Bangladesh University of Professionals

Department of Law
Program: LL.M. (Master of Laws)

Course Title: Comparative Constitutional Law

Course Code: (Law: 5102)
Assignment On: Presidential Prerogative Mercy in Bangladesh: A
Comparative Legal Analysis.

Submitted To:
Dr. Muhammad Ekramul Haque
Professor
Adjunct Faculty, Department of Law
Faculty of Security and Strategic Studies (FSSS)
Bangladesh University of Professionals (BUP)

Submitted By:
Masudur Rahman Rana
ID: 2042361045
E-mail: ranalaw65@gmail.com
Date of Submission: 08.07.2020

1
 TABLE OF CONTENTS

Serial List of Contents Page

Number Numbers
 Cover Page 1

 Table of Contents 2

 Abstract 3

1. Introduction 4

2. Meaning of Pardon 4-5

3. Legislative Background 6

4. Power of Pardon in Bangladesh 6-7

5. Power of Pardon in the International Sphere 7-11

6. The Abuse of the Power of Pardon in Bangladesh 11-13

7. Recommendations 13-14

8. Conclusion 15

 Bibliography 16-17

2
 Abstract:

The Presidential prerogative mercy is common almost every democratic country in the world.
The power of pardon is an important component of executive powers, which allows the President
to intervene and grant pardon, it is the discretionary power of the President. It is considered as
the last shelter of justice. This article has specially focused on Bangladesh and international
provisions of prerogative mercy. In UK, USA, South Africa, India there have some specific
guidelines and conditions. But this things are absent in Bangladesh. When government execute
clemency, it is their responsibility to use this power through neutrality and good conscience but
not arbitrarily. But hardly these things are followed in Bangladesh. This article has pointed out
the present condition of presidential clemency in different country constitutions, its pitfalls in
Bangladesh and way to overcome.

Key Words: Prerogative Mercy, Bangladesh, Abuse, Guideline, Constitution.

3
 1. Introduction:
Everyone should get the last chance, from that thinking prerogative mercy introduced almost
every country in the world. Generally it is used to avoid the miscarriage of justice. This power is
ensured by the constitution of Bangladesh. It may be exercised either before or after the
conviction and need not wait for the verdict of the court (Attorney General of Trinidad and
Tobago v. Philli, 1994).1 The constitution of Bangladesh through its Article 49 offers the
President of the Republic to exercise this authority. In Bangladesh, the power to pardon, which is
described as the prerogative of mercy, is a constitutional power vested in the President. In
Bangladesh it is not provided any specific guidelines and judicial review still not introduced. As
a result, in Bangladesh different government has been used this power for their own interest. The
history of pardon in Bangladesh, took place considering only political ground and affiliation. In
this article, I have tried to explore the background and objective of prerogative of mercy, its
practice, the threatened constitutional provisions and the practicable control against this
prerogative in the light of Bangladesh constitution. To this end, I have visited the concepts and
practices of prerogative of mercy in India, UK, USA and South Africa with the descriptive and
legal comparative methods of study. This research can possibly strike the controversy of
clemency being alleged as a paradox in a democratic State having glorious history of political
positivism.

2. Meaning of Pardon:
In general, pardon means to forgive a person of his or her offence. In other words, grant of
pardon wipes off the guilt of accused and brings him to the original position of innocence as if he
had never committed the offence for which he was prosecuted. The word prerogative actually
comes from the Latin term "prærogativa" or “prærogativus” which means "special right, previous
choice or election."

The Black’s Law Dictionary (Garner, 2009) defines the word “pardon”, as “the act or an
instance of officially nullifying punishment or other legal consequences of a crime. A pardon is

1
Attorney General of Trinidad and Tobago v. Philli (1994) 1 AC 394

4
usually granted by the Chief Executive of a government such as the President in respect of
federal offences and the Governor in respect of State offences.2

In US v Wilson,3 Chief Justice Marshall defined a pardon as:

… an act of grace, proceeding from the power entrusted with the executive of laws, which
exempts the individual, on whom it is bestowed, from the punishment the law inflicts for a crime
he has committed. It is the private, though official act of the executive magistrate delivered to the
individual for whose benefit it is intended and not communicated officially to the court.
According to Cambridge Advanced Learner’s Dictionary (2008),4 the word prerogative means
something which some people are able or allowed to do or have, but which is not possible or
allowed for everyone.

According to Oxford Advanced Learner’s Dictionary (2005),5 the word prerogative means a
right or advantage belonging to a particular person or group because of their importance or social
position.

Granting of pardon may be of two kinds, absolute or unconditional. An unconditional pardon

wipes out both the conviction and sentence and restores all civil rights of the individual
concerned as if he had never been convicted of the offence (R. v. Foster, 1985).6 Conditional-
when the grant of pardon is conditional, the protection provided by the pardon is not available
until the condition is complied with and pardon becomes valueless due to non-compliance with a
condition to which it is subject (Attorney General of Trinidad and Tobago v. Philli, 1994) and
the pardoned person may be made to suffer the punishment he was originally sentenced.7

2
A Hamilton (1788), The Federalist No. 74
3
Burdick v United States (1915), 236 U.S. 79
4
Cambridge Advanced Learner„s Dictionary (2008)
<https://dictionary.cambridge.org/dictionary/english/prerogative> accessed on 27 June, 2020
5
Oxford Advanced Learner‟s Dictionary (2005)
<https://www.oxfordlearnersdictionaries.com/definition/english/prerogative> accessed on 27 June, 2020

6
R v. Foster (1985) 79 Cr.App.R. 61
7
Mahmudul Islam: Constitutional Law of Bangladesh (Mullick Brothers, 2 nd Edition, 2002) P 324

5
 3. Legislative Background:
During the British rule, the Power of Pardon was historically vested in the British monarch. At
common law, a pardon was an act of mercy whereby the king forgave any crime, offence,
punishment, execution, right, title, debt, or duty. This power was absolute, unfettered and not
subject to any judicial scrutiny. From this source, it came to find a place in the constitutions of
India. Consequently this power is exercised in Bangladesh. In Bangladesh, the President
exercises this power on the advice of Prime Minister. The President may exercise the power
either before or after conviction and need not wait for the verdict of the court.8 Article 499 of the
Constitution of Bangladesh provides- The President shall have power to grant pardons, reprieves
and respites and to remit, suspend or commute any sentence passed by any court, tribunal or
other authority. In addition to these constitutional provisions, the Criminal Procedure Code,
189810 in Sections 401 and 402, provides for pardon. Sections 54 and 55 of the Penal Code,
186011 confer power on the appropriate government to commute sentence of death or sentence of
imprisonment for life as provided therein.

4. Power of Pardon in Bangladesh:

Pardoning Power is exercised in different countries all over the world. The study of the legal and
practical exercise of the power helps us to understand Bangladesh position.
There is no specific guideline in Bangladesh constitution to pardon mercy. According to the
Constitution, the President is to exercise the prerogative power of mercy in consultation with or
in accordance with the advice of the Prime Minister. The President cannot act independently in
exercising the prerogative power of mercy. As a result, every government is using this power as
per its whim and caprice and day by day the tendency to use this power is increasing. All the
prerogatives those have been given till the date are completely politically biased.

8
Ibid, p 5
9
The Constitution of Bangladesh, 1972
10
The Code of Criminal Procedure, 1898
11
The Penal Code, 1860

6
The High Court Division12 in a verdict in April 2012 said that the powers of the President to
pardon, suspend or remit sentences of any convict should be exercised fairly and on unbiased
relevant principles. The court pronounced the verdict in a case involving presidential clemency
to a fugitive convict. It is well settled that the court cannot direct the President and the
government in exercising their powers according to Article 49 of the constitution and section 401
of the Code of Criminal Procedure, 1898. The judgment provides, ―but the action of the
President or the government, as the case may be, must be based on some rational, reasonable, fair
and relevant principle which is non-discriminatory and it must not be guided by any extraneous
or irrelevant considerations. Possibly it is high time for the government to think about the matter
to avoid controversy, criticism and misuse of power, the court observed.
An argument against prerogative mercy is that, Article 2713 of Bangladesh Constitution: All
citizens are equal before law and are entitled to equal protection of law. In this circumstance the
power to clemency goes against the fundamental right in some cases as all men are not equally
treated to grant clemency.

5. Power of Pardon in the International Sphere:

The origin and application of the pardon power in different jurisdictions, relevant to this study,
are examined in this section. Importantly, the nature and extent of restraints, if any, on the
exercise of the pardon power are highlighted. The purpose is to determine what lessons could be
learnt by Bangladesh from the operation of the pardon power in these jurisdictions. The selected
jurisdictions are, India, United Kingdom (UK) United States and South Africa:

5.1 In India:
In the Constitution of India,14 the power of Presidential Pardon is found in Article 72. Article 72
says that the President shall have the power to grant pardons, reprieves, respites or remissions of
punishment or to suspend, remit or commute the sentence of any person convicted of any

12
Mohammad Arafat Hossain and Md. Sher-E-Alam: A Legal Analysis of the Presidential Prerogative of Mercy in
Bangladesh (Metropolitan University Journal) p 145
13
Ibid, p 6
14
The Constitution of India, 1950

7
offence. A parallel power is given to the Governor of a state under Article 161 of the Indian
Constitution. In addition to these constitutional provisions, the Criminal Procedure Code, 1973 15
in Sections 432, 433, 433A, 434 and 435, provides for pardon. Sections 54 and 55 of the Indian
Penal Code, 186016 confer power on the appropriate government to commute sentence of death
or sentence of imprisonment for life as provided therein.

Article 72 and 161 is subject to judicial review. It was held by the Supreme Court of India in the
case of Maru Ram v. Union of India (1980).17 It was subsequently confirmed by the Supreme
Court in case of Kehar Singh v. State of India (1988).18
If the Court cannot sit in judgment on how discretion is exercised, what exactly is it reviewing?
The Supreme Court in the 1997 case of Mansukhlal Vithaldas Chauhan v. State of Gujarat19
said that the Court does not sit as a court of appeal but merely reviews the manner in which the
decision was made particularly as the Court does not have the expertise to correct the executive
discretion for the judge‟s discretion but to confine itself to questions of legality, which mean in
effect the following five basic questions: 1. Did the decision making authority exceed its
powers? 2. Did the authority commit an error of law? 3. Did the authority commit a breach of the
rules of natural justice? 4. Did the authority reach a decision that no reasonable tribunal would
have reached? 5. Did the authority abuse its powers?
In Satpal v. State of Haryana (2000),20 the Supreme Court quashed an order of the Governor
pardoning a person convicted of murder on the ground that the Governor had not been advised
properly with all the relevant materials.
In Epuru Sudhakar v. Government of Andhra Pradesh (2006),21 the Court set aside a
remission granted by the Governor of Andhra Pradesh on the ground that irrelevant and
extraneous materials had entered into the decision making.44

15
The Code of Criminal Procedure, 1973
16
The Indian Penal Code, 1860
17
Maru Ram v. Union of India (1980) 1 SCC 107
18
Kehar Singh v. State of India (1988) AIR 653, SCR Supl (3)1102
19
Mansukhlal Vithaldas Chauhan v. State of Gujarat (1997) 7 SCC 622
20
Satpal v. State of Haryana (2000) 5 SCC 170
21
Epuru Sudhakar v. Government of Andra Pradesh (2006) Writ Petition (Cri.) 284-285

8
The Supreme Court of India, in Narayan Dutt v. State of Punjab (2011)22 has held that the
exercise of power is subject to challenge on the following grounds: a) If the Governor had been
found to have exercised the power himself without being advised by the government; b) If the
Governor transgressed his jurisdiction in exercising the said power; c) If the Governor had
passed the order without applying his mind; d) The order of the Governor was malafide; e) The
order of the Governor was passed on some extraneous considerations. Thus, in these judgments
concerning the Governor‟s exercise of pardon, the Court seems to have widened the grounds for
judicial review by enumerating specific grounds on which the grant of pardon can be considered
arbitrary.23

5.2 In UK:
The power to grant pardons and reprieves is known as the royal prerogative of mercy.24 It is the
standard policy of the government to only grant pardons to those who are considered "morally"
innocent of the offence. Pardons are generally no longer issued prior to a conviction, but only
after the conviction. The use of the Royal prerogative of mercy is now a rare occurrence. At
present, the monarch exercises the power on the advice of the Home Secretary, whose decision
can, in some situations, be challenged by judicial review. 25 In R v Secretary of State for the
Home Department, ex parte Bentley,26 the Court held that the royal prerogative of pardon is a
flexible power. Thus, the Home Secretary‟s discretion on the exercise of the prerogative of
mercy is a wide discretion. Nevertheless, the Home Secretary‟s decision to pardon a prisoner is
susceptible to judicial Review. Thus, it may be concluded that in the UK, judicial review of the
power of pardon is extremely restricted in scope, because the British constitutional structure
recognizes the supremacy of Parliament and provides an altogether narrower scope for judicial
review.27

22
Narayan Dutt v. State of Punjab (2011) 4 SCC 353, para 24
23
Bikas Chatterjee v. Union of India (2004) 7 SCC 634 at 637
24
Ibid, p 7
25
L Sebba: Clemency in Perspective (Lexington: Mass Lexington Books, 1977) pp 225-228
26
R v. Secretary of State for the Home Department (1994) QB 349
27
M M Islam: Judicially Reviewing the President‟s Prerogative of Mercy- A Comparative Study (Bangladesh
Research Publications Journal, 2012) pp 257-266

9
5.3 In USA:
Article II of the US Constitution28 grants the President the power to grant reprieves and pardons.
A Presidential pardon may be granted at any time; however, the pardoned person need not yet
have been convicted or even formally charged with a crime. Clemency may also be granted
without the filing of a formal request and even if the intended recipient has no desire to be
pardoned. The pardon power of the President extends only to offences cognizable under federal
law. However, the Governors of most of the 50 states have the power to grant pardons or
reprieves for offences under State criminal law. In Hoffa v. Saxbe (1974)29, a condition imposed
on a pardon was challenged as unconstitutional. The District Court held that the “framework of
the constitutional system” establishes limits beyond which the President may not go in imposing
and subsequently enforcing conditions on pardons. In Burdick v. United States (1915)30, the
Court upheld an offender‟s right to refuse a presidential pardon granted in order to compel him to
testify in a case which conflicted with his right against self-incrimination. However, apart from
judicial scrutiny in this area, the power of pardon has been allowed to be exercised freely.

5.4 In South Africa:

In the South African Constitution, 1996, the power of pardon is vested in the President by Article
84(2) (j), which provides that: “The President is responsible for… pardoning or reprieving
offenders and remitting any fines, penalties or forfeitures”.. The power under section 84(2) (j) of
the Constitution of South Africa 1996 can be used to pardon an individual, or a group of
people.31
This power of the President is only exercised in highly exceptional cases. To pardon a person is
to forgive a person for his/her deeds. Pardon is only granted for minor offences after a period of
10 years has elapsed since the relevant conviction. For many serious offences pardon will not be
granted even if more than 10 years have elapsed since the conviction.

28
Constitution of the United States, 1789
29
Hoffa v. Saxbe (1974) 378 F. Supp. 1221 D.D.C
30
Burdick v. United States (1915) 236 U.S. 79
31
President of South Africa v. Hugo (1997) 4 SA 1 Para 29

10
In Hugo’s case, President Mandela remitted the sentences of all mothers with children under the
age of 12 who were imprisoned for having committed minor offences. In Albutt32 and Chonco33
70 President Mbeki pardoned certain people who would have been eligible for amnesty from the
Truth and Reconciliation Commission, but who failed to apply for it.
While the power is broad, it is not unrestricted. The most significant restriction is that it must be
exercised in a way that is consistent with the Constitution.34 Thus, the President cannot pardon in
breach of the Bill of Rights and must act in good faith.

In UK, USA, South Africa this power is exercised rarely as it is very sensitive and public opinion
may go adverse if it is executed unscrupulously. They have strong commission, which examines
the merit and demerit of it with extensive cautions, then they submit their observation report, and
the clemency mostly depends upon it. Even in India, day by day the way of misusing this power
is shrinking as the court is empowered to review it. But the condition in Bangladesh is miserable
and it did not set judicial review process yet.

6. The Abuse of the Power of Pardon in Bangladesh:

The power of pardon is reserved to avoid any miscarriage of justice. But this power has been
abused through various ways. Article 49 of this Constitution provides- The President shall have
power to grant pardons, reprieves and respites and to remit, suspend or commute any sentence
passed by any court, tribunal or other authority. But there is no specific guideline in this
constitution. As a result, every government is using this power as per its whim and caprice and
day by day the tendency to use this power is increasing. In Bangladesh, the power of the
presidential clemency is being used in an unrestrained way.
Military ruler HM Ershad was the first to exercise the power entrusted upon the President. In
1987 he showed clemency to his party cadre Azam Khan, who was convicted for killing Awami
League leader Moyezuddin Ahmed.

32
Albutt v. Centre for the Study of Violence and Reconciliation (2010) 3 SA 293 CC
33
Minister for Justice and Constitutional Development v. Chonco( 2010) 4 SA 82 CC
34
Certification of the Constitution of the Republic of South Africa, 1996 (4) SA 744 (CC) para 116

11
The number of influencial clemency under different governments in Bangladesh is shown
in the table below:
Year Incumbent President Ruling Party Number of
Clemency
1. 1987 HM Ershad Jatiya Party 01
2. 2005 Prof. Dr. Iajuddin Bangladesh Nationalist 02
Ahmed Party
3. 2008 Prof. Dr. Iajuddin Caretaker Government 01
Ahmed
4. 2009 Md. Zillur Rahman Bangladesh Awami 01
League
5. 2010 Md. Zillur Rahman Bangladesh Awami 18
League
6. 2011 Md. Zillur Rahman Bangladesh Awami 02
League

Source: <http://newagebd.com/newspaper1/archive_details.php?date=2012-02-28&nid=51887>
accessed on 26 June, 2020

During 2005 in the tenure of BNP led government, two people, including Sweden expatriate
Mohiuddin Jhintu, were given clemency. Later Fakhruddin Ahmed led Caretaker Government
also granted clemency to a convict sentenced to death. After the Awami League had assumed
office, one was given clemency in 2009, 18 in 2010 and 2 in 2011. The ruling Awami League
has been highly criticized for having 18 people pardoned by the President at the same time. The
Asian Human Rights Commission35 claimed that the President was just playing the same cards
as his predecessors had and his successors would, with no sense of justice and humanity. Awami
League is still in the power and from 2009 to 2020 they exercising this so called political game
for their own interest.

The culture of pardoning initially started in different way as by promulgating the Indemnity
Ordinance 1976 by President Khondaker Mostaq Ahmed which was also ratified by the next

35
Ibid, p 7

12
Parliament in 1979 and that draconian law prohibited any investigation and prosecution of the
murder of Sheikh Mujib, the father of the nation and members of his family.36

Therefore, this has long been a fascinating observation that the decisions of mercy by the
Political Supremes have served the political purposes disregarding the merits of the case.
Interestingly, no governments have yet made public which principles were followed at admitting
clemency. Impropriety in dealing with the sensitive power, in Bangladesh it can be called as
political game.

7. Recommendations:
In this condition, the unrestrained power of the presidential clemency is needed to be restrained
for the sake of justice. Implications on the projection to remove the wretchedness caused by
random and unjustified exercise of prerogative of mercy in Bangladesh must need to ensure. The
following recommendations may be made to bring this under positive control:

i. Article 49 of constitution may be amended including sufficient specific guidelines for

granting clemency.
ii. To protect the discriminatory mercy, the Supreme Court of Bangladesh can keep
significant role by suo moto. The provisions of article 49 remains advantageous in the
aspect of judicial scrutiny because it did not mention whether the exercise of the
prerogative mercy can be challenged or not. It can be suggested that article 49 should be
amended following the classical references (the point of judicial review, the conditions
for mercy and the limitations) of articles 72 and 161 of Indian Constitution.
iii. In the course of seeking mercy, the convicted should be in a favorable position which was
insisted in UK, USA and South Africa whereas it is an equitable gain. The standing of the
mercy petitioner can be weighed with his age, previous criminal record, the undergone
and remain period of imprisonment, nature and seriousness of the offence, contribution to

36 Md Rabiul Islam: An Elucidation on Prerogative of Mercy to Assess Its Limits in the Constitution of Bangladesh
with a Comparative Study (Jahangirnagar University Journal of Law, Volume-II, 2014)

13
 the state, physical condition, good behavior during imprisonment, reasonable public
sympathy etc.
iv. An effective scrutinizing commission should be formed, which will be presided over by a
Session Judge or a Supreme Court Judge and its other members may be criminologist and
some others who are experts in criminal laws. The commission will verify the
applications and check every aspects of pardoning systematically and recommend who
deserves pardon and who does not deserve.
v. Since the Prime Minister advises the President in granting pardon, the Prime Minister
should be more alert, lest a stigmatized offender gets the opportunity of being pardoned.
i. To what extent, the President has granted mercy may be disclosed in print and electronic
media. These ways of featuring can be an effective mode of ensuring transparency.
ii. In the course of clemency, political culture or political game in Bangladesh that should be
change for the benefit of the whole society.
iii. Provisions may be provided in the constitution so that conscious citizens may raise voice
against the misuse of this power.
iv. And most of the grounds of clemency should be conditional and not of absolute.

14
 8. Conclusion:
In fine, it may be said that clemency has its own significance. The necessity of granting mercy
can„t be denied. It is the last shelter of judicial mistake. I endure with the existence of
prerogative of mercy in Bangladesh. It could satisfy people, if it would have been exercised for a
rational and sustainable manner. Paradoxically, the deficiency of judicial scrutiny on the
President‟s power of pardoning has generated silent autocracy in Bangladesh. Whatever the
views the politicians hold, the bargain question affecting the justiciability of the prerogative of
mercy exercised capriciously has nullified the spirit of the Constitution of Bangladesh which
offers the norms of rule of law and natural justice. With keep an eye before India, UK, USA and
South African Constitutional provisions, through Constitutional amendment Bangladesh should
introduce judicial review provision for the Presidential prerogative mercy. Lastly, the pardoning
authority must keep in mind that this power is delegated by the citizens for their greater interest
and the authority has no right to use it for the personal interest at all.

15
 Bibliography:

o Primary Sources:

Cases:

• Albutt v. Centre for the Study of Violence and Reconciliation (2010) 3 SA 293 CC
• Attorney General of Trinidad and Tobago v. Philli (1994) 1 AC 394
• Bikas Chatterjee v. Union of India (2004) 7 SCC 634 at 637
• Burdick v. United States (1915) 236 U.S. 79
• Epuru Sudhakar v. Government of Andra Pradesh (2006) Writ Petition (Cri.) 284-285
• Hoffa v. Saxbe (1974) 378 F. Supp. 1221 D.D.C
• Kehar Singh v. State of India (1988) AIR 653, SCR Supl (3)1102

• Mansukhlal Vithaldas Chauhan v. State of Gujarat (1997) 7 SCC 622

• Maru Ram v. Union of India (1980) 1 SCC 107
• Minister for Justice and Constitutional Development v. Chonco ( 2010) 4 SA 82 CC
• Narayan Dutt v. State of Punjab (2011) 4 SCC 353, para 24
• President of South Africa v. Hugo (1997) 4 SA 1 Para 29
• R v. Foster (1985) 79 Cr.App.R. 61
• R v. Secretary of State for the Home Department (1994) QB 349
• Satpal v. State of Haryana (2000) 5 SCC 170

Statutes:

• Constitution of the United States, 1789

• The Constitution of the Republic of South Africa, 1996
• Indemnity Ordinance, 1976
• The Code of Criminal Procedure, 1973
• The Code of Criminal Procedure, 1898
• The Constitution of Bangladesh, 1972
• The Constitution of India, 1950
• The Penal Code, 1860

16
 o Secondary Sources:

Books:

• L Sebba: Clemency in Perspective (Lexington: Mass Lexington Books, 1977) pp 225-228

• Mahmudul Islam: Constitutional Law of Bangladesh (Mullick Brothers, 2nd Edition,
2002) P 324
• M M Islam: Judicially Reviewing the President‟s Prerogative of Mercy- A Comparative
Study (Bangladesh Research Publications Journal, 2012) pp 257-266

Journal Articles:
• A Hamilton (1788), The Federalist No. 74
• Md Rabiul Islam: An Elucidation on Prerogative of Mercy to Assess Its Limits in the
Constitution of Bangladesh with a Comparative Study (Jahangirnagar University Journal
of Law, Volume-II, 2014)
• Mohammad Arafat Hossain and Md. Sher-E-Alam: A Legal Analysis of the Presidential
Prerogative of Mercy in Bangladesh (Metropolitan University Journal) p 145

Website and Blogs:

• Cambridge Advanced Learner„s Dictionary (2008)
<https://dictionary.cambridge.org/dictionary/english/prerogative> accessed on 27 June,
2020
• Oxford Advanced Learner‟s Dictionary (2005)
<https://www.oxfordlearnersdictionaries.com/definition/english/prerogative> accessed
on 27 June, 2020
• Clemency under different governments in Bangladesh
<http://newagebd.com/newspaper1/archive_details.php?date=2012-02-28&nid=51887>
accessed on 26 June, 2020

17