This article is written by Ritika Sharma pursuing  B.Com LLB (Hons.) from the University Institute of Legal Studies, Panjab University. This article discusses the essential elements, concepts and exceptions to the offence of defamation and lists down 10 landmark cases which highlight and interpret the exhaustive definition highlighted under Section 499 of the Indian Penal Code.

It has been published by Rachit Garg.

Table of Contents


Reputation forms an intrinsic part of everyone’s life. People care about their honour and name like they care about their life. In the case of Subramanian Swamy v. Union of India (2016), the constitutional validity of the offence of criminal defamation was challenged but the Supreme Court observed that the right to reputation is protected under Article 21 of the Constitution of India, 1950. Defamation under the Indian Penal Code, 1860 refers to attacking another person’s reputation by making or publishing defamatory statements against them. It could be libel or slander. Libel is defamation in some permanent form such as written, printed, etc., and slander is defamation through spoken words or gestures.

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Offence of defamation

Sections 499, 500, 501 and 502 of the Indian Penal Code, 1860 contain the provisions regarding the offence of defamation. Section 499 lays down a comprehensive definition of defamation and its exceptions. According to these provisions, the three essentials of the offence are as follows:

  • Making or publication of imputation: An imputation regarding any person has been made or published. It could be either libel or slander. When the statement consists of words or gestures, then it is called slander, while when these are in permanent form, they are called libel.
  • Means of imputation: The imputation should have been made via words, writing, signs or visible representations. Editors, printers, publishers and distributors could be made liable for the offence of defamation. However, if the editor of a newspaper can avoid the charge of defamation against him/her by proving that libel was published without their knowledge and in their absence. 
  • Intention of harming the reputation: There should be the presence of intention of harming the reputation of another person. Reputation refers to the opinion of others about a person. The imputation should be made with the intention of lowering the moral or intellect of a person in the eyes of society. The presence of mens rea is sine qua non of the offence of defamation. 


There are 4 explanations with Section 499 to make it lucid as to what constitutes defamation: 

  • Defamation of the dead: The Section covers the offence of defamation against a dead person also provided that the imputation is both defamatory to the deceased and hurtful to his/her relatives.
  • Defamation of a company or collection of persons: An offence of defamation against any corporation could be made out when the words accuse it of mismanagement or fraud in its dealings.
  • Defamation by innuendo: Sometimes the words in their literal sense appear to be non-defamatory, but there is hidden sarcasm which intends to harm the reputation. This also constitutes defamation.
  • Meaning of harming reputation: Explanation 4 to Section 499 lays down that it refers to lowering the moral or intellect of a person. Also, harming someone’s reputation by calling them of a lower caste or lowering their credit would be included in the offence.


Section 499 contains some exceptions which allow people to speak, write, or publish words that otherwise would be considered defamatory. There are 10 exceptions under which defamatory material can be excused. Following are the exceptions:

Truth for the public good

If a true statement has been made or published for the public good, then it will not amount to the offence of defamation. It is pertinent to note that the truth of the statement need not be proved literally, but it must be substantially true.

Public conduct of public servants

Under this exception, opinions are protected if they are made against public servants in their public duties. Therefore, any fair criticism or comments have been immunised if made with good faith, i.e., they should be made without carelessness or negligence. This exception preserves the principle of rule of law which is pivotal to democratic countries.

Conduct of any person touching any public question

When any statement is made in good faith regarding any public question, it is protected under the third exception. For example, in the case of Jawaharlal Darda v. Manoharrao Ganpatrao Kapiskar (1998), a publisher, who published a statement against a minister regarding the misappropriation of government money, was held not guilty of the offence of defamation. 

Reports of proceedings of courts

Publication of the reports which highlight the proceedings of the court will not amount to the offence of defamation. The explanation of the fourth exception enunciates the definition of a court. It states, “a Justice of the Peace or other officer holding an enquiry in open court preliminary to a trial in a Court of Justice, is a court.” The report should be fair and should not only reflect one side of the proceedings and create any kind of bias in the minds of the readers. 

Comments on cases

Comments or opinions on the merits of the case are not considered defamatory if they are made in good faith while respecting the conduct of parties, witnesses, or agents. For instance, A says, “I think Z’s evidence on that trial is so contradictory that he must be stupid or dishonest.” A is within this exception if he says this is in good faith, in as much as the opinion which he expresses respects Z’s character as it appears in Z’s conduct as a witness and no further. 

Opinion on any public performance

The sixth exception protects the opinions on the merits of performances that the performer has submitted for the comments of the society. However, the opinion should be made with respect to the character in the performance and should be in good faith. For example, if A says, “I am not surprised that Z’s book is foolish and indecent, for he is a weak man and a libertine.” A is not within this exception, inasmuch as the opinion which he expresses of Z’s character is an opinion and not founded on Z’s book. Further the explanation appended to this exception states, “a performance may be submitted to the judgement of the public expressly or by acts on the part of the author which imply such submission to the judgement of the public.” For instance, a person who makes a speech in public submits that speech to the judgement of the public. 

Censure by the person in authority

Censure passed by a person in authority is included within the exceptions if the following conditions are fulfilled:

  • Person is in authority over other via law or by means of any lawful contract and
  • Censure is passed in good faith and
  • Censure relates to the matters to which the lawful authority relates.

Accusation in good faith to authorised person

If an accusation is made against any person in good faith, then it does not amount to defamation when the person making the  accusation has lawful authority over the other, that is, the authority should have some jurisdiction in the matter. For instance, if A in good faith accuses Z before a Magistrate then it will be exempted under this part. 

Imputation for protection of interests

When imputation is made in good faith for the protection of the interests of the person who is making it or for any third party or in general public good, then it will not amount to the offence of defamation. For example, A, a Magistrate, in making a report to his own superior officer, casts an imputation on the character of Z. Here if the imputation is made in good faith and for the public good, A is within the exception. 

Conveying caution in good faith

The last exception says that if a caution is conveyed for the good of another person or for the public good, then that caution communicated in good faith is covered under the exceptions. The burden of proof is on the person conveying the caution that it is made in good faith and for the public good.  

Punishment for defamation

Sections 500, 501 and 502 stipulate the punishment for the offence of defamation. According to these provisions, the following offences are punished with simple imprisonment for a term which may extend to 2 years or with fine or with both:

  • Defaming another person
  • Printing or engraving matter known to be defamatory
  • Sale of printed or engraved substances containing defamatory matter.

Landmark defamation cases in India

Subramanian Swamy v. Union of India, Min. of Law (2016)

In this case, the constitutional validity of the offence of defamation under Sections 499 and 500 of the Indian Penal Code,1860 was challenged against the right to freedom of speech and expression, but the Supreme Court upheld the validity of these provisions.

Facts of the case

A writ petition under Article 32 of the Indian Constitution was filed which challenged the constitutional vires of the offence of defamation under the Indian Penal Code. The petitioners contended that the offence of defamation breaches the right to free speech and expression under Article 19(1)(a) of the Indian Constitution. 

Contentions of the petitioners

  • The petitioners submitted that the right to freedom of speech and expression is an integral part of democracy and carries constitutional significance and is a part of the basic structure of the Indian Constitution.
  • The right ensured under Article 19(1)(a) is of utmost importance and has priority over other rights, therefore, in case of conflicts, the right to free speech and expression is not to be curtailed unless it hinders the community interest.
  • The reasonable restrictions provided under Article 19(2) of the Constitution protects the interest of the general public and not any individual. Thus, Section 499 of the Indian Penal Code cannot be granted protection under this constitutional provision. 
  • As Article 19(2) is an exception to Article 19(1)(a) of the Constitution, it cannot be liberally construed and its ambit cannot be widened.
  • The concept behind the test of reasonable restriction is that if the restriction infringes the fundamental right in an excessive manner, then it cannot pass the test of reasonableness. Moreover, restrictions should be reasonable in substance and procedure, and the procedure for complaints for the offence of defamation does not pass the test of reasonableness.
  • Explanation IV to Section 499 of the Indian Penal Code provides a wide ambit for the offence of defamation, and it allows a greater width and ambit without any guidance, hence it is arbitrary.

Contentions of the respondent

  • Respondents, while highlighting the importance of the right to reputation, submitted that it is an integral part of the right to life protected under Article 21 of the Indian Constitution. Also, it is an inseparable element of a person’s personality that cannot be overlooked.
  • Article 19(2) is to be read as a part of speech and expression as it cannot be considered as an absolute right. Thus, the offence of defamation is covered under the exception provided under Article 19(2).
  • All the constitutional provisions are to be read in context with the Preamble, which talks about fraternity and states, “fraternity assuring the dignity of the individual and the unity and integrity of the Nation”. Thus, it aims at preserving the dignity of the individuals and hence, the restriction imposed by Section 499 satisfies the motive of constitutional fraternity.
  • Press can influence the minds of the public and cannot be given unbridled power. Even explanation I to Section 499 of the Indian Penal Code does justify truths unless they are for the public good. 
  • It was also submitted that the contention that the law of criminal defamation protects the interests of only an individual does not hold good as defamation serves the public purpose and is for the larger interests of society.
  • Reputation cannot be compensated in monetary terms as it is linked with self- respect, honour and dignity. Therefore, the argument of the petitioners that a civil remedy could be granted in case of defamatory remarks is not tenable. 

Observations of the Court

The two-judge bench of the Supreme Court upheld the constitutionality of the offence of defamation under the Indian Penal Code by making the following important observations:

  • It was observed that there is no ambiguity in the intent of the legislature behind associating wider words in the words of narrower sense and thus, the rule of noscitur a sociis, which is a rule of construction, cannot be applied.
  • Any person cannot, in the name of freedom of speech and expression, defame others, and hence, the Court held that, “it is difficult to come to a conclusion that the existence of criminal defamation is absolutely obnoxious to freedom of speech and expression.” 
  • Furthermore, the Court stated, “protection of reputation is a fundamental right. It is also a human right. Cumulatively, it serves the social interest. Thus, we are unable to accept that provisions relating to criminal defamation are not saved by doctrine of proportionality because it determines a limit which is not impermissible within the criterion of reasonable restriction.

Chaman Lal v. State of Punjab (1970)

In this case, the Supreme Court laid down the basis of establishing the good faith and bona fide as specified in the exceptions to Section 499 of the Indian Penal Code. 

Facts of the case

According to the facts of this case, one President of the Municipal Corporation wrote a letter which contained defamatory remarks against a nurse of the local hospital. Complaint was filed against the accused under Section 499 of the Indian Penal Code. The accused contended that the imputations were true and he made them in good faith. The imputations were sent to the lawful authority. 

Observations of the Court

The alleged accused was punished for a simple imprisonment of two months and the Supreme Court laid down the following basis of proving good faith and bona fides:

  • The circumstances under which the letter was written or words were uttered.
  • Whether there was any malice.
  • Whether the accused made any enquiry before he made the allegation.
  • Whether there are reasons to accept the version that he acted with care and caution.
  • Whether there is a preponderance of probability that the accused acted in good faith.

With respect to the nature of an interest, the Supreme Court said that the “interest of the person has to be real and legitimate when communication is made in protection of the interest of the person making it. If that be so, then good faith is automatically drawn in and good faith obviously does not require logical infallibility”.

M.K. Parameswara Kurup v. N. Krishna Pillai (1966)

This case highlighted the privilege of practising advocates and that their conduct can be covered under the ninth exception to Section 499 of the Indian Penal Code. 

Facts of the case

A petition under Section 561-A of the Criminal Procedure Code, 1973 was filed in order to quash the charge framed by the First Class Magistrate. The petitioner in this case was a practising advocate and a charge was made against him under Section 500 of the Indian Penal Code. The charge said that the counter affidavit contained certain imputations against the complainant which were defamatory and untrue. The advocate had attested those affidavits before they were put before the Court.

Observations of the Court

The Kerala High Court held him not guilty as it was observed that the counsel can come within the ambit of ninth exception to Section 499 of the Indian Penal Code when he does not abuse his position or make malicious allegations. Following are the significant points that were observed by the Court in this case:y

  • Assuming that it was the lawyer who drafted the written statements, there can be no offence against him. A counsel owes a duty to his client and he must carry out faithfully his client’s instructions. If the client makes serious allegations against a party in a suit, it is the counsel’s duty to plead those allegations in the plaint or written statement, or other pleadings. No doubt, the counsel must perform his duty with discretion, and clearly he should not plead what are obviously irrelevant, wanton, wild or reckless allegations.
  • It must be remembered that a counsel is not a judge in the case and it is not for him to decide whether the allegations made by his client are true or false. He is bound, except in very exceptional circumstances, to accept his client’s words. If serious and untrue allegations are made he brings himself open to a prosecution for defamation, but he cannot be successfully prosecuted unless it is clearly shown that he had acted in bad faith or maliciously.

G. Narasimhan & Ors. etc. v. T.V. Chokappa (1972)

In this case explanation 4 of Section 499 was examined by the Supreme Court and the principle that the defamatory remarks should relate to some specific person or group was highlighted.

Facts of the case

A complaint was filed under Section 500 and 501 of the Indian Penal Code by the Chairman of the Reception Committee of the Dravida Kazhagam against the editors and publishers of the newspapers The Hindu, Indian Express and Dinamani. The conference of the committee had passed a resolution which pleaded with the authorities to take suitable steps to see that coveting another man’s wife is not made an offence under the Indian Penal Code”. However, the newspapers published this news by stating that the resolution was that, “it should not be made an offence for a person’s wife to desire another man.” 

The issue that arose was whether the conference organised by Dravida Kazhkam was an identifiable body so that any imputation against it would be considered defamation against the members of the committee.

Observations of the Court

The Supreme Court quashed the proceedings before the Magistrate and took note of the following points:

  • While elucidating upon the scope of explanation 2 to Section 499 of the Indian Penal Code, the Court stated, “such collection of individuals must be an identifiable body so that it is possible to say that with definiteness that a group of particular persons, as distinguished from the rest of community, was defamed. Therefore,in a case where explanation 2 is resorted to, the identity of the company or the association or collection of persons must be established so as to be relatable to the defamatory words or imputations. Where a writing inveighs against mankind in general, or against a particular order of men, eg, men of gown, it is no libel. It must descend to particulars and individuals to make it a libel”.
  • Regarding the conference in the case, the Court laid down, “it is impossible to have  a definite idea as to its composition, the number of persons who attended, the ideas and ideologies to which they subscribed, and whether all of them positively agreed to the resolution in question. The evidence was that the person presiding read out the resolution and as no one got up to oppose it, it was taken as approved by all. The Conference clearly was not an identifiable or a definitive body so that all those who attended it could be said to be its constituents who, if the conference was defamed, would in turn, be said to be defamed”.

MP Pillai v. MP Chacko (1986)

This case is significant as it elaborates upon the fact that in the case of any published material, the complete text is to be taken into consideration so as to decide whether it is defamatory or not.

Facts of the case

In this case, the matter was with regard to an article titled “Syrian Christians and National Integrity”. It was published in two parts where the first part complimented the ancestry of Syrian Christian community while the other part highlighted that the community was engulfed in unemployment and poverty due to which some women of the community have to indulge themselves in prostitution to feed them and their families. Moreover, priests and nuns were applauded for their service for mankind. A complaint was filed alleging that the article defamed the community.

Observations of the Court

The Court observed that the article is to be read in whole so as to measure its impact. Also, the background circumstances are to be taken into consideration while deciding whether the article is defamatory or not.

It was also stated by the Hon’ble Court that, “Even the alleged defamatory imputations are only against some among the Syrian Christian girls working abroad and some of the Syrian Christian ladies who became nuns. Probably their families also could be said to have been defamed. These girls or the ladies who became nuns or their families form only a section of the Syrian Christian Community which itself is unascertainable. They are only unascertainable and indefinite individuals or groups among the Syrian Christian Community. The complainant cannot say by any stretch of imagination that he will come within that group so that he could claim that he was individually defamed. There is no imputation against the Syrian Christian Community as such, even taking for granted that the first respondent was competent to file a complaint as a member of that community or on behalf of that community”. 

Kanwar Lal v. State of Punjab (1963)

This case highlighted the difference and scope between the eighth and ninth exceptions to Section 499 of the Indian Penal Code.

Facts of the case

A defamation charge was made against a police officer for having passed defamatory imputations against his neighbour Ram Rakhi via a letter to the District Panchayat Office, Ludhiana. The contents of the letter said that the Ram Rakhi was of loose character and had illicit relations with some people and that she was engaged in immoral activities.  The police officer was held to be liable by the Sessions as well as the High Court, the accused appealed before the Supreme Court contending that he should be granted protection under the eighth and ninth exceptions. 

Observations of the Court

The Supreme Court disagreed with the appellant and upheld the conviction. The following points were observed by the Court which were instrumental in understanding the ambit of eight and ninth exceptions to defamation under Section 499 of the Indian Penal Code:

In order to establish a defence under this exception, the accused would have to prove that the person to whom the complaint was made had lawful authority over the person complained against, in respect of the subject matter of the accusation. If the District Panchayat Officer had such lawful authority, the last paragraph of the offending communication would have justified such a plea. But there is no basis for such a plea”.

The difference that was highlighted by the Apex Court between the eighth and ninth exceptions was that, according to the eighth exception, the person making the defamatory remarks should have a lawful authority, while in the ninth exception, the statements are made by the person who has interest in the matter and the requirement of belonging to the lawful authority is not necessary.

Moreover, the Court stated, “even if good faith be taken to have been established, the imputation has to be made for the protection of the interest of the person making it… besides the making the imputation, the person to whom the imputations is conveyed must have a common interest with the person making it which is served by the communication”.

Dogar Singh and Anr. v. Shobha Gupta and Anr.(1998)

The judgement in this case laid emphasis on the term ‘good faith’ used in exception 3 to Section 499.

Facts of the case

In this case, the Principal of Punjab Public School, Pugwara, Mrs. Shobha Gupta, filed a case against two persons alleging that they had made defamatory remarks in the complaint which they had submitted to the Deputy Commissioner, Kapurthala. The accused stated in the complaint “that  the building of the aforesaid school is quite unsafe and it may bring about any disaster upon the students of this school at any time; that the indiscipline among the students is to an unlimited extent and this has created a great problem for the nearby residents. Neither the school has any ground for proper accommodation; that it appears that this school has become a meeting place for the both sexes and the principal, Mrs. Shobha Gupta is turning a deaf ear towards the character of the students; that if these are not checked in time, they may become a great problem for the city”. In an enquiry before the SDM, the allegations of the accused were found to be false and their complaint was dismissed. Consequently, MMrs.Shobha Gupta filed a case of criminal defamation against the accused persons. 

Observations of the Court

The Punjab and Haryana High Court held that the complaint contained reckless statements and was without any basis. The accused cannot be granted protection under exception 3 of Section 499 of the Indian Penal Code. The following was observed in this case:

  • The allegation that the school is the meeting place of opposite sexes was reckless and was made intentionally to disrepute the school principal. As they did not act in good faith, therefore, cannot be justified under exception 3. 
  • It was stated by the Court that, “the question whether the accused acted in good faith, would depend on the facts and circumstances of each case – the nature of the imputation made, the circumstances under which it was made, the status of the person making the imputation, the existence or otherwise of malice in his mind when he made the imputation and whether he acted with due care and attention and was satisfied as to the truth of the imputation or the relevant considerations in deciding the question”.

MC Verghese v. TJ Ponnan (1970)

This judgement addressed the question of whether communication between husband and wife is privileged communication and comes within the ambit of eighth exception to Section 499 of the Indian Penal Code.

Facts of the case

A complaint was filed by Mr. Verghese, who was the father-in-law of TJ Ponnan. The latter had written a letter to his wife Ruchi when she was at her father’s place in Trivandrum. The letter contained defamatory statements against Mr. Verghese. The complaint was filed before the district magistrate. The District Magistrate held that the communication between husband and wife does not amount to publication as they are one in the eyes of the law according to English law. It was observed by the Magistrate that this communication will be considered privileged and hence, does not amount to the offence of defamation. However, this decision was reversed by the Sessions Court stating that the rule under the Common Law that husband and wife are one in the eyes of law cannot be applied in India, but the High Court again reversed the order and upheld the decision of the District Magistrate. Thus, the appeal was filed before the Supreme Court.

Observations of the Court

The Supreme Court held that this case does not fall within the ambit of privileged communication or eighth exception to Section 499. The Supreme Court relied upon the ruling in Tiruvengada Mudali v. Tripurasundari Ammal (1980) and held that Section 499 was exhaustive and nothing should be permitted beyond its exceptions. It was stated that, “a person making libellous statements in his complaint filed in court is not absolutely protected in a criminal proceeding for defamation, for under the eighth exception and the illustration to Section 499, the statements are privileged only when they are made in good faith. There is authority therefore for the proposition that in determining the criminality of any act under the IPC, the courts will not extend the scope of special exceptions by resorting to the rule peculiar in English common law that the husband and wife are regarded as one”.

Jawaharlal Darda v. Manoharro Ganpatrao Kapiskar (1998)

This case pertains to the status of accurate and true reports of assembly proceedings published in newspapers. 

Facts of the case

A complaint was filed under Sections 499, 500, 501 and 502 of the Indian Penal Code and it was alleged that the Chief Editor of the newspaper Lokmat is to be charged for defamation for the publication of news of the Maharashtra legislative proceedings. The news contained details that when a question regarding misappropriation of government funds was asked by the minister, he admitted it by saying that the enquiry concluded that there was a misappropriation. Further, he revealed 5 names, including that of the complainant, and stated that they were involved in misappropriation. 

Observations of the Court

The Supreme Court very succinctly highlighted that the reporting by the newspaper was true and accurate and was in good faith. It was also stated that, If the accused bona fide believing the version of the Minister to be true published the report in good faith it cannot be said that they intended to harm the reputation of the complainant. It was a report in respect of public conduct of public servants who were entrusted with public funds intended to be used for public good. Thus the facts and circumstances of the case disclose that the news items were published for public good. All these aspects have been overlooked by the High Court”.

Mohammad Abdulla Khan v. Prakash K (2018)

This case examined the application of vicarious liability principle in the offence of criminal defamation. 

Facts of the case

A complaint was filed under Sections 500, 501 and 502 of the Indian Penal Code against the respondent, who was the sole owner of the newspaper called Jaya Kirana. The Sessions Court dismissed the complaint,  the complainant approached the High Court under Section 482 of the Criminal Procedure Code. The High Court, however, held that the complaint regarding defamation can only be filed against the editor of the newspaper and not against its owner as there is not any concept of vicarious liability under the criminal law. It was observed by the High Court that if punishment would be announced for the owner, then it would lead to miscarriage of justice. The appeal was filed against this order of the High Court. 

Observations of the Court

The Supreme Court set aside the judgement of the High Court and observed the following:

  • “The extent of the applicability of the principle of vicarious liability in criminal law particularly in the context of the offences relating to defamation requires a serious examination in appropriate cases because the owner of a newspaper employs people to print, publish and sell the newspaper for a financial gain out of the said activity”.
  • It was made distinct in this case that both owner and printer of the newspaper and the persons who offer to sell could be liable for the offence of defamation under Section 501 of the Indian Penal Code. 


Since reputation is important for every being, the offence of defamation is also crucial and time and again, its provisions are challenged for violating the right to speech and expression ensured by Article 19(1)(a) of the Constitution of India. Section 499 lays down the list of exhaustive cases and circumstances where a person could be charged for making defamatory imputations as well as where their acts could be justified under the exceptions. The controversies around this offence are prevalent and the judiciary has played a vital role in addressing several questions that arise. Furthermore, the Law Commission is also instrumental in making proposals for eliminating the conflicts surrounding the offence.

Frequently asked questions (FAQs)

What is good faith?

The term good faith is used in the exceptions to Section 499 of the Indian Penal Code. It is defined under Section 52 of the Indian Penal Code as, “nothing is said to be done or believed in good faith which is done or believed without due care and caution”. The significant elements are care and caution. In the case of defamation, there should be some reasonable cause for passing the defamatory remarks.

Whether the communication between husband and wife is privileged and would be justified under the eighth exception?

The principle that a husband and wife are one in the eyes of law is an English doctrine and the Indian Courts rejected it by stating that Section 499 is already exhaustive and this principle is not applicable in India. Thus, in India communication between husband and wife is considered privileged for the offence of defamation. 

What is the difference between contempt of Court and libel of Court?

When someone obstructs the administration of justice and lowers the authority of the Court then it is referred to as contempt of Court. While if any imputation is published against the integrity of any judicial officer then it is called libel of the Court and is punishable under the Indian Penal Code.

Whether the owner or printer of the newspaper could be held liable for the offence of defamation?

It has been decided in multifarious cases that along with the editor, owner and printer could also be held liable for the offence of defamation 

Whether lawyers be made liable for the defamatory imputations in the affidavit?

Lawyers cannot be made liable for defamatory remarks contained in the affidavit as this would make it difficult for them to practice without any fear of charges against them and they won’t be able to discharge their duties fearlessly.


  • The Indian Penal Code, 1860
  • Pillai, P S A (2019) Criminal Law, LexisNexis, Haryana.

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