Research Methods And Legal Writing

PROJECT SUBMITTED TO
DR. B.R. AMBEDKAR LAW UNIVERSITY, JAIPUR
IN PARTIAL FULFILLMENT OF THE REQUIREMENT
PRESCRIBED FOR THE LL.M. 1st SEMESTER EXAMINATION
2022-23
BRANCH: CRIMINAL AND SECURITY LAWS
BY:
NAME: HEMANT SINGH
ROLL NO: 13

UNDER THE SUPERVISION OF

MRS. MAMTA SONI

DR. B.R. AMBEDKAR LAW UNIVERSITY, JAIPUR

2023

1
 CERTIFICATE
This is to certify that Ms. HEMANT SINGH has worked under my supervision and guidance.
The work contained in this project is original and has not been submitted in part or in full for
any other degree either in this University or any other University previously by the candidate.
I am satisfied that this research work is worthy of consideration for the award of the Degree
of Master of Laws in post graduate stream of Law and has been complied with the Anti-
Plagiarism Guidelines issued by the competent authorities from time to time.

Place: Jaipur, Rajasthan Prof. MRS. MAMTA SONI

Date: 16/01/2023 (Supervisor)

2
 ACKNOWLEDGMENTS

The success and final outcome of this project required a lot of guidance and assistance from
many people and I am extremely privileged to have got this all along the completion of my
project. All that I have done is only due to such supervision and assistance and I would not
forget to thank them. I respect and thank MRS. MAMTA SONI for providing me an
opportunity to do the project work in IPR and giving us all support and guidance, which
made me complete the project duly. I am extremely thankful to him for providing such a nice
support and guidance, although she had busy schedule managing the corporate affairs. I owe
my deep gratitude to our project guide, MRS. MAMTA SONI who took keen interest on
our project work and guided us all along, till the completion of our project work by providing
all the necessary information for developing a good system.

I heartily thank our internal project MRS. MAMTA SONI for her guidance and suggestions
during this project work. I am thankful to and fortunate enough to get constant
encouragement, support and guidance from all Teaching staffs which helped us in
successfully completing our project work. Also, I would like to extend our sincere esteems to
all staff in laboratory for their timely support.

Place: JAIPUR HEMANT SINGH

Date: 16TH JAN., 2023 Roll no. 13
BRANCH:CRIMINAL AND SECURITY LAWS
LL.M. Student,
Dr. B. R. Ambedkar Law University, Jaipur.

3
 DECLARATION

I, HEMANT SINGH hereby declare that this project titled “Compensatory Jurisdiction
Under Criminal Law” is based on the original research work carried out by me under the
guidance and supervision of Prof. MRS. MAMTA SONI for the fulfillment of the
requirements of the Degree of L.L.M. Master of Laws in post graduate stream of Law and
has been complied with the Anti-Plagiarism Guidelines issued by the competent authorities
from time to time including but not limited to this University as well.

The interpretations put forth are based on my reading and understanding of the original texts
and they are not published anywhere in the form of books, monographs or articles. The
books, articles and websites etc. which have been relied upon by me have been duly
acknowledged at the respective places in the text.

For the present dissertation which I am submitting to the University, no Degree or Diploma
has been conferred on me before, either in this or in any other University.

Place: JAIPUR HEMANT SINGH

Date: 16TH JAN., 2023 Roll no. 13
BRANCH:CRIMINAL AND SECURITY LAWS
LL.M. Student,
Dr. B. R. Ambedkar Law University, Jaipur

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 Table of Contents

Table of Acronyms and Abbreviations….......................................................................6

Table of Cases…...............................................................................................................7
Table of Statues…............................................................................................................8
Chapter1 Introduction....................................................................................................9-10
1.2 Objective
1.3 Research methodology
1.4 Research problem
1.5 Research question
Chapter 2 Compensatory Jurisdiction.........................................................................11-13
2.1 What is Compensatory Jurisdiction
Chapter 3 Historical Background of Compensatory Jurisdiction............................14-17
3.1 Pre-Independence: British Period
3.2 Post Independence
Chapter 4 Compensatory Jurisdiction in Criminal Law...........................................18-20
Chapter 5 Conclusion.......................................................................................................21
Bibliography…..................................................................................................................22-23

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 LIST OF ACRONYMS AND ABBRIVIATIONS

AIR All India Reporter

CrPC Criminal Procedure Code

SCC (SC) Supreme Court Cases (Supreme Court)

Cri.LJ Criminal Law Journal

Sec. Section

Sub. S. Sub. Section

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 TABLE OF CASES

 Bank of Bengal v. Joined Company, (1831) 1 BR 87.

 State of Rajasthan v. Vidyawati, AIR 1962 SC 933.

 Kasturi Lal v. State of Uttar Pradesh, JT1987(3) SC234.

 Chairman, Railway Board and Others v. Mrs. Chandrima Das, (2000) 2 S.C.C.465.
 Nilabati Behara v. State of Orissa, (1993) 2 S.C.C.746.
 Rudal Shah v. State of Bihar, (1983) 3 S.C.C.508.
 D.K. Basu v. State of West Bengal, AIR 1997 SC 610.
 State of Maharashtra v. Madhukar N. Mardikar, AIR 1991 SC 207.

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 TABLE OF STATUTES

 CODE OF CRIMINAL PROCEDURE, 1973

 THE CONSTITUTION OF INDIA, 1950

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 CHAPTER-1

1.1 Introduction

Whenever an offence is happening it has two players involved one the offender and other the
Victim. Though from the ancient time the crime or the offences kept taking places, but the
centrifugal point has always been the Offender. From the ancient time punishing the
offender has always been paramount to that effect that five theories for punishing the
offender evolved from a subsequent time to show the society that repeating the same would
have same consequent on the person doing the same. Later reformative theory came where
reforming the offender same in the picture. Eventually even when today crime takes place the
first statement within us comes, “Punish the offender” but there is hardly any buzz for the
victim. The portentous thing is that more than the offender it‟s the Victim who suffers and in
the course of time victim becomes the offender and the offender becomes the victim. The
victim Compensation is the administration‟s method for monetarily helping casualties and
survivors of wrongdoing, yet the present framework is underused and some of the time
abused. Notwithstanding physical mischief, casualties and survivors may endure sincerely
and fiscally. Victim expenses can incorporate therapeutic and psychological well-being
advising costs and the expenses of settling or supplanting harmed or demolished property. the
victim who can‟t work because of physical or mental weakness loses wage.

Victim‟s remuneration has dependably been the sobbing poor person at the entryway of
criminal equity. Although, it is a deep-rooted idea its improvement on more logical lines and
furthermore as a branch of criminology has started since a couple of decades back. A few
nations have taken up the diverse plans of installment of pay to their casualties of
wrongdoing.

1.2 Objective of the study

Compensation is granted to the victims of any offence. There are various statutes that aim to
provide compensation to the victims. This article aims to provide information about the
compensatory jurisprudence in India and also bestows information with respect to the
concerned statutes. This article also aims to provide a keen knowledge about the dearth of
laws in providing adequate compensation to the victims.

1.3 Research Methodology

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In this project, I have used Doctrinal Research Methodology for the research. For the
completion of this research work secondary sources of information have been utilized to
collect data. The other sources of information shall include standard reference books, law
reporters (AIR, SCC, Cri.LJ, RCR (Cri.)), Committee and commission reports and journals.

1.4 Research Problem

This project discusses compensatory jurisprudence in India and examine Whether
compensation can be a means of dispensation of justice to the rape victims or victims of any
criminal offence? What is the judicial approach in this regard and whether an extensive
compensation program can be developed to ameliorate the condition of rape victims or
victim of any criminal offence?

1.5 Research Question

1. How Compensatory Jurisdiction Evolved in India?

2. How the Judicial System exercise this Jurisdiction in imparting Justice?

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 CHAPTER-2
Compensatory Jurisdiction

2.1 What is Compensatory Jurisdiction:

The inception of compensatory jurisprudence is an escalating sign stipulating that the
judiciary has taken the onus of aegis to the right of life and personal right of all the citizens
notwithstanding of the non-appearance of any prompt constitutional allocation as well as
judicial precedents. The endowment of judiciary to rectify contends of victims of crime is no
less noteworthy. The higher courts have played an ascendant role in reassuring compensatory
justice to the victims of crime. While granting such compensatory succor, they have
exercised due heed and prudence to ensure that people‟s credence in judicial process is not
debilitated and the victims‟ protective rights are not repudiated from them. Some of the
landmark judgments of the Supreme Court fortifying restorative justice to victims of crime
contemplate the growing perturb of judiciary to secure the rights of victims.

The concept of compensation to victim of crime, peculiarly to the crime victims by the state
is acquiring much significance. Though this concept is an antique one, its evolution on more
scientific guidelines and also as a bifurcation of criminology has begun since a few decades
ago. The contemporary states which are titled as welfare states have perceived the gravity of
the subject of compensation to the victims of crime and are appropriately recording up
various victim compensation programs, as part of their mainstream well-being. Several
Nations have upraised the scheme of reckoning of compensation to victim of crime.

The term „compensation‟ means alter for the loss endured. Compensation is something
offered to make things balanced, an entity given to make amends for sufferings, recompense,
reimbursement or bay. It is counter balancing of the victim‟s sufferings and loss that result
from victimization. The reasoning or essence for compensation maybe the following three
grounds:
1. As an additional type of social insurance
2. As welfare measure another facet of the government/public assistance of the
unprivileged.
3. A way of meeting an overlooked governmental obligation to all citizens.

In India there is no compendious legislation or statutory sleight dispensing for compensation

to victims of crime. In some European countries provisions are made for remission of
11
compensation to the victims of crime in the itinerary of criminal proceedings. Justice needs
that an individual who has agonized must be compensated. Basically, the accused is
accountable for the injury spawned to the victim. We have statutes, underneath which
compensation may be given to the victims of crime.
1. The Fatal Accident Act, 1855.
2. The Motor Vehicles Act, 1988
3. The Criminal Procedure Code, 1973
4. The Constitutional Remedies for Human Rights Violation.
5. The Probation of Offenders Act, 1958.

The reactions to crime have been distinct at distinct stages of human civilization. There are
various theories available prevailing to “Reaction to crime”. Prominent among these theories
are Retribution theory, Utilitarian theory, Deterrent theory etc. In common, every theory
provides reasonable punishment. The objects of punishment can be summarized as:
1. Partly of creating example of the criminal.
2. Partly of discouraging the criminal from repeating the same act
3. Partly of reforming the criminal by eliminating the evil conscience and
4. Partly of gratifying society is feeling of retribution which the act is supposed to
evoke.
The law in the initial stages of advancement was to compensate the victim and not to punish
the offender. Narada was the first to endorse compensation to the victims by the offender in
order to redress his sins. If we go back to the genesis of criminal law, we see that the victim
and his family engross a central position it is the victims and who have the right to request
vengeance or guilt. However, over the centuries, his family with the progression of the state
and the administration of state prosecution the mantle of the victim has reformed from his
central position the victim has been transposed to a marginal one. The Court ruled that the
quantum of compensation must be equitable, depending upon the facts, context and justness
of victim‟s claim. The accused must be given equitable time for payment of compensation
and if necessary, it may be ordered to be paid in installments.

Victim‟s compensation has always been the weeping beggar at the door of criminal justice.
Although, it is an age-old concept but its development on more scientific lines and also as
branch of criminology has begun since a few decades ago. Several countries have taken up
the different schemes of payment of compensation to their victims of crime. In India as well,

1
there are different statutory provisions in criminal justice under which the compensation can
be awarded to the victim of crime, viz. Fatal Accident Act, 1855, Probation of Offenders Act,
1958 and Code of Criminal Procedure, 1973.

Few decades ago, the criminologists/sociologists acknowledged the importance of

compensation and its benefits for the victims of crime. In pursuance of the recommendations
of Law Commission1, a provision for the compensation to the victims of crime has been
provided in Section 357 of Cr. P. C. According to the sub s. (1) and sub s. (3) of s. 357, “The
court may award compensation to the victims of crime at the time of passing of judgment, if
it considers appropriate in a particular case in the interest of justice”. In 2008, the
Government introduced major amendments to the CrPC, in order to strengthen India‟s
criminal justice system. The amendment for the first time tried to define the term “victim”
and restore the outdated laws related to provision of compensation to victims.

1
Law Commission of India, 41st Report Law Commission of India on Indian Penal Code,1860 (1969).

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 Chapter-3
Historical Background of Compensatory Jurisdiction

Towards the finish of the medieval times, anyway the organization of pay started to lose its
power, because of the concurrent development of Royal and Ecclesiastical control which had
a sharp qualification amongst torts and wrongdoings. The idea of remuneration was firmly
identified with that of discipline and it was converged to a few degrees in the Penal Law, yet
in the meantime, various offenses like murder, theft and assault were never again viewed as
torts which could be settled by remuneration, however were viewed as violations against
society and were culpable as such. Progressively, as the State cornered the organizations of
discipline, the privileges of the harmed were isolated from the Penal Law and the
commitments to pay harms or remuneration turned into a piece of the Civil Procedure.2

The interest for pay for the casualties of wrongdoings was modified amid the Corrective
changes development of the nineteenth Century. It was talked about at fifth International Jail
Congress in the later 50% of the century. Regardless of the solid promotion of Jermy
Bentham and various driving Penologists, the acknowledgment of the standards of the state
obligation to pay remuneration for the casualties of wrongdoing stayed as far off as ever.
Among numerous different recommendations One was that open Tribunals, while passing
sentences in regard of offenses prepondering Civil component viz. in Petty Larceny, break of
trust and cheating and so forth ought to be enabled to urge dissolvable guilty parties to make
money related compensations to the casualties. Another proposal was that if the guilty parties
were wiped out, they ought to be made to work for the State till they earned enough to
remunerate their casualties.

3.1 Pre-Independence: British Period:

India was governed by the British up to 1947 in which year we accomplished in reliance. In
England the idea of State risk for the demonstrations of the workers what‟s more, authorities
are impacted by the teaching of „Ruler can‟t be blamed under any circumstance‟. The East
India Organization (alluded as EIC) started its vocation in India as a business company yet in
course of time because of recorded reasons it obtained sovereign forces and it is as it were in

2
Kishore K., The History of Compensation of the Victims of Crime 27, Cr. L. J (2006).

1
the wake of increasing such power a refinement is drawn amongst sovereign and non-
sovereign capacities which it worked out.
On account of Bank of Bengal v. Joined Company 3
, the Supreme Court (at Calcutta)
dismissed the supplication of sovereign resistance in an issue including the recuperation of
enthusiasm by the Bank of Bengal due on the promissory notes from the EIC for the
arraignment of War.

3.2 Post Independence Period:

The primary case after autonomy including the convoluted risk of State was, State of
Rajasthan v. Vidyawati4, in which the Supreme Court of India kept up that the State is
vicariously subject for the torts conferred by its authorities.

Hardly any decades back, the criminologists/sociologists recognized the significance of

remuneration and its advantages for the casualties of wrongdoing. In compatibility of the
suggestions of Law Commission of 41st Report (1969), a far-reaching arrangement for the
pay to the casualties of wrongdoing has been given in Sec.357 of Cr. P. C. As per the sub s.
(1) and sub s. (3) of s. 357, “The court may grant pay to the casualties of wrongdoing at the
season of going of judgment, in the event that it thinks about proper in a specific case in light
of a legitimate concern for equity”.

In 2008, the Government acquainted significant revisions with the CrPC, keeping in mind the
end goal to fortify India‟s criminal equity framework. The change out of the blue made an
endeavour to characterize the expression “casualty” and re-establish the obsolete laws
identified with the arrangement of remuneration to casualties. Lamentably it by and by leaves
the arrangement of pay to the sole circumspection of the judge‟s something that has been
infrequently practiced voluntarily in the past-the vanishing point of Indian casualty
remuneration law.

It is relevant to examine in short, historically, the action taken by a person against the state.
The Indian law was in a state of skepticism from its colonial times. This was because the
theory of tortuous liability as it subsisted in England was airily followed in India. Though
culpability subsisted in some areas, the Indian courts had been preoccupied with the maxim

3
(1831) 1 BR 87
4
AIR 1962 SC 933.
1
“King can do no wrong” that they formulated a divergence between sovereign and non-
sovereign functions. The decision of the Supreme Court in Kasturi Lal v. State of Uttar
Pradesh5, relinquished that the practice of a sovereign function will not generate a tort
maneuver. This decision was fallacious, and to a degree was reformed by later decisions
recapitulated in this article, but has still not been entirely overruled. Most judges either
abutting avoid reference to it or differ its ratio.

Compensation to victims is a recognised principle of law being enforced through the ordinary
civil courts. Under the law of torts, the victims can claim compensation for the injury to the
person or property suffered by them. It is taking decades for the victims to get a decree for
damages or compensation through civil courts, which is resulting in so much hardship to
them. The emergence of compensatory jurisprudence in the light of human rights philosophy
is a positive signal indicating that the judiciary has undertaken the task of protecting the right
to life and personal liberty of all the people irrespective of the absence of any express
constitutional provision and of judicial precedents.

The Idea of Compensation to victim of crime particularly to the crime victims by the state is
gaining much importance. Though this idea is an age old one, its development on more
scientific lines and also as a branch of criminology has begun since a few decades ago. The
modern states which are described welfare states have realized the importance of the subject
compensation to the victims of crime and are accordingly taping up several victim
compensation programs, as part of their general welfare. Various countries have taken up the
scheme of payment of compensation to victim of crime.

The Supreme Court of India has played the most commendable role in evolving
compensatory jurisprudence for the victims. Some of the landmark cases in which the
Supreme Court provided compensation to the victim include Chairman, Railway Board and
Others v. Mrs. Chandrima Das6, in which the Supreme Court ordered compensation to the
rape victim, who was a Bangladeshi national, by the government for the rape committed in
the Yatri Niwas managed by the Indian Railways at Howrah Station.

5
JT 1987(3) SC234
6
(2000) 2 S.C.C.465.

1
Then again, in Nilabati Behara v. State of Orissa7,the Supreme Court granted compensation
of Rs. 1, 50, 000 to the mother of departed, who died in police custody due to torment. In
both the cases, the Court held that victims‟ fundamental rights under Article 21 of the
Constitution of India, 1950 were violated.

In Rudal Shah v. State of Bihar8, the Supreme Court made it categorically clear that the
higher judiciary has the power to award compensation for violation of fundamental rights
through the exercise of writ jurisdiction and evolved the principle of compensatory justice in
the annals of human rights jurisprudence. Thus, the role of the Supreme Court in this
direction is laudable. The only thing required is the assistance of the legislature in the form of
comprehensive law on victims‟ compensation and rehabilitation and executive assistance in
the form of better implementation of the law.

7
(1993) 2 S.C.C.746
8
(1983) 3 S.C.C.508

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 Chapter-4
Compensatory Jurisdiction Under Criminal Law

The theory of compensation in criminal law is mainly about compensation to the victim of a
crime. A victim to a crime is one who has suffered any loss because of some act or omission
of the accused. The victim not only suffers physical injuries but also psychological and
financial hardships too. The plight of a victim is only made worse by lengthy hearings and
tedious proceedings of courts and improper conduct of the police. The victim is literally
traumatised again in the process of seeking justice for the first injury. The legal
heirs/guardians of the victim too come in the same definition.

The law makers made provisions in the Criminal Procedure Code, 1973 under Section 357(3)
to enable the Courts to award any amount of compensation to the victims of a crime. This
was depicted in the landmark case of Hari Kisan where the Supreme Court had awarded
compensation as punishment, of Rs. 50,000. Not only this, the lower courts were asked and
advised to “exercise the power of awarding compensation to the victims of offences in such a
liberal way that the victims may not have to rush to the civil courts”

The rape victim has to undergo from plethora of austerity like mental trauma, loss of income
due to pregnancy and expenses suffered during child birth due to the offence. Also, in the
contemporary Indian society, a rape victim is disdained even though she is the sufferer and
not the offender. In the course of a rape trial, if the offender is just punished or asked to
reimburse fine, the judgment does not approbates the victim as her condition is not
reinstituted. Hence, it becomes exceptionally indispensable to compensate such a victim. A
women‟s right to compensation initiate from Article 21 of the Indian Constitution which
states the right to life and personal liberty. The Supreme Court held that a woman can be
reimbursed paradoxically in the mid stages of the trial as well as at the culmination of the
trial. The Supreme Court even proposed the foundation of Criminal Injuries Compensation
Board (CICB) under Article 38(1) of the Constitution of India whose duty would be to
reimburse such victims and give them solace. However, no cognate board has been
established.

1
In the leading case of D.K. Basu v. State of West Bengal 9, the Supreme Court held that a
sufferer of custodial right possess every right to be reimbursed as her Right to Life has been
infringed by the official of the State. In another case, the Supreme Court held that the
session‟s court too possess the authority to provide compensation to the sufferer even if the
trial has not been accomplished. In fact, in the case State of Maharashtra v. Madhukar N.
Mardikar10, Supreme Court was of the view that “even a prostitute has a right to privacy and
no person can rape her just because she is a woman of easy virtue.

There is plethora of case law where the Supreme Court has awarded compensation to the
victims whose plight was brought to the notice of the apex court either by themselves or by
way of FIR with the aim of protecting the human rights of the victims in our criminal justice
system and to fulfill the constitutional obligation the apex court can instruct the government
to bestow on jurisdiction on the criminal courts by making statutory provisions for the
compensation to the victims of crime irrespective of whether the accused is convicted or not
and to make statutory provisions for participation of the victims in prosecution along with
prosecuting agency in a criminal case initiated on a police report.

When a crime is perpetrated against an individual, the victim is deprived of a lot apart from
suffering, damages and injuries. The duty of a judiciary should not only be to penalize the
guilty but also to reimburse the victim as even if the accused is penalized, the victim‟s loss is
not reimbursed. The reimbursement granted should at least try to put the victim in a condition
in which he was before. It is not like victims of crime cannot seek for compensation as such a
prayer is assessable under civil laws, but filing two distinguished suits for the same offence
in two different courts. The proceedings for one suit are most of the time is agonizing, that
such a methodology of filing distinguished suits only gives the victim a second
traumatization.

The concept behind providing compensation is legal as well as merciful. The impotence to
safe guard the person by the State makes it legally mandatory for the State to reimburse him.
The victim goes through such an adverse suffering and many times enduring loss of income
only makes it cerebral for him to be compensated. In cases where a person perishes or is sent
into a vegetative state, reimbursement should be very exorbitant as many times, the victim

9
AIR 1997 SC 610
10
AIR 1991 SC 207

1
himself is the sole “read earner of the family and hence his injuries affect the life of his
family too. In such cases, if the accused is only imprisoned or asked to pay a tiny fine, no
virtuous happens to either the accused or the victim‟s family.

Now we understand that reimbursement is not only needed but is in fact a very prime aspect
of even criminal law and the courts should not use this sparingly but a little liberally. Of
course, they should be cautious of not giving too high compensation and hence should be
cautious. The government should take into cogitation the suggestions of the Supreme Court
and set up Compensation boards to aid the victims with financial issues. Prior to CrPC
(amendment) 2008, India is deficient of an all-inclusive legislation for compensation of
victims. Compassionate treatment of victims under the criminal justice system itself guides to
the faith in the system which is enhanced by way of compensation programs, independent of
creed of offenders.

2
 Chapter 5
Conclusion

Every crime depicts the failure on the obligation of the state to respect, protect and fulfil the
human rights of its subjects. Hence, brief review of the existing legal framework in the area
of providing compensation to victims very little has been done either through statutes or by
schemes to address the series of problems faced by the victims because of crimes. Therefore,
it is desirable that the structures of criminal justice as well as their theoretical bases should
reflect the interests of individual victims as well as the broader interests of the state.

It is not to be forgotten that if the victim chooses not to cooperative with the criminal justice
system, the whole system will collapse. It is now mandatory that court should determine in
every criminal case the necessity as to awarding compensation. The Criminal Procedure
(Amendment) act, 2008 which incorporated Sec 357A, providing for victim compensation
fund is a giant leap in this regard. The recent contribution of apex court in implementing this
provision is also appreciable and that presently it has become obligatory on the part of court
to provide interim compensation in deserving cases. It is not necessary that conviction of the
offender must be recorded. Though Supreme Court has taken initiative to make the judicial
members to be aware of this scheme, it is also necessary that common men also must be
made aware of this provision. Legal awareness camps must be held in this regard. It is also
important that wider publicity must be given in the media as to the availability of this
scheme.

2
 BIBLIOGRAPHY

Books & Journal Referred:

 International Journal of Criminal Justice Sciences, Vol 13 Issue 2, Dipa Dube, Victim
Compensation Schemes in India: An Analysis (2018).
 K.N.C. Pillai's, General Principles of Criminal Law, Eastern Book Company, 2nd
Edition, 2011.

Website Referred:

 Jus Dicere. 2021. Compensatory Jurisprudence Under Criminal Law: An Analysis -

Jus Dicere. [online] Available at: <https://www.jusdicere.in/compensatory-
jurisprudence-undercriminal-law-an-analysis/#_ftnref9> [Accessed 6 December
2021]

 Bbau.ac.in. 2021. [online] Available at:

<https://www.bbau.ac.in/dept/HR/TM/LL.M.203%20Unit%204.Compensatory%20Ju
stice%20Juris.Preeti%20Misra.pdf> [Accessed 6 December 2021].

 India, l., 2021. Compensatory Jurisprudence. [online] Legalservicesindia.com.

Available at: <http://www.legalservicesindia.com/article/1888/Compensatory-
Jurisprudence.html> [Accessed 6 December 2021].

 India, l., 2021. Compensatory Jurisprudence in India. [online]

Legalservicesindia.com.
Available at: <http://www.legalservicesindia.com/article/2035/Compensatory-
Jurisprudence-In-India.html> [Accessed 6 December 2021].

 International Journal of Legal Science and Innovation. 2021. Compensatory

Jurisprudence in India - Int'l J. of Legal Sci. and Inno. [online] Available at:
<https://www.ijlsi.com/compensation-jurisprudence-in-india/> [Accessed 7
December 2021].

 Legalserviceindia.com. 2021. Development of Compensatory jurisprudence by

Supreme Court of India.

2
[online] Available at: <https://www.legalserviceindia.com/legal/article-2907-
development-of-compensatory-jurisprudence-by-supreme-court-of-india.html>
[Accessed 7 December 2021].