MARCH, 2017 | ISSN: 2394- 5044 THE WORLD JOURNAL ON JURISTIC POLITY

PLEA BARGAINING IN THE INDIAN CRIMINAL JUSTICE SYSTEM:

AN ANALYSIS

Rajat Bawaniwal
Faculty of Law, Jamia Millia Islamia, New Delhi

The Indian judiciary is regarded as one of the most powerful judiciaries across the globe,
but this powerful judiciary is being crippled by the weight of pending cases. In order to
solve this problem, the legislature introduced the concept of plea bargaining in the Indian
Criminal Justice System. This paper makes an effort to analyse the thought process of the
legislature in incorporating the concept of plea bargaining in India by going into the
recommendations of the Law Commission and the Committee on Reforms of the
Criminal Justice System. Author tries to trace the origin of the concept of Plea bargaining.
Further effort has been made to survey the present legal position regarding plea bargaining
in India by going into the provisions of law and judicial decisions. Pitfalls under the
legislation are discussed along with suggestions for better implementations of the
provisions. The paper concludes by calling for a comprehensive study to review the
functioning of plea bargaining in order to bring it in conformity with its desired objective
of bringing down the pendency and ensuring speedier disposal of cases.

Introduction

There is a very famous quote: “Justice should not only be done but should manifestly and
undoubtedly be seen to be done, and ‘time’ is certainly a big factor in ensuring that justice
is not only done but is also manifestly and undoubtedly seen to be done. Keeping this in
mind, right to speedy trial has been declared as a fundamental right under Article 21 of the
Constitution.1 Unfortunately, this fundamental right to speedy justice has largely remained
a dead letter and the Indian judiciary has remained exceptionally slow in delivering justice.
Due to the unreasonably long drawn process of providing justice, a common Indian is
usually ready to bear some brunt rather than asserting his right in a court of law. With
regard to criminal justice system, the situation is no better. There are more than 2.18 crore
cases pending in district courts across the country; 12 states have more than 5 lakh cases to
decide; while a little more than one case, on an average, is awaiting conclusion for at least
10 years.2 The majority of the cases in India end in acquittal and the conviction rate is
abysmally low. The legislature has recognized this problem of the backlog of cases and as
a result officially introduced the concept of ‘Plea Bargaining’ by way of Criminal Law

1
Hussainara Khatoon v. State of Bihar, AIR 1979 SC 1360.
2
Utkarsh Anand, “More than 2 crore cases pending in India’s district courts: Report” The Indian
Express, June 9, 2016.

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(Amendment) Act of 2005 in order to curb this growing menace of back logging of cases
in the Indian Courts and to ensure higher rate of conviction.

Definition

There is no universally applicable definition of plea bargaining. As the term implies, plea
bargaining involves an active negotiation process whereby an offender is allowed confess
his guilt in court (if he so desires) in exchange of a lighter punishment that would have
been given for such an offence. In legal terminology, a plea-bargaining is simply an answer
to a claim made by someone in a civil or criminal case under common law using the
adversary system.3 Black’s Law Dictionary4 defines it as:

“The process whereby the accused and the prosecutor in criminal case work out a mutually
satisfactory disposition of the case subject to the Court approval. It usually involves the
accused pleading guilty to a lesser offence or to only one or some of the courts of a multi-
count indictment in return for a lighter than that possible for the graver charge.”
A simple definition of the term “Plea Bargaining” was initially given by the Canadian Law
Commission as follows:5

“Any agreement by the accused to plead guilty in return for the promise of some benefit”
From the point of view of the accused, it means that he trades conviction and a lesser
sentence, for a long, expensive and tortuous process of undergoing trial where he may be
convicted. In practice, it represents not so much of “mutual satisfaction” as perhaps “mutual
acknowledgement” of the strengths or weaknesses of both the charges and the defences,
against a backdrop of crowded criminal courts and court case dockets. Thus, it involves an
active negotiation process by which the accused offers to exchange a plea of guilty, thereby
waiving his right to trial, for some concessions in charges or for a sentence reduction.

Plea Bargaining is of three types:

1. Charge Bargaining: Here the defendant pleads guilty to a less serious charge, or to one
of several charges, in return for dismissal of other charges.

2. Sentence Bargaining: It is a process where the accused has an option of admitting guilt
and settling for a lesser punishment.

3. Fact Bargaining: Negotiations which involves an admission to certain facts in exchange

of an agreement not to introduce certain other facts.

3
Surender Kumar, Kulwant Singh “Concept of Plea Bargaining and Criminal Law in India: An
Analysis” Vol – I, Issue – IV VOR (October 2013).
4
8th edition, 1190 (2004)
5
Law Reform Commission of Canada: Criminal Procedure: Control of the Process, 45 Working
Paper 15(1975).

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Origin of the Concept of Plea Bargaining

Plea Bargaining is a concept that originated in the United States and it has evolved over
the ages to become a prominent feature of the American Criminal Justice system.6 In the
United States of America, more than 75 percent of criminal cases end in guilty pleas, almost
all resulting from plea bargaining. Hence it is often said that the American Criminal Justice
would collapse if plea bargaining is removed from it. Plea bargaining was held to be
constitutionally valid by the US Supreme Court in Brady v. United States7 where the
Supreme Court held that merely because the agreement was entered into out of fear that
the trial may result in a death sentence, would not illegitimise a bargained plea of guilty.
The U.S. Supreme Court has approved practices such as plea bargaining when properly
conducted and controlled.

Historical Background of Plea Bargaining in India

The concept of plea bargaining (if not directly as it stands today, then in a similar fashion)
has been a part of criminal jurisprudence in India since Vedic times. Apart from prescribing
various kinds of punishments the Dharamasastras, in a separate chapter titled “Prayaschita”
suggested various models of self-purification by confessing the guilt. In Vedic period
prayaschita was used as a basis of imposition of reduced penalty, which was justified by
various scholars of sastras and smritis.8 In Post Vedic period, instances of plea bargaining
are abundant in the Mauryan Period where plea-bargaining was practiced informally and
episodically in the form of conciliation, as one of method of state craft. Plea-bargaining in
the form of Quisas system flourished in the Mughal period. Quisas was a king of ‘blood
money’ which was given by the accused to the deceased victim’s next kin in homicide cases.
Under the British rule, adversarial system of common law came into force. The British
legal system was aimed at punishing the offenders rather than bargaining away the
punishment through compensation and thus the concept of plea bargaining was done away
with. In the post independence era, on the recommendations of the Law Commission and
its further endorsement by the Report of the Committee on Reforms of the Criminal
Justice System, 20039, finally the concept of Plea bargaining was introduced in India by
way The Criminal Law (Amendment) Act, 2005, which was passed in the winter session
of the Parliament. The provisions regarding Plea bargaining are embodied under Chapter
XXI-A of Code of Criminal Procedure.

Law Commission’s View on Plea Bargaining

The Law Commission of India advocated the introduction of ‘Plea Bargaining’ in the
142nd, 154th and 177th reports. Law Commission in its one hundred forty second report on

6
Sulabh Reawri and Tanya Aggarwal “ Wanna make a deal? The introduction of plea bargaining
in India” 2 SCC (Cri) J-12 (2006).
7
397 U.S. 742 (1970)
8
Vaschaspati Tripathi, Pracheen Bharat Ki Dand Vayavastha, 176 (1989).
9
Headed by Justice V.S. Malimath, former Chief Justice of Karnataka and Kerela High Courts.

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“Concessional Treatment for Offenders who on their own initiative choose to plead guilty
without any Bargaining”10 recognised the problem exercising the minds of all concerned
with the administration of Justice, that of mounting arrears of criminal cases and
unconscionable delays in disposal therof and undertook suo moto exercise resulting in the
culmination of the 142nd Report. The report extensively dealt with the various issues
revolving around the introduction of a scheme like plea bargaining. The report dealt with
the magnitude of the problem of delays in criminal cases.11 The successful practice of plea
bargaining in the USA was observed. The report also took into consideration the objection
to the introduction of the concept of plea bargaining in Indian Legal System to all
offences.12 Some of the objections to the introduction of plea bargaining in India to all
offences as mentioned in the report are as follows:

 The country’s social conditions do not justify the introduction of the concept.
 The legal aid apparatus is also available for consultation if they cannot afford legal
counsel.
 The defendants are generally advised by their trusted lawyers and there are no grounds
to think that a defendant, except in very rare cases and circumstances, would make
confession of guilt entailing personal and social consequences to him not with standing
his innocence.
 Pressures from prosecuting agencies may result in convictions of the innocents.
 The poor will be the ultimate victims of the concept.
 Plea Bargaining may increase the incidence of crim.
 Criminals may slip through impunity.

Keeping in mind the objections raised by several groups, the report propounded several
safeguards in order to make the objections redundant. The report proposed a different plea-
bargaining scheme than prevailing elsewhere in five important areas, namely:13

 There will be no contact between the public prosecutor and the accused for the purpose
of invoking the scheme. The initiative will be solely with the accused who alone can
make the application.
 The decision to accord concessional treatment will rest solely with a judicial officer
functioning as a Plea-Judge.
 There will be no bargaining with the judicial officers and an application once made
will bot be allowed to be withdrawn and the accused will not know what the judicial
officers will do. He will only make a representation and plead for such concessional
treatment as, according to him would be appropriate.

10
Law Commission of India, 142nd Report on Concessional Treatment for Offenders who on
their own initiatve choose to plead guilty without any Bargaining (1991).
11
Ibid at chapter II.
12
Ibid at Chapter VII.
13
Ibid at Chapter X.

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 The sole arbiter will be the judicial officer and, therefore, there will be no risk of
underhand dealings or for coercion or improper inducement by the prosecution.
 The aggrieved party and the public prosecutor will have a right to be heard wand place
their points of view.

The Law commission recommended the application of the scheme in the first instance as
an experimental measure to offences which are liable for punishment with imprisonment
of less than seven years and/or fine and the scheme may be made applicable to offences
liable to be punished with imprisonment for 7 years and more after properly evaluating and
assessing the results of the application of the scheme to offences liable to be punished with
imprisonment for less than 7 years.

The 154th Law Commission Report, inter alia, recommended the introduction of ‘Plea
Bargaining’ in the Indian Criminal Justice System. The report made specific mention to
the 142nd Law Commission report for the justification of the introduction of the concept
of Plea Bargaining. It recommended that a separate Chapter XXIA on Plea bargaining be
incorporated in the Code of criminal Procedure.14 Subsequently 177th Law Commission
report, inter alia, also endorsed the recommendations of the 142nd and 154th Report and
advocated the introduction of Plea Bargaining. Though endorsing Plea bargaining as a
means of speedier justice, 177th Law Commission Report, based on the analysis of the 142nd
and 154th report and various judicial decisions of the Supreme Court was reluctant to
include any provision regarding plea bargaining in the accompanying Bill and called upon
the Government to take a policy decision on the question whether to introduce the said
concept. The Report of the Committee on Reforms of the Criminal Justice System, 2003
stated that plea-bargaining being a means for the disposal of accumulated cases and
expediting the delivery of criminal justice should be introduced.15 The Committee thus
reaffirmed the recommendations of the Law Commission of India in its 142 nd, 154th and
177th Reports.

Judicial View on Plea Bargaining

As the concept of plea bargaining was gaining popularity in the USA, voices from different
corners were coming for the induction of the concept of plea bargaining in India. But India,
being a unique Nation due to its socio economic conditions repeatedly rejected this concept
of plea bargaining. The Indian judiciary was no different and took a very stringent view
against Plea Bargaining. The debate around plea bargaining mainly revolved around the
question of morality and the Supreme court held the view that it amounted to immoral
compromise in criminal cases. One of the earliest cases in which the concept of plea

14
Law Commission of India, 154th Report on The Code of Criminal Procedure (1996) at 9.10.
15
Government of India, Report: Committee on Reforms of Criminal Justice System (Ministry of
Home Affairs, 2003) available at
http://www.mha.nic.in/hindi/sites/upload_files/mhahindi/files/pdf/criminal_justice_system.pdf

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bargaining was considered by the Hon’ble Court was Madanlal Ramachander Daga v. State
of Maharashtra16where a very strict view was taken and it was held that:
“In our opinion, it is very wrong for a Court to enter into a bargain of this character.
Offences should be tried and punished according to the guilt of the accused. If the Court
thinks that leniency can be shown on the facts of the case it may impose a lighter sentence.
But the Court should never be a party to bargain by which money is recovered for the
complainant through their agency. We do not approve of the action adopted by the High
Court……”17

In Thippaswamy v. State of Karnataka,18 the Supreme Court held that enforcement or

imposition of sentence in revision or appeal after the accused had plea bargained for a
lighter sentence or mere fine in the trial court as unconstitutional being violative of Article
21.

Justice P.N. Bhagwati in Kasambai Abdul Rahmanbhai Seikh v. State of Gujarat,19

declared plea bargaining as unconstitutional. In this case, judgment of the High Court was
set aside by Supreme Court and the plea of guilty was ignored. Conviction of accused was
set aside and the case was sent back to the Magistrate for trial in accordance with law. It
was held that such a procedure would be unreasonable, unfair and unjust amounting to
violation of Article 21 as interpreted in Maneka Gandhi’s case.20 It would have the effect
of polluting the pure fount of justice, because it might induce an innocent accused to plead
guilty to suffer a light and an inconsequential punishment rather than go through a long
and arduous criminal trial which, having regard to our cumbrous and unsatisfactory system
of administration of justice, is not only long drawn out and ruinous in terms of time and
money, but also uncertain and unpredictable in its result and judge also might be likely to
be deflected from the path of duty to do justice and he might either convict an innocent
accused by accepting the plea of guilty or let off the guilty accused with a light sentence.

The Supreme Court again in Kachhia Patel Shantilal Koderlal v. State of Gujarat and
another21 held that the practice of plea bargaiing is unconstitutional, illegal and would tend
to encourage corruption, collusion and pollute the pure fount of justice.

In State of Uttar Pradesh v. Chandrika,22 the Supreme Court held that it is not permissible
to dispose of the case on the basis of plea bargaining and observed:

“It is settled law that one basis of plea bargaining Court may not dispose of the criminal
cases. The Court has to decide it on merits. If accused confesses hi guilt, appropriate

16
AIR 1968 SC 1267.
17
Id at 1270.
18
AIR 1983 SC 747.
19
AIR 1980 SC 854.
20
Maneka Gandhi v. Union of India, AIR 1978 SC 597.
21
(1980) 3 SCC 120.
22
AIR 2000 SC 164.

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sentence is required to be imposed…… Mere acceptance or admission of the guilt must

not be a ground for reduction of sentence.”

Major change in judicial thought process took place after the concept of plea bargaining
was official added in the Code of Criminal Procedure. While recognising the concept of
plea bargaining, the Gujarat High Court observed in the State of Gujarat v. Natwar
Harchanji Thakor,23 that the very object of the law is to provide easy, cheap and expeditious
justice by resolution of disputes, including the trial of criminal cases and considering the
present realistic profile of the pendency and delay in the administration of law and justice,
fundamental reforms are inevitable. There should not be anything static. It can thus be said
that it is really a measure of redressal and it shall add a new dimension in the realm of
judicial reforms.

Process of Plea Bargaining under the Code of Criminal Procedure

The process of plea bargaining was brought in as a result of criminal law reforms introduced
in 2005.24 Section 4 of the Amendment Act introduces Chapter XXIA containing Section
265A to 265L to the Code of Criminal Procedure which came into effect on 5th July, 2006.

Section 265 A prescribes the application of the provisions of Chapter XXIA to cases where
the offence, which appears to have been committee by the accused is such that the
maximum punishment for such offence does not exceed 7 years. The section further takes
out from the purview of this chapter the offences which affect the socio-economic
condition of the country or offences against a woman, or a child below the age of fourteen
years. Subsection 2 empowers the Central Government to determine the offences under
the law for the time being in force which shall be the offences affecting the socio-economic
condition of the country.

The application for plea bargaining has to be filed by the accused in the court in which
such offence is pending trial.25 The application has to contain a brief description of the case
relating to which the application is filed including the offence to which the case relates and
is to be accompanied by an affidavit sworn by the accused stating therein that he has
voluntarily preferred, after understanding the nature and extent of punishment provided
under the law for the offence, the plea bargaining in his case and that he has not previously
been convicted by a Court in a case in which he had been charged with the same offence.
Thereafter, the Court issues notice to the Public Prosecutor or the complainant of the case,
as the case may be, and to the accused to appear on the date fixed for the case. It is
mandatory on the part of the judge to examine the accused alone in camera and to satisfy
itself that the accused has filed the application voluntarily and subsequently provide time
to the public prosecutor or the complainant of the case, as the case may be, and the accused
to work out a mutually satisfactory disposition of the case which may include giving to the

23
(2005) Cr. L.J. 2957.
24
The Criminal Law (Amendment) Act, 2005 (Act 2 of 2006).
25
Section 265-B(1).

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victim by the accused the compensation and other expenses during the case and thereafter
fix the date for further hearing of the case if the court is satisfied that the application is
voluntary. In case the court is not satisfied that the application is voluntary or the accused
has previously been convicted by a court for the same offence it shall proceed further from
the stage such application for plea bargaining was filed.26

It is the duty of the court to ensure, throughout the process of working out a satisfactory
disposition of the case, that it is completed voluntarily by the parties participating in the
meeting.27 The court is empowered to award the compensation to the victim in accordance
with the mutually satisfactory disposition agreed by the parties. The court is also
empowered to release the accused on probation of good conduct or after admonition under
section 360 or for dealing with the accused under the provisions of the Probation of
Offenders Act, 1958.28 The court may also sentence the accused to half of such minimum
punishment as prescribed, if any.29 If the court finds that the offence which the accused has
committed provides for a maximum punishment, then the court may award one-fourth of
such punishment.30

The judgment delivered by the court in accordance with the provisions of Chapter XXIA
of the Cr.P.C. is final and no appeal lies against such judgment. However such judgments
are subject to challenge under Articles 226 and 227 of the Constitution before the High
Court by filing Writ Petition and Article 136 of the Constitution before the Supreme
Court by filing Special Leave Petition.31 S.265-I provides for the application of S. 428 for
setting off the period of detention undergone by the accused against the sentence of
imprisonment imposed under Chapter XXI-A in the same manner as they apply in respect
of the imprisonment under other provisions of the Code. S. 265-K states that the
statements or facts stated by the accused in an application for plea bargaining shall not be
used for any other purpose except for the purpose of Chapter XXI-A.

Pitfalls under Chapter XXI-A

Addition of Chapter XXI-A containing provisions regarding plea bargaining is a step in

the right direction by the legislature in tackling the problem of backlogging of cases and
ensuring speedier disposal of cases. Chapter XXI-A contains various provisions which are
in tune with objective of introducing the concept of plea bargaining. Chapter XXI-A
contains provisions allowing the accused to voluntarily apply for plea bargaining. It further
makes provision for ensuring finality of judgments so that appeal does not drag on
frustrating the very purpose of plea bargaining, setting off period of detention already
undergone by the accused and making way for the court to provide compensation to the

26
Section 265-B(4).
27
Section 265-C Proviso.
28
Section 265-E(a)
29
Section 265-E(c).
30
Section 265-E(d).
31
Section 265-G.

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accused and releasing the accused on probation. All these provisions are commendable and
ensure speedier disposal of case but there are various loopholes which cannot be ignored.

The scope of the application of Chapter XXI-A is brought down to a large extent. This
goes against the very purpose of the introduction of the concept of plea bargaining. The
provisions of chapter XXI-A are not applicable to offences punishable with death or
imprisonment for life or of imprisonment for a term exceeding seven years. Further
offences against women and children below fourteen years and offences affecting the social
economic condition of the Nation are kept out of the purview of Chapter XXI-A. It is not
permitted for a person who has been convicted of the same offence to apply for plea
bargaining.32 This provision further restricts the application of the provisions of Chapter
XXI-A.

Section 265A(2) confers arbitrary power to the government to decide those offences which
constitute socio economic offences. There are no guidelines in the chaper laying down the
basis for classifying offences as socio economic offences. This could later result in violation
of Article 14 in case an accused feels that the classification is arbitrary and discriminatory.33

Under the provisions of Chapter XXI-A, the court is responsible for deciding whether the
application filed by the accused is voluntary or not. In a country like India, a person may
be voluntarily agreeing to Plea Bargaining in order to avoid expensive and long drawn
litigation despite being innocent. The Act is silent on such cases whether it would amount
to voluntarily filing application or involuntarily.

Further, in case the court feels the application has been filed involuntarily, then it is
required to continue from the stage where the application was filed. Entrusting the duty
on the Courts to decide on whether a case is fit for plea bargaining or not also will take up
time of the courts. Instead, this process may be more time consuming since the courts will
have to first determine whether the application is voluntary or not and accordingly decide
after that.34

Section 265C is titled Guidelines for mutually satisfactory disposition but no timeline is
prescribed for such disposition. The next step after the mutually satisfactory disposition is
the preparation of report by the court and the court has to record such observations and
proceed further in accordance with the provisions of Cr.P.C., even here there is no time
prescribed for the preparation of the report and recording observations which is a major
drawback and essentially goes against the purpose of introducing plea bargaining.

Conclusion

32
Section 265-B.
33
Rosie Athulya Joseph “Plea Bargaining: a means to an end” available at
http://www.manupatra.com/roundup/326/Articles/Plea%20bargaining.pdf (Visited On 2nd
January 2017).
34
Ibid.

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Judicial backlog is a major problem that India is facing today. There are various reasons for
backlogging of cases and every positive step taken in the direction of dismantling the cause
of backlogging or providing a solution should be welcomed with open arms. Introduction
of the concept of Plea Bargaining is one such step aimed at bringing down the number of
pending cases and ensuring speedier disposal of cases. Despite being in the statute books
for about 10 years, the usage of plea bargaining is still very low. There is a need to make
the police, prosecuting agencies, and defending lawyers familiar with the benefits of
availing plea bargaining which would ultimately save the precious time of courts and save
the money of the litigants which can very well be used to compensate the victim. The ambit
of plea bargaining was restricted to very limited number of offences as the concept was
introduced on an experimental basis but the question remains: How long will be the
experimentation period? There is an urgent need to take up a thorough study on its working
and the impact, so that appropriate changes can be introduced. There is also a need to
amend the law relating to Plea bargaining as contained under Chapter XXI-A of the Code
of Criminal Procedure in order to make it an effective tool in transforming our criminal
justice system. The time is ripe for an overall evaluation of the present system of plea
bargaining so that instead of remaining a dead letter in the statute books, plea bargaining
achieves its purpose of improving the situation with regard to pendency of cases and its
speedier disposal.

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