of property and the Rafale
deal and to explain under section 403,404 in this context while discussing scope and
regarding the same.

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 I.HISTORICAL BACKGROUND

The Rafale deal controversy 1is a political controversy in India related to the purchase of
36 multirole fighter aircraft for a price estimated at €7.8 billion by the Defence Ministry of
India from France's Dassault Aviation. The origin of the deal lies in the Indian MRCA
competition, a multi-billion dollar contract to supply 126 multi-role combat aircraft to
the Indian Air Force.

New Delhi:

In April 2015, Prime Minister Narendra Modi had announced that India will buy 36 French-
manufactured Rafale fighter jets off-the-shelf from Dassault, the French aircraft builder and
integrator. The Rafale was chosen in 2012 over rival offers from the United States, Europe
and Russia. The step was needed to upgrade India's ageing fleet. The original plan was that
India would buy 18 off-the-shelf jets from France's Dassault Aviation, with 108 others being
assembled in India by the state-run Hindustan Aeronautics Limited or HAL in Bengaluru.

The Modi-led BJP government, however, rowed back from the commitment of the last UPA
government to buy 126 Rafales, saying the twin-engined planes would be too expensive and
the deal fell through after nearly decade-long negotiations between India and France. There
were a lot of hiccups over costs of the aircraft. However, faced with the dipping number of
fighters and a pressing need to upgrade the Indian Air Force, Prime Minister Narendra Modi
intervened and decided to buy 36 "ready-to-fly" fighters instead of trying to acquire
technology from Dassault and make it in India. Soon after the deal was declared, the
Congress accused the ruling BJP of non-transparency in the multi-billion dollar deal and
called it one of biggest failures

In January 2016, India confirmed order of 36 Rafale jets in defence deal with France and
under this deal, Dassault and its main partners - engine-maker Safran and electronic systems-
maker Thales - will share some technology with DRDO (Defence Research and Development
Organisation) and some private sector companies and HAL under the offsets clause.
The twin-engine Rafale combat jet is designed from the beginning as a multi-role fighter for

1
https://en.wikipedia.org › wiki › Rafale_deal_controversy

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air-to-air and air-to-ground attack is nuclear-capable and its on-board Electronic Warfare
(EW) systems can also perform reconnaissance and radar jamming roles.

Nearly one- and-half years after Prime Minister Narendra Modi announced the proposal
during a visit to Paris, finally in September 2016, India signed an inter-governmental
agreement with France, dubbed as "Rafale deal", in which India will pay about Rs 58,000
crore or 7.8 billion Euros for 36 off-the-shelf DassaultRafale twin-engine fighters. About 15
per cent of this cost is being paid in advance. As per the deal, India will also get spares and
weaponry, including the Meteor missile, considered among the most advanced in the world.
Additionally, an accompanying offset clause was sealed through which France will invest 30
per cent of the 7.8 billion Euros in India's military aeronautics-related research programmes
and 20 per cent into local production of Rafale components.

In November 2016, however, a political warfare over the Rafale deal began and the Congress
accused the government of causing "insurmountable loss" of taxpayers' money by signing the
deal worth Rs 58,000 crores. It also claimed that the Anil Ambani-led Reliance Defence
Limited had been unfairly picked to be the French firm's Indian partner.
The claims were rebutted by Defence Minister NirmalaSitharaman and Anil Ambani-led
Reliance Defence Limited with the government saying that the renegotiated deal was
transparent and better than the deal negotiated by the previous UPA government as it includes
a superior weapons package and logistical support, which had been absent in the previous
one. Reliance Defence had also said that its subsidiary Reliance Aerostructure and Dassault
Aviation formed a joint venture - Dassault Reliance Aerospace, after a bilateral agreement
between two private companies and "the Indian government has no role to play in this."

The Congress, however, kept up its attacks on the government for refusing to table details of
the Rafale deal over alleged irregularities. The Defence Minister NirmalaSitharaman told the
Parliament earlier this week that the details of the deal with France for the Rafale fighter jets
cannot be disclosed as per the inter-governmental agreement as it is "classified information".

Officials say that due to national security reasons, there is a confidentiality clause in the
Rafale deal which bars the buyer and seller from talking about the pricing, making it
impossible for any government to reveal any detail about the defence deals.2

2
https://www.ndtv.com › All India

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In a counter-attack to the Congress, Finance Minister ArunJaitley accused the party of
"seriously compromising" country's security by seeking details of weaponry purchased along
with the aircraft. He also advised Congress chief Rahul Gandhi to "learn" from former
Defence Minister Pranab Mukherjee "lessons on national security".

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 II.SECTION 403 AND 404 OF INDIAN PENAL CODE,1860

DISHONEST MISAPPROPRIATION (section 403)

Whoever dishonestly misappropriates or converts to his own use any movable property,
shall be punished with imprisonment of either description for a term which may extend to
two years, or with fine, or with both.

Illustrations

(a) A takes property belonging to Z out of Z's possession, in good faith, believing, at any
time when he takes it, that the property belongs to himself. A is not guilty of theft; but if A,
after discovering his mistake, dishonestly appropriates the property to his own use, he is
guilty of an offence under this section.

(b) A, being on friendly terms with Z, goes into Z's library in Z's absence, and takes away
a book without Z's express consent. Here, if A was under the impression that he had Z's
implied consent to take the book for the purpose of reading it, A has not committed theft.
But, if A afterwards sells the book for his own benefit, he is guilty of an offence under this
section.

(c) A and B, being joint owners of a horse, A takes the horse out of B's possession,
intending, to use it. Here, as A has a right to use the horse, he does not dishonestly
misappropriate it. But, if A sells the horse and appropriates the whole proceeds to his own
use, he is guilty of an offence under this section.

Explanation 1- A dishonest misappropriation for a time only is a misappropriation with the

meaning of this section.

Illustration

A finds a Government promissory note belonging to Z, bearing a blank endorsement. A,

knowing that the note belongs to Z, pledges it with a banker as a security for a loan,
intending. at a future time to restore it to Z. A has committed an offence under this section.

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Explanation 2- A person who finds property not in the possession of any other person, and
takes such property for the purpose of protecting if for, or of restoring it to, the owner does
not take or misappropriate it dishonestly, and is not guilty of an offence; but he is guilty of
the offence above defined, if he appropriates it to his own use, when he knows or has the
means of discovering the owner, or before he has used reasonable means to discover and
give notice to the owner and has kept the property a reasonable time to enable the owner to
claim it.

What are reasonable means or what is a reasonable time in such a case, is a question of fact.

It is not necessary that the finder should know who is the owner of the property, or that any
particular person is the owner of it; it is sufficient if, at the time of appropriately it, lie does
not believe it to be his own property, or in good faith believe that the real owner cannot be
found.

Illustrations

(a) A finds a rupee on the high road, not knowing to whom the rupee belongs. A picks up
the rupee. Here A has not committed the offence defined in this section.

(b) A finds a letter on the road, containing a bank note. From the direction and contents
of the letter he learns to whom the note belongs. He appropriates the note. He is guilty of an
offence under this section.

(c) A finds a cheque payable to bearer. He can form no conjecture as to the person who
has lost the cheque. But the name of the person, who has drawn the cheque, appears. A
knows that this person can direct him to the person in whose favor the cheque was drawn.
A appropriates the cheque without attempting to discover the owner. He is guilty of an
offence under this section.

(d) A sees Z drop his purse with money in it. A picks up the purse with tile intention of
restoring it to Z, but afterwards appropriates it to his own use. A has committed an offence
under this section.

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 (e) A finds a purse with money, not knowing to whom it belongs; lie afterwards discovers
that it belongs to 4 and appropriates it to his own use. A is guilty of an offence under this
section.

(f) A finds a valuable ring, not knowing to whom it belongs. A sells it immediately
without attempting to discover. the owner. A is guilty of an offence under this section.

Essential Ingredients
The two important ingredients of this section are:

i. the accused misappropriated or converted to his own use another's property

ii. such property must be movable property

iii. the accused did so dishonesty

General Comments
Section 403 of the Indian Penal Code defines criminal misappropriation of property and
prescribes punishment thereof. Criminal Misappropriation is a new offence carved out from
theft. Theft is removal of property from the possession of the owner. But in criminal
misappropriation, the taking is upon finding or other coming across of the property, and not
from the possession of a person. Criminal misappropriation may almost amount to theft,
though it is not quite theft. This is because the initial removal is not from any person's
possession and hence, does not satisfy an essential ingredient of theft. when possession has
been innocently acquired but from subsequent intention or knowledge, the retention
becomes wrongful and amounts to its criminal misappropriation.3

Misappropriation means to take possession of property and putting it to unauthorised or

wrongful use. It especially applies to instances of putting somebody else's property to one's
use. Under this section, as stated earlier, the initial taking of the property may be innocent.
For instance, if a person, finds and picks up a watch on the road, it is an innocent act.
However, the honest act of picking up the watch will change to criminal misappropriation, if,
instead of returning the watch to the owner, the person wears the watch himself and puts it to
his own use. So, in criminal misappropriation, the person comes into possession in some
neutral or innocent way. If the watch, which is found, is returned to the owner, then no

3
PSA Pillai's, Criminal Law, Tenth Edition, 2008, Lexis Nexis, p1053 206Ibid.

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offence is committed. However, if the person retains it and puts it to his own use, then it
amounts to criminal misappropriation.

(A) DISHONEST MISAPPROPRIATION OR CONVERSION TO ONE’S OWN USE:

For an offence under this section it is not necessary that the property should be taken
with dishonest intention, the possession of the property may come innocently and then by
subsequent change of intention, or knowledge of some new facts with which the party was
not previously acquainted, the retaining of that property becomes wrongful or fraudulent. The
essence of offence under this section is that some property belonging to another which comes
into the possession of the accused innocently is misappropriated or converted by the accused
to his own use. There must be actual conversion of the thing misappropriated to the accused's
own use. Mere retaining of an article found does not amount to criminal misappropriation.
Misappropriation or conversion need not be permanently, it may be even for a time.
Illustrations (a), (b) and (c) show that the original taking was innocent but the offence of
criminal misappropriation is constituted because of subsequent dishonest conversion or
appropriation. Where 'A' took possession of a stray cattle and it was not shown that the cattle
was stolen property, and he dishonestly retained it, he was liable under this section. But
where a person found a purse on the pavement of a temple and put it in his pocket, but was
immediately thereafter arrested, it was held that he was not guilty of criminal
misappropriation, for it could not be assumed that by the mere act of picking up the purse or
putting it in his pocket he intended to appropriate its contents about to his own use.

In Ram Dayal,4' a girl 'A' found a gold necklace and she handed it over to 'another girl' C. B,
brother of A represented to C that the necklace belonged to a man of his acquaintance, and
thus took it in his possession. On inquiry by a police officer a few hours later, B repeatedthe
representation but afterwards gave up the necklace. The representations were proved to be
untrue to the knowledge of the accused B. He was, therefore, held guilty of criminal
misappropriation.

4
1886 P.R. NO. 24 OF 1886

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(B) MOVEABLE PROPERTY: Only movable property can be the proper
subject-matter of an offence under this section. A bull set at large in accordance with Hindu
religions usage is not 'property' of any one, and not the subject of ownership by any person,
as the original owner has surrendered all his rights as its proprietor and has given the animal
freedom to go anywhere it liked.

It was held in Gadgayya v. PurunSiddeshwar5, that the property of an idol or a temple must
be used for the purposes of that idol or temple and any other use of that property, being
dishonest, would amount to criminal misappropriation. Where A is employed to collect
money and he collects and retains money so collected from the debtor of his master, because
money is due to him as wages, he would be guilty under this section.

InNarain Singh v. State of M.P6, it was held that where the accused happened to be the
Chairman of a Samiti and he retained a certain amount from money which he had recovered
from members of the Samiti andretention continued even after he ceased to be the Chairman,
the act ofretentionwould not amount to criminal breach of trust, because an offence of
criminal breach of trust involves entrustment which is absent in this case. Amounts recovered
from members were dues and receipts were issued to them in respect of the same, the act of
the accused would amount to criminal misappropriation punishable under section 403 of the
act.

Dishonest misappropriation of property possessed by deceased person at the time of his

death: (404)
Whoever dishonestly misappropriates or converts to his own use property, knowing that such
property was in the possession of a deceased person at the time of that person’s decease, and
has not since been in the possession of any person legally entitled to such possession, shall be
punished with imprisonment of either description for a term which may extend to three years,
and shall also be liable to fine, and if the offender at the time of such person’s decease was
employed by him as a clerk or servant, the imprisonment may extend to seven years

5
1897 Unrep. Cr. C. 919
6
1986 Cri. L.J. 1481 (M.P.)

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INGREDIENTS:

(1) The property must be movable property.

(2) Such property was in possession of the deceased at the time of his death

(3) The accused misappropriated it or converted it to his own use

(4) The accused did so dishonestly

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 III.JUDICIAL INTERVENTIONS ON CRIMINAL
MISAPPROPRIATION OF PROPERTY

Section 403 of the Indian Penal Code defines criminal misappropriation of property and
prescribes punishment thereof. Criminal Misappropriation is a new offence carved out from
theft. Theft is removal of property from the possession of the owner. But in
criminalmisappropriation, the taking is upon finding or other coming across of the property,
and not
from the possession of a person. Criminal misappropriation may almost amount to theft,
though it is not quite theft. This is because the initial removal is not from any person's
possession and hence, does not satisfy an essential ingredient of theft. when possession has
been innocently acquired but from subsequent intention or knowledge, the retention becomes
wrongful and amounts to its criminal misappropriation.
Misappropriation means to take possession of property and putting it to unauthorised or
wrongful use. It especially applies to instances of putting somebody else's property to one's
use. Under this section, as stated earlier, the initial taking of the property may be innocent.
For instance, if a person, finds and picks up a watch on the road, it is an innocent act.
However, the honest act of picking up the watch will change to criminal misappropriation, if,
instead of returning the watch to the owner, the person wears the watch himself and puts it to
his own use. So, in criminal misappropriation, the person comes into possession in some
neutral or innocent way. If the watch, which is found, is returned to the owner, then no
offence is committed. However, if the person retains it and puts it to his own use, then it
amounts to criminal misappropriation.

I n Ramaswamy Nadar v State of Madras 7the appellant carried on prize competition as a

proprietor of a firm. Certain persons, who had money in connection with prize competition no
92, complained that they had not received their prize money though it had been announced
that they had competed for the prizes offered. The accused in his capacity as the proprietor
dishonestly induced prosecution witness 1 to 3 to compete in his bumper competition no 92
by paying entry fee to the tune of Rs 2,640 on the representation that the prize winners would
get a sum of Rs 3,10,000 and that on that representation, he had collected Rs 1,15,000 from
the public, out of which he had spent Rs 19,000 towards expenses of advertising and holding

7
AIR 1958 SC 56

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the competition. It was alleged that he was actuated by a dishonest intention when he
collected amount towards payment of prizes offered. The High Court convicted the appellant
under Sec 403 of the Indian Penal Code. The question was whether the High Court was
justified in coming to the conclusion that misappropriation is clearly established.
Allowing the appeal the Supreme Court said that the High Court has erred in coming to that
conclusion. To prove an offence under Sec 403 of the Indian Penal Code, the prosecution has
to prove (i) that the property in the case the net amount Rs 96,000 was the property of the
prosecution witness 1-3 and others and (ii) that the accused misappropriated that sum it to his
own use and (iii) that he did so dishonestly.
Justice Sinha held:
None of these constituents elements of the offence can be categorically asserted to have been
made out. The entry fee rightly came into the coffers of the accused. No doubt, he had
promised to award prizes of the total value of Rs 3,10,000 but there was no further obligation
that the
prized money had to come either wholly or in part, from out of the sum collected by him by
way of entry fee. he was carrying on the business, and was found by the courts below to have
disbursed lakhs of rupees to winners of prizes in the previous competitions. There was no
such entrustment, nor was there any rule laid down for appropriation of the sum collected in
a particular way. There being no duty to make appropriation in a particular way, the appellant

could not be held guilty of having misappropriated Rs 96,000 which was the total net

collection in competition no 92. Appeal allowed. Conviction dismissed8

In VeljiRaghavji v State of Rajasthanthe managing partner of a partnership firm

had realised certain amounts from business, but put t to own use. He was charged for criminal

appropriation. The Supreme Court held that if he as an owner of a property uses his property

in whichever way he wants to use it and with whatever intention, will not be liable for

misappropriation and that would be so, even if he is not the exclusive owner thereof. A

partner has undefined ownership along with the other partners over all the assets of the

8
https://www.casemine.com › judgement

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partnership. If he chose to use any of them for his own purposes, he may be accountable

civilly to the other partners; but, he does not thereby commit any misappropriation.

THE RAFALE DEAL CASE9

The Supreme court struck down Centre's claim of privilege on the newly
published Rafale papers, setting the stage for the top court to examine these during a review
of its earlier ruling that had given a clean chit to the government on Rafale.

"We deem it proper to dismiss the Union's plea," a three-judge bench led by CJI RanjanGogoi
said. The court will fix a date for the review hearing later. The government had alleged that
these documents widely published in the media had been purloined or stolen and hence were
Not to be admitted as evidence in the court proceedings.
The petitioners, who sought a review of the court's clean chit on the ground of errors of fact,
urged the court to examine these documents during the review hearing. The petitioners
include the likes of activists lawyer Prashant Bhushan and ArunShourie. The government in
its argument had insisted that the documents on which the case rests were “stolen” and could
not be used in a court of law.10
The “documents were stolen or purloined by former or current officers in the ministry of
defence,” attorney general KK Venugopal had said. “These are privileged documents under
the Official Secrets Act (OSA)… These were stolen to be published. An investigation is
underway. Criminal action will be taken against those who have published it.”
He first referred to “two newspapers” in this regard and subsequently named The Hindu and
ANI, a news agency. A review is a limited exercise in which the same bench that dealt with
the case earlier re-examines its ruling in the light of new facts.
In an affidavit before the top court, the central government, through the Defence Ministry,
has also said the leakage offended terms of the agreements with France.“Additionally, those
who have conspired in this leakage are guilty of penal offences under the Indian Penal Code
including theft by unauthorised photocopying and leakage of sensitive official documents,
affecting national security,” the government said in its affidavit. On March 6, the central
government, represented by Attorney General (AG) K KVenugopal, had told the Supreme

9
W.P.(C) NO.1205/2018
10
https://www.scobserver.in/court-case/rafale-fighter-jet-deal

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Court the documents, based on which details of alleged misdoings in the purchase of 36
Rafale fighter jets from France were published by newspapers, were stolen from the Ministry
of Defence either by current or former employees of the ministry.

As these documents pertained to defence deals and were covered by the Official Secrets Act,
the government was planning to take “criminal action” against the newspapers that published
the stories and the petitioner who used it in his petition, A G Venugopal had told the court.
Since the stories and petitions included top secret defence documents that were stolen, the top
court should dismiss the review petitions, AG had then saidIn its affidavit on Wednesday, the
Centre also told the Supreme Court that it was trying to find out “where the leakage took
place so that in future the sanctity of decision making process in governance is maintained”.
The documents used by the petitioner, the central government said, were accessed in an
unauthorised manner “with the intention to present a selective and incomplete picture of
internal secret deliberations”, the Centre said.

A three-judge bench, led by Chief Justice RanjanGogoi, is hearing a review petition on its
December 14 judgment in which it had dismissed probe into the purchase of Rafale fighter
jets. The review petition has been moved by former Union Minister Yashwant Sinha and
ArunShourie, as well as Senior Advocate Prashant Bhushan, among others.On December 14,
the top court had dismissed all pleas seeking a court-monitored probe into the purchase of 36
Rafale fighter aircraft from France.

top court had then said it had found “no occasion to doubt the (decision-making) process”
and thus would not interfere.In their review petition moved before the top court, Sinha,
Shourie and Bhushan have alleged that the government had suppressed crucial facts related to
the fighter aircraft deal and hence mislead the court. They had alleged that the court had
relied on “patently incorrect” claims made by the Centre in the note it had submitted to the
top court while it was hearing the original petition.

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 CONCLUSION

Dishonest misappropriation is the essence of this section. Dishonesty is as defined in sec.24,

IPC, causing wrongful gain or wrongful loss to a person. The meaning of wrongful gain and
wrongful loss is defined in sec 23, IPC. In order to constitute an offence, it is not enough to
establish that the money has not been accounted for or mismanaged. It has to be established
that the accused has dishonestly put the property to his own use or to some unauthorized use.
Dishonest intention to misappropriate is a crucial fact to be proved to bring home the charge
of criminal breach of trust. Hence it’s clear that for an offence to fall under this section all the
four requirements are essential to be fulfilled. The person handing over the property must
have confidence in the person taking the property, so as to create a fiduciary relationship
between them or to put him in position of trustee. The accused must be in such a position
where he could exercise his control over the property i.e., dominion over the property. The
term property includes both movable as well as immoveable property within its ambit. It has
to be established that the accused has dishonestly put the property to his own use or to some
unauthorized use. Dishonest intention to misappropriate is a crucial fact to be proved to bring
home the charge of criminal breach of trust.

It is submitted that the offence of criminal breach of trust is very much common in today’s
world. It happens during the daily routine of a common man’s life. From offices to the
marriage ceremonies, everywhere its presence can be traced. Not only in the truest sense but
also there are many cases of white collar crimes, where the person without any intention
involves in such crimes. The best way to get rid of such crime is by educating people about
the stringent laws regarding this offence. In case of same by public servant, the laws are more
stringent and thus they deter the public servant to commit such crimes.

In this way this section is satisfactory in itself. The provisions laid down in the Indian Penal
Code are enough to cope up with the problem of Criminal Breach of Trust. The only thing
required is the effective implementation as well as application of law as many of the cases go
unreported and through regular investigations they wouldn’t go unnoticed.

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 BIBLIOGRAPHY

Books:

 Bare act : The Indian Penal Code,1860

 Dr K.L Vibhute ,PSA Pillai's Criminal Law , published by lexis nexis, edition
11th,2012
 Ratanlal and Dhirajlal: The Indian Penal Code, published by lexis nexis, edition 35th
2017

Websites:

 https://www.ndtv.com/india-news/what-is-rafale-deal-controversy-all-you-need-
to-know
 https://www.scobserver.in/court-case/rafale-fighter-jet-deal
 https://www.lawoctopus.com/academike/criminal-misappropriation

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