CENTRAL UNIVERSITY OF SOUTH BIHAR

SCHOOL OF LAW & GOVERNANCE

SESSION: (2021-2026)

CODE OF CRIMINAL PROCEDURE

ASSIGNMENT ON: Analysis of the jurisprudence of Bail in the light of
judicial pronouncements

SUBMITTED TO: SUBMITTED BY:

DR. SURENDRA KUMAR ANKITA KUMARI
PROFESSOR CUSB2113125027
DEPARTMENT OF LAW SECTION- “A”
SLG

DATE OF SUBMISSION: 12/04/2023

ACKNOWLEDGEMENT

1
I wish to express my sincere appreciation to my professor, who has the substance of a genius.
He convincingly guided and encouraged me to be a good law student and do right thing even
when the road got though. Without your persistent help, the goal of this assignment would
not have been realized. I express my sincere gratitude to you for your honest teaching and
guidance. It is the whole heartly appreciated that your great advice for my study proved
monumental towards the success of this study. You always inspire me to excel myself in the
field of law. Also, I wish to acknowledge the support and great love of my family members
and friends. They kept me going on and this work would not have been possible without their
input. I would like to recognize the invaluable assistance into you all provided during my
assignment. I would like to thank all people whose assistance was a milestone in the
completion of this assignment.

THANK YOU

2
 TABLE OF CONTENT

Contents
ABSTRACT ............................................................................................................................................
4
INTRODUCTION ..................................................................................................................................
4
MEANING AND DEFINITION OF BAIL: ...........................................................................................
5
OBJECTIVES AND BAIL PROVISIONS IN CrPC..............................................................................
5
HISTORY OF BAIL ...............................................................................................................................
6
BAIL: ABANDONMENT OF RIGHTS ................................................................................................
6
COMMISSION REPORT ON BAIL ......................................................................................................
6
TYPES OF BAIL: ...................................................................................................................................
7
1. Regular Bail ................................................................................................................................ 7
2. Interim Bail ................................................................................................................................. 7
3. Anticipatory Bail ......................................................................................................................... 7
WHY IS JAIL AN EXCEPTION?..........................................................................................................
8
CONSTITUTIONAL PERSPECTIVE: ..................................................................................................
9
INTERNATIONAL PERSPECTIVE: ..................................................................................................
10
JUDICIAL VERDICT ON BAIL: ........................................................................................................
11
CRITICAL ANALYSIS OF BAIL JURISPRUDENCE IN INDIA: ....................................................
12
CONCLUSION .....................................................................................................................................
13
BIBILIOGRAPHY ...............................................................................................................................
14

3
ABSTRACT
One of the most common terms that one comes across while delving into the domain of
criminal law is bail. Bail is a judicial process that has to be conducted impartially and
judicially and in accordance with statutory and constitutional prescripts. Bail in its essence is
a fine balance between the right to liberty of the person accused of an offence and the
interests of society at large. In general parlance, bail refers to release from custody, whether it
is on personal bond or with sureties. In the present moments, bail in India is a highly
debatable issue. There are number of reports that shed light on the state of the criminal justice
system in India.

INTRODUCTION
Bail is a provisional release of a detained person, who is accused of a criminal offence and
therefore the judgement is yet to tend. Bail is granted keeping in mind the target behind arrest
which is to make sure the presence of the accused before the court for the trial with none
inconvenience. However, if the presence of the accused is often guaranteed without detaining
the person, then it might be unjust to violate his right to liberty. Therefore, bail may be a sort
of security deposited to seem before the court for release. Bail is rule and jail is an exception
is a judicial principle that was laid down by the Supreme Court during a landmark judgement
of State of Rajasthan v. Balchand in 1978. The judgement was based upon several rights
that are guaranteed by the constitution of India with Article 21 being the foremost important
one. Detention of a person infringes his right to life and personal liberty as guaranteed under
Article 21 of the constitution of India. The most purpose of detention is to make sure easy
proceedings by availing the accused for the trials with none inconvenience. Thus, if it is often
ensured that the accused are going to be available as and when required for the trial, them,
detaining the person isn’t necessary. Therefore, it had been held that the provisions of the
CrPC 1973 regarding the arrest of a private must be interpreted during a sense that unless
indispensable, detention of an individual must be avoided.

MEANING AND DEFINITION OF BAIL:

The term bail has not been defined in the Criminal Procedure Code 19731, nevertheless, but
the word ‘bail” has been used in Criminal Procedure Code 1973, through the term “bail”,
‘bailable’ and ‘non-bailable’ have been collectively been used approximately 102 times in
CrPC, 1973. Section 2(a) of CrPC defines bailable offence as an offence which is shown as
bailable in the first scheduled, or which is made bailable in the first schedule, or which is
made bailable by any penal law for the time being in force2.

Literally the expression ‘bail’ denotes a security for appearance of a prisoner for his release3.
Etymologically, the word is derived from old French verb “bailer” which means to “give” to

1
Vaman Nairain Ghiya V. state of Rajasthan, 2009, 2SCC 281
2
Bare Act of Criminal Procedure Code, 1973
3
oxford dictionary, chamber 21 century dictionary

4
“deliver” although another view is that its derivation is from the Latin term ‘bajulare’
meaning “to bear a burden”. In general parlance, bail refers to release from custody, whether
it is on personal bond or with sureties.
According to Black’s law dictionary defines bail as “procuring the release of a person from
legal custody, by undertaking that he/she shall appear at the time and place designated and
submit him/herself to the jurisdiction and judgement of the court”.
According to Law Lexicon “bail is security for the appearance of the accused, on giving
which he is released pending trial or investigation.”
There are two aspects of bail- freedom of the individual and the interest of justice. So, the
provisions of bail restore individual liberty without hampering the objectives of the arrest.
Chapter XXXIII of CrPC from section 436-450 talks about provisions as to bail and bonds.

OBJECTIVES AND BAIL PROVISIONS IN CrPC

The reason for arrest or detention of an accused person is to ensure that if he is found guilty
of the charges, he is available to receive his sentence. But what if the accused person
promises to appear for the trial from time to time? Then there is no reason to deprive the
person of his liberty. That is where the provisions of bail come into the picture. The main
objective of granting bail to an accused in jail is to ensure that while the trial continues, if the
accused is not a threat to a society or going to tamper with the evidences and coerce the
witness, he should not be deprived of his freedom. In short, the basic objective usually
recognized to the institution of bail, is to ensure the presence of the person accused of an
offence at trial while maximizing personal liberty in accordance with the principle of the
constitution. The CrPC 1973 and other legislation must be amending to reflect these
constitutional mandates while ensuring that justice and initiative to prevent crime are not
diluted.

HISTORY OF BAIL
The concept of bail can trace back to 399 B.C, when Plato tried to create a bond for the
release of Socrates. The modern bail system evolved from a serious of laws originating in the
middle age in the England4. During the Mughal rule, the Indian legal system is recorded to
have an institution of bail with the system of releasing an arrested person on his furnishing a
surety. The use of this system finds reference in the 17th century travelogue of Italian traveler
Manucci who himself was restored to his freedom bail from imprisonment for a false charge
of theft. He was granted bail by the then ruler of Punjab, but the kotwal released him only
after he furnished a surety. Under Mughal law an interim released could possibly be actuated

4
www.legalserviceindia.com, dated 19.10.2019, at 11;04 p.m

5
by the consideration that if dispensation of justice got delayed in one’s case then
compensatory claim could be made on the judge himself for losses sustained by the aggrieved
party5. During the British Raj in India criminal courts were using two well understood and
well-defined forms of bail for release of person held on custody. These were known as
Zamanat and Muchalka67. Its latest reflection is the improved version of the provisions
relating to bail in the code of criminal procedure, 1973 which were preceded by the adoption
of the constitution 1950.

BAIL: ABANDONMENT OF RIGHTS

The gravity of offence was immaterial for grant of bail. “ whether it’s a significant crime,
whether it’s the cash laundering act or the other law, the principles to be followed in grant of
bail are one and therefore the same as per the Criminal Procedure Code”. When these
principles weren’t followed, it might amount to throwing a significant challenge to the rights
of the accused. It had been time a three-judge bench of the Supreme Court clearly laid down
the law for all courts to follow in order that the rights of the accused aren’t trampled upon and
a message was sent to the trials court.

COMMISSION REPORT ON BAIL

The commission seeks to enhance on a provision introduced in 2005 to grant relief to
thousands of prisoner languishing without trial and to decongest India’s overcrowded prisons.
Section 436A of the Code of Criminal Procedure stipulates that a prisoner shall be released
on bail on personal bond if he or she has undergone detention of half the utmost period of
imprisonment specified for that offence. The Law Commission recommends that those
detained for an offence that might attract up to seven years imprisonment be released on
completing one-third of that period. For those that had spent the entire period as under trials,
the amount undergone could also be considered for remission. Generally terms, the
commission cautions the police against needless arrests and magistrates against mechanical
remand orders. Based on the recommendations of the Law Commission in its 41st report of
the code of criminal procedure7-the law relating to bail got suitably modified, in tune with the
constitutional objectives and sought to strike a fine equilibrium between the freedom of

person and interest of social order. The provisions namely section 436, 437 and 439 of
chapter XXXIII of CrPC were streamlined in 1973.
In last few decades, the societal contexts, its relations, are changing pattern of crimes,
arbitrariness in exercising judicial discretion while granting bail are compelling reasons to
examine the issue of bail and to chart a roadmap for further reform. The department of legal
affairs, Ministry of law & justice, Government of India, vide its letter dated 11.09.2015
forwarded a note from the Ministry of law & justice dated 01.09.2015, on the need for a Bail

5
J.N Sarkar, Mughal Administrator in India, 108 (1920)
6
The concept and system of bail, Indian law Institute, page 5
7 st
law commission report, 1969, the code of criminal procedure, 1898 vol. I

6
act in India. The department made a reference to the law commission “to examine desirability
pf having a separate Bail Act, keeping in view the similar provisions in the United Kingdom
and other countries”. Later however, the Law Commission vide letter dated 21.12.2016 was
referred to achieve the objective by bringing necessary changes in the existing provision of
CrPC. It gives an illustrative list of conditions that would be imposed in lieu of sureties of
financial bonds. It advocates the necessity to impose the “least restrictive conditions”.
However, because the report warns, bail law reform isn’t the panacea for all problems of the
criminal justice system. Be it overcrowded prisons or unjust incarceration of the poor, the
answer lies in expediting the trial process. For, in our justice system, delay remains the first
source of injustice.

TYPES OF BAIL:
There are generally 3 types of bail in India which a person apply depending upon the stage of
the criminal matter:
1. Regular Bail- A regular bail can be granted to a person who has already been arrested
and kept in police custody. A person can file bail application of regular bail8.
2. Interim Bail- Interim bail is a bail granted for a short period of time. Interim bail is
granted to an accused before the hearing for the grant of regular bail or anticipatory
bail.
3. Anticipatory Bail- People, who discern that he may be arrested by the police for a
non-bailable offence, can file an application for anticipatory bail. It is like an advance
bail obtained under section 438 of CrPC. A bail under section 438 is a bail before
arrested and a person cannot be arrested by the police if anticipatory bail has been
granted by the court.

The law of bail like any other branch of law has its own philosophy and occupies an
important place in the administration of justice and the concept of bail emerges from the
conflict between the police power to restrict liberty of a man who is alleged to have
committed a crime, and the presumption of innocence in favor of alleged criminal. An
accused is not detained in custody while the object of punishing him on the assumption of
guilt. The court in this case, dealt with difference between bail under section 438 and 439
pointing out that section 439 can be invoked only when the accused is in custody. The court
has authority to refuse bail if it has apprehend that the accused may not be available for trial.
This is so even when the accused is entitled for bail on the ground of non-submission of
chargesheet within the statutory period.

In Brij Nandan Jaiswal V. Meena Jaiswal the petitioner was charged with murder. He
was reused bail by the session’s court. However, the High Court granted him bail under
section 437, CrPC. It was questioned by the complainant, upholding the right of complainant;
The SC declared that ‘it was now a settled law that the complainant can always question the
order granting bail if the said order is not validity passed. It is not as if once a bail is granted

8
Under section 437 & 439 of the CrPC 1973

7
by any court, the only way is to get it cancelled on account of its misuse. The bail order can
be tested on merits also9. In this case the Court find out that the High Court granted bail
mechanically and hence it was reversed by the Supreme Court. SC observed in P.
Chidambaram case “it is not a rule that bail should be denied in every case. Delhi High Court
making observations on the merits of the case10”. The purpose of the bail is ensuring the
appearance of accused before the court whenever required but in certain cases, granting bail
is not required.

BAIL IS THE NORM AND JAIL IS THE EXCEPTION11

WHY IS JAIL AN EXCEPTION?

The appliance of the reformative theory to the principles of punishment involves a balance
between two theories namely 1. Deterrent theory 2. Punitive theory i.e., to reform an accused
and to stay him faraway from hardened criminals in jail which are deemed to be universities
of crime.
Furthermore, with an increase in human rights activism, the equilibrium between the freedom
of a private and therefore the interest of society has become the most concern. So unless there
are some cogent reasons like chances of the accused fleeing from the justice or the fear of
him tampering the evidence or inducing the witnesses, detention of the accused is against his
fundamental right to liberty which is completely uncalled for. Therefore, the courts make sure
that an individual isn’t detained unless the interest of justice suffers if an arrest isn’t made.
ARNESH KUMAR VS. STATE OF BIHAR
It is a landmark judgement, which was pronounced by the apex court as it imposed further
checks and balances on the powers of the police before an arrest and after an arrest. Supreme
court has given the direction to all, the State governments, to instruct police officers not
precisely arrest the accused without check list and scrutinize all the facts and first did
preliminary investigation before arrest.
“Arrests brings humiliation, curtail freedom, and casts scars forever. Law makers know it so
also the police. There is a battle between the law makers and police and it seems that the
police have not learned its lesson: the lesson implicit and embodied in CrPC.
Recently, in the case of Munawar VS. State of Madhya Pradesh, the SC granted bail to him,
only on the basis that the investigation authorities does not follow the guidelines mentioned

under the Arnesh Kumar case, which clearly shows us that how much liberty of individual is
sacred, and no one have right to curtail anyone personal liberty.

9
.Id.at 596
10
http:/www.indiatoday.in/india/story/supreme-court-grants-bail-to-chidambaram-in-inx-media-case 1624960
04.12.2019
11
State of Rajasthan V. Balchand alias Baliya 1978

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NEW TREND: NOT BAIL, JAIL IS THE NORM
Right to life and personal liberty is one of the most important and beautiful fundamental right
mentioned in our constitution under Article 21. The part-III of the constitution is wholly and
solely based on the principles of natural justice. Generally, no provision is found in any
statute for the observance of the principles of natural justice by the adjudicating authorities.
The question then arises whether the adjudicating authority is bound to follow the principles
of natural justice. The law is well settles after the powerful pronouncement by Byle J in
Cooper V. Wandsworth Board of Works. The principle laid down in the mentioned case is
accepted in India also. In the famous case of A.K Karipak vs. Union of India, speaking for
the SC, Hegde J propounded:
“The aim of the rules of natural justice is to secure justice or to put it negatively to prevent
miscarriage of justice. The rules can operate only in areas and covered by any law validly
made. In other word they do not supplant the law of the land but it supplement it”.
Par Contra, Bail jurisprudence in India is also based on the principles of natural justice and
individual liberty. In the famous case of Narasimhulu V. Public Prosecutor, justice Krishna
Iyer remarked that “The subjects of bail belongs to the blurred are of the criminal justice
system and largely hinges on the hunch on the bench, otherwise called judicial discretion”.
The recent trend of arbitrariness in exercising discretion has been a serious roadblock in
achieving the ends of justice. In case involving high profile individuals, bail is granted
without considering the enormity of the case. However, on the other side, investigating
agencies arrested or detained the individuals without doing preliminary investigation, and the
agencies blindly follow the order of their political masters, likewise we can easily seeing the
illegal detention of Adv. Sudha Bhardwaj, IPS Sanjiv Bhatt, Dr. Kafeel, comedian
Munawwar Farooqui and many more.

CONSTITUTIONAL PERSPECTIVE:
Article 21 of our constitution provides that “No person shall be deprived of life and personal
liberty except according to procedure established by law”. The commission of Inquiry Act,
1952, it must be recommended that if any procedure for depriving a person of his life is not
fair, just and reasonable, then that procedure will be void as violating Article 21.
In Maneka Gandhi vs. Union of India12, it was held that the procedure under Article 21
must be just, fair and equitable. Before a person is deprived of his life and personal liberty,
the procedure established by law must be strictly followed, and must not be departed from the
disadvantage of the person affected13.

12
AIR 1978 SC 597
13
Bashira vs. state of U.P AIR 1968 SC 1313

9
In the case of Joginder Kumar vs. State of U.P14. the SC has given directions on the rights
of the arrested person in the light of Article 21 and 22. The Supreme Court of India in the
case of Gudikanti Narasimhulu vs. Public Prosecutor, High Court of Andhra Pradesh15
observed that the personal liberty, deprived when bail is refused, is too precious a value of
our constitutional system recognized under Article 21 that the fundamental power to negate it
is great trust exercisable, not casually but judicially, with lively concern for the cost to the
individual and the community. In Rajesh Ranjan Yadav vs. C.BI, court remarked that while
Article 21 is of great importance, a balance must be struck between the right of liberty of the
person accused of an offence and the interest of the society. No right can be absolute and
reasonable restriction can be placed on the exercise of the rights. The grant of bail due to
prolonged confinement cannot be said to be an absolute rule because the grounds of bail must
depend upon the contextual facts and circumstances.
Bail in its essence is a fine balance between the right to liberty of the person accused of an
offence and the interests of society at large. The grant or refusal of bail on economic
conditions i.e., monetary surety violates Article 14 and 15 of the constitution of India and
runs contrary to the constitutional ethos. Personal liberty and rule of law finds its rightful
place in the constitution in Article 22 which includes measures against the arbitrary and
indefinite detention.

INTERNATIONAL PERSPECTIVE:
The UDHR in Article 2 states that every person is entitled to all the right and freedom in the
declaration without discrimination. Article 2(I) of ICCPR also reiterate the same and further
obligates each state party to respect and ensure to all persons within its jurisdiction the rights
in the covenant without16. More importantly, Article 26 not only provides for equality before
the law but equal protection of law. Thus, it prohibits any discrimination based on capricious
factors such as race, color, sex, language and religion, political or national origin.
The UDHR along with ICCPR in Article 9 (I) stated that the fundamental rights to liberty,
security and protection against arbitrary detention. By virtue of the fundamental right the
state is placed under an obligation to protect and preserve the liberty and the security of
citizens against arbitrary arrest and detention. In order for the detention to be lawful and not
arbitrary, it must be consistent with the substantive rules of national and international laws as
well as the principles and guidelines preserving fundamental rights.

14
AIR 1994 SC 1349
15
AIR 1978 SCR (2) 371
16
UN Human Rights Committee (HRC), ICCPR general comment no. 18 November1989

10
JUDICIAL VERDICT ON BAIL:
In Babu Singh vs. State of UP it was held that refusal to grant bail in a murder case without
reasonable ground would amount to deprivation of personal liberty under Article 21. In that
case the court held that refusal to grant bail amounted to deprivation of life and personal
liberty of accused persons. Personal liberty of an accused or convict is fundamental and can
be taken away only in accordance with procedure established by law. So, deprivation of
personal liberty must be founded on the most serious consideration relevant to the welfare
objectives of the society specified in the constitution. In the circumstances of in the case, the
court held that the subject to certain safeguards, the appellants were entitled to be released on
bail.
In Sanjay Chandra vs. CBI well known as 2G scam, the appellants, facing charges
under sections 420 B, 458, 471 and 109 of IPC and section 13(1) (D) of Prevention of
Corruption Act, 1988, were denied bail by the special judge, CBI and also by the HC. The SC
directed the appellants to be released on bail subjected to certain conditions and held that in
determining whether to grant bail both the seriousness of the charge and severity of
punishment should be taken into consideration. Bail is not to be denied merely because of the
sentiments of community against the accused. The detention of under trial prisoners in jail
custody to an indefinite period violates Article 21. Every person detained or arrested is
entitled to speedy trial. It looks that the applicants have to remain in jail longer than the
period of detention, if they are convicted.
The apex court of India in the case of State of Maharashtra vs. Sitaram Popat Vital held
that the few factors to be taken into consideration, before granting bail, these are
1. The nature of accusation and the severity of punishment in case of conviction and the
nature of supporting evidence,
2. Reasonable apprehension of threat to the complaint
3. Prima facie satisfaction of the court in support of the charge.
At the certain matters require investigation for the court to effectively decide upon bail
application, like:
1. Whether there is or is not a reasonable ground for believing that the applicant has
committed the offence alleged against him.
2. The nature and gravity of charges

11
 3. The severity of the punishment which might fall in the particular circumstances in
case of a conviction
4. The likelihood of the applicant absconding, if released on bail
5. The character, means, standing and status of the applicant
6. The likelihood of the offence being continued or repeated on the assumption that the
accused is guilty of having committed that offence in past.
7. Opportunity of the applicant to prepare his defense on merits.

The Apex court of India in the case of Prahlad Singh Bhati vs. NCT Delhi and others held
that,The condition of not releasing the person on bail charged with an offence punishable
with death or imprisonment for life shall not be applicable if such person is under the age of
16 years or is a woman or is sick or infirm, subject to such conditions as may be imposed.

CRITICAL ANALYSIS OF BAIL JURISPRUDENCE IN INDIA:

One of the most important and long overdue reforms in the bail jurisprudence in India is that
bails should be granted keeping in mind the innocence principle by the courts. Very often, the
bails get denied merely by looking at the nature of the offence and often ignoring the fact that
the crime on the part of the accused has not yet been established by the court after following
the due process and procedure established by the law. A thorough account of the evidences,
witnesses and the history of the accused must be kept in mind while granting bails to make
the process more rational, fair and transparent.
Moreover, in order to prevent miscarriage of justice in various statutes brought in to protect
particular disadvantaged sections of the society like section 498A, section 375 and SC/ST
prevention of atrocities act, there should be quick and effective redressal mechanism to finish
the trial efficiently without inordinate and unnecessary delays so as to acquit the innocent
people falsely accused in these cases and save valuable and productive years of their life
which would even lead to safeguarding the valuable human resources of the country. Last but
not the least, the Indian bail system which often relies heavily on furnishing bonds and
securities, the poor and the lower economic strata of the society have to bear the brunt of their
poverty and find themselves in a disadvantaged position. In the case of Moti Ram vs. State
of M.P 1978, it was held that the setting arbitrary amounts as sureties or bonds violates the
right to freedom and right to equality of poor section of the society and wreaks the whole
purpose of ensuring justice to everyone which is the goal of the Indian constitution. Thus, the
amounts of sureties must be reasonable and must be decided keeping in the mind the
economic feasibility and affordability of the accused.
Thus, all these grey areas should be taken into light and necessary reforms should be brought
in at the earliest so as to ensure that the provision of bail establishes a system of check and
balances within the country and legitimate bails are given to those who deserve them so that
the law of the land can be maintained and rule of law is not violated in the country.

CONCLUSION

12
The right of a bail and fair trial required moderation not only to the person accused of an
offence, but also consideration of the public and society at large as represented by the state.
The accused should not be subjected to undue or unnecessary detention prior to conviction.
Every citizen of India has basic fundamental rights to freedom guaranteed under Article 21 of
the Indian constitution. Bail is rule and jail is exception is a judicial principle that was laid
down by the Supreme Court during a landmark judgement of state of Rajasthan vs. Balchand
in 1978. The judgement was based upon several rights that are guaranteed by the constitution
of India with Article 21 being the foremost important one. Detention of a private infringes his
right with Article 21 being the foremost important one. Detention of a private infringes his
right to life and liberty as guaranteed under Article 21 of the constitution of India, the most
purpose of detention is to make sure easy proceedings by availing the accused for the trials
with none inconvenience. Thus, if it is often ensured that the accused are going to be
available as and when required for the trial, then, detaining the person isn’t necessary.
Therefore, it had been held that the provisions of the Criminal Procedure Code, 1973
regarding the arrest of a private must be interpreted during a sense that unless indispensable,
detention of an individual must be avoided.

13
BIBILIOGRAPHY

WEBSITES
1. https://www.legalserviceindia.com
2. https://www.writinglaw.com
3. https://www.lawctopus.com
4. https://www.ilsindia.com
BOOKS
1. Ratanlal & Dhiraj lal, The code of criminal procedure, 22nd edition
2. K.N Chandrasekharan Pillai, Lectures on criminal procedure [Introducing probation and
juvenile justice], sixth edition
NEWSPAPER
1. INDIA TODAY
2. THE HINDU
JOURNALS

1. DR. Nilanchala sethy “ right to bail” A jurisprudential approach International journal of

humanities and social science invention (IJHSSI)ISSN (online) volume 09(3), 2020, pp 05-11

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