This article has been written by Indrasish Majumdar an intern at LawSikho. The article has been edited by Ruchika Mohapatra (Associate, LawSikho) and Arundhati Das (Intern at LawSikho).
This article has been published by Shoronya Banerjee.
Understanding Section 313 of CrPC : meaning and interpretation
Section 313 of the Criminal Procedure Code, 1973 bestows upon the court, the power to examine the accused with respect to the evidence which has been produced against him. This is in line with principles of natural justice i.e. ‘Audi Alteram Partem.’ The section also embodies the basic principle of fair trial to the accused. The statement, however, cannot be solely used for the conviction of the accused or to give him any advantage whatsoever. The statement taken by the accused is recorded without administering any oath and hence, cannot be used as evidence. Further, the accused can also not be cross-examined.
The term ‘evidence’ as used in the section is not defined anywhere in the Code. It is defined in the Indian Evidence Act. Usage of the word ‘may’ in Section 313(a) reveals how the accused cannot raise any concern even if the former decides not to question him. However, the presence of the word ‘shall’ in Section 313(b) suggests that the questioning of the accused is mandatory after the witnesses have been examined and that the absence of the same would result in the violation of the rights of the accused. Therefore, the focus should be on inviting the attention of the accused onto each and every piece of evidence that has the potential of being used against him and giving him the due chance to provide an explanation for the same. Questions posed to the accused must be fair, reasonable, and should be easily understandable.
Further, the questions asked must relate to the whole case and not to a specific part as such. The answers given by the accused cannot be the sole basis of his punishment, they can only be used to appreciate the prosecution evidence. Additionally, Section 313(5) also provides the accused a chance to file a written statement as sufficient compliance with the section.
Sometimes, it so happens that the Appellate Court discovers later that a significant question that was vital from the case’s viewpoint was missed out in the first place. The omission of the same would not by itself, nullify the order of the court. The court should rather try to come up with a remedy that would correct the order. Further, it is the responsibility of the Court to bring before the accused, all such facts and circumstances, which can be used against him. Notifying such facts and circumstances to the accused is not a mere formality but also an embodiment of a vital principle of natural justice.
Scope and objectives of Section 313 of CrPC
The fundamental objective of the section is to provide the accused a fair opportunity of being heard. Often, the accused either turns out to be an illiterate person or someone who is not completely aware of his right to a fair trial. Therefore, as reflected by the verbatim, “for the purpose of enabling the accused personally to explain any circumstances appearing in the evidence against him”. As such, the most important aim behind introducing the section is to establish a link between the accused and the court.
Further, in case the lower court fails in providing the accused with an apt opportunity to furnish an explanation, the higher court can, under such circumstances, deny the validity of the question. Further, the presence of the word ‘generally’ in Section 313(1) (b) does not narrow down the scope of the section to a particular number of questions or to a certain nature of questions. The questions should relate to the whole case or any specific part if required. Such questions should also carry an explanation if needed, so as to enable the accused to understand them better. In cases of multiple witnesses, the court is not required to pose a separate question from each witness. The court may club the statements of each of these witnesses and form one question. Most importantly, it must be notified to the accused that his statements can be used against him in the Trial Court. As such, he should be made aware of the same.
There are cases wherein the accused, owing to his exigent conditions, fails to remain physically present before the Trial Court in order to answer the questions. In such cases, an application has to be filed before the Court with an affidavit confirming the following points:-
I. Facts that explain his reason for not being able to be physically present before the court.
ii. An assurance from the side of the accused that in the given circumstances, no harm would be caused to him.
iii. An undertaking that obliges him to the final decision of the court and that he would not question the same.
Therefore, given the series of events and happenings over the year, Section 313 has witnessed evolution. The primary interest of the section lies in updating the accused with every piece of evidence which can be used against him. Hence, it is made for the benefit of the accused to allow him to justify himself before the court.
The Code requires the Trial Court to assess and examine the case as a whole. Only such information and circumstances that have been made aware of the accused can be used against him for the purpose of trial and not any other piece of information. As such, evidently, the section is meant for the bestowing upon the accused, the proper opportunity of a fair trial.
Procedure envisaged under the Section : point of relevance
From a general reading of Section 313(1) of the Code, it can be interpreted that the court had power or discretion at any stage of inquiry to question the accused without giving any warning previously. The discretion/power can be seen by the use of the term “may” in the sub-clause (a), while sub-clause (b) makes the question to the accused mandatory as it uses the word “shall” in it.
Section 313(3) suggests that it will not make the accused liable, if the accused is not giving answers or if the accused gives false answers to the question asked by the court under said provisions. The answers given during examination of accused under subsection (1) may be put in evidence and taken into consideration, that the evidence can be any for the accused or against the accused, for the inquiry or for the trial, for the offence which tends to show by the answers of accused.
While questioning the accused, there should be no scope of ambiguity left i.e. the question should be formed clear, logical, and understandable. While examining the accused, the socio-economic and academic qualification and capacity of understanding the question of the accused must be considered by the court. The Trial Court must take a higher degree of care while examining illiterate and rustic defendants.
“The incriminating material is to be put to the accused so that the accused gets a fair chance to defend himself. This is in recognition of the principles of Audi Alteram Partem.” The purpose of the section is to give a chance to the accused person for explaining any incriminating circumstance made against him and to prove his innocence. Hence, the procedure must be followed so that the purpose and object of the section get served. Section 313 of CrPC nowhere provides the manner in which the accused shall be examined. Nevertheless, the Apex Court has always been of the view that the trial courts have to look after each and every pertinent material state of affair which appear as evidence against the accused, so as to enable the accused to defend any situation disclosed in the evidence and let the accused describe what the accused wants to say with respect to the case of the prosecution. Each material circumstance that is meant to be used against him must be questioned individually to the accused. The questions must be formed in such a fair way that they can be easily appreciated and understood by even illiterate or ignorant people.
Thus, it can be concluded that Section 313 is a bridge for establishing a direct conversation between the accused and the court for the purpose of enabling the accused to explain all the circumstances put forward to him and it, for a point of time put aside all counsels, witnesses, prosecutors and all other persons related to the case.
Under Section 313 the following things need to be considered while examining the accused
1. The statements given under this section do not have evidentiary value. Accused is not entitled to punishment even if he has given a false answer to the questions.
2. Accused has the right to remain silent and cannot be compelled to speak. Accused is free to answer or refuse to answer the question asked.
3. Language of Section 313 of CrPC is easily comprehensible so that it leaves no place for misapprehension for the purpose of the section.
4. The scope and purpose of the question to be asked is limited i.e. the object of the section is to enable the accused to explain the circumstances that are being used against him as evidence. There is a statutory obligation on courts to put forward questions to the accused while the accused do not have any obligation to answer them.
5. While questioning the accused any point that is incriminating or significant which can result in injustice or prejudice shall not be left out. Any such point cannot be used against the accused if it is left out while questioning.
6. While examining the deaf and dumb accused proper care has to be taken. The court is duty-bound to take the help of an interpreter or someone who can comprehend the signs of the accused for knowing the criminal nature of the act done by the accused, whether the accused is deaf or mute.
In-depth analysis of Section 313
While it is true that in the past few years, the right of the accused to a speedy and fair trial has gained due popularity, the overall awareness regarding creating better conditions for the accused which allows him to be examined in a reasonable ambiance still remains under question. Unfortunately, the attention gathered for creating rights of the accused has only attracted ‘sporadic attention’ from the judiciary as well as the Parliament. Keeping in mind the miscarriage of justice that takes place, the Supreme Court has laid down that a balance ought to be drawn between the prerogative of the prosecution and the rights of the accused.
Right to silence : a gray area in criminal jurisprudence
“Right to silence” as enumerated in Section 313 of CrPC authorizes courts to question the implicated or witnesses on incriminating circumstances arising in the course of investigation whether it be in his favor or against. Section 313(2) affirms that the accused is not obligated to administer an oath when making statements under the particular section. Therefore, he/she cannot be held liable for any comments made under Section 313. The section while aiding the accused, by providing him/her with an opportunity to accept or reject with a suitable explanation any incriminating evidence before it is held against him in the court of law also states the answers given may be considered by the court as evidence, if the prosecution is himself able to make a convincing case, and the right of accused is not infringed under Article 20(3). Therefore, the accused should nonetheless be cautious of what he is stating and remain silent if he/she believes the evidence might incriminate him.
Enshrined under Article 20(3) of the Constitution of India, the Right often gets diluted by the ratio enunciated in the judgment (Prahlad v State of Rajasthan), which preserves the right of the accused against self-incrimination. Right to silence is an important constitutional right recognized by the judiciaries in most countries. The following segment of the article in addition to outlining judicial interpretations of Section 313 adjudges the applicability and legality of such a practice in light of the legislative intent of its framers.
Prahlad v. State of Rajasthan
In a recent Supreme Court judgment, Prahlad v. State of Rajasthan, dated 14/12/2018, a murder conviction was upheld because of the defendants’ inability to provide an explanation for the incriminating pieces of evidence against him. In this case, an eight-year-old girl was raped and murdered. In this case, the accused was proclaimed a person who had purchased sweets for her from a sweet shop. After which the victim was not seen. The assaulted and mutilated body of the girl was discovered the day after she was last seen at the sweet shop. The Sessions Court framed charges under Section 302 of the IPC (Indian Penal Code) and Section 4 of the POCSO Act against the accused. While the conviction was upheld by the trial court and High court the Apex court relieved him of charges under the POCSO due to insufficient evidence but held him guilty of murder under Section 302. Conviction, in this case, was based primarily on inferences deduced from the inability of the accused to suitably explain the incriminating circumstances. However, convicting someone based on his silence abrogates the right of the accused under Article 20(3) of the Indian Constitution reading “No accused person can be compelled to be a witness against himself”. The judgment paves way for a precedent of convicting accused on adverse inferences from their silence under Section 313 of CrPC.
Deducing adverse inferences (the jurisprudential perspective)
Deducing adverse inferences against the accused’s silence, while interrogating under Section 313, has been deliberated in many cases by the Apex Court on several occasions The conflict with respect to the “right to silence” in addition to jeopardising the right of the accused in getting proper justice, obstructs the performance of law enforcers in applying the law and pronouncing judgment. The court has been vacillating in its stance with respect to allowing adverse inferences to be deduced or not from the silence of the accused. In Ramnaresh and ors. v. The State of Chattisgarh it was dictated the court was allowed to deduce inferences, adverse or otherwise from the silence of the accused as long as the evidence was admissible in law. The court was allowed to base inferences in favor of or against the accused on the basis of such statements. The “right to silence” enumerated under Article 20(3) is not vitiated in the process the court ruled. In Munish Mubar v. the State of Haryana, it was made obligatory for the accused to answer implicating circumstances associated with himself, irrespective of whether it could pave way for adverse inferences to be derived with respect to him/her.
The Apex Court in Barendra Singh v. The State of M.P held that inferences adverse in nature from the accused’s silence may be used for corroborating him in further trial by the prosecution, even if it cannot be used against him per se in the same case, it can be used in any other trial. In Raj Kumar Singh and Raju v. State of Rajasthan, the court prescribed “an adverse inference can be taken against the accused only if the incriminating material stood fully established and the accused is not able to furnish any explanation for the same.” However, the Prahlad judgment overruled the dictum in Raj Kumar Singh by stating adverse statements may be relied upon to the extent of convicting the accused.
Article 20(3) of the Indian Constitution reads “no person can be compelled to be a witness against himself”, subsuming “the right against self-incrimination”. Three conditions apply with respect to this right:
1) presumed innocence of the accused,
2) the onus of establishing guilt is on prosecution,
3) the accused is not being coerced into making testimonies against his/her will.
However, the Prahlad judgment stated, while the accused is allowed to remain silent, if the same extends to any incriminating circumstances, adverse inferences may be deduced. The conflict between Section 313 and Article 20(3) of the Indian Constitution is apparent, wherein it is the prosecution who is supposed to establish the guilt of the accused by facts. Convicting on the basis of his/her statements is against due process, and hampers the administration of justice for law enforcers in addition to violating the fundamental right guaranteed under Article 20(3).
Legislative intent behind Section 313
The legislative intent behind drawing adverse inferences may be established by contrasting Section 313 of Crpc with Section 342 of the code of 1898. As Section 342(2) of the 1898 code states “The accused shall not render himself liable to punishment by refusing to answer questions or by giving false answers to them, but the court and the jury (if any) may draw such inference from such refusal or answers as it thinks fit.” “Section 313” enacted in 1972 omits the later part of Section 342 of 1898 Code, ”The accused shall not render himself liable to punishment by refusing to answer such questions, or by giving false answers to them”. As is implicit, framers of the 1972 code did not envisage the drawing of inferences against the silence of the accused with respect to any incriminating evidence. The intention was further clarified post ratification of “Part 3 of Article 20.”
D.D Basu, discussing the dissenting opinion in the case of Adamson v. California mentioned “if you cannot compel an accused to make a statement against himself, you cannot draw any inference against him because he remains silent, since that would obviously oblige him to speak, rather than remain silent.”He additionally stated deducing adverse inferences on an individual’s reluctance to testify, is equivalent to punishing that person for wanting to exercise his rights under Article 20(3). It can therefore be stated that the legislative intent of the proviso was not directed towards the law enforcers or the accused to be affected since the same would be intransigent to the fundamental right of the accused enshrined under Article 20(3).
Validity of the right to silence
The Indian judiciary embodies due process and the theory of due process is grounded on beliefs of liberalism. Therefore, the judicial machinery, while adhering to due process, assents to follow principles of liberalism along with. The Prahlad case showcases instances where the court has deviated from its stance. It needs to be noted that Section 313 and Article 20(3) were enacted with an objective to give the accused a chance to answer incriminating circumstances which can be used against him.
The court is, therefore, allowed to deduce inferences only from answers provided with respect to the incriminating circumstances and not his silence. Deducing adverse inferences from the silence of the accused countermands rationale behind not administering an oath to the accused while making statements under Section 313. Ensuring the accused is not governed by fear of perjury when delivering his account of the case. The mechanism of drawing adverse inferences taints the reliability and the validity of the statements made under the proviso, rendering it ineffective to be considered as evidence under Section 3 of the Indian Evidence Act.
The constitutional guarantee as provided in Article 20(3) underpins the “right to silence” of the accused. Drawing adverse inferences irrespective would contravene Article 20(3) and constitute testimonial compulsion. The judiciary should acknowledge the “right to silence” for an unrestricted right as part and parcel of “the right to free trial (Article 21)” and in-process establish its rarity in the field of criminal law.
The Supreme Court in a recent judgment delivered on 26thAugust 2019, considered the rights of the accused under Section 313 of the Code of Criminal Procedure. In Samsul Alam v. State of Assam, the appellant’s conviction of murder was upheld by the Gauhati High Court. However, when questioning the accused under Section 313, only two questions were put to him, as noted by the Apex Court. The same was noted perfunctory by the Supreme Court. It is under the principle of “audi alteram partem”, the right to be heard. The accused was acquitted taking into consideration the hasty manner in which the statements under the section were recorded.
In Shivaji Sabarao Bobade v. The State of Maharashtra, a three-judge bench of the Apex Court deliberated on the consequences of omitting certain incriminating evidence against the accused before him. The Supreme Court cautioned by stating: “The cherished principles of the golden thread of proof beyond reasonable doubt which runs through the web of our law should not be stretched morbidly to encompass every hunch, hesitancy, and degree of doubt. The excessive solicitude reflected in the attitude that a thousand guilty men may go out, but one innocent martyr shall not suffer is a false dilemma. An only reasonable doubt may be attributed to the accused. Otherwise, any practical system of justice will break down and lose credibility with the community.”
The Court commented in case it finds the prosecution had failed to examine the witnesses for reasons not tenable or proper, the court may be justified in deducing adverse inferences against the prosecution. The bench held it was fundamental and in furtherance to the right to a fair trial that the attention of the prisoner is drawn to, every incriminating or inculpating material against him, so as to provide him with an opportunity to explain it.
In Ashraf Ali v. State of Assam, the Court deliberated on the objective of Section 313. It stated the objective of Section 313 was to initiate a dialogue between the court and the accused. It is proper and logical to question the accused about a point of evidence if it is an important piece of information against the accused, and his/her conviction is to be based on the same.
The objective and purpose of Section 313 are to preserve the rights of the accused under Article 20(3) of the Constitution, dictated by the court while referring to the 1898 CrPC where a similar provision had been subsumed under Section 342. The court mooted the “Sixth Amendment to the United States Constitution” which laid down the rights to accused as under Section 313, the right to be informed on the nature and cause of accusation. The court stressed the importance of the examination of the accused to take place in proper form and manner. An evasive answer the court stated to a question concerning a fact adduced in evidence might aid the court in appreciating the evidence better.
It can be deduced from the ratio of the above-mentioned cases, Section 313 is a statutory provision deeply rooted in the criminal justice machinery. The section enables the accused to speak honestly with “impunity”, as proviso (2) of the section allows the statement to be recorded without administering the oath, therefore the accused is saved from making him liable by proffering false answers. Therefore, unless the prosecution demonstrates beyond reasonable doubt that the statements of the accused are fabricated, the version of the accused in his statement should be accepted by the court. The section bestows on the trial court a strenuous duty to place before the accused each and every inculpatory material available against him appearing in evidence, failing which the trial process would be vitiated. The section aids the court in going a long way to realize its objective of ascertaining the truth, which is fundamentally the guiding principle of India’s criminal justice mechanism. Some more judgments are presented in detail:-
1. Samsul Haque v. The State of Assam
The Supreme Court considered the rights of the accused enshrined under Section 313 and stated that the implicative material is to be put to the accused so that the accused gets a fair chance to defend himself. This is in recognition of the principles of audi alteram partem.
Several people (A 1-9) were accused of murdering a person. The sessions judge concluded that A1, A5, and A6 were proven guilty beyond doubt and the rest were acquitted. Further, during the trial, only two questions were put in the said statement. The convicts filed an appeal before the Gauhati High Court. The appeal of the convicted accused was dismissed by the High Court, thus, that matter attained finality.
The title of Section 313 of CrPC suggests that it was drafted in order to empower the court to examine the accused. However, the section in essence is not limited to power but is also a duty cast upon the court to indulge in an inquiry to enable the accused to elaborate and explain the circumstances appearing in the evidence against him. Each object and material that is presented as evidence against the accused shall be put to him specifically, distinctly, and separately and failure to do so amounts to a serious irregularity vitiating trial if it results in prejudice to the accused.
Hon’ble Justice Sanjay Kishan Kaul in his judgment said that “The object of Section 313 of the CrPC is to establish a direct dialogue between the Court and the accused. If a point in the evidence is important against the accused, and the conviction is intended to be based upon it, it is right and proper that the accused should be questioned about the matter and be given an opportunity of explaining it.”
The questions put by the court shall put forward conclusive conservation which ensures that all the facts and circumstances are taken on the note. Therefore, when a court fails to put any specific question on an inculpatory material in the prosecution evidence, it dismisses any chance of refuting the materiality of the evidence. In furtherance, this causes a miscarriage of justice. Furthermore, the recording of a statement of the accused under Section 313 is not a purposeless exercise.
2. Sharad Birdichand Sarda v. State of Maharashtra
“If the circumstances are not put to the Accused in his statement under Section 313 of the Code of Criminal Procedure, they must be completely excluded from consideration because the Accused did not have any chance to explain them.”
A woman was found dead in her home. Two theories were raised regarding her death. The first one was that she gave up on the torture of her in-laws and committed suicide. The second, that her husband had an extra-marital affair and to make way for the same, he murdered his wife.
Both the High Court and the Trial Court rejected the theory of suicide and found that Manju was murdered by her husband. The High Court took note of 17 circumstances that in consequence contributed to a conclusion that the evidence produced by the prosecution was complete and conclusive. However, the value and relevance of the evidence itself were in question when an appeal was made before the Apex Court.
The foundation of the said decision by both the courts was the circumstantial evidence. There is a threat to the value of the said evidence, as it was deemed to be inconsistent with Section 313 of the CrPC. It was held that many of the circumstances put forward were irrelevant and rather overlapped with each other. Further, even the ones that were exclusively relevant and vital to the conclusions drawn were not in consonance with Section 313 of CrPC. Thus, they cannot be taken into consideration. If the evidence was not brought in front of the accused, it dismissed the chance of the accused nullifying or countering it with a fresh set of circumstances or reasoning.
Various pieces of evidence were used to prove the ill-treatment of the deceased, however, none of them were brought to question, which eliminated the possibility of a dialogue that CrPC prescribed through Section 313. No questions were put to the appellant in this regard in the course of his examination under Section 353 of CrPC even if there is any evidence about any ill-treatment of the deceased by the appellant or his parents it was completely excluded from consideration.
3. Ashraf Ali v. State of Assam
A man was accused of Section 304 of the Indian Penal Code and the accused placed the plea of alibi. The alibi was rejected and subsequently was put to 10 years of rigorous imprisonment. The learned judge of the High Court reduced the sentence to 5 years. However, the High Court in its examination found that the evidence and circumstances that formed the base of the prosecution case had not been specifically placed before the accused. It was also noted that the Trial Court faltered in its duty in the examination.
However, the High Court felt that no material prejudice was caused to the accused as he was found to be absconding for a long time. Therefore, the matter came in front of the Supreme Court in finality.
As per the s. 313 of CrPC it is fundamental that an accused is made aware of each detail that puts him behind the bars. This does not extend to a formality that can be sufficed by a questionnaire, but the courts need to take care that the accused knows and understands everything that has been leveled against him. The absence of such information or knowledge regarding the information may gravely imperil the validity of the trial itself.
Principles laid down
1. Reena Hazarika v. State of Assam
The solemn duty that is upon the courts is to dispense justice after adequately considering the defence of the accused and the attempt at refuting the evidence and circumstances put forth against him under Section 313 of the CrPC and to either accept or reject the same for the reasons specified in writing.
2. Shamu Balu Chaugule v. State of Maharashtra
3. S. Harnam Singh v. The State
Not indicating the inculpatory material in its relevant facets by the court to the accused shall add to the vulnerability of the prosecution case. This shall also be noted by the courts as the recording of a statement of the accused under Section 313 is not a purposeless exercise.
4. Sujit Biswas v. State of Assam
The very purpose of examining the accused under Section 313 of the Code of Criminal Procedure is to meet the requirement of the principles of natural justice, i.e., audi alteram partem.
With the changing structures of institutional motives and a continuous variation of power dynamics, it becomes necessary to highlight the powers of the court and distinguish them from the rights of the accused. Section 313 of CrPC is one such section that does both and is integral to the criminal procedure. In the pretext, while examining the section, the linguistics suggests that it is limited to the inherent power of the court to question the suspect, however through a layered understanding which is also based upon certain judgments from the Apex Court, one can understand the underlying conscience of the principles of fair chance and right to be heard in a courtroom.
The section is a balance between the power of the court to examine the evidence themselves and hold it up against the accused along with the opportunity given to the accused to explain himself and put a defence. The attempt to strike a perfect balance is difficult with the scope of the law and its subjects changing with time. Therefore, with the evolution of laws, certain grey areas were identified. The insouciant conflict with the accused’s right to remain silent also gradually caught attention. Additionally, in the process of expanding analysis, it was noticed that there have been instances where there was an adverse effect of the statements made and conclusions brought upon in the scope of Section 313.
The pillar of judicial thought that brings clarity, as well as perspective to the bare text of the law, was consistent with regards to Section 313 where it stated across various judgments that the value of evidence exhausts if it is not scrutinised by a magistrate and brought before the accused. The right to refuse the given evidence, and form a conversation that has the capability of bringing out meaningful conclusions irrespective of the conditions and literacy of the accused is undeniable. Therefore, it can be concluded that Section 313 of CrPC is a provision that aids the principles of a fair trial by giving the opportunity to the accused to ascertain the value, conditions, and circumstances lying beside any evidence. The section is of great importance and is one of the pillars that support the desire for equity in judicial scrutiny.
- Sabhori Kumari, ‘Examination of Accused under Section 313’ <https://districts.ecourts.gov.in/sites/default/files/workshopscjrajam.pdf> accessed 14 March 2020
- Govt. of India, ‘Analyzing Section 313 of CrPC’ (2013) <http://mja.gov.in/Site/Upload/GR/Title%20NO.202(As%20Per%20Workshop%20List%20title%20no202%20pdf).pdf> accessed 15 March 2020
- Singh, Aishwarya Pratap, Inquisitorial Powers of the Court in Adversarial System: A Bird’s Eye View (February 6, 2018). http://dx.doi.org/10.2139/ssrn.3118880 accessed on 12 March 2020.
- Indian Legal Services, ‘Defense of the accused Under Sec.313’ <http://www.legalservicesindia.com/law/article/1099/5/-Defence-of-The-Accused-U-s-313-CrPC;-Non-Consideration-Can-Vitiate-Conviction> accessed 20 March 2020
- Chetan Lokur, ‘Section 313 CrPC, Audi Alteram Partem, and the Rights of the Accused’ (Bar and Bench, 7 October, 2019) < https://www.barandbench.com/columns/section-313-crpc-audi-alteram-partem-and-the-rights-of-the-accused> accessed on 24 Mar 2020
- DD Basu, ‘Commentary on the Constitution of India’ (9th Edition, 2002) vol 2 (derived from the 180thLaw Commission Report).
- R.V Kelkar’s, Criminal Procedure (first published 1977, EBC)
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