DR.

RAM MANOHAR LOHIYA NATIONAL LAW

UNIVERSITY, LUCKNOW

Section 498A –Does Criminal Justice System Need a Re-

Look?

Semester- V
Submitted By: Submitted To:

Kritika Singh Mr. P.K. Gautam

Section B Asst. Professor (Law)

Roll No.091 Dr. RMLNLU

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 Acknowledgment
Expressing gratitude is a pleasant but difficult job when one sincerely tries to put them in
words. To list them all is not practicable, even to repay them in words is beyond the domain
of my lexicon.

I am highly indebted to Mr.P.K.Gautam, for firstly, allowing me to take this topic just on the
ground that I have interest in the topic, secondly, for providing me outstanding assistance at
every step of my preparation of this project. I am extremely thankful to him for his
constructive criticism and helpful suggestions. His constant encouragement helped me to
work harder.

Further, I would like to give my sincere gratitude to the Madhu Limaye Library, Librarian sir
Mr. Manish Bajpayee and his team for helping me in finding material on the topic. Without
their support this project could not have been completed because finding detailed material on
this topic is not easy task.

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Table of Content

Page Number

1. List of Abbreviation………………………………………..……………………..4
2. List of Cases……………………………………………………..………………...5
3. Introduction………………………………………………………….…………….6
4. Hypothesis………….………………………………………………….…………..7
5. Scope of Study……………………………………………………………………..7
6. Objective of Study………………………………………………………………....7
7. Research Methodology……………………………………………………….........7
8. Literature Survey……………………………………………………………..........8
9. History and Basic Elements of Sec. 498A………………………………………...9
10. Sec. 498A and Cr. P.C. Provision- Major Area of Concerns
 Compoundability of Offence…………………………………………………11
 Bailability…………………………………………………………………….14
 Power of Arrest of Police…………………………………………………….14
 Registration of FIR…………………………………………………………..15
11. Suggestions and Submissions
 No Dilution of Sec. 498A is warranted but reform is Required in the Procedural
Law Attached to the Section………………………………………………...17
 The Offence shall be made compoundable in Certain Circumstances………17
 Power of Arrest of Police……………………………………...…………....19
 No specific Provision required to Curb the False case filing…………….....20
 Need of Immediate Empirical Data Collection……………………………..20
 Bailability…………………………………………………………………...21
 Cognizableness……………………………………………………………..21
 Registration of FIR…………………………………………………………21
12. Conclusion………………………………………………………………………23
13. References………………………………………………………………………25

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Introduction

“Sometimes legislative drafting creates bad law and good judges or vice versa and the rest is
left to litigants either to succeed or suffer”

-Anonymous

“Several enactments and provisions have been brought on the statute book during the last two
or three decades to address the concerns of liberty, dignity and equal respect for women
founded on the community perception that women suffer violence or deprived of their
constitutional rights owing to several social and cultural factors. Meaningful debates and
persuasions have led to these enactments. The insertion of Section 498A IPC is one such
move and it penalizes offensive cruel conduct of the husband and his relatives towards the
married woman. The provision together with allied provisions in Cr. P.C. are so designed as
to impart an element of deterrence in such crimes.1”
India, a nation which is classic example of patriarchal society, has been a constant witness of
violence against women in marriage. And hence came 498A. However the provision has
come under continuous criticism because of it alleged misuse. Cases have come where
frivolous complaints or allegations have been made with oblique motive to wreck personal
vendetta. Supreme Court went upto saying that “by misuse of the provision, a new legal
terrorism can be unleashed.”2
“Quite recently the division bench of Supreme Court in Arnesh Kumar v. State of Bihar3
observed that- “The fact that Section 498-A is a cognizable and non-bailable offence has lent
it a dubious place of pride amongst the provisions that are used as weapons rather than
shield by disgruntled wives. The simplest way to harass is to get the husband and his relatives
arrested under this provision.””
This judgment led to a debate on Section 498A with feminist activists calling it an ‘anti-
women’ judgment4 and some calling it ‘the much-needed air of change’.
“The offence under section 498A is non-bailable, non-compoundable and cognizable offence
which according to some scholar a major reason of its misuse. Arbitrary use of power of
arrest by police has further complicated the matter. But misuse of a provision, in itself cannot

1
243Rd Report of Law Commission of India on Section 498A. Page 2, Para 1.3.
2
Sushil Kumar Sharma v. UOI AIR 2005 SC 2071.
3
Criminal Appeal No. 1277 OF 2014.
4
Jayanthi Natrajan, ‘SC Order Weakens Dowry Law, Hurts Women Rights’ The Hindusthan Times (28 August
2014) < http://www.hindustantimes.com/analysis/a-crime-is-after-all-a-crime/article1-1257229.aspx > accessed
on 26-09-2018

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be a ground for doing away with the provision. This section 498A and its related Cr.P.C
provisions demand a difficult task of balancing rights of women and at the same time
protecting husbands and in-laws from undue violation of their liberties due to exaggerated
claims and frivolous complaints. “

In light of this background it becomes important to figure out what exactly is the problem
with the section, if at all there is a problem.

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History and Basic Elements of Section 498A

Section 498A, the only section of Chapter XXA (Title of chapter- Of Cruelty by Husband or
Relatives of Husband) of the Indian Penal Code. The same was inserted by Criminal Law 2ND
Amendment Act, 1983 (Act No. 46 of 1983). It came into force on 25th December 1983 and it
reads as follows-

“Whoever, being the husband or the relative of the husband of a woman, subjects such
woman to cruelty shall be punished with imprisonment for a term which may extend to three
years and shall also be liable to fine.

Explanation- For the purpose of this section, "cruelty" means-

(a) any wilful conduct which is of such a nature as is likely to drive the woman to commit
suicide or to cause grave injury or danger to life, limb or health (whether mental or physical)
of the woman; or

(b) harassment of the woman where such harassment is with a view to coercing her or any
person related to her to meet any unlawful demand for any property or valuable security or is
on account of failure by her or any person related to her to meet such demand.”

“If we look into the Statement of Objects and Reasons of the Criminal Law 2ND
Amendment Act, 1983(Act No. 46 of 1983), it clearly observes that though the number of
dowry deaths are on increase, however such cases where cruelty of husband and his relatives
results in suicide or murder of the wife, are just a small fraction of cruelty inflicted upon
women. Basically Sec. 306, IPC and the Dowry Prohibition Act, 1961 were found to be
inadequate tackle cruelty against women in marriage and in backdrop of this sec. 498A was
introduced. Before coming into existence of this section cruelty towards a wife by her in laws
or/ and husband were covered in general provisions of IPC dealing with assault, hurt,
grievous hurt etc. The amendment intended to define the substantive offence of cruelty to
women by her husband and relatives of him.

As far as scope of this sec. is concerned then the ordinary dictionary meaning of ‘cruelty’ has
not been given to word as it is vague and can be given various interpretation. 5 ‘Cruelty’ has

5
Sunagal L. Hegde v. Laxminarayan Anat Hegde 2003 Cr. LJ 1418 (Kant.), Krishna Lal v. UOI 1994 Cr. LJ
3472 (P&H) , K. Subramaniam v. State 1988 2 Crimes 633 Mad, Arvind Dhawan v. State of Haryana 1998 3

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been defined categorically and clearly. It is apparent, neither every cruelty nor every
harassment has element of criminal culpability for the purposes of Section 498-A. For the
purpose of Section 498A IPC which is peculiar to Indian families, victim spouse is always the
'wife' and guilty is the husband and his relatives-near or distant, living together or separately.
Ingredients of 'cruelty' as contemplated under Section 498A are of much higher and sterner
degree than the ordinary concept of cruelty applicable and available for the purposes of
dissolution of marriage i.e. Divorce. 6
“

Bare reading of the provision clear shows that-

 Under Explanation a, the prosecution must show that-

firstly, there was a wilful conduct on the part of the offender, (wilful conduct contemplates
obstinate and deliberate behaviour). Hence mens rea is essential requirement.

secondly, the nature of act was such so as to drive a woman to commit suicide or to cause
grave injury or danger to life or limb. (This can be both mental and physical).

 Under Explanation b the cruelty pertains to harassment with demand of dowry. The word
'harassment' in ordinary sense means to torment a person subjecting him or her through
constant interference or intimidation. If such tormentation is done with a view to 'coerce'
any person and in this case, the wife to do any unlawful act and in this case to meet the
unlawful demand of property or valuable security, it amounts to "harassment" as
contemplated by Section 498-A. Thus to constitute "harassment" following ingredients
are essential:-

firstly, Woman should be tormented i.e. tortured either physically or mentally through
constant interference or intimidation;

secondly, Such act should be with a view to pursue or compel her to do something which she
is legally or otherwise not expected to do by using force or threats; or Intention to subject the
woman should be to compel or force her or her relatives to fulfil unlawful demands for any
property or valuable security.7

This section is wider in scope than Section 304B which covers only dowry death. Sec. 498A
covers even those cases where cruelty did not result in death.

RCR (Cri) 593 (P&H), Sarala Prabhakar v. State of Maharasthra 1990 Cr. LJ 407 ac cited in S.K. Sarkaria, R.
A. Nelson’s Indian Penal Code (Volume 3, 9th edn., Lexis Nexis Butterworths (2003) 4627.
6
Savitri Devi v. Ramesh Chand 2003 Cr. LJ 2759.
7
Savitri Devi v. Ramesh Chand, 2003 Cr. LJ 2759.

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Section 498 and Cr. P.C. -Major Area of Concern

Compoundability of Section 498A-

“Compounding in the context of criminal law means forbearance from the prosecution as a
result of an amicable settlement between the parties. As observed by Calcutta High Court in a
vintage decision in Murray, compounding of an offence signifies “that the person against
whom the offence has been committed has received some gratification, not necessarily of a
pecuniary character, to act as an inducement of his desiring to abstain from a prosecution”. 8

Certain offences punishable under the sections of the Indian Penal Code can be compounded
as per Sec. 320 of Cr.PC. The section provides for compounding the offence through two
mechanism one simply and another with permission of court. Who can compound the given
offence has also been provided. However 498A is not mentioned under this section and hence
cannot be compounded.

There is preponderance of opinion in favour of making the offence under S.498-A

compoundable with the permission of the court. The court in Ramgopal v. State of MP
opined that the offence should be made compoundable. 9 If the parties decide to either settle
their disputes amicably to salvage the marriage or decide to put an end to their marriage by
mutual divorce, they should be allowed to compound the offences so that criminal
proceedings don't chase them if they want to start their marital life afresh or otherwise. The
past should not haunt them nor the hatchet they have buried should be allowed to be dug up
and mar their present life or future married life.10 “

Justice Malimath Committee’s Report on Reforms of Criminal Justice System strongly

supported the plea to make Section 498A a compoundable offence. The Committee observed:

“A less tolerant and impulsive woman may lodge an FIR even on a trivial act. The result is
that the husband and his family may be immediately arrested and there may be a suspension
or loss of job. The offence alleged being non-bailable, innocent persons languish in
custody.11

th
“Similarly, the 154 report of Law Commission of India (1996) recommended inclusion of S.
498A in the Table appended to Section 320(2) so that it can be compounded with the
8
237th Report of Law Commission of India on Compoundability of Offences, Page 6, Para 1.2.
9
SLP (Crl.) No. 6494 of 2010
10
Savitri Devi v. Ramesh Chand 2003 Cr. LJ 2759.
11
Page 191, Para 16.4.4.

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permission of the Court.12 Further, the 177th Report13, The Department-Related Parliamentary
th
Standing Committee on Home Affairs in its 111 Report on the Criminal Law (Amendment)
th
Bill 2003 (August 2005),14 The 128 Report of the said Standing Committee (2008) on the
Code of Criminal Procedure (Amendment) Bill, 200615 had similar views.

237th LCR which specifically relates to Compoundability of IPC offences suggested that – “if
the wife is prepared to condone the ill-treatment and harassment meted out to her either by
reason of change in the attitude or repentance on the part of the husband or reparation for the
injury caused to her, the law should not stand in the way of terminating the criminal
proceedings.” 16 The report asked to take more holistic and practical approach because even
social harms do not operate in vacuum. The stand of 243rd report is no different.17”

Argument against Making the offence Compoundable-

“It is argued that the dowry and harassment for dowry is a social evil and how the law which
is designed to punish those who harass the wives with demand of dowry can be stopped to
take its full course and be made a tool at the hands of husband through the private
compromises. The social consciousness and the societal interest demands such out of court
settlement cannot be allowed. The legal recognition of amicable settlement in such cases
would encourage the forbidden evil i.e. the dowry, they say.

The other argument which is put forward against compounding is that hapless women
especially those who are not much educated and who do not have independent means of
livelihood, may be pressurized and coerced to withdraw the proceeding and the victim
woman will be left with no option but to purchase peace though her grievance remains
unsolved.”

Arguments in favour of Making the Offence Compoundable-

Section 498A should not be allowed to become counter-productive. It is quite often argued
that road of sec 498A is different from that of other offences. Here a family, a marriage,
sometimes kids are involved. In our country still both the social factors and legal factors aims
at saving a marriage. In matters relating to family life and marital relationship, the advantages

12
Page 48, Para 2.
13
As cited in 237th Report of Law Commission of India on Compoundability of Offences. Page 13, Para 3.7.
14
As cited in 237th Report Law Commission of India on Compoundability of Offences. Page 21, Para 5.8.5.
15
As cited in 237th report Page 22, Para 5.8.6.
16
Page 16, Para 5.4
17
Page 42, Para 19.5.

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and beneficent results that follow from allowing the discontinuance of legal proceedings to
give effect to a compromise or reconciliation would outweigh the degree of social harm that
may be caused by non-prosecution. 18

“If the proceedings are allowed to go on despite the compromise arrived at by both sides,
either there will be little scope for conviction or the life of the victim would become more
miserable. In what way the social good is achieved thereby? 19 The conviction rate in respect
of the cases under s.498A is quite low – it is about 20%. One of the reasons is subsequent
events such as out-of-court settlement, the complainant women do not evince interest in
taking the prosecution to its logical conclusion.”
The permission to compound does not amount to legal recognition of violence against
women. Rather it amounts to take into consideration the ground realities of Indian society
where the family members/ elders try to reconcile the matter. Compoundability further
becomes important for protecting interest of children because in the whole tussle and
hostility, children are the worst victim.20

As far as this argument is concerned that out of court settlement in cases of social evil should
not be allowed, then let’s not forget many offences having the potentiality of social harm, not
merely individual harm, are classified as compoundable offences.

Quashing of Proceedings-

“Sometimes when parties come to an out of court settlement in cases of S.498A and hence
file for quashing proceedings of the case. Courts have in various cases used the inherent
power available to it under sec. 482 Cr.P.C. Courts have opined that though case is non-
compoundable in nature, however if parties have jointly expressed their willingness for
compromise, then the same can be allowed. Courts can exercise inherent power in sec. 482
Cr.P.C. to permit the same.21However at various places courts said that in light of mandatory
language of section 320 another case court held that a non compoundable offence cannot be
compounded by writ jurisdiction of HC or inherent power of HC.22 Court again in Heerala

18
237th Report of Law Commission of India on Compoundability of Offences, Page 16, Para 5.4.
19
237th Report of Law Commission of India on Compoundability of Offences, Page 17, Para 5.4
20
Tr. Ramaiah v. State of Madras HC, MP no 1 of 2008 in Cr.O.P. No. 10896 of 2008 as cited in 243 rd Report
of Law Commission of India on Section 498A, Page 4, Para 2.2.
21
State of Rajasthan v. Gopal Lal 1992 Cr LJ 273.Gurusharan Kaur v. State 1993 CrLJ 2076 (Raj). Daggupati
Jayalakshmi v. State 1993 CrLJ 3162 (AP), Mahesh Chand v. State AIR 1988 SC 2111 as cited in Ratanlal and
Dhirajlal, The Indian Penal Code (32nd edn., Lexis Nexis Butterworths Wadhwa, 2010) 2769.
22
Neeta Sanjay Togde v. Smt. Vimal Saashiv Togde 1997n CrLJ (Bom) 3263 as cited in Ratanlal and
Dhirajlal, The Indian Penal Code (32nd edn., Lexis Nexis Butterworths Wadhwa, 2010) 2769.

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Prasad Verma v. State23 accepted plea of wife who had earlier charged her husband u/s 498A
that when she has no grievance and is living happily with her in-laws, hence it is duty of the
court to encourage genuine settlement because any hyper technical view would be counter
productive and against the interest of women. Court accepted it. Again in B.S. Joshi v. State
of Haryana24 held that a HC when approached by both the parties and jointly prayed for
quashing of the criminal proceedings filed by wife u/s 498A, is empowered to quash the
criminal proceedings though the offence is not compoundable for securing ends of justice.
Section 320 neither affects nor limits the inherent power of HC. But agin in Nazimunnisa v.
State of Karnataka25 and Bankat v. State of Maharshtra26 were hesitant to accept such views.
“

Hence in light of this inconsistent approach of the courts it becomes further important to
decide immediately whether the offence shall be made compoundable or not? Further the
procedure under Sec. 482 Cr.P.C. is time consuming and costly also.

Bailability

The Malimath Committee Report on Reform in Criminal Justice System observed that- once
an FIR is lodged with police under sec. 498A/406, it becomes an easy tool at the hands of
police to arrest or threaten to arrest husband and other relatives named in the FIR without
even considering the intrinsic worth of allegations and making a preliminary inquiry. When
the members of the family are arrested and sent to jail with no immediate prospect for bail,
the chances of amicable reconciliation and salvaging the marriage will be lost once and for
all.27

Power of Arrest of Police

“Supreme Court in Nand Raj v. State of Punjab28 expressed concern over the ‘tendency of
roping in relatives of husnad in over enthusiasm and anxiety to seek conviction for maximum
people. This ultimately weakens the case itself.

23
2006 Cr LJ 778. (Jhar).
24
AIR 2003 SC 1386 as cited in KI Vibhute, PSA Pillai’s Criminal Law (10th edn., Lexix Nexis Butterworths,
2008).775.
25
2001 i Kant LJ 577 KI Vibhute, PSA Pillai’s Criminal Law (10th edn., Lexix Nexis Butterworths, 2008).
776.
26
2005 I SCC 343.
27
Page 191, Para 16.4.
28
2000 Cr.LJ 2993 SC as cited in S.K. Sarkaria R. A. Nelson’s Indian Penal Code (Volume 3, 9th edn., Lexis
Nexis Butterworths 2003) 4654.

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There is a growing tendency amongst the women to rope in each and every relative-including
minors and even school going kids nearer or distant relatives and in some cases against every
person of the family of the husband whether living away or in other town or abroad and
married, unmarried sisters, 'sister-in-laws, unmarried brothers, married uncles and in some
cases grand-parents or as many as 10 to 15 or even more relatives of the husband.29

The biggest problem is indiscriminatry and arbitrary arrest in cases without looking into the
peculiar circumstances of each case. “

Registration of FIR-
“Immediate registration of FIR in case of this sec. has been opposed by various groups. In
fact in case of Tr. Ramihah v. State following directions were given to the police authorities:
i) “FIR should not be registered in a routine manner.
ii) Endeavour of the police should be to scrutinize complaints carefully and then register FIR.
iii) No case under section 498-A/406 IPC should be registered without the prior approval of
DCP/Addl. DCP.
iv) Before the registration of FIR, all possible efforts should be made for reconciliation and in
case it is found that there is no possibility of settlement, then, necessary steps should, in the
first instance, be taken to ensure return of sthridhan and dowry articles to the complainant.30
However this case brings us to question- whether the registration of FIR can be deferred for
sometime i.e., till initial investigation and reconciliation process is completed?
In Bhajan Lal’s case,31 the Supreme Court observed, “It is therefore, manifestly clear that if
any information disclosing a cognizable offence is laid before an officer in charge of a police
station satisfying the requirements of Section 154(1) of the Code, the said police officer has
no other option except to enter the substance thereof in the prescribed form, that is to say, to
register a case on the basis of such information.” However, in a recent case of Lalita Kumari
v. State of Uttar Pradesh32, the question whether a police officer is bound to register the FIR
when a cognizable offence is made out or he has the discretion to conduct some kind of
preliminary inquiry before registration of FIR, has been referred to a larger bench of Supreme
Court in view of the apparent divergence in views. The law on this point is therefore in an
uncertain state. In this situation, the police in various States have to follow the law laid down

29
Savitri Devi v. Ramesh Chand, 2003 Cr. LJ 2759.
30
HC MP no 1 of 2008 in Cr.O.P. No. 10896 of 2008
31
State of Haryana v. Bhajan Lal, AIR 1992 SC 604
32
AIR 2012 SC 1515

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or directives issued by the respective High Courts in regard to registration of FIR till the law
is settled by the Supreme Court.”
Shri Amarjit Singh, Member of the Commission has suggested that except in cases of
physical violence, the FIR need not be registered instantaneously without any enquiry being
made. Whether there should be a legislative provision in this regard specifically with
reference to F.I.Rs under S, 498-A is a matter on which a fresh look could be taken after the
Supreme Court interprets the relevant Sections in the above case.33
Conclusions

The future of many marriages, of many helpless woman who suffer in silence and of many
poor husband who have been falsely implicated in this sec. depends on how seriously and
immediately we react to these reforms which are need of the hour.

Courts have time and again shown concern about the misuse of the provision,34 hence
reforms in the procedure is immediately warranted especially because the so-called misuse of
provision had made even the genuine cases being looked down as false cases. With my own
personal experience with police and general data It has been observed that policeman have
become suspicious about every woman who files case under sec 498A. An interview of a
Police Officer in Jaipur claimed that as high as 90% of cases under this sec are false!35 It is
clearly an exaggeration but it shows that the provision which was to protect woman, has
become enemy of them, making them prone to be doubted about, to be judged and to be
tagged as ‘jhoothi’/ ‘villain’36

“We are at cross road where at one place we need to protect woman and their rights, but at
the same time we don’t want our ‘would be husband’ to get 498A pre-wedding jitters (as used
498a.org –a blog run by NRIs who are strongly working against misuse of the sec.) 37 A wise
and pragmatic moderations without overlooking the need and relevance of the retention of
penal sanctions necessary to protect and promote women’s rights and interests, is what we
need.

33
Page 8. Para 2.7.
34
Pawan Kumar v. State of Haryana AIR 1998 SC 958.
35
‘Majority of Dowry Cases Are Fakse-Says SP’ The Times of India- Patna City (19 August 2003) <
http://www.498a.org/contents/paperArticles/majorityOfDowryCasesAreFalse.pdf > accessed on 29-09-2018
36
‘Some Brides are Villians, Not Victims-Lawyers’ The Times of India Kolkata (1 May 2001) <
http://www.498a.org/contents/paperArticles/Some%20brides%20are%20villains%20not%20victims.pdf >
accessed on 19-03-2015
37
‘498A gives Men Pre-Wedding Jitters’ Vijay Times Banglore City (07 April 2005)<
http://www.498a.org/contents/paperArticles/498aGivesMenPreWeddingJitters.pdf > accessed on 29-09-2018

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NCRB data 2013 shows that around 3 Lakh cases were filed under sec. 498A in the year
2013. Out of which 90% were chartsheeted. However the conviction rate is mere 16% which
is well below the average conviction rate of 23-25%.

In toto, a pragmatic and holistic approach is needed. Courts have time and again repeated the
need for re-look at the sec. 498A and called for change based on ground realities of our
society and of our system.38The offence shall remain non-bailable, but compounding the
offence shall be allowed. Rules for arrest power of police are very clearly and categorically
have been specified. Need for the hour is these rules shall be strictly followed. “

But in the ultimate analysis any number of legislative action will be ineffective and
inadequate until gender bias in social institutions and the generally discriminative social
attitude towards women is transformed. Within the institution of marriage the gender roles
have to be redefined, so that a patriarchal order is replaced by a gender equal order.39

38
Preeti Gupta v. State of Jharkhand, AIR 2010 SC 3363 .
39
KI Vibhute, PSA Pillai’s Criminal Law (10th edn., Lexix Nexis Butterworths, 2008) 768.

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References-

Books-

1. P.K. Das, Protection of Women from Domestic Violence (Universal Law Publishing,
2011)
2. M.U. Qureshi, Women and Crime (SBS Publishers,2006)
3. Shobha Saxena, Crime Against Women and Protective Laws (Deep & Deep
Publications, 2004)
4. Dr. Monica Chawla, Women and Protective Law (Regal Publications, 2013)
5. Ramesh Bhandari, Women Rights and Welfare (Alfa Publications, 2010)
6. Ratanlal and Dhirajlal, The Indian Penal Code (32nd edn., Lexis Nexis Butterworths
Wadhwa, 2010)
7. KD Gaur, Criminal Law Cases and Materials (6th edn., Lexis Nexis Butterowrths
Wadhwa: 2009)
8. S.K. Sarkaria, R. A. Nelson’s Indian Penal Code (Volume 3, 9th edn., Lexis Nexis
Butterworths 2003)
9. KI Vibhute, PSA Pillai’s Criminal Law (10th edn., Lexix Nexis Butterworths, 2008)

Journal Articles-

1. Indira Jaising. ‘Concern for Dead, Condemnation for Living’ XLIX (30) EPW <
http://www.epw.in/system/files/Concern%20for%20the%20Dead%2C%20Condemna
tion%20for%20the%20Living.pdf > accessed on 26-09-2018

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