NOIDA INTERNATIONAL UNIVERSITY

WHITE COLLAR CRIMES

PREPARED BY
VAISHALI GUPTA,
BALLB, X SEMESTER,
ROLL NO.: BALLH-1501012

SUBMITTED TO
DR. P.K. DAS, ASSISTANT PROFESSOR
CRIMINOLOGY AND PENOLOGY
NOIDA INTERNATIONAL UNIVERSITY

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 TABLE OF CONTENTS
INTRODUCTION...............................................................................................................................3

CHRONOLOGICAL MILIEU OF THE EMERGENCE OF WHITE COLLAR CRIMES........6

WHITE-COLLAR CRIME CORPORATE CRIME: CORRELATIVE FEATURES..................7

CAUSES OF WHITE-COLLAR CRIME.........................................................................................7

a) NOT REALLY A CRIME.......................................................................................................7

b) NOT REALIZABLE................................................................................................................7

c) LACK OF AWARENESS.......................................................................................................7

d) NECESSITY............................................................................................................................7

e) GREED.....................................................................................................................................8

f) TECHNOLOGY......................................................................................................................8

g) COMPETITION......................................................................................................................8

h) LEGISLATION.......................................................................................................................8

WHITE COLLAR CRIME IN INDIA...............................................................................................8

CASE STUDY......................................................................................................................................9

1. Kingfisher Airlines Fraud.....................................................................................................11

2. Punjab National Bank fraud case.........................................................................................12

JUDICIAL RESPONSE....................................................................................................................12

CONCLUSION..................................................................................................................................14

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 INTRODUCTION
“The practitioners of evil, hoarders, the profiteers, the black marketeers, and speculators are
the worst enemy of our society. They have to be dealt with sternly. However well placed
important and influential they maybe, if we acquiesce in wrongdoing, people will lose faith in
us.”

-Dr. S. Radhakrishnan

Industrial revolution ushered an era of plenty but simultaneously gave birth to many new
problems. In the wake of industrialization a newer form of criminality was born which has
now assumed menacing proportions. Unlike the traditional crimes, this newer form of
criminality is associated with the upper and middle class people and is committed by them in
course of their occupations. This adversely affecting the health and material welfare of the
community as a whole and is also threatening the entire economic fabric of the state1.

The most influential criminologist of the 20th century and also a sociologist, Edwin Hardin
Sutherland, for the first time in 1939, defined white collar crimes as “crimes committed by
people who enjoy the high social status, great repute, and respectability in their occupation”.
The five attributes of the given definition are:

 It is a crime.

 That is committed by an important person of the company.

 Who enjoys a high social status in the society.

 And has committed it in the course of his profession or occupation.

 There may be a violation of trust.

Sutherland also included crimes committed by corporations and other legal entities within his
definition. Sutherland‘s study of white collar crime was prompted by the view that
criminology had incorrectly focused on social and economic determinants of crime, such as
family background and level of wealth. It is true to the common knowledge that there are
certain professions which offer lucrative opportunities for criminal acts and unethical
practises which is very often overlooked by the general mass of the society. There have been
crooks and unethical persons in business, various other professions, who tend to become

1
Dr. Sanjay I. Soanki, “A Critical Study on White-Collar Crimes in India” available at
http://www.ijbmi.org/papers/Vol(6)11/Version-3/H0611035258.pdf (Visited on 15 February, 2020).

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unscrupulous because of no reason apart from the thirst of gaining more and more for
themselves. These deviants have least regard for ethical and moral human values. Therefore,
they carry on their illegal activities with impunity without the fear of loss of respect and
prestige. These crimes are of the nature of white collar crimes which is the essential outcome
of the development of the competent economy of the twenty-first century. Related to the
corporate sector, white collar crimes are defined as non-violent crimes, generally committed
by businessmen and government professionals. In simple words, crimes committed by people
who acquire important positions in a company are called white collar crimes. They are often
master minded and are carried out in a planned manner by technocrats in the form of scams,
frauds, etc. facilitated by technological advancements. They range from antitrust offences to
healthcare fraud; impose enormous financial, physical and social harms on individuals,
communities, and society; as well as pose significant problems for law enforcement and
regulatory agencies that attempt to control and prevent such offenses.2

It is known to all that certain professions offer lucrative opportunities for criminal acts and
unethical practices which hardly attract public attentions; there have been crooks and
unethical persons in business, various professions, and even in public life. They tend to
become unscrupulous because of their neglect at school, home and other social institutions
where people get training for citizenship and character building. These deviants have scant
regard for honesty and other ethical values. Therefore, they carry on their illegal activities
with impunity without fear of loss of prestige or status. The crimes of this nature are called
‘white collar crime’. And they are essentially or outcome of competitive economy of mid-
twentieth century. Industrial revolution ushered an era of plenty but simultaneously gave
birth to many new problems. In the wake of industrialization a newer form of criminality was
born which has now assumed menacing proportions. Unlike the traditional crimes, this newer
form of criminality is associated with the upper and middle class people and is committed by
them in course of their occupations. This adversely affecting the health and material welfare
of the community as a whole and is also threatening the entire economic fabric of the state.
The criminality in these Classes are deep rooted and extends to such varied forms that it is
difficult to describe all of them. They extend from smuggling to adulteration and from tax
evasion to frauds and misappropriation, exhibited in numerous permutation and
combinations. The common feature of all this criminality is that the same which is born out
of greed, advance and rapacity; and committed in the course of trade, industry, commerce,
2
Gennaro F. Vito, Jeffrey R. Maahs, Criminology- Theory, Research and Policy 388 (Jones & Bartlett Learning,
3rd edition)

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business and profession of upper and middle classes. These crimes have adversely affected
the social and economic fabric of the state and the community alike and have been planned
development for the future a very difficult job. Sutherland has called these crimes, “white
collar crime”, while Sayre has described them, “public welfare offences”, there are others
who call these crimes “regulatory offences” and yet others “crime of strict liability”, while
many others have called it as “socio-economic crimes also”. The genesis of socio-economic
crimes/white collar crime has almost the same all throughout the world and it would be found
that socio-economic criminality is in away the product of industrial revolution, although
Renaissance and reformation also had contributed to the emergence of these crimes in no
small measure. Renaissance had cast many a doubt on the very existence of the absolute or
the Ultimate and in consequence the people became irreligious if not altogether atheists. The
fear of Ultimate was increasingly abandoned in favour of lure of the material. The one
emotion that seems to have unmistakably sobering effect on groups and individuals in this
fear of ultimate, the fear of world beyond, the fear of what might happen to oneself, to one’s
near and dear and the fear of consequences generally. The psychology, which kept and
maintained the stress on purity, resistance to temptation and the pursuit of goodness, was
increasingly abandoned in favour of money and material things. Money became to be an end
and be all the entire human activity. In fact, money became an obsession with every
individual. The high ethical codes and morale values were abandoned and thrown to winds in
pursuit of money and all sorts of frauds, misappropriations, misrepresentations, corruption
and adulteration came to be committed by the people in the course of their trade, commerce,
industry and professions. Crimes committed by the affluent in the course of normal business
activities:

 Conspiracies – use position for gain

 Expanded by some to include a wider range of “middle-class” criminality and “high-
tech” Crimes
 Legitimate business, deviant activity
 Internal vs. External judgments
 Secrecy
 Opportunity structures
 Institutional crimes

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 CHRONOLOGICAL MILIEU OF THE EMERGENCE OF WHITE
COLLAR CRIMES
The earliest documented case of white-collar crime law dates back to 15th century is
England. There has been a case popularly known as the Carrier‘s case of 1473, where the
agent was entrusted to transport wool and he attempted to steal some of it for him. Therefore
the Star Chamber and Exchequer Chamber of the English Court of Law adopted the breaking
bulk‘ doctrine as it constituted the crime of larceny. However, the growth of industrial
capitalism in the eighteenth century ushered a new history of crime and criminality. The very
base of industrial capitalism is based on coercion and robbery. Now, before we discuss the
topic let us understand the meaning of capitalism. The process of emergence of these
conditioned was termed by Karl Marx as ‘primitive accumulation’ while in the words of
Adam Smith, it was previous accumulation.

Therefore, the Dutch Marxist, William Bonger contended that criminal attitude develops
among the working class under capitalism due to conditions of misery and at the same time
the criminal attitude develops among the bourgeoisie from the avarice fostered when
capitalism strives.It succeeded in United States of America in 1890, when Congress passed
the Sherman Antitrust Act which took the initiative to make the monopolistic trade illegal.

Other industrialized countries like Great Britain had a history of penalties involving white
collar crime by that time, but it was not as sweeping as the Sherman Act. Some nations
implemented a smattering of these laws, known as competition or antitrust law, but did not
have a strong binding force for a long time. But more anti-white-collar crime sentiment rose
in the late 19th century and early 20th century in the United States as a result of a group of
journalists known as muckrakers. They laid much focus on the prevalent stock fraud,
insurance fraud and underhanded practices of monopolistic companies that had grabbed
under the Sherman Act. The muckraker exposes gave rise to public resentment and thereby
called for in some reform. By 1914, Congress attempted to solidify and strengthen the
sentiment laid down by the Sherman Act, which was used against labour unions, with the
Clayton Antitrust Act. This Act was much stricter and went much further than the Sherman
Act in making particular monopolistic practices illegal.

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 WHITE-COLLAR CRIME CORPORATE CRIME: CORRELATIVE
FEATURES
White-collar crime tends to be made up of complex, sophisticated and relatively technical
actions. White-collar crime tends to be intermingled with legitimate behaviour Victimization
tends to be diffuse. Harm is not always conceptualized or identifiable as such because it is
usually spread out over a substantial number of victims. The monetary sums that are involved
to be quite large.

 White-collar criminals steal by manipulating symbols rather than objects

 White collar crime occurs extends overtime

White collar crime is rarely prosecuted and rarely convicted. Penalties are light. With respect
to perception and prosecution, evidence indicating that they have taken place is not as clear-
cut as with street crime.

CAUSES OF WHITE-COLLAR CRIME

The general perception is that the white collar crimes are committed because of greed or
economic instability. But these crimes are also committed because of situational pressure or
the inherent characteristic of getting more than others. However, there are various reasons for
white collar crimes.3

a) NOT REALLY A CRIME: Some offenders convince themselves that the actions
performed by them are not crimes as the acts involved does not resemble street
crimes.
b) NOT REALIZABLE: Some people justify themselves in committing crimes as they
feel that the government regulations do not understand the practical problems of
competing in the free enterprise system.
c) LACK OF AWARENESS: One of the main reason of white collar crime is the lack
of awareness of people. The nature of the crime is different from the traditional
crimes and people rarely understand it though they are the worst victims of crime.
d) NECESSITY: Necessity is another factor of committing crimes. People commit
white collar crimes in order to satisfy their ego or support their family.

3
Aashish Ahuja, “Analysis of White Collar Crimes In India”, available at
https://blog.ipleaders.in/analysiswhite-collar-crimes-india/ (Visited on 12 February, 2020).

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 e) GREED: People of high strata are financially stable. But, still they commit crimes out
of greed. For this purpose, they adopt all sorts of illegal methods to have an economic
gain.
f) TECHNOLOGY: Another reason behind the commission of white collar crimes can
be technology. The emergence of new technologies, political pressure or growing
business, has led to many more ideas which has resulted in the commission of crimes.
g) COMPETITION: White collar crimes usually occur because of the desire to beat the
competitor and to reach ahead of them. To win, crimes like forgery, bribery and
frauds are committed.
h) LEGISLATION: One of the major reasons behind the rise in the commission of
white collar crimes are that there are not enough laws to deal with such kinds of
crimes. In most of the cases, white collar criminals are not even prosecuted. The
implementation of Information Technology Act 2008 is fragile due to lack of trained
workers. It is tough to find white collar criminals because the crimes which are
committed are mostly done in private places and hence there is no eye witness.4

WHITE COLLAR CRIME IN INDIA

In these types of offences not only the individual is being victimised with pecuniary loss but
also, such offences like peddling drugs and narcotic substances, counterfeiting of currency,
financial scams are some of the crimes which evoke serious concern and impact to the
national security and governance. Violation of foreign exchange regulations and import and
export laws are frequently resorted to for the sake of huge profits.5

In the India, there has been prevalence of white-collar crimes over a period of time. They are
spreading like a rapid fire in every sphere of society. Though corruption, one of the species of
white collar crimes, has been the most talked about issue in all spheres- social, economic and
political, not much stringent steps/actions have been taken to curb this menace.6 The Indian
Penal Code 18607 is the earliest comprehensive and codified criminal law of India. It
specifically does not mention the word ‘white-collar crimes’ but deals with many offences

4
Raj Krishna, Rishabh Goswami, “White Collar Crimes: A Conceptual Discussion” available at
http://ijldai.thelawbrigade.com/wp-content/uploads/2016/11/Raj-Krishna.pdf (Visited on 11th February, 2020).
5
Dr. Manju Koolwal, White Collar Crimes (Kamal Publisher, New Delhi, 2015).
6
G. Nagarajan & Dr. J. Khaja Sheriff, White Collar Crimes in India, International Journal of Social Science &
Interdisciplinary Research available at http://indianresearchjournals.com/pdf/IJSSIR/2012/September/16.pdf
(Visited on February 14, 2020).
7
Act 45 of 1860

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which are closely linked to white collar crimes such as bribery and corruption 8, counterfeiting
of coins and government stamps9, of offences relating to weights and measures 10, offences
relating to adulteration of food stuffs and drugs11, misappropriation of public property and
criminal breach of trust12, cheating13, forgery and offences relating to documents14 and
counterfeiting of currency15.

Corruption, fraud, and bribery are some of the most common white collar crimes in India as
well as all over the world. The Business Standard on 22.11.2016 published a report titled
‘The changing dynamics of white collar crime in India ’ stating that in the last 10 years, the
Central Bureau of Investigation (CBI) has found a total of 6,533 cases of corruption out of
which 517 cases were registered in the past two years.

Statistics showed that 4,000 crores worth of trading was carried out using fake or duplicate
PAN cards. Maharashtra showed a rapid increase in the number of online cases with 999
cases being registered. The report also mentioned that around 3.2 million people suffered a
loss because of the stealing of their card details from the YES Bank ATMs which were
administered by Hitachi Payment Services. 

Advancement in commerce and technology has invited unprecedented growth in one of the
types of white collar crimes, known as cybercrime. Cybercrimes are increasing because there
is only a little risk of being caught or apprehended. India’s rank on Transparency
International’s corruption perception index (CPI) has improved over the years.

In 2014, India was ranked 85th which subsequently improved to 76th position in 2015
because of several measures to tackle white collar crimes. In 2018, as per the report of The
Economic Times, India was placed at 78th position, showing an improvement of three points
from 2017, out of the list of 180 countries.

India is a developing country and white collar crimes are becoming a major cause for its
under development along with poverty, health, etc. The trend of white collar crimes in India
poses a threat to the economic development of the country. These crimes require immediate

8
Indian Penal Code, 1860- Section 168, 169, 171B, 171C, 171E, 171H.
9
Ibid section 230 – 263.
10
Ibid section 264 – 267.
11
Ibid section 272 – 276.
12
Ibid section 403 – 409.
13
Ibid section 415 – 420.
14
Ibid section 463 – 489.
15
Ibid section 489A – 489D.

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intervention by the government by not only making strict laws but also ensuring its proper
implementation.

The Reports of the Vivin Bose Commission of Inquiry which looked into the affairs of
Dalmia Jain group of companies (1963) highlighted that how industrialists indulge
themselves in white collar crimes such as forgery, fraud, falsification of accounts, tampering
with records for personal gains and tax evasion etc.16

The theory of natural rights and laissez faire did not permit the state to interfere in the
material pursuit of the individuals, associations or communities, with the result that socio-
economic criminality multiplied beyond recognition and therefore, initially it had fallen on
the shoulders of courts and judges to reshape the traditional criminal jurisprudence in the
context of socio-economic crimes. It was only thereafter the state intervened and took some
measures to regulate this newer form of criminality but the crisis of moral values and ethical
codes had already set in and even the state’s belated intervention could not completely
eradicate this malady. Mahesh Chandra – material socio-economic crimes Mahesh Chandra –
published in 1979 (Delhi higher judicial service) Versus Organized crime: organizational
directed towards deviance White-collar crime is not a classic, clear-cut case of deviance. It
has one foot in conventionality and one foot in deviance. Most of us hold the conception that
“crime” is what street people of at least poor people do. Thus, there is a certain incongruity in
seeing an affluent, 60 years-old banker in handcuffs and a prison uniform. Some character
about white collar crime mostly seen in India are:

 Deliberate acts motivated by profit

 Corporate Culture : Criminogenic: Differential Association
 Element of Learning, Peer support, Rationalization and Neutralization
 Victimization: Diffuse
 Lack of reporting and defining
 Civil vs. Criminal violations
 Sociological category
 Sanctions: small fine, big payoffs
 Investigation: Limited resources, problem of technology
 Activity hidden in normal business – secrecy (Medical Profession)

16
Prof. N.V. Paranjape, Criminology & Penology with Victimology 147 (Central Law Publications, 16th
edition, 2015)

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 CASE STUDY
1. Kingfisher Airlines Fraud
In the 17-bank consortium, SBI has the largest exposure to Kingfisher Airlines, the company
promoted by liquor baron Vijay Mallya. The banks altogether has an exposure of about Rs
7,000 crore to the airline, of which SBI's alone stands at Rs 2,000 crore.

The airline's loans to SBI had become an NPA (after 90 days non-payment of interest) as on
31 December 2011. In the next one month, at least five more lenders in the consortium
classified Kingfisher as NPA too. That was the end of banks’ love-affair with Mallya and the
now-grounded airline.

Until then, banks were competing with each other to lend to the company. Interestingly, even
when its financials were deteriorating sharply, the banks sounded hopeful of a revival story.
But the end came too fast, leaving a huge bad loan pile of Rs 7,000 crore to banks. (To put
the amount in perspective, that's almost half of what state-run banks used to get from the
government as annual capital infusion).

The only major instance, when banks at least made a serious effort to clamp down on Mallya
was when United Bank — one of the 17 lenders — classified him as a wilful defaulter. But,
even there the bank had to withdraw the tag after a Kolkata court verdict that followed soon.
Court freed Mallya purely on technical grounds.

The court observed that the grievance redressal committee - the panel that declares a
borrower defaulter - of the bank was not constituted as per regulatory guidelines set by the
RBI. It had four members, while it should have had only three.

Kingfisher is just one example, where courts have come to the rescue of loan defaulters.

There are many similar cases where promoters have fooled banks (by diverting funds from
end-use, or siphoning off the cash, for personal gains), but managed to get reprieve from
courts to delay the recovery process.

Theoretically, there is no reason why financial frauds by wily promoters should be treated
different from other types of criminal activities but instances of a company promoter being
brought before law and punished for wilful default is a rarity.

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 2. Punjab National Bank fraud case
One of the most recent scandals, the Punjab National Bank fraud case is about the fraudulent
letter of undertaking worth Rs. 14,356.84 crore (US$ 2.1 billion) that was issued by the
Punjab National Bank at its branch office at Brady House in Fort, Mumbai, making the bank
liable for the amount. This fraud was masterminded by jeweler and designer Nirav Modi in
collusion with two PNB officials.

After discovering the fraud, PNB filed a complaint with the CBI wherein it was alleged that
Nirav, Ami Modi, Nishal Modi and Mehul Choksi, committed the offence of cheating PNB
and causing a huge financial loss.

Modi is on the Interpol’s most wanted list for committing the criminal conspiracy, since
February 2018. Currently Modi is in UK, and is seeking political asylum in Britain though
the Indian government has officially asked for his extradition.

The Enforcement Directorate has begun attaching assets of the accused and is seeking to
immediate confiscation under the Fugitive Economic Offenders Ordinance. On a later date,
CBI named key officials Usha Anantha Subramanian, former CEO of PNB, executive
directors KV Brahmaji Rao and Sanjiv Sharan in a charge sheet holding them responsible for
failure to implement several circular and caution notices issued by the RBI regarding the
reconciliation of SWIFT messages and core banking systems.17

JUDICIAL RESPONSE
The Prohibition of Corruption Act, 1986 and the Code of Criminal Procedure, 1973, both
provide special impunity by Section 19 and Section 197, respectively. The sanction
contemplated in Section 197 of the Code concerns a public servant who “is accused of any
offence alleged to have been committed by him while acting or purporting to act in the
discharge of his official duty”. To restrict the unnecessary harassment of public servant, these
sections provide that no court shall take cognizance without prior sanction for prosecution
from the appropriate authority.

Dealing with corruption related matters, where often sanction for prosecution of a public
servant is either refused or delayed by the government, Supreme Court observed in the
Vineet Narain v. Union of India 18, that the corruption cases against public servant were often

17
Available at https://www.businesstoday.in/sectors/banks/pnb-fraud-companies-owned-by-nirav-modi-
mehulchoksi-received-rs-427-crore-in-july-2014/story/272700.html (Visited on 15th February, 2020).
18
(1998)1 SCC 226.

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delayed due to refusal or delayed sanction by the competent authority despite the
investigation agency having disclosed a prima facie against the public servant. The Court
held that sanction to prosecute not being a quasi-judicial function, the competent authority
must give sanction if it is satisfied that material placed before it is sufficient for prosecution
of the public servant. The Supreme Court reiterated this approach in Subramanium Swamy
v. Dr. Manmohan Singh19, and reaffirmed that the 3 months time limit imposed on the grant
of governmental sanction under section 19 of Prevention of Corruption Act, 1988 for the
prosecution of public servant for corruption must be strictly adhered to.

In the case of Jaylalitha v. Union of India20, the Supreme Court admitted that corruption is rampant
among the public servants. Court further stated that corruption corrodes the moral fabric of the society
and is harmful to the national economy. Corruption by persons occupying high posts in government,
by misusing their powers can cause considerable damage to the national economy, national interest
and image of the country.

In Ram Narayan Poply v. C.B.I. 21, the Apex Court expressed concern for adverse effect of white
collar crimes and held that economic offenders should not be allowed to ruin the economy of the
country and they should be sternly dealt with.

The Supreme Court in State of Gujarat vs. Mohanlal Jitamalji Porwal and Anr. 22 has
differentiated between the general crimes and white collar crimes. In the above-mentioned judgement,
Justice Thakker had stated that murder can be committed in the heat of moment but these economic
offences are committed with a cool calculation and planned strategy to gain personal profits.

In case of Nimmagadda Prasad v. C.B.I.23, the appellant along with Jagan Mohan Reddy,
enriched himself for more than 40,000 crores of rupees by the influence of Jagan Mohan’s
father Dr. Y.S. Rajasekharan Reddy who was the then Chief Minister of Andhra Pradesh. The
Chief Minister, Late Dr. Reddy extended many undue favours to the appellant by abusing his
official position and thereby allotting 18879 acres of land to the appellant and in return, he
paid illegal gratifications amounting to 854.5 crores rupees to Y.S. Jagan Mohan Reddy and
his group of companies. Illegal gratifications were paid in the guise of investments/share
application money to give them corporate colour in order to escape criminal charges. The
appellant’s prayer for bail was dismissed by the Supreme Court in the view of the fact that he
was involved in a grave economic offence of alienating prime lands to selected private
19
AIR 2012 SC 1185.
20
(1999) 5 SCC 138.
21
AIR 2003 SC 2748.
22
AIR 1987 SC 1321
23
AIR 2013 SC 2821.

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companies/individuals under the garb of development using deceptive means resulting in
wrong ownership and control of material resources detrimental to common good. The Court notes that
the appellant was a person of means and as such, he could influence witnesses, therefore, it would not
be proper to release him on bail.

CONCLUSION
The threats and harm posed by White Collar Crimes to the well-being of Indians and the
economic development of this country cannot be underestimated. The White Collar Crimes is
the bane of most developing countries especially India. It is leading cause of it’s under
development with its concomitant effects of poverty, squalor and disease.

White Collar Crimes thrives on weak institutions, bad leadership and bad governance;
something urgently needs to be done to nip in bud the increasing incidence of White Collar
Crimes before the economy collapse. These White Collar Criminal activities because of
widespread corruption in our offices & every walk of life are not likely to be done away with
so soon. Until & unless each of our laws is properly enforced in their letters & Spirit by the
law enforcing agencies & officials concerned with full honesty & integrity. Though the anti-
corruption law & have analysed in the last chapter of my thesis. It is this law which needs
much of its proper enforcement especially against those who are seldom prosecuted should be
punished to the maximum. So also each of the laws which & have analysed in other chapters
need their proper enforcement by all those who are in the balm of affairs. Be it the

 The Prevention of Food Adulteration Act, 1954.

 The Essential Commodities Act, 1955.
 The Prevention of corruption Act, 1988.
 Tax evasion laws etc.

More stringent regularity laws & punishment for White Collar Crimes criminals for effective
implementation with a clear message of deterrence. Now there should be a separate chapter
on White Collar Crimes should be incorporated in Indian Penal Code by awarding the code.
So that White Collar Crimes criminals connected by the court & do not escape punishment
because of high social status. Above all, public vigilance will always be required to have a
positive change in the longer run.

14