Witness Protection in India1

You cannot witness for me, being slain 2

The concept of witness protection in India has been recognized after a string of cases decided by
the courts which dealt with the protection of the identity of the witnesses. The aspect of witness
tuning hostile has not been new in our judicial system. The lack of proper and effective
protection system and the influence of the mighty, has lead many a times lead to the ineffective
justice dispensation. This paper highlights the various lacunas in the witness treatment and the
recommendation which can be effectively implemented for the protection of the witnesses who
are considered as one of the main pillars in the proper deliverance of justice.

Introduction

The ordinary meaning of the word “witness” is a person present at some event and able to give
information about it 3 . In other words, a witness is a person whose presence is necessary in the
eyes of law, in order to prove a thing or incident. But neither Code of Criminal Procedure nor
any other statute properly defines the aforesaid word. In fact, there is no good definition for
witness. Various statutes have tried to define it but none of them have been able to cover all the
aspects of it. The various foreign statutes and case laws forming precedents have detailed out the
definition for the outlined analysis of the word and have finally held it to be an autonomous
concept giving the liberty of a wide interpretation for the term Witness.

Role of witness

The role of a witness is paramount in the criminal justice system of any country. The statutes and
the laws framed in our country are such that due importance is placed on the evidentiary value of
a material. In such a case, witness has a major role to perform in the dispensation of justice. It is
rightly said that witnesses are the eyes and ears of justice 4 . According to Judge Wadhwa “A
criminal case is built on the edifice of evidence, evidence that is admissible in law. For that,
witnesses are required whether it is direct evidence or circumstantial evidence 5 . Thus a witness
has a primary role with reference to both the complainant and the accused. “By giving evidence

1
SHRUTI KURUP, 4th Year, national University of Advanced Legal Studies, Kochi (NUALS)
2
William Shakespeare (Henry VI Part I)
3
Dorling Kindersley Illustrated Oxford Dictionary, Dorlin Kindersley Ltd. & Oxford University Press, 1998
Edition, Page 958.
4
Bentham
5
Wadhwa J. in Swaran Singh v. State of Punjab, (2000)5 SCC 68 at 678

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relating to the commission of an offence, he performs a sacred duty of assisting the court to
discover the truth. It is because of this reason that the witness either takes an oath in the name of
God or solemnly affirms to speak the truth, the whole of the truth and nothing but truth. He/she
performs an important public duty of assisting the court in deciding on the guilt or otherwise of
the accused in the case. He submits himself to cross-examination and cannot refuse to answer
questions on the ground the answer will incriminate him”. 6

The role of the witness is also a crucial one. He stands on the sword of delivering the true
statement, non abidance of which can lead him to face the trial under Section 190 of the Indian
Penal Code (hereinafter the “IPC”) and thereafter can be penalized under Section 193-195 of the
same for the aforesaid offence.

The most crucial part played by witnesses in bringing offenders to justice is central and the most
foresight in any modern criminal justice system, since the successful conclusion of each stage in
criminal proceedings, usually depends on the cooperation of witnesses. Their role at the trial is
particularly important, where the prosecution must prove its case by leading evidence, often in
the form of oral and cross examination of witnesses, which can then be challenged by the
defence, at a public hearing. A number of factors have led to increased attention on the role of
witnesses in criminal proceedings, not only in India, but also at the international level. This raise
of awareness has been both due to the intrinsic and extrinsic factors, and the raise in the need for
the efficient dispensation of justice. Perhaps the two most important have been the emergence of
interest in the status of the victims in criminal procedure and the significant rise in terrorist and
organized crimes 7 .

The Indian scenario

The sad and unfortunate situation which prevails in Indian context on the aspect of witness and
laws for their protection is that, there is no law relating to the protection of witnesses as in
developed countries like UK, US, Canada and Australia. As a result of this, the witnesses are not
at all treated properly. And at the same time they and their family members are also not secure
since they are sometimes subjected to life threatening intimidations. Now a day the vulnerability
of the witnesses is so prominent, that even the courts have broken their silence and have
appealed for the witness protection law. The Supreme Court has also evaluated the importance of
the need for witness protection, “In cases involving influential people, the common experience is
that witnesses do not come forward because of fear and pressure... (it) depicts a tremendous
need for witness protection in our country if criminal justice administration has to be a reality 8 "
6
Committee on Reforms of Criminal justice System, Headed by Justice Mallimath,, Volume I, Page 151
7
The Scottish Executive Central Research Unit, Briefing Paper on Legal Issues and Witness Protection in
Criminal
Cases, by Mark Mackarel, Fiona Riatt and Susan Moody, Department of Law, University of Dundee.
8
Times of India June 11, 2009

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In the case of Swaran Singh v. State of Punjab 9 Wadhwa J. while delivering the judgment
expressed his opinion about the conditions of witnesses in the following words:

“The witnesses …are a harassed lot. A witness in a criminal trial may come from a far-off place
to find the case adjourned. He has to come to the Court many times and at what cost to his own-
self and his family is not difficult to fathom. It has become more or less a fashion to have a
criminal case adjourned again and again till the witness tires and he gives up. The need for
witness protection has been felt so greatly to this extend that the High Court of Delhi has issued
guidelines for the effective protection and conduct of the same until new laws were made for the
same 10 .

The witnesses, who are considered to play a vital role in the proceedings, have to face a lot of
hurdles during the administration of the criminal justice system.

1.) Firstly, for the evidence aspect, a witness is called or summoned to the court
inconsiderate to the fact that he/she might have hurdles in doing the same or that they
might be lacking financial capability in making this gruesome approach to the courts.
Even in this case he is neither compensated nor does the court reimburses his travel
expenditure.
2.) When he somehow reaches the court, the treatment bestowed on him is also not proper.
The Mallimath Committee has expressed its opinion about such witnesses by saying,
“The witness should be treated with great respects and should be considered as a guest
of honor 11 .” Our country has a large number of people who are illiterate and might not
be aware of the proper proceedings of the courts and also the fact that they might be a
“first time visitor” in the court and needs help with respect to the proper proceedings and
other obligations. After a troublesome journey to the court, the witness is treated like an
unimportant person, with least regard to his importance in the eyes of law. In most of the
Courts, there is no designated place with proper arrangements for seating and resting
while waiting for his turn to be examined as a witness in the court. The basic etiquettes
for the treatment of human being, is in many a circumstance, may not be shown to them.
3.) Even if this kind of privileged treatment is not enough to break the morale of the witness
in approaching the court for the dispensation of justice, the fact that Indian courts are
famous in adjourning cases acts finally in making the witness thinks many a times for the
next time he/she is being summoned. The tread of today in adjourning cases and the huge
backlog of cases with the delay in justice are quite strong enough as a point to make that
many a witnesses give up coming to the courts after a point of time.

9
Swaran Singh v. State of Punjab, (2000)5 SCC 68 at 678
10
Times of India October 14, 2003
11
Committee on Refroms in Criminal Justice System, Headed by Justice Mallimath,, Volume I, Page 151

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 4.) The privileged case, if it comes up to the court, also is not the final treat for the witness.
He is treated inconsiderately and mainly harassed in oral examination of the defense is
such a way like he/she is the actual culprit of the crime. This hoax image of the court and
the oral examination of our judiciary have created a fear psychosis in the minds of the
people, and they are unwilling to be a witness in any case, proving the major backlash to
our justice dispensation system.

The worst case scenario comes up before the courts when the witness, in order to escape the
situation, which by its face value looks like he/she will be prosecuted in the case for which he is
giving evidence, turns hostile or ends up committing perjury.

The problem of hostile witness

Today the root cause for the high acquittal rate in our criminal justice system is the witness
turning hostile. The term "hostile" witness has its genesis in the Common Law. The function of
the term was, to provide adequate safeguard against the "contrivance of an artful witness" who
willfully by hostile evidence "ruin the cause" of the party calling such a witness. It was felt that
such actions are per se destructive, not only of the interests of the litigating parties, but also in
the quest of the courts to meet the ends of justice 12 .

It is pertinent to mention, that the "safeguard" as envisaged under the Common Law, consisted of
contradicting witnesses with their previous statements or impeaching their credit by the party
calling such witnesses. To initiate the "safeguard", it was imperative to declare such a witness as
"hostile". For this purpose, Common Law laid down certain peculiarities of a 'hostile' witness,
such as," not desirous of telling the truth at the instance of the party calling him" or” the
existence of a 'hostile animus' to the party Calling such a witness."

The domestic law differs to a significant degree in this respect. Firstly, the provision (S.154 of
The Indian Evidence Act, 1872) only talks about permitting "such questions as may be asked in
cross-examination". Secondly, the law nowhere mentions, the need to declare a witness as
hostile' before the provision can be invoked. Thirdly, the judicial consideration (under S.154) is
only to be invoked, when the Court feels that "the attitude disclosed by the witness is destructive
of his duty to speak the truth".

Since the guilt of the accused is proved to a great extent on the basis of the evidence or the
information given by such a witness, therefore perjury or the giving of false evidence has to be
severely censured. Perjury today has also become a way of life in the Courts. Every now and
then, there occurs an incident when a witness turns hostile, in turn crashing the entire mechanism
of judicial proceedings for the delivery of justice. In some cases the judge knows that whatever
12
Nishant gaurav Gupta, Report on Protection of witness.

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the witness is saying is not true and is going back on his previous statement. The Judge here
ignores this fact and does not even file a complaint against him. It was rightly contented by Mr.
Soli Sorabjee, the former Attorney General, “Nothing shakes public confidence in the criminal
justice delivery system more than the collapse of the prosecution owing to witnesses turning
hostile and retracting their previous statements 13 .

The case of witness turning hostile is a major backlash to the judicial proceedings because it not
only shakens up the confidence of the common man in the working of the judiciary; it establishes
a dominant authority of the mighty who think they can overpower even the judiciary and the
justice dispensation mechanism. The sad conclusion of the well recognized common law and the
Indian domestic law is that while the former seeks to categorize witnesses as “hostile" or
"adverse", for the purpose of cross-examining, the latter endeavors not to make such a
distinction. All that the domestic law seeks to do is elicit hidden facts from the witnesses for the
sole purpose of determining the truth.

The widely debated and much in news, The Best Bakery case has generated a heated debate in
this area. The drama began with Zahira Sheikh, the prime witness in the Best Bakery case,
turning hostile, along with 37 out of the 43 other witnesses. Zahira, the daughter of the Best
Bakery owner witnessed the barbaric killing of 14 people, which included employees of the
bakery and members of her family on March 1, 2002, in the post-Godhra carnage. The carnage,
said to be the worst of its kind in the history of independent India, gained notoriety due to the
overt support and complicity of the state machinery in the riot.

Not only the Gujarat carnage, but also other famous cases like the BMW Hit and Run case, the
Jessica Lal Murder case, Priyadarshini Mattoo rape and murder case all signals to the witness
turning hostile attribute when an influential and powerful element is called to the courts. Even
though there have been many cases wherein the courts have openly recognized the fact that the
sheer influence of the power and might on the vulnerable witness, made them hostile, the due
protection of the witnesses would have made a really different outcome of the same case.

Need for a witness protection program in India

Witness protection program and witness protection laws are simply the need of the hour.
In fact, it is the absence of these laws that has helped in further strengthening the criminals and

13
The Indian Express, October 26, 2003, The Columnists, Witness Protection by Soli Sorabjee.

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offenders. But ironically, in India, such programs and laws are a far cry from reality, where leave
alone protection, the witness is not even treated with respect. The Supreme Court in many recent
cases have dealt with and discussed the need for the witness protection program 14 .
The Witness Protection Program is a legal band-aid, where drastic surgery encompassing the law
is required. What we need is an enabling environment which empowers the citizens to manage
their own security. There are many recommendations of many commissions from administrative
to judicial and from police to human rights activists that address these issues in detail. The policy
should be on security and community role in creating a law abiding culture. The role of the
police is in enhancing community security as distinct from criminalizing people and also as
distinct from the role of the army. The role of the state lies in providing institutional protection to
law abiding citizens. The central role in creating a law abiding society lies with individual
citizens, and the community. The role of the state is supportive. When the state usurps this
legitimate role of the citizens and indeed makes it illegal for citizens to perform this function
then we quickly land up on this slippery slope.

Most developed Countries have well formulated and comprehensive witness protection
programs to safeguard witnesses in important criminal cases. For example, the US has the Victim
and Witness Protection (1982), the Victims’ Rights and Restitution Act (1990) and Australia has
the Protected Disclosures Act (1994). Unfortunately, despite the high rate of crime and low rate
of conviction, India has not drawn up even a rudimentary framework to protect witnesses in
crucial cases. The traditional exclusive dependence on the police to protect the witness has
proven ineffectual in building the confidence of witnesses to take risks for bringing the guilty to
justice.

The record of convictions in communal riot cases is much worse. The sad example of the 1984
anti-Sikh riots wherein not even a single person has been found guilty till date, speaks for itself.
According to Asghar Ali Engineer, a scholar who has made an extensive study of communal
riots in India, the rate of acquittal is more than 90 percent. A witness protection program is
critical not only in riot cases, which are known for their abysmally low rate of conviction, but
also in combating organized crime. The Protection of witnesses is very important in the
investigation and prosecution of organized crime as the witnesses are subject to intimidation by
the accused. Witness protection program enables and inculcates a sense of confidence in the
witnesses to turn up to the court without any fear of their life or the lives of their beloved or
without any external influence on them.

14
NHRC v. State of Gujarat: 2003 (9) SCALE 329, PUCL v. Union of India: 2003(10) SCALE 967, Zahira
v. State of Gujarat 2004(4) SCC 158, Sakshi v.Union of India: 2004 (6) SCALE 15 and Zahira v.Gujarat
2006 (3) SCALE 104.

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Only the fear of stringent legal action can act as a check in making sure that hostile witness rates
come down again. But this goal can only be achieved with the coordinated and cooperative
efforts of the three concerned agencies police, government and judiciary. The political will to
initiate this program should be displayed by the government by initiating the said bill in
parliament; the legal aspects can be looked into by the judiciary, and, the execution can be
entrusted to the police. It should be noted that in cases where the witness is also the aggrieved
party or victim of the criminal act in question, they face dual risks:

i) Reconciling with their past trauma and;

ii) Fear of not inviting additional danger to themselves and their loved ones.

In these situations, witness protection programs can act as the much needed support system. The
key to a witness protection program is the safety and security of witnesses before, during and
after trial, which is missing in all these areas when it comes to the Indian legal scenario. Security
after trial is virtually nonexistent in India. The sad fact is that if the witnesses are not given the
due protection required by the law, they will have the fear of their lives and will not be of much
help in delivering the needed justice. The risk factor involves in here is that while in many cases
the witnesses lose their faith in the government and the judiciary, in many other cases the
affected people or the victims turn to other recourses to get justice, both of which prove harmful
to the effectiveness of the government and the security of the nation at large.

Recommendation

While it is clear now that there exist no specific law with regard to the witness protection in
India, the need of the hour is to create a law for the same. While the same is being debated, the
judiciary should make efforts to see that the general aspects to be looked in when it comes to
witness protection should be adhered to. An important step in this area has been taken up by the
Ministry of Home Affairs, by forming a Committee on reforms in the Criminal justice system,
known as the Mallimath Committee Report. This Committee analyzed the whole criminal justice
system and also made the possible recommendations in various areas. The committee also
analyzed the conditions of witnesses in India and have tried to make suitable recommendations
in the form of amendments in various provisions in CrPC and also other recommendations
relating to the treatment of witnesses in the courts. But the committee has only went to the extent
of mentioning attributes of what to do whereas the ambit of how to come about it still is an arena
left widely open. In other words, although it has highlighted the miserable conditions of the
witnesses in India and made recommendations for their protection, but it has not gone into much
details.

Also the Law Commission of India in its 154th Report has dealt with the conditions of witness in
our system and has requested the legislature to make suitable laws without any further delay. The

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14th Law Commission had referred to this aspect while submitting its report (154th Report) on
the Code of Criminal Procedure. After considering the earlier reports of the Commission, the
reports of the National Police Commission and the responses it received pursuant to the
circulation of its Working Paper, the Commission suggested the following measures:
(a) “It is necessary to amend section 164 CrPC so as to make it mandatory for the
investigating officer to get statements of all material witnesses questioned by him during
the course of investigation recorded on oath by the magistrate. The statement thus
recorded will be of much evidentiary value and can be used as previous statement. Such
recording will prevent the witnesses turning hostile at their free will. Such a change will
also help the Police to complete the investigation and submit a final report on the basis of
such statements made on oath and on other facts and circumstances stated as recovery,
etc.”
Accordingly, the Commission suggested introduction of sub-section (1A) in section 164. The
Commission however felt that adoption of this course would require recruitment of a good
number of additional magistrates, which course; it thought may not be immediately feasible
though this course was the most desirable one.

(b) The other alternative measure suggested by the 14th Law Commission was to retain the
existing provisions in sections 161, 162 and 172 of the Code of Criminal Procedure and
to provide some checks against the witnesses turning hostile. The suggested measures
were: taking the signature of the witness, if he is literate, on his statement, giving a copy
of the statement to the deponent under acknowledgement and thirdly to send copies of the
statements to the appropriate magistrate as well as to the superior Police officers 15 .

But the Law Commission found a difficulty as far as the introduction of first recommendation is
concerned. The difficulty was in recruitment of as many more magistrates as may be required, if
the first measure suggested by it were to be introduced. Therefore the Commission suggested the
following alternative in its 178th Report 16

“In all offences punishable with ten or more years imprisonment (with or without fine) including
offences for which death sentence can be awarded, the Police shall have the statements of all
important witnesses recorded under section 164 by a magistrate.”

The 198th Law commission report on witness identity protection and witness protection
programme lays down extensive details as to what all the powers of the magistrate, the various
courts and the central and the state government with regard to the same is. The law commission

15
The Law Commission of India, 154th Report on the Code of Criminal Procedure 1973, Volume 1, 1996
16
The Law Commission of India, 178th Report on Recommendations For Amending Various Enactments, Both
Civil and Criminal, December 2001.

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has recommended various modes of protecting the identity of the witness both before and after
trials.

1.) At the stage of investigation-

The Magistrate will have to consider the material relied upon by the prosecutor for
substantiating the danger to the witness or his property or those of his relatives, and, if
necessary, the Magistrate can examine the witness. If the Magistrate comes to the conclusion
that there is likelihood of danger, he can grant identity will, however, be disclosed to the
Magistrate and none else. Further, the real identity will not be reflected in the court records but
the witness will be described by a pseudonym or a letter from the alphabet.

2.) During inquiry and before recording evidence at the trial-

In the inquiry before the Magistrate the prosecutor or the witness has to make a fresh
application and this is necessary even if some of the witnesses have been allowed anonymity
and given a new identity during investigation. The Magistrate or judge has to pass a fresh
preliminary order granting anonymity. The Magistrate or Judge will consider the material
produced by the prosecutor or the witness as to the danger to his life or property or that of his
relatives, and will, if necessary, hear the witness. All this has to be in camera and the
accused/his lawyer will not be present. However, the Magistrate or Judge will have to hear the
accused or his lawyer separately and disclose to them the material relating to the alleged danger
to the witness, but not any facts which may enable the accused or his lawyer to discover the real
identity of the witness. If, during inquiry, the Magistrate or Judge grants identity protection by a
preliminary order, it will ensure not only for the period during inquiry, trial, but at the later
stages of appeal or revision and even after the case has been finally concluded.

3.) Recording evidence during the trial in the Sessions Court: two-way closed circuit
television 17

4.) Witness Protection Programmes

Witness Protection Programmes refer witness protection outside the Court. At the instance of the
public prosecutor, the witness can be given a new identity by a Magistrate after conducting an ex
parte inquiry in his chambers. In case of likelihood of danger of his life, he is given a different
identity and may, if need be, even relocated in a different place along with his dependants till be
trial of the case against the accused is completed. The expenses for maintenance of all the
persons must be met by the State Legal Aid Authority through the District Legal Aid Authority.
The witness has to sign an MOU which will list out the obligations of the State as well as the

17
The law commission of India 198th report on Witness Identity Protection and Witness protection
Programme Part 1 August 2006.

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witness. Being admitted to the programme, the witness has an obligation to depose and the State
has an obligation to protect him physically outside Court. Breach of MOU by the witness will
result in his being taken out of the programme 18 .

Though the recommendations of the Law Commission and other agencies of the government,
with regard to the witness protection programme have been made at various intervals of time, the
need of the hour is the incorporation of the same as law for the effective implementation of the
same.

The Criminal Law (Amendment) Act, 2005 19 which was enforced in 2006, bought certain
changes to the Penal Code, Code of Criminal Procedure and Evidence Act. The Act has
introduced Section 195A to the Penal Code, whereby threatening or inducing any person to give
false evidence is made punishable. By virtue of the said amending Act, Section 195 of Cr.P.C.
has also undergone changes. Section 154 of Evidence Act empowers the court to permit the
person who calls a witness to put any question to him which might be put in cross examination
by the adverse party 20 .

But the only two effective legislations providing for effective physical protection of witnesses
have been the Terrorist and Disruptive Activities (Prevention) Act, 1987 and its avatar, the
Prevention of Terrorism Act, 2002. Some of the sections of these Acts provided effective
methods to provide for witness protection with respect to specific cases. Secrecy of Witness’
Identity: Section 13 of TADA, the Terrorist and Disruptive Activities (Prevention) Act, 1987 and
Section 30 of POTA, the Prevention of Terrorism Act, 2002 (now repealed) provides that the
court may take such measures as it deems fit to keep the identity and address of witnesses secret.
Provision for trial of sexual offences: Section 13 of TADA and Section 30 of POTA provide that
proceedings of these natures shall be held in camera, so that there is adequate protection of the
witnesses who are giving their testimony.

Further, the development of the need for Witness Protection program can be highlighted through
the development of the plethora of judgments that have been passed by the various courts in the
country. The judiciary has constantly urged the Parliament to evolve a definite and regulatory
mechanism to deal with witness protection as a lack of such a scheme clearly hampers the
deliverance of justice 21 .

18
The law commission of India 198th report on Witness Identity Protection and Witness protection
Programme Part 2 August 2006.
19
(No.2 of 2006)
20
Witness Protection- Bird’s Eye View- A. Hariprasad
21
Witness Protection Law Vis-à-vis hostile Witness- Swapnesh Warg.

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A while back the Delhi High Court issued guidelines to the police on providing protection to
witnesses to curb the menace of their turning hostile leading to acquittal of accused in heinous
crimes 22 . The guidelines were as follows:

1) Member Secretary, Delhi Legal Services Authority would be competent authority who
on, receipt of a request on a witness, decide “whether a witness requires protection, to
what extent and for what duration”,
2) However the protection would be available only to witnesses who were to depose in cases
punishable with death sentence or life imprisonment.
3) In deciding whether to grant protection to a particular witness, the Competent Authority
“shall” take into account the nature of the risk to the security of witness emanating from
the accused or his associates and the nature of probe or the criminal case.
4) The authority shall also consider the importance of the witness and the value of evidence
given or agreed to be given by him/her besides the cost of giving protection to him or her.
5) While recording the statement of witness under Section 161 of the CrPC, it would be the
duty of the investigating officer to make the witness aware of these guidelines and also
the fact that in case of any threat he/she can approach the competent authority.
6) Once the competent authority decides to extend the protection to a particular witness, it
“shall” be the duty of the police Commissioner to provide protection to him or her.

The court further said that the guidelines shall operate for the protection of witnesses till
enactment of a suitable legislation.

Conclusion
This is the very right moment when the enactment of a stringent witness protection program can
prove fruitful in the long run. This program is an effective assurance for the protection of the
identity and the safety of the law abiding citizens and also to be treated with fairness, respect,
and dignity, and to be free from intimidation, harassment, or abuse, throughout the criminal
justice process who come up to the courts to testify so as to provide a helping hand in the
dispensation of justice. As long as witnesses continue to go hostile and do not make truthful
deposition in Court, justice will always suffer and people’s faith in the credibility of judicial
process and justice system will continue to erode and shatter As is rightly said that laws should
be framed according to the needs and aspiration of the people of a country. There will be no
harm in imbibing the spirit of law from the various other countries with reference to the witness
protection program. It is the nation’s duty to protect the righteous and law abiding citizen, the
protection they seek. The very gist of the argument comes to that the concept of witness identity
protection can be made effective and fruitful, if it is worked out in a machinery which is truthful
and corruption free at the first place. The level of professionalism needed in the proper and
22
Times of India October 14, 2003

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effective implementation of this program is quite high and only trustworthy officers and people
should be made a part of this system to make sure that the law works for well of others.

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