Submitted By:

Rishabh Lade (MNLU Mumbai)      

Yash Meshram (MNLU Mumbai)


Introduction: –

Every human is born with certain basic rights that he is entitled to for instance, right to live and the right to freedom, etc. Similarly, every citizen of every country is presented with certain rights that are absolutely fair without any prejudice in the spirit of common brotherhood and consciences like the right to life, right to equality, right to freedom, right to education, right to equality, right to freedom of religion and many more. However, the same rights of a person can get surrendered if the person gets detained/ arrested for committing a crime. Indian Legal System Jurisprudence is based on very important Legal Maxim ei incumbit probation, qui dicit, non qui negat. It literally means the burden of proof lies upon the person who affirms not who denies. i.e., the prosecution must prove the guilt beyond a reasonable doubt rather than the accused. According to this principle, there is a presumption of innocence for every individual unless he or she is proven guilty. This rule prevents the harassment, embarrassment, and punishment of innocent responsible people who might be wrongfully or maliciously framed. In general, the principle states that a person is considered to be innocent unless proven guilty. An unlawful arrest of an individual can violate Article- 21 of the Indian Constitution that states that no human shall be denied of his right to life and personal liberty except if established by law. which means that the process must be fair, clear and not arbitrarily or oppressive. An accused person is an entity who has been alleged to have committed an offense. Our Indian Constitution and CrPC provide certain rights to an arrested person that cannot be taken away.

Today, India faces a huge problem of illegal arrests as well as custodial deaths which are majorly caused due to illegal arrests. the police seem to have by and large lost the faith that the public are otherwise expected to repose in them. There is ample evidence to the show that the police blatantly infringe the law themselves, under the cover of duty and effectuate arbitrary arrests and detention, despite various safeguards under the Constitutional and Statutory Law, being in place. The right to personal liberty is one of the most important rights guaranteed to every individual and it is eventually the State, which is to ensure a check on efforts towards encroachments on the same. In this perspective the researcher has made an analytical and objective study of the law of ‘arrest and detention’ under the Indian Constitution and Code of Criminal Procedure 1973 Further interpretation of the law through judicial ratio.

Police Brutality in India

India’s P Jayaraj and his son E Bennicks have become the faces of India’s systemic problem with police brutality. Both men were arrested and in police custody from June 19 to June 23 during which time they were tortured, sexually assaulted, denied medical treatment, transported over long distances against their will, and eventually, they died after being rushed to the hospital while still under police custody.[i] According to the first information report by the police officers who arrested them, it was because they violated coronavirus lockdown laws by keeping their mobile accessory shop open for just 15 minutes after the curfew. an offense that should have warranted a warning or at most a fine with the threat of potentially facing six months in prison instead it cost them their lives. the gruesome details of their killings caused an outcry against police violence prompting calls for police reform and accountability with many likening the case to that of George Floyd’s death at the hands of police in the u.s in May[ii]. but the deaths of jayaraj and Bennicks are hardly isolated cases, the national campaign against torture a consortium of human rights groups recently published a report on India revealing that during 2019 alone 1731 people died in custody amounting to almost five people a day. 125 of them occurred in direct police custody 93 of which died due to torture[iii]. But none of the police officers on duty were charged the report also mentions how police officers regularly attempt to destroy evidence of torture, fail to conduct post-mortems, perform hasty cremations and it also notes various accounts of sexual abuse and violence even against children, toddlers. Tamandu ranks second amongst the worst defending states. 2019 status of policing report in India surveyed over 12000 police officers across 21 states and provided further insights, two out of five police personnel in India said they would prefer to punish culprits of minor offenses as opposed to a legal trial. while an overwhelming three out of four police thought it was normal to beat up criminals to extract confessions and one in four thought that killing a dangerous criminal is better than a legal trial[iv]. “First, their knees were smashed with sticks, or lathis their knees were completely crushed and smashed. Next, their faces were pushed against a wall, and blows were rained on their backs and bottom till it ripped and bled. They were taken to a spot where there were no CCTV cameras and steel-tipped wooden lathis, or batons, or sticks were shoved up their buttholes several times and there was also a great deal of torture and damage inflicted on their genitalia because eyewitnesses of the body have stated they’ve said that both the genital region and the backside were completely ripped and mangled[v].” This is Suchitra, a popular radio presenter, DJ, and singer in Tamil Nadu. She was one of the first celebrities to break the story in English for people outside of South India. the cases of Jayaraj and his son Bennicks are tragic examples of this police mentality with the extent of the torture they endured for so minimal a crime.

non-cooperation of Sathankilam police not handing over relevant records the lathis, made in torturing the accused, is unprecedented in torturing accused is unprecedented, it was not a simple lack of professionalism in a police investigation or in the chain of criminal justice system, namely the police they call the medical officer, the magistrate and the jail authorities, have miserably failed to perform their respective legally bound duties which highlight the systemic rot.

The Indian police have a great deal of power, and it is frequently impossible to hold them accountable. Let’s look at an example. Even without proving anything, a police officer can put a doubtful object in your pocket and lock you up by presenting a non-bailable case. Second, about 30 million cases in India are pending in court for 10 20 30 years. As a result, your only alternative is to make a deal with the cops. Police reforms are frequently proposed but seldom executed, owing to whatever agreement they have with politicians. Even if the case is false, a police officer knows that putting a case against a middle-class person will ruin their lives. This is because it takes at least 15 years for a court case to be resolved, and during that time you are broken, destroyed, stressed, suicidal, and miserable.

Custodial deaths as a measure of police violence

According to a response made in the Rajya Sabha by the Minister of State for Home Affairs in June, 427 persons died in police custody between 2016 and 2019. In one example, the National Human Rights Commission suggested that the police be disciplined. Police custody denotes that the accused is in the custody of the police and is being held in the station lockup. This is in contrast to judicial custody, in which the accused is the responsibility of the magistrate and is imprisoned. Until found guilty and convicted in a court of law, a person in police or judicial custody is called a suspect. Only a third of India’s 4.3 lakh prisoners had been convicted of a crime as of 2015, with two-thirds accused of crimes and awaiting trial[vi]. If judicial custodial deaths are included, there have been 5,476 deaths in detention in the last three years.

“Police attribute the majority of the deaths on suicide, illness, or natural causes,[vii]” according to a 2016 Human Rights Watch report on India’s failure to eliminate police custody killings. In many of these cases, however, family members claim that the deaths were caused by torture.”

The researchers discovered that this response was the same regardless of social class or educational degree. There was also no evident link between the acceptance of police brutality and the degree of crime in a given location. They did discover, however, that respondents who sympathised with police officers’ stressful working conditions were more inclined to condone custodial violence.

Constitutional Provision for Accused Person

The Indian Constitution is recognized as the country’s fundamental law of the land. The Constitution is the source of all legislation passed by the legislature. It includes protections for both citizens and non-citizens. The Indian Constitution guarantees equality[viii], and the concept of legal aid has its origins in this Article. If a person cannot acquire legal protection due to poverty, the role of equality before the law and equal protection under the law will remain a Constitutional shibboleth. The Constitution treats all citizens equally and ensures that they are protected by the law, yet ordinary people confront “barriers to access to justice.” Illiteracy, a lack of financial means, and social backwardness are all key issues that prevent ordinary people from obtaining justice. When a person lacks the financial wherewithal to access a court, justice becomes unequal.

The restriction of access to justice in the criminal justice system has a direct influence on the liberty of victims and accused, who are disproportionately from the socially and economically disadvantaged. Selective application of the law[ix] and its use as an instrument of oppression against the poor breaches the right to equality before the law and equal protection under the law, because the police, not the law, defines what is right and wrong.

Part III of the Indian Constitution ensures that all citizens have fundamental rights and that some of these rights, such as the right to equality (Article 14) and the right to life (Article 21), are guaranteed to all people. Both of these articles are crucial to comprehend the nature and scope of the right to legal aid as a means of obtaining justice. The denial of access to justice to a person because of economic and social inequalities is a manifestation of a breach of the right to equality[x] as part of the scheme of Articles 14 and 21, which had to wait until the late 1970s for judicial interpretation. Before this, an arrested person’s constitutional right to legal representation was thought to be included in Article 22 of the Constitution[xi].

The right to life and personal liberty is guaranteed under the Indian Constitution. This privilege cannot be taken away unless a legal procedure is followed[xii]. Only when a procedure adheres to natural justice principles is it considered fair and just. If the right to counsel a lawyer is critical to a fair trial, it is also critical to ensure that the accused has adequate resources to defend himself. Even if the deceased did not want legal assistance, a violation of fair trial standards would invalidate the trial and conviction.

According to the Constitution, a person arrested should not be held in jail without first being notified of the reason for his arrest and should not be denied the opportunity to speak with and be represented by a lawyer of his choice[xiii].

The Constitution further states that the state should try to promote the welfare of the people by establishing and protecting a social order in which justice, social, economic, and political, informs all institutions of national life as effectively as possible[xiv].

In 1976, a new provision, Article 39-A[xv], was introduced into the Constitution for providing free legal assistance and the principle of equal justice. Article 39-A, which was incorporated under Part IV Directive Principles of State Policy, reads as follows: “Equal justice and free legal aid. The State shall ensure that the legal system operates in a manner that promotes justice on an equal footing, and shall, in particular, provide free legal aid, through appropriate legislation or schemes or in any other manner, to ensure that no citizen’s right to justice is denied due to economic or other disabilities.”

By introducing Article 39-A, the State has recognized the right to free legal aid as a non-enforceable directive principle of State policy. The judiciary, on the other hand, has imaginatively interpreted Article 21 of the Constitution’s guaranteed fundamental right to life and liberty to include the right to legal help at the expense of the state[xvi]

Statutory Right for Arrested Person

Socrates says that “convicting a wrong person is more harmful to society than giving freedom to the accused”. One must be aware of the crime case of Jerome and Tyrone Copper or O.J. Simpson. In this case, the person was free due to lack of evidence, in the eye of the law, it is stated that ‘Innocent Until Proven Guilty’ is to protect the rights of a person who might be wrongfully detained. The accused in India are often granted some rights which include the right at the time of arrest, right at the time of trial, rights during search and seizure, and rights during the time of proceedings. The police have the authority to arrest any person under cognizable offense without going to the magistrate, therefore it becomes the duty of the court to check the reality of investigation to avoid the misuse of power by police or for any personal benefits. Arresting a person even under suspicion is considered illegal. Under the Code of Civil Criminal Procedure ‘Arrest’ is defined as ‘restriction of rights of a person.

The court stated that even though it says the restriction of right it is arrest is more precisely defined as ‘Restriction of Liberty’. A person who has been arrested has been allowed by law to ease their arrest and to give them a fair trial.

1)    Right to know the ground of arrest

Every police officer or the person who is arresting the person must communicate with the arrested person and tell them for which offense or other grounds they have been arrested. Our Constitution has also observed this status as a Fundamental Right which is defined in Article 22(1) which states that ‘No person who is arrested shall be detained in custody without being informed as soon as may be, of the ground for such arrest nor shall be denied the right to consult and to be defended by a legal practitioner of his choice[xvii]

In one case it is court observed as the right of a person to know his ground for arrest is his precious right, also the court stated that while stating a reason for arrest by police to the arrested person it is very much essential that person should communicate in their local language or languages that help them to understand the situation, for an instance a Maharashtra person arrested in West Bengal for a cognizable crime that the police officer they must tell the arrested person in their language of understanding if they say we communicate in Bengali language and the person is not aware of language then it is considered as wrong.

The right to information on the ground of arrest is recognized by Sections 50, 55, and 75 in the case where the arrest is made to obey a warrant of arrest or where the arrest is made by a police officer without a warrant[xviii].

The rules were made after the decisions in the case of Joginder Kumar v. State of U.P.[xix] and D.K. Basu v. the state of W.B.[xx]  refer to above have been enacted in section 50-A making it compulsory on the part of the police officer to inform the friends or relative of the arrested person about his arrest etc, and also make an entry in a register maintained by the police. The magistrate is also under an obligation to satisfy himself about the compliance of the police in this regard.

In a given case, Madhu Limaye members of Lok sabha, and a few other people were arrested. Madhu addressed the petition in the form of a letter to the Supreme Court under Article 32, that he and his companions were arrested but not communicated to know the grounds for arrest, they also raise the contention that as they were not communicated their fundamental right under Article 22(1) has been violated. From the above arguments the court grant bail to Madhu and other people on the sole ground given above.

2)Information regarding the right to be released on bail

In code of criminal procedure,1973 section 50(2) provides: where the police officer arrests without warrant any person other than a person accused of a non-bailable offense, he shall inform the person arrested that he is entitled to be released on bail and that he may arrange for sureties on his behalf[xxi].

The reason because a person is given bail is to perform speedy trials, it is said a person on bail has more freedom to prove his innocence than the same person if he remains in jail.

3)Rights Against Arbitrary Arrest

Section 49 of Cr.PC provides that there should be no more restraint than is justly necessary to prevent escape i.e. reasonable force should be used for the purpose, if necessary; but before keeping a person under any form of restraint there must be an arrest[xxii]. Restraint or detention without arrest is illegal. One must be aware of the case of Aryan Khan was his lawyer argued that the officers have detained Aryan unnecessarily.

4)Person arrested not to be detained more than 24 hours

One of the landmark cases in India for detection is Khatri v. the State of Bihar[xxiii], In this case, the court observed that it is a constitutional and legal requirement to produce in front of a Judicial Magistrate within 24 hours of arrest, so that the fundamental right should not be curtail. Sometimes police have given taking confessions or to take out some information they pressurize the arrested person thus to avoid such circumstances the above right is given to the arrested person.

The right to be brought before a magistrate within a period within 24 hours of arrest has been created with a view. (1) to prevent and detention to extract a confession, or as a means of compelling people to give information; (2) to prevent police stations being used as though they were prison a purpose for which they are unsuitable; (3) to afford an early recourse to a judicial officer independent of the police on all question of bail or discharge. If a police officer fails to produce the arrested person before a magistrate within 24 hours of the arrest, he shall be held guilty of wrongful detention.

5)Right to consult a legal practitioner

The right to counsel a lawyer to the accused arose from the very moment when he is arrested. The main doctrine of the judiciary is Free and Fair Trial for All. Article 22(1) of the Constitution provides that no person who is arrested shall be denied the right to consult a legal practitioner of his choice. Further Supreme Court held that the state must provide free legal aid to an accused person if he cannot hire a legal consultant. The legal aid is provided since the accused is produced in front of the magistrate for the first time, till the case has been resolved.

6) Right to be taken before a magistrate without delay

In both situations, whether the arrest is made without a warrant or under a warrant by a police officer or by anyone else, the person making the arrest must bring the arrested person before a judicial magistrate or, if a judicial magistrate is unavailable, any executive magistrate with such jurisdiction without delay. It is also stipulated that the detained person should not be held in any location other than a police station before being brought before the magistrate. These issues are covered under sections 56 and 76 of the Criminal Procedure Code of 1973, which are as follows:

Section 56- Person arrested to be taken before magistrate or officer in charge of the police station- A police officer who arrests without a warrant shall, without undue delay, take or send the person arrested before a magistrate with jurisdiction in the case, or before the officer in charge of a police station, subject to the provisions of this section regarding bail[xxiv].

Section 76- Person arrested to be brought before the court without delay- The police officer or other person executing the warrant of arrest shall (subject to the provisions of section 71 as to security) bring the person arrested before the court before which he is required by law to produce such person without undue delay: provided, however, that such delay shall not exceed 24 hours, exclusive of the time necessary for the journey from the place of arrest to the magistrate’s court[xxv].

Police Reform Bill

The Anti-Torture Bill was introduced in India in 2010, and it has been debated in parliament several times since then, but it has yet to be passed. Globally, it was first considered by the United Nations in 1975, and because India is a member of the UN, any UN law must apply to India as well. We need to have a law passed by the legislature. To make the UN Convention Against Torture of 1975 a law, a bill called the Prevention of Torture Bill 2010 was introduced in the Lok Sabha in 2010[xxvi]. As a result, if a public official tortures another person, he will face a penalty under this measure. This bill defines the term “torture” very broadly and simply, stating that if a public servant tortures a person to extract information or obtain a confession if he injures that person gravely or tortures his life, limb, or mental or physical well-being, then all of these things are considered torture and are prohibited by this act. The same will be punished with a ten-year sentence. After being cleared by the Lok Sabha, the bill is sent to the Rajya Sabha for additional examination before the Rajya Sabha Select Committee Suggestions Committee makes some recommendations for the bill. Comity proposes that the definition of torture is enlarged, that the punishment for every woman or child who has been tortured be increased, and that an independent authority be established to investigate all activities and offer all necessary compensation to the victims. After incorporating all of these suggestions, the bill was presented to the Rajya Sabha several times, but it has yet to be passed by the Rajya Sabha[xxvii]. In 2017, the Law Commission stated that they are seriously considering the bill, but that before passing it, Amendment should be done in the Indian Penal Code, Indian Evidence Act, and Criminal Procedure Act should be made.

Judicial Proceedings

The first case is Rudul Shah vs. the State of Bihar (1983)[xxviii], in which petitioner Rudul Shah was imprisoned for 14 years unjustly. His immediate release was asked in a habeas corpus writ. This decision is significant because it is the first time the Supreme Court has recognized that if a state violates an individual’s constitutional rights, the individual will be compensated. In Saheli vs Commissioner of Police (1989)[xxix], police and zamindar misbehaved with the rented mother and her 9-year-old child, resulting in the death of the 9-year-old youngster. The mother was compensated by the Supreme Court, which awarded her Rs 75,000. This case is significant because the Supreme Court offered the Delhi administration the option of recovering the money from the police officer who caused the incident. Suman Behera was arrested by police and her body was discovered the next day on a railway track with multiple injuries in the third case, Nilabati Behera Vs 1993[xxx] of Orissa. The petitioner was awarded Rs 1lakh 55 thousand in compensation, and we learned of this in the last two cases while granting compensation. Compensation is determined according to the circumstances of the case, however, in this case, the Supreme Court stated that it is the role of the state, not the police officers, to provide compensation. The next case is Joginder Singh vs State of Uttar Pradesh (1994)[xxxi], in which the Supreme Court stated that an arrest made without cause is invalid. According to the Supreme Court, police officers have the authority to make arrests, but they must have a reasonable reason for doing so. D.k. Basu versus State of West Bengal[xxxii], the most important case of custodial violence, was decided in 1997. Custodial violence and police torture were acknowledged by the Supreme Court in this instance, and the court stated that custodial violence constituted an attack on human dignity. In this case, the court stated that despite several recommendations and procedures, cases of torture and deaths in police custody continue to rise. In this case, there were a total of 11 standards that every police officer must follow while making an arrest. These guidelines and rights are available to every arrested person in the country.

  1. Whenever a police officer is handling an interrogation or an arrest, they must wear a name tag with their name and designation visible, and the police must keep a record of who is handling the case or interrogation.
  2. memo of arrest If a police officer arrests someone, they must save an arrest memo with all the information of the arrest, including the signature of any witnesses, the time, date, and location of the arrest.
  3. Arrested persons’ relatives or friends must be informed of their arrest, as well as where he has been imprisoned, and they must keep an official journal in which all records must be listed, such as which officer is managing the case and who has been told.
  4. Inspection Notes It should be mentioned if the arrestee has any severe or minor injuries. Both the officer and the arrestee would sign the inspection memo. A copy of the inspection memo will be given to the arrestee.
  5. Medical Examination After the person’s arrest, he should be medically examined every 48 hours and all of these records should be reviewed. 6. A copy of the medical report, inspection memo, and arrest memo will be given to the magistrate for their records.
  6. During the interrogation, the arrested person has the Right to meet with his lawyer.
  7. Every district and state headquarters should have a police control room where they may receive all information linked to an arrest within 12 hours of the arrest and show it on the Police Control Room board.


The Constitution of India has guaranteed, as a fundamental right to its citizens, protection against illegal interferences by another individual. As per the right to life and personal liberty, which is the most important right, deprivation of liberty could be possible only by resorting to the procedure established by law. Article 22 provides the safeguard to a person who has been deprived of his personal liberty by arrest and detention. Arrest and detention as a power exercisable by the State, which has the effect of making a direct in the road into the liberty of a person, ought to be exercised in accordance with the law. The Indian criminal justice system is sacrosanct and its principles are to be well within the parameters of and in consonance with the guarantees of the Constitution. It is the bounden duty of the State to explore ways and means to control crime and criminality within the constitutionally permissible parameters. The fact that the present criminal justice system has failed to curb the escalating crime rate is a pointer to the pressing need for the State to look beyond the old age law of arrest and detention and adopt a constitutionally viable and scientifically effective method to deal with both crime and criminals.

The Court in two landmark judgments i.e. Joginder Kumar and D.K Basu311 clarified that, apart from interpreting the Constitutions, by and large, in terms in consonance with the International Standard, additionally also provided various safeguards which were not even incorporated in the Indian law. This has proven to be the Court’s effort in fulfilling the aspiration of international norms. Sometimes, however, it is witnessed, that even the judiciary is depicting a double standard when on one hand it chooses to vouch for a procitizen approach while interpreting the Constitution, it speaks a tone favouring the State while dealing with the Criminal Procedure Code and the power of the State to arrest. Thus, although the role of the judiciary is pivotal in protecting the rights of a person, yet, instances of differences in the approach have been witnessed while analyzing various cases. The trends show that the judiciary itself is inconsistent in its approach.

Although giving separate directions for the arrest of some persons who are vulnerable is justified, because they are prone to be abused and there is a specific need of protecting their interests. There is, however, no such need of giving special privileges to public servants, by taking the plea of dignity and reputation of the office. Such an argument for such privileges would be against the constitutional guarantee of equality before the law. The Court providing special procedural requirements to special groups is an area of serious concern, as such classification would have the tendency of creating a rift inter-se the common and special people and the society would once again move to the concept of class-based society. Thus, the suggestion, that instead of carving out exceptions, a common norm and procedure applicable to all should be put in place. Alternatively, the special norms could be stretched to one and all, regardless of one’s post, position, etc.

[i] Smitha TK, TN Alleged Police Custodial Murder: “Clothes Were Soaked in Blood” TheQuint (2020), https://www.thequint.com/news/india/custodial-death-tamil-nadu-sathankulam-thoothukudi-police-brutality-jayaraj (last visited Nov 19, 2021)

[ii] How George Floyd Was Killed in Police Custody (Published 2020), The New York Times, 2021, https://www.nytimes.com/2020/05/31/us/george-floyd-investigation.html (last visited Nov 19, 2021)

[iii] Conference Report Strengthening Legal Protection Against Torture in India, (last visited Nov 19, 2021)

[iv] idts

[v] Mana Stars, Singer Suchitra Emotional About Jayaraj and Fenix Issue | Manastars YouTube (2020), https://www.youtube.com/watch?v=bl13BFI-g_s&t=17s (last visited Nov 19, 2021)‌

[vi] Vital Stats, PRS Legislative Research (2021), https://prsindia.org/policy/vital-stats/pendency-cases-judiciary (last visited Nov 19, 2021)

[vii] “Bound by Brotherhood” India’s Failure to End Killings in Police Custody,‌(last visited Nov 19, 2021)

[viii] Constitution of India, Article 14

[ix] Report of the Expert Committee on Legal Aid: Processual Justice to the People, Government of India, Ministry of Law, Justice and Company Affairs, 10 (1973)

[x] S. Murlidhar, Law, Poverty and Legal Aid: Access to Criminal Justice, 1, 2004, at page 79

[xi] S. Murlidhar, Law, Poverty and Legal Aid: Access to Criminal Justice, 1, 2004, at page 79 at page 80

[xii] Constitution of India, Article 14, Article 21

[xiii] Constitution of India, Article 14, Article 21

[xiv] Constitution of India, Article 14, Article 21, Article 38

[xv] Constitution (Forty-Second Amendment Act), 1976

[xvi] S. Murlidhar, Law, Poverty and Legal Aid: Access to Criminal Justice, 1, 2004, at page 78

[xvii] Constitution of India, Article 21

[xviii] The Code of Criminal Procedure 1973, Section 50, section 55, Section 75

[xix] 1994 SCC (4) 260

[xx] AIR 1997 SC 610

[xxi] The Code of Criminal Procedure 1973, Section 50 (2)

[xxii] The Code of Criminal Procedure 1973, Section 49

[xxiii] 1981 SCC (1) 627

[xxiv] The Code of Criminal Procedure 1973, Section 56

[xxv] The Code of Criminal Procedure 1973, Section 76

[xxvi] LAW COMMISSION OF INDIA Implementation of “United Nations Convention against Torture and other Cruel, Inhuman and Degrading Treatment or Punishment” through Legislation, (2017), (last visited Nov 19, 2021)

[xxvii] Idts

[xxviii] 1983 SCR (3) 508

[xxix] 1990 AIR 513

[xxx] 1993 AIR 1960

[xxxi] 1994 SCC (4) 260

[xxxii] (1997) 1 SCC  416

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