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Witness Production In The View Of The Indian Judicial System (By-Mrgank Kashyap)
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Witness Production In The View Of The Indian Judicial System
Authored
By-Mrgank Kashyap
LL.M
Student, Galgotias University
Introduction
The role of a
witness is critical in any country's criminal justice system. They are an
essential component of any civilized society's justice system. Each of their
statements is critical because it has the power to alter the course of history.
The entire case they bring the case forward by providing evidence relating to
the commission of an offense putting the criminal justice system into action.
"Witness is the eyes and ears of Justice wrote Jeremy Bentham”. The
witness may be unable to speak the truth in court due to circumstances beyond
his control, such as negligence or ignorance, or a combination of these
factors.
In its various provisions, the 1973 Code of Criminal Procedure attempted
to define it. Section 161 of the Code, for example, states that "any
police officer conducting an investigation under this section Chapter, or any
police officer of a rank not lower than that which the State Government may, by general or special order,
prescribe in this regard, acting on
such officer's requisition, may question orally any person who is supposed to be familiar with the facts and circumstances of the case."
The Term "Witness" Is Explained
As?
The word "witness" does not have a definition in Indian
criminal law. As a result, it is critical to rely on the ordinary dictionary
definition of the word. The term is defined by the Oxford Dictionary as
"one who testifies in a court of law; an indifferent to both parties,
sworn to speak the truth, the whole truth, and nothing but the truth". The
witness is defined by Black's Law Dictionary as "one who sees, knows, or
vouches for something, or one who gives testimony, under oath or affirmation in
person, or by oral or written deposition, or by affidavit." The Indian
Evidence Act of 1872 provides for the competency of witnesses as well as the
mode of examination of witnesses.
As a general rule, anyone is competent
to testify. Unless the court believes he is
unable to understand or respond to the questions posed to him. Rational
responses to them could be due to
old age, extreme old age, or disease, regardless of the cause. Body or mind, or any other similar cause, As a
result, no one is specifically declared to be incompetent. Even a lunatic is not declared incompetent unless his
lunacy prevents him from performing his duties. Comprehending or responding to inquiries.
Witness
Protection Under Indian Laws Code Of Criminal Procedure, 1973:
1The
Code of Criminal Procedure specifies the detailed procedure for criminal
trials. It is worth noting that the
CRPC. Modern law recognizes the role of the witness in criminal trials. Section 160 of the
CRPC empowers a police officer to summon a witness. In this case, the payment
of reasonable travel expenses incurred by the person for traveling shall be made under this section. Section 284 of
the CRPC states that whenever it appears
to the court that the attendance should be
made without delay if the
witness is required to be examined during the trial the court may
waive the personal examination Attendance of a witness, as well as the issuance
of a commission, are required to achieve justice.
Furthermore, the accused is responsible for the costs associated with the
issuance of a commission for examination. Section 309 of the CRPC states that
every inquiry or trial should be held as soon as possible and that once the
examination of witnesses begins; it should be completed as soon as
possible, Continue on a day-to-day basis unless the Court adjourns the
proceeding for good cause. Article 312 of The Criminal Procedure Code empowers
the criminal court to order the payment of reasonable expenses incurred by the
complainant or parties. Attendance at court proceedings as a witness the
government will pay the amount.
The Unlawful Activities
(Prevention) Act, 1967:
2This Act contains
two provisions that address the issue of
Witness. Threatening a witness is punishable
under Section 22 of the Act. It states that anyone
who threatens a witness with a violent act, or who unlawfully restrains
or confines the witness, etc., will be imprisoned.
Furthermore, witnesses are protected under Section 44 of the Act. This section
states that the proceeding may be conducted
in private if the court so desires. This section provides two types of protection to witnesses: identity protection and the confidentiality of the witness's address. The application under this section can be made by the
witness on his or her behalf. Furthermore, anyone who violates the provisions
of this section will be imprisoned. Suo moto action by the public prosecutor or
court based on the witness's life is in danger. The Terrorist and Disruptive
Activities (Prevention) Act, 1987:
The Terrorist and Disruptive Activities (Prevention) Act of 1987 was enacted specifically to combat terrorist activities in India. Witnesses are protected under
Section 16 of the Act. It specifies that if
the designated court so desires, the proceedings can be held in private. Furthermore, under subsection
(2), the Designated Court may take
steps to protect the identity of the witness and keep the address of any
witness secret. based on an application made by a witness or his prosecutor, or based on suo moto cognizance by the court.
Furthermore, if a person violates the provisions of
this section, he will be punished.
Prevention Of Terrorism Act,
2002:
3Witness protection is also provided for under the Prevention of
Terrorism Act of 2002 (POTA, 2002). Section 3(7) provides for imprisonment for
anyone who threatens a witness with a violent act, places any wrongful
restraint or confines the witness, or does any unlawful act to threaten him.
Furthermore, Section 30 of the Act provides for witness protection. It states
that the proceedings can be held in private if the Special Court so desires.
Furthermore, on an application made by a witness or his prosecutor or court on
suo moto cognizance, the Special Court under sub-section - 2 may take measures
to protect the identity of the witness and keep the address of any witness
secret. Furthermore, if any individual If he violates the provisions of this
section, he will be punished.
The National Investigation Agency
Act, 2008:
4The National Investigation Agency was established in 2008 to
combat terrorist activity. Witness protection is also provided for under the
NIA Act. The Special Court has the authority to hold court proceedings in private under Section 17 of the Act.
Whenever it appears to the court that the witness's or the person
on whose behalf the witness is testifying's
life is in jeopardy If a person's identity or address is in jeopardy,
this section protects that person's identity and address. Witnesses can be granted the privilege of secrecy. The
application for protection under this section can be made either by Suo moto cognizance
can be taken by a witness,
prosecutor, or even the court. The person who violates the Any violation of
this section will result in imprisonment.
Examining
the Law Commission's Report on Witness Protection?
5In
1958, the 14th Law Commission Report 23 considered a new perspective on
'Witness Protection” About the aforementioned matter, it was stated that there
were "inadequate arrangements for witnesses in the Courthouse, the scales
of traveling allowance and daily (allowance) paid to witnesses for attending
court in response to a summons issued by the Court." The Report
acknowledged that inadequate arrangements for witnesses had been made, but it
focused on the physical aspect rather than the emotional or mental turmoil
endured by the witnesses. The Law Commission Report, presided over by Mr. M.C
Setalvad pondered the
witnesses'
financial perspectives and stated that they had to be compensated for the time
and effort they expended in attending the proceedings. The report focuses on
and gives due consideration to the well-being, suitability, and remuneration of
the witness to assist the court of law. The report is based on the assumption
that if the witness is not thoroughly investigated, it may result in the
witness developing a negative attitude, which will prevent him from supporting
the court in its fight for justice.
Analysis 154 Law Commission
Report
6The 154th Law Commission Report 24 in 1996, which dealt
entirely with 'Protection and Facilities to Witnesses,' did not dispute the
fact that criminals were walking free due to a lack of witness protection. The
Report vouched for those witnesses turning hostile because they were subjected
to not only physical but also mental torture. According to the Report, the
allowancesfor attending court proceedings must
be made on a case-by-case basis. A much more realistic basis and a
simple procedure must be obtained, resulting in convenience and reducing any delays.
It also stated that witness
protection is a right that should be treated with the utmost respect.
It was also mentioned that
Legislation to protect must instill trust in the public and witnesses. Allow
them to come forward and assist the courts as needed. The Report
was published. Firm in stating that
time is of the essence, and when the
court lists cases, It must be kept
to avoid wasting the time of the
witnesses. The Highest The court was tasked with providing guidelines to all criminal courts for the listing of the cases.
Law Commission 172 Report
7Due
to the case of Sakshi v. Union of India, the 172nd Law
Commission Report took on the subject of Rape Laws to amend and define the term
'rape' to include all types of
forcible penetration. In this regard, the Report stated, "Provided that
where the evidence of a person under the age of sixteen who is accused of sexual assault or other
heinous crime If a sexual offense is to be
recorded, the Court may take
appropriate measures to ensure that it is not
repeated. That such person is not
confronted by the accused while also ensuring the accused has the right to be cross-
examined."
This recommendation was incorporated into the Criminal Procedure Code in 1973. It was suggested that in the case of a minor victim who has been assaulted, the principle of natural
justice must be flexible in allowing the victim to provide evidence to support his or her claim Screen to avoid
further mental anguish this strikes a balance between procedural law and
substantive law. Defending the rights of the accused as well as the mental
health of the victim
Law Commission 178 Report
8The 178th Law
Commission Report focused on the role of police officers in crime
prevention
.securing the witnesses and keeping them from becoming hostile The Report
suggested Section 164 A of the 1973 Code of Criminal Procedure is being inserted. The section is organized for the recording of witnesses in front of the magistrate. This,
however, did not apply to all offenses, but only to those punishable by
imprisonment for more than ten years, with or without a fine, or by the death
penalty.
Criminal Law a When the Criminal Law (Amendment) Bill, 2003 was introduced in the
Rajya Sabha, it modified the recommendations
by reducing the recording of witness statements with the magistrate from ten years to seven years. In addition to its point of
view on balancing In the interests of the witnesses, victims, and accused, the
Rajya Sabha ensured that the witness's statement must be investigated
to determine whether the witness is going
back. on the previous statement as a result of any type of inducement, pressure,
or other external
factor influences
.amendment
Bill 2003.
Justice
Malimath Committee Report:
9The
Justice Malimath Committee's Report on Reforms of the Criminal Justice System
consisted of 158 recommendations that elaborated on the need for witness
protection, which will
Increase the number of rightful convictions and bring down the cost of
the criminal justice system Justice for society.
The Report examined the erroneous problem of the witness's safety, as
well as the safety of their family or dependents. Being rational in their
approach, the Report also states
that protection does not have to be provided
in all cases, but rather depends on
the gravity of the offense. Case,
threats, if any, and the accused's
background If the crime is particularly
heinous, The Court must go so far as
to allow the Witness to change his or
her identity.' Depending on the discretion of
the judge, camera' proceedings should be
carefully permitted. Court, along with
witness rights protection, must be favorable to the cross-examination privileges.
Law Commission 198 Report
10The
Report presented a Consultation Paper and invited the public to provide feedback through a Questionnaire.
The authenticity of the witness is tested if they go back or retract their previous statements, according
to the paper. Witnesses and their families will be physically and mentally protected until the trial is over. The trial must strike a balance
between concealing the identity of the witnesses and the right to a fair trial to conduct cross-examination of the accused. There is a need for comprehensive legislation,
and there must be criteria in place to provide this protection. In
addition, the paper addressed some realistic
aspects such as police protection and witness relocation. another state or region.
The Report did not overlook the fact that the accused has a right to an
open and public trial in a criminal court, as well as the right to
cross-examine witnesses in their presence. However, the accused's rights are
not absolute and can be limited to such an extent. the extent to which justice
is administered fairly There were two types of Witnesses who were called:
1.
Victim-witnesses who are acquainted with the accused
could include any acquaintance, family member, or relative. This type of witness does not need to change its identity
because it is the very cause of it. Only physical protection is available in these cases. can be distributed
to the witness and his dependents
2.
Victims are unidentified witnesses who testify against
the accused. Terrorist bombing is one
example. If the court deems it necessary, physical protection and
identity change can be granted. When a threat is harmful to someone's livelihood, it falls into this category. The identity of the witnesses and their identities are to
be kept secret until the end of the
trial.
Finally, the report stated that, in addition to changing the identity of
witnesses, the witnesses should be relocated to a different location with their
dependants, and the expenses of witness protection should be borne by the State
Legal Aid Authority through the Legal Aid Authority for the District Aside from
that, there must be a memorandum of understanding. Between the State and the
witness that establishes both parties' obligations Contravention on the part of
the witnesses will result in his removal from the program.
Ramesh And Others Vs. State Of Haryana
2566 SC
11Witnesses
turning hostile in criminal cases
are becoming a common occurrence, almost a regular occurrence. There could be a
variety of reasons for the witnesses' behavior or attitude. It is possible that when the statements of
such witnesses were recorded by the police during the investigation under
Section 161 of the Code of Criminal Procedure, 1973, the Investigating Officer
forced them to make such statements
and, as a result, they resolved from them while deposing in Court, and rightfully so. However, in most
cases, this is no longer
the case. This trend of hostile
witnesses is caused by a variety of
other factors. It could be a fear of testifying against the
accused/delinquent, political pressure, pressure from other family members, or
any number of other sociological factors. It is
also possible that witnesses have been influenced by monetary considerations.
There is no clear-cut
legislation in place to combat witness hostility." One of
the main reasons for witness hostility has been threats and intimidation.
10 Law Commission 198 Report
"Witnesses are the eyes and ears of justice," said Jeremy
Bentham. When witnesses are unable to properly depose in court, it results in a low rate of conviction, and many
times even hardened criminals escape conviction. It undermines public trust in the criminal justice system.
Satish S/O Bandu Ragde Vs. State Of
Maharashtra 161 Bombay HC 2017
12A two-judge bench of this court issued directions for the establishment of special centers
for the examination of vulnerable
witnesses in criminal cases to
facilitate a conducive environment in which
a vulnerable victim could make a statement before the court. In Bandu's case,
the Court addressed the suggestion that special centers be established for the examination of vulnerable witnesses in criminal
cases in the interest
of creating a Conducive environment in the Court to encourage a vulnerable victim to make a
statement. "Such centers should be established with all necessary
safeguards," the Court said.
Mahendra
Chawla and Others vs. Union of India and Others (2019) 14 SCC 615,
13The Supreme Court issued a landmark decision in Mahendra
Chawla v. Union of India which is the first attempt to bring witness protection
within the purview of the law and hold the state accountable for effectively
implementing it. This decision comes in the wake of several fatal attacks on
witnesses in the past.
According to
the Central Government's affidavit, the Witness Protection Scheme, 2018, is based on input from 18 states/union
territories, 5 state legal services authorities, and open sources such as civil
society, three high courts, and police personnel. It is also stated that the scheme
was developed in collaboration with
the National Legal Services Authority (NALSA).
It is stated that the scheme's
aim and objective are to ensure that the investigation, prosecution, and trial of criminal offenses are not hampered
because witnesses are intimidated or fearful of
giving evidence in the
absence of protection from violent or other criminal recrimination. It seeks to promote law
enforcement by facilitating the protection of individuals who are
directly or indirectly involved in assisting
criminal law enforcement agencies and the administration of justice in general.
The Court ordered that the Witness Protection Scheme, 2018, be implemented by the Union of India, as
well as the states and union territories. The Court ruled that it shall be
the 'law' under Article 141/142 of the Constitution until appropriate
legislation on the subject is enacted.
Following the aforementioned provisions of the Scheme, vulnerable witness
deposition complexes shall be established
by the States and Union Territories in all
district courts throughout India.
Delhi Witness Protection Scheme,
2015
14The
Delhi Witness Protection Scheme, 2015 is the first piece of legislation in
which the term "witness" is defined. Section 2 (m) of the Scheme
defines a witness as "any person who has knowledge of any criminal act or
possesses any document relating to that criminal act." the same, and he
has made or agreed to make the statement in the course of a criminal proceeding
Section
– states that 3 of the Scheme, the witness is classified into three
categories, based on the threat. Perception Section 6 of the scheme outlines
the procedure for requesting witness protection.
Section 7 of the Scheme provides for various types of protection that are
proportional to the threat and only
last for a limited time. They may include
no meeting between the witness and
the accused during the trial, concealment of the witness's identity, close
protection, and regular patrolling. Around the witness's house, temporary
change of residence, in-camera
proceedings, and awarding The Witness Protection Fund provided financial
assistance to the witness for
relocation and sustenance. or beginning a new vocation/profession, etc. 9th
section 8 The Act protects the
identity of the witness in serious
infractions A separate application must be
made to the competent authority under this section. Examination of
witnesses and their families that must take
place during an investigation or trial.
13 Mahendra Chawla and Others vs. Union of India and
Others (2019) 14 SCC 61
Witness Protection Scheme 2018
15The
Central Government finalized the "Witness Protection Scheme, 2018"
("Scheme") in consultation
with the National Legal Services Authority. Following that, the Hon'ble Court, in its judgment dated 05.12.2018, noted
the critical importance of having a witness protection mechanism/scheme in India. However, in the absence of a statutory regime, the Scheme was duly adopted and declared to be law by the Hon'ble Court under Article
141 of the Constitution, until a suitable law was framed in this regard.
In extreme cases, the Witness Protection Scheme, 2018 envisages means of
ensuring witness life/safety in events ranging from; providing a police escort
to witness up to Courtroom or using audio-video means for recording the
testimony of such witness to steps ensuring anonymity, temporary residence in
the safe house, providing new identity, relocation of witnesses, etc. The
Scheme, among other things, provides for categorizing witnesses into three
categories based on threat perception, namely Category A20, Category B21, and
Category C22, and it also provides for the establishment of a State Witness
Protection Fund, which is operated by the Department/ Ministry of Home under
the State/ Union Territory Government, to meet the expenses incurred during the
implementation of Witness Protection Order, passed by Competent Authority. The
genesis of a Witness Protection Order, according to the Scheme, is the filing
of an application in the prescribed form before the Competent Authority of the
concerned District, through its Member Secretary. Clause 6 of the Scheme
specifies the procedure for processing such application(s) based on a Threat
Analysis Report ("TAR") prepared by the Additional Commissioner of
Police/Deputy Commissioner of Police in charge of the concerned Police Station,
and its disposition within five working days of receipt of said Report. The
aforementioned Clause also empowers the Competent Authority to issue interim
protection orders until a final decision on the witness' application is made,
as well as to conduct monthly follow-ups and review of the final order of
protection issued. Witness Protection Orders, proportionate to the threat and
for a specific duration and subject to monitoring/review, that may be issued
include monitoring of mails/phone calls; ensuring witness and accused do not
come face to face during investigation/trial; concealment of identity; holding
in-camera trial; regular patrolling
14 Delhi
Witness Protection Scheme http://dslsa.org/wp-content/uploads/2015/12/Delhi-Witness-Protection-Scheme-2015.
around witness' house, and so on. The Scheme also includes provisions for
witness identity protection (Clause 9), identity change (Clause 10), witness
relocation (Clause 11), confidentiality and record preservation (Clause 13),
and so on. Furthermore, under Clause 12 of the Scheme, every state is required
to publicize the scheme widely, and the Investigation Officer and Court are
required to inform witnesses about the Scheme's existence and key features.
Loopholes In The Scheme:
Though the
Witness Protection Scheme, 2018, is a welcome step toward witness/victim
safety, it does have some shortcomings. For starters, the protection envisioned
therein is limited to three months at a time. Second, the basis of orders that
may be issued under the Scheme appears to be
heavily based on recommendations/advice given in TAR(s) by concerned police officials, who are frequently
prone to corruption, superior/political pressures, and so on. Moreover, while
the Scheme provides for confidentiality and the preservation of records, there
are no penalties for such
violations. The Scheme also makes no provision
for the witnesses' occupation/work/education in
the interim. In contrast, the Witness Protection Bill, 201529 included, among other things, specific provisions
regarding the penalties that may be imposed for violating the terms of the said Bill; orders for the safety and security
of the protectee30 from the beginning
of the investigation until the stage after trial on terms as warranted by the
Court based on the individual's threat perception; and so on. There were
specific provisions in the said Bill
relating to the protectee's right to
practice an alternate occupation without jeopardizing the integrity of the case
or the continuity of education of juvenile
protectees, which were lacking in the
Scheme. A similar Bill for the Protection of Witnesses' Identity31 was
introduced in Parliament.
Unfortunately, neither of the aforementioned Bills could be made into a statute.
Haryana Witness Protection Scheme
16The
Haryana government has announced its witness protection scheme, which aims to
provide complete protection to witnesses in criminal cases as well as their
immediate families. The new institutional mechanism, known as the 'Haryana
Witness Protection Scheme, 2020,' aims to ensure free and fair trials by
protecting, even changing, the identity of witnesses and relocating them to an
anonymous location until the trial is completed.
The new program divides witnesses into three categories based on threat
perception: the first covers witnesses whose own lives or the lives of their
families will be affected during the investigation, the trial, and after it.
The second category includes cases in
which witnesses' reputations, property, or family members' reputations
are jeopardized. Witnesses who are
intimidated or harassed fall into the third category. Other safeguards include
ensuring that witnesses do not meet any of the suspects in the case during the
investigation, installing security features such as close circuit cameras, alarms,
and security doors in their homes, police escorting to and from courtrooms,
in-camera trials, using special witness courtrooms, expediting deposition
during the trial, and monitoring witnesses' emails and phone calls.
Maharashtra Witness Protection
Scheme 2017
17The
Maharashtra Witness Protection and Security Act, 2017, protect not only the
witness but also their family members during the trial of serious crimes. The term "witness" is defined in Section 2 (e) of the Act to include the victim and his close
relatives who are under threat of prosecution for serious offenses. Section 6
of the Act addresses the aspect of
witness protection in serious crimes
The Committee is authorized by the Act to provide witness protection if the application is made by the witness, a relative, or someone else authorities
referred to in the section
Section 7 of the Act addresses the procedure for providing witness
protection. The District Committee is the highest authority to take action on
an application for protection in a criminal trial made by a witness whose life
is in danger. Before granting protection, the committee will conduct a thorough
investigation into the threat perception. Sections 8 and 9 of the Act are
applicable and provide protection during the investigation and trial as
directed by the committee 11th section mandates that the investigating officer
not reveal the names and addresses of the witnesses until the investigation is
completed. Disposition of the case, and if they violate the provision, they
will be punished following Section 13with imprisonment.
Many States Fail To Implement The
Witness Protection Scheme
“The Supreme Court observed that witnesses' right to testify in court in
a free and fair manner, free of any pressure or threat, is under serious attack
today.” “The right to life guaranteed to the people of this country includes
the right to live in a society free of crime and fear, as well as the right of
witnesses to testify in court without fear or pressure.”
Hari Vs. State Of Uttar Pradesh 2021
SC 685
18To
begin with, the State has a clear role to
play in protecting witnesses, at least in sensitive cases involving those in power, who have political patronage and
can wield muscle and money power, to prevent trials from becoming tainted and
derailed, and truth from becoming a casualty. As a protector of its citizens, it must
ensure that during a court trial, the witness can safely depose the truth without fear of being haunted by those against
whom the witness deposed.
Mithlesh Narayan Tiwari State Of U.P
And Others Writ - C No. - 18204 Of 2021
19"The
State Government's statements are merely a smokescreen, and the Witness
Protection Scheme, 2018, is not being properly implemented by the State
respondents," the Court observed in dismissing the petition directing the
State to implement the Witness Protection Scheme. The Allahabad High Court
issued notice to the UP Government in December 2020 on a PIL (public interest
litigation) seeking effective implementation of the Witness Protection Scheme,
2018.
The Madras High Court expressed its displeasure with the
non-implementation of the Witness Protection Scheme, 2018, in September 2020. "Though the
Witness Protection Scheme was developed in 2018,
the system still does not provide confidence to witnesses to come out with the truth as opposed to hard-core
criminals," the Bench observed.
Conclusion
Furthermore,
there are a few flaws that must be
addressed. The Witness Protection Scheme, 2018, provides for three
months of temporary protection for the witness, after which the witness is vulnerable to threats from the accused. As a result, the three-month limit should be reduced, and the witness will be protected as long as the threat perception exists.
Furthermore, the scheme categorizes
the witness based on threat perception; however, such categorization will not
serve the purpose of scheme incorporation. According to the scheme's
provisions, the Threat Analysis Report must be prepared by the scheme's head.
The presence of police in the district raises the possibility of political or
influential people interfering in high places. A profile is important. Without
a doubt, the scheme appears to be a watershed moment in the incorporation of a
legal framework for the protection of witnesses during the trial, but due to
the scheme's limitations, it will not benefit the witness.
Our criminal justice system has been rightly focused on protecting the
rights of the accused, but the rights of witnesses have been ignored. When he approaches the Court to give his testimony, the witness appears
helpless. In the landmark decision of Mahendra Chawla and Others vs. Union of
India & Others, the Supreme Court endorsed the draught Witness Protection
Scheme, 2018, and directed the Central and State governments, as well as Union
territories, to enforce the scheme in letter
and spirit. Furthermore, the Supreme Court The court also declared the scheme to be
'law' under Article 141/142 of the Constitution until any appropriate action is taken Enactment at the federal or state level.
The scheme is a
ground-breaking initiative for witness protection during the trial. During the
co. While drafting such policies, a reference to
Australian legislation can be made,
as the provisions in Australian
legislation are very effective in
protecting witnesses from treatment and intimidation imposed by the accused. As
a result, the Indian Parliament should also include such provisions. a policy
that would make it easier for witnesses to testify
Article Information
Witness Production In The View Of The Indian Judicial System (By-Mrgank Kashyap)
Authors: Mrgank Kashyap
- Journal IJLRA
- ISSN 2582-6433
- Published 2022/09/12
- Volume 2
- Issue 7
About Journal
International Journal for Legal Research and Analysis
- Abbreviation IJLRA
- ISSN 2582-6433
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