Published Paper
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BANKING FRAUDS
IN INDIA
AUTHORED BY - ADV. ANKITA RAVINDRA
SANCHETI
Submitted
To The Modern Law College For The Degree Of L.L.M.
INTRODUCTION
The term ‘Banking Fraud’ or ‘bank fraud’ as it is used interchangeably,
has received very few attempts at its
definition, Largely due to the reason that Banking Frauds as such have not been recognised by none of the market
regulators, legislators or experts of the field as a distinct and imminent problem. This casual attitude
towards the problem of Banking Fraud has deprived the issue of banking Fraud of the due attention of theorists as well.
In the Black’s Law Dictionary, the meaning the term of ‘bank Fraud’
is adopted from an American
Legislation as, “The criminal offense of knowingly executing or
attempting to execute, a scheme or
artifice to defraud a financial institution or to obtain property owned by or
under the control of a financial
institution, by means of false or fraudulent pretenses, representations, or promise.
Various authors on banking including even those who are writing books
distinctively on the issue of Banking
Frauds have not attempted to define Banking
Fraud, rather have tried to give the broad outline
of the Banking Frauds by enumerating different
instances of Frauds in banking sector.
The Indian legislature has attempted the definition of Bank Fraud’ while
proposing the Criminal Law (Second
Amendment) Bill, 1995 in the Lok Sabha
for creation of ‘Bank Frauds’
as a separate Offence
under the Indian Penal Code, 1860, as follows, “Whoever dishonestly or
fraudulently (a) removes or Conceals or transfers or causes to be transferred any Property in his custody
or control which
is subject to Any form of security
interest created in favour of any Bank without the express or implied consent or Concurrence of
such banks or he furnishes any Statement which is false in any material particular to Any bank concerning any property which is in his Custody or control
and
which is either subject to any Form or security interest in favour of any bank
or Which is offered by him to any bank to be made Subject
to any security interest in favour of the bank, Shall be punished with imprisonment of either
Description which may extend to two years or with fine Or both”. This proposed legislative definition of ‘bank fraud’
dealt solely With the frauds with respect
to security interest, which is definitely a Serious fraud causing huge losses
to banks. However, this proposed
Definition lacked the comprehensiveness or even the scope for Inclusion of various dimensions of Banking Frauds
which is desired of An evolving definition. The term ‘Banking Fraud’ contains two elements namely Danking’ and
‘fraud’. Beginning with simple money-changing as per it’s the earliest
traced history, the term ‘banking’
has today found
synonymy with five core functions of accepting deposits, lending,
investment, repayment and facilitating of withdrawal of money.[1]
And
in common parlance, ‘fraud’ is a dishonest act done with the Intention of
gaining benefit by causing loss to
others. Legally speaking, ‘fraud’ refers to a false statement of fact by a
person or his agent who himself
doesn't believe the statement to be true, made with an intention of deceiving another party, and inducing him to enter
into a contract on that basis.[2]
Thus 'fraud' is a wide term which
includes any behaviour by which one person intends to gain a dishonest
advantage over another. It signifies
not only act of commission but also an act of omission which is intended to cause wrongful gain to one person
and/or wrongful loss to another.
Accordingly
‘Banking fraud’ is a broad term used to signify all types of frauds committed
in a banking system. It may be
committed with accounts, negotiable instruments, loans, securities or any other Banking service. Again, it may
be pulled off by customer, employee, outsider or by the bank itself, or by two or more of parties
in connivance with each other.
A common term to describe
all such Frauds is ‘Banking Fraud’. Banking frauds may be committed by
way of concealment, embezzlement, breach
of trust, theft, cheating, forgery,
falsification of accounts,
conspiracy etc.
OBJECTIVE OF THE
STUDY
1.
To trace out the various
traditional as well as modern
technological frauds prevailing in the banking
system.
2.
To find out the relevancy and adequacy of Indian law on Banking
Frauds.
3.
To judge the impact of modern techniques and trends of business system in allowing
or excluding Banking
Frauds.
HYPOTHESIS
1. The modern Banking techniques make Banking Frauds more probable.
2.
In the 21 Century, the Banking System
because of its modem technology is vulnerable to Banking Frauds.
RESEARCH METHODOLOGY
The nature of the present study is such that it is difficult to come
across authentic first hand data on
the number and manner of instances of Banking Frauds. There is dearth of
literature on the issue of Banking
Frauds. Thus, the research methodology has been adopted in such a manner so as to optimally utilise the available limited information. As the occurrences of Banking Frauds
are not limited to a place,
banking institution or category customers. Keeping this in view, the Doctrinaire Research Method has been
used.
BANKING FRAUDS
IN INDIA
Theft
In Merriam Webster Dictionary ‘theft’ is defined as ‘the act of stealing’
specifically the felonious taking
and removing of personal liberty with intent to deprive the rightful owner of
it or an unlawful taking’. Oxford
Dictionary defines ‘theft’ as ‘the action or crime of Stealing’. collins English Dictionary defines ‘theft’ as the
dishonest taking of property belonging to another person with the intention
of depriving the owner permanently of its possession. Chambers 21St Century Dictionary defines ‘theft’ as stealing; an act of stealing someone
else's property, with the intention
of permanently depriving them of it.[3]
Under the Indian
Penal Code, 1860, whoever intending to take dishonestly any moveable property out of the possession of any person
without that person’s
consent, moves that property
in order to such taking,
is said to commit theft.[4]
In the
clear cases of theft at banks, the perpetrator may be an insider or
outsider. A crooked cashier may
personally use the cash due for deposit, count money short or temporarily embezzle cash. Members of public or
members of staff other than the cashier, can also commit theft by distracting the cashier generally or by creating emergency situations.
Robbery
To ‘rob’ means to despoil
(person etc.) of or of property by violence, feloniously plunder (person, place, often of) deprive of what is due.
Wharton’s Law Lexicon defines ‘robbery’ as the unlawful and forcible taking from the person of another, of goods or
money to any value, by violence or putting him in
fear.
Under
the Indian Penal Code, robbery is defined as an aggravated form of theft or
extortion. It holds that in all
robberies there is either theft or extortion with violence, whether actual or purported.[5]
Under the ambit of banking frauds, ‘robbery’ is included as it is a wrong
committed against the banking system,
resulting into frauds against the customers. And even in the present times of electronic frauds, bank robberies still pose a threat in bank premises
during transshipment of currency,
at ATM premises, etc.
Dacoity
‘Dacoity’
is an offence under the Indian Penal Code, 1860, of hindustani origin, the
preceding Hindi word being ‘Dacoity’
meaning gang-robbery. The Indian Penal Code covers a robbery committed or attempted by five or more persons conjointly, under the head ‘dacoity’. Thus, dacoity is an aggravated form of robbery,
wherein the minimum number of participants is five under the Indian law. A peculiar offence created to
meet the law enforcement requirement of the colony of India by the British ‘dacoity’ was intended to be compulsorily
punished with harsher sentence of imprisonment
for life or with rigorous imprisonment upto ten years and fine to have a
deterrent effect. However, here
again, bank-docoity is not a separate or distinctly punishable offence under the Indian Penal Code, 1860, which
deprives bank-dacoities of double-shielded protection which it requires to have an
effective deterrent effect
against possible perpetrators.
Frauds Relating
to Bills and Receipts
Banking institutions are dealing with multifarious functions in
consonance with development of trade
commerce, and intercourse. The majority of the monetary transactions of trading
activities are done by the banking
institutions as per the standing instructions of the borrowers/customers. Banking
institutions as an agent of borrower or depositors are bound to comply with the instructions of the latter. The payment
claimed from Banking Institutions as a matter of rights is by virtue of certain receipts or bills
which are in the nature of dispatch paper etc. Whenever, such type of claim for payment is made before
the Banking Institutions they are supposed to receive and make payment accordingly. For this purpose, Banking
Institutions are protected by virtue of Section 10 of the Negotiable Instruments Act, 1881.[6]
The Banking Institutions as per their
manuals are under obligation to inquire about the authenticity or genuineness of such bills or receipts. No doubt, banks are
quite vigilant to deal with such kind of receipts
because of which
wrong payments are claimed by unauthorized claimants. If the frauds
are committed with these kinds of bills
or receipts, they obviously prove very costly
for the banking institutions.
Frauds with respect to purchased bills can take form of bogus or stolen railway
or motor transport receipt, discounting of spurious bills with inflated
value and goods of which receipt
is being discounted with bank are already removed or are actually of lesser
value than claimed in the bill.
In fact, banking institutions are vigilant to confirm the authenticity of
these kinds of receipts or bills
before making payment. The banks are thoroughly checking the documents so that
this kind of frauds may not be
committed in the future. Only after full satisfaction. Banking Institutions release
payment or honour
these bills so that the parties may not suffer any delay in case of genuine
transactions. But still the perpetrators of such frauds are better
equipped with the technology and these kinds of
frauds are still prevalent
in banking institutions.
Frauds Relating
to Lending (Loan)
The index of the development of any Country
may be traced through the development in economic means and enhancement in living
standards. India, being a developing Country is playing a significant role in rural as well as urban
area to develop its infrastructure, education, to eliminate poverty,
to provide basic commodities, to establish industrial units, to promote
artisans, to produce
agricultural product and to flourish business activities etc. As a
general policy of the government to
achieve these objectives, loans facility is provided to explore the possibilities
of these hidden compulsive
objectives. The Central Government and the State Governments are encouraging in their general policy to provide
loans to the agriculturists, businessmen, children for vocational and higher studies,
to establish small and big industrial units and to carry on small artisans
business etc.
These kinds of facilities not only provide
an opportunity to public at large but also strengthen them financially so that they may uplift
their standards which results into socio-economic empowerment in the society. But every general scenario has a dark side too.
The loan facility which is duly provided is also infected
by frauds which
impose restrictions on the banking
institutions to impose
innumerable standards to provide this facility. Lot of instances are
there, where loans were given to more
than one person against the same property as security; the borrowers
disappeared after taking loans; bogus
firms took loans; loans taken on one pretext were used for another purpose; inflated bills are shown for machinery and
accessories never supplied; and machinery purchased with loans first
hypothecated, then sold to
third parties without informing the banks. High profile borrowers increase the debt-recovery
problem of the banks. Loan related troubles keep hounding the banking institutions[7] and the
Finance Ministry of Central Government.[8]
As a matter of fact, it is not a difficult task to prevent the loan frauds. Proper
precautions, training programmes can minimize the possibility of committing these kinds of frauds and proper utilization can be done to achieve the
substantial objective for which this facility is provided. The procedural requirements or requisites
need a re-look to fill up the gap in future. As an affirmative step, the banking market leader SBI has
decided to publish in newspaper the details of loan defaulters to make the borrowers
clear their dues.[9]
Frauds Relating
To Cheques
The basic purpose of banking institutions is to provide
the safety, security
and utilisation of money to provide proper facilities to their
customers. That is the reason why the Banking Institutions are getting greater importance in everyone’s
life. The Banking Institutions are dealing with their customers on the basis of certain instruments. these instruments
are used for the purpose of negotiation
and the customers are at liberty to get any kind of subscribed facilities from
the Banking Institutions. Negotiable Instruments Act, 1881 is such
kind of legislation which provides
the principles to deal with the Banking
Institutions. Recognized instruments possessing the quality
of negotiability are entitled to be called as Negotiable Instrument for
this purpose Negotiable Instrument means promissory note,[10] bill of exchangers[11] and cheque.[12] As per Section
6, a cheque is a bill of
exchange drawn on a specified banker, and not expressed to be payable otherwise
than on demand. In Banking
Institutions, so far the frauds relating to cheques are very common.
Cheque frauds are so common
that they are found relating
to both very nominal amount
and to high amount.
A Voluminous number of cases
are pending before the courts
which compel the administration of justice to set separate
courts to adjudicate or settle the cases relating
to the cheques. Presently, the cheque
frauds include counterfeit bank drafts or traveler’s cheques or other cheques; stolen cheques encashed through impersonation;
forged signatures on cheques; material alteration in cheques with respect
to value, validity
date, name of the payee,
nature of cheque
with reference to its
crossing, negotiability etc.; issue of cheques against insufficient funds,
cheques issued against non-existent accounts; forged seals or stamps or fingerprints (in case of illiterate account-holders), fidgeting done with cheque-writer etc. which are common.
The above information reveals
that cheque frauds
are very common. The Reserve Bank of India is continuously circulating directions and
guidelines to eliminate this menace of cheque-frauds. that is the reason why the Central Government
and Reserve Bank of India framed the policy to
transform the existing system with new Magnetic Ink Character Recognition
(MICR) system, which will work on the
basis of technology known as e-cheque and open the new vista in the banking
sector from January 1, 2013.
Frauds Relating
to e-Banking
The whole discussion remains incomplete without
the reference of internet banking
also known as e-banking.
In fact, the new generation banking institutions are pioneers in introducing
internet Banking system. The
technological transformation systems in banking institutions has increased interestingly during the last few years.
The Miraculous change
which has transformed the banking system with the help of world wide web
(www) right from 1990, eliminated the
territorial restrictions and
supplemented the wide range of services as per the customers’ convenience. This compels
the banking institutions to remain in competition by providing more smart services
at the click of the mouse to facilitate their customers. This enhanced
the capability and the imaginative reality
by providing electronic fund transfer (EFT), RTGS, EDP, EDI, ACH, MICR cheques, SWIFT etc. along with that, banks have
also facilitated lives of their customers by making available them online utility bill payment options, online
securities trading, demat accounts and funds related
management; online purchase
and sale; online
booking available for services ranging
from transport to movies, online fee deposits at educational, health and
the like service providing institutions; online shopping; online recharge facility
for prepaid services
like television broadcasting
services, mobile phone talk time and many more. E-banking frauds which are virtually a great issue in 21st Century and which raise the challenges for
the future because of radical transformation of the existing
banking structure give rise to unforeseen consequences.^9 It Is not denied
that RBI had set up a working group to examine or to find out major areas of technological frauds and to take measures
to regulate and supervise these sensitive issues. As a compulsive requirement, all the Banking Institutions in India
who are offering e-services are supposed
to obtain the prior approval from RBI to do the e-banking services. The RBI
regularly supervises and inspects the
records of banking institutions to maintain the security standards for transparent, authentic, and reliable
system and to pinpoint any kind of irregularity, embezzlement, etc. But there is no denial to this fact that still the
e-frauds are increasing gradually,'[13]
sustainably which impose a great
threat to achieve the public confidence at large. Thus, this is a new kind of issue which invites innumerable challenges
in the banking institutions, which are supposed to be redressed by having
visibility in unforeseen situations.
Fraud through
Money Laundering
The 21st Century
witnessed from the very beginning that money is the backbone of all the transactions in the world. The concept of
globalization and liberalized policy changed the entire pattern of domestic economy because of which territorial
limitations are no more hurdles in any kind of transaction. To maintain pace with the world economy,
is very difficult for the developing world, who is considered as second
generation after developed countries, to remain at par with them. The influential effect of world order is cumbersome in developing countries like India where
innumerable vicissitudes which may be because of social, economic,
political, cultural, legal and technological
restrictions are hurdles to maintain sustainable gateway to fulfill the aspiration
of present times. Presently, money
laundering pose a great threat in such a way because of which there is always substantial loss of legitimate sources. “Money laundering means acquiring, owning,
possessing or transferring any proceeds (of money) of crime or knowingly
entering into any transaction related to proceeds of the
crime either directly or indirectly or concealing or aiding in concealment of the proceeds or gains of
crime, within or outside India. It is a process for the conversion of money obtained illegally to appear to have originated from legitimate source.[14]
Thus, the above definition reveals that money laundering is a crime, but
at the same time, the dishonest
intention also involves itself within the definition of banking fraud. The
simple reason for calling money laundering of fraud
or crime is that it is wrongful gain originated from illegitimate sources. In India, all the
banking institutions are prone to these kinds of transactions. As a significant development to control
this menace the Indian Parliament has passed the Prevention
of Money Laundering Act, 2002.[15]
This act provides provisions for confiscation of property derived from or involved
in money-laundering. All the banking
institutions including co- operative
banks are covered under this legislation and any kind of negligent action on
behalf of banking institutions will
bring them under the domain of this legislation as culprits. Banks are supposed to be very vigilant so that they
shall not become part to such transactions. The banking institutions are supposed to maintain record of such
transactions for ten years; so that in case of
any kind of reporting of money laundering, proper cognizance would be made as per the Provisions of this Act of 2002. Even though the Enforcement directorate
is duly formed with designated authority
to trace out the cases of money laundering, but unfortunately, still a lot of
instances are available where
the money has been transferred, acquired, concealed, gained
or converted illegally and created huge frauds and loss
to the exchequer of the government. It is evident
from the recent
reporting where there banks i.e. HDFC, ICICI Bank and Axis Bank are
found involved in money laundering activities.'[16]
LEGAL
PERSPECTIVE UNDER GENERAL LAWS TO CURB BANKING FRAUDS IN INDIA
LEGISLATIVE PERSPECTIVE TO CURB THE MENACE OF BANKING FRAUDS
UNDER THE INDIAN PENAL CODE, 1860
Looking
at the gravity and the likely effect of banking fraud, it must be treated not
only as a civil wrong,[17]
but also as a criminal act.[18]
The basic philosophy which works behind treating an act as ‘crime’
is that certain acts are forbidden at the pain of punishment.
Rupert
cross and Philip Osterley opine, “A crime is a legal wrong for which the
offender is liable to be prosecuted
and if convicted, punished by the state”.
Now, which
acts can be termed as crimes and which not, is defined
and regulated by the concerned legal system, more precisely, by the ‘criminal law’s[19]
of the concerned legal system. Under the Indian
legal system, at the macro level, the criminal law is covered by the Indian
Penal Code of 1860, the Code of
Criminal Procedure of 1973, and the Evidence Act of 1872. The Indian Penal Code is the substantive law defining the
crimes, while the Code of Criminal Procedure and the Evidence Act are the adjective
laws regulating the procedure in trials of crimes.
The
Indian Penal Code is a pre-independence legislation, enacted at a time when
India was under the British rule.
Brought into force on January 1, 1862, presently this legislation is applicable
in the whole of India except the
State of Jammu Kashmir. Ironically the Indian Penal Code of 1860 does not recognize
tanking fraud' as a separate
crime. In fact, the Indian
Penal Code doesn't
define even 'fraud'
as a crime as such. Therefore, in case of banking
fraud, various provisions of the Indian
Penal Code are attracted, depending upon the facts of each case. Penal
provisions covering 'banking fraud'
are broadly incorporated in the Indian Penal Code under Chapter II-General Explanations,[20] Chapter
XII- Of offences Relating to Coin and Government Stamps',[21] Chapter
XVIII-
Of Offences against Property,[22]
and Chapter XVIII-Of Offences Relating to Documents and to Property Marks.[23]
LEGAL
PERSPECTIVE TO CURB THE MENACE OF BANKING FRAUDS UNDER THE LAW OF TORTS
The
law of torts, a creation of common law system, is that branch of justice
delivery mechanism which provides
relief in those civil matters wherein otherwise the legislature scheme has
failed to provide. A tort is
generally understood as a civil wrong other than breach of contract and breach of trust, the remedy
for which is a common law action
for unliquidated damages.
Fraud
as a civil wrong has its originating roots in law of torts. As the discussion
so far has shown in contractual issues also courts have looked
towards common law meaning of fraud to apply it as an element vitiating contract. Under law
of torts, 'Deceit or Fraud' is covered under the head 'Liability for misstatements', along with the sub-heads of
'Liability for Negligent Misstatements' and
'Liability for Innocent Misrepresentation'. This classification of
misstatements makes evident the distinction between fraudulent statements on one hand and negligent
and/or innocent misrepresentations on the other.
Fraud Or Deceit
The tort of fraud or deceit is committed when a person knowingly makes a
false statement or representation
thereby inducing the plaintiff to act upon it and becomes actionable when the plaintiff
suffers loss by acting upon it. Thus,
the essentials of tort of fraud or deceit are:
1. A false statement or representation of fact
2.
Knowledge of falsity
of such statement
3.
Intention to deceive
the plaintiff, and
4. Plaintiff being actually deceived and suffering loss/damage caused thereby
LEGISLATIVE PERSPECTIVE TO CURB THE MENACE OF BANKING FRAUDS
UNDER THE INDIAN CONTRACT ACT, 1872
The
banking Business is essentially contractual in nature and in governed by the
provision of Indian Contract Act. The
relationship between civil liability under the Contractual Law and the problem banking frauds has been proved
numerous times. Thus, study of the provision of Indian Contract Act 1872 and problem
of banking frauds has been taken up together to explain the impact of general contractual law on the curtailment or cure of the civil
wrong of banking
fraud.
In
the realm of private laws, no other law can claim to have such a pervasive
effect on the individuals of the society, as the law of Contract.
Sir Federick
Pollock says:
“The Law of Contracts may be described as the endeavour of public
authority…. To establish a positive
sanction for the expectation of good faith which has grown up in the mutual
dealings of men.’’[24]
Sir William
Anson says:
“The Law of Contracts is intended to ensure that what a man has been
promised to him shall be performed.”[25]
Every
‘banking fraud’ committed definitely violates the Customer-banker relationship
in one of its various manifestations,
such as debtor and creditor, trusteeship, agency, bailment or as an account-holder. All these forms of relationship emerge from the formation of contract between
the customer and the banker.
Hence, it is pertinent to elaborate on the nature and essentials of a contract
under the Indian Contract Act, 1872.
CONCLUSION
Today, Banking frauds is a critical issue before the Country. but the
pace of development for an effective mechanism to fight it, is Negligible. Banking frauds affect
the modern quality
of life and imposes a
detrimental effect on the national growth. A number of Strategies can be
developed by both the Reserve Bank of India
(herein After referred
to as RBI) and Government of India to curb the menace of Banking Frauds. However,
these strategies can only be effective if they strengthen the development of a more effective
banking system, in fact, within the banking system fraud is one of
the areas which need immediate
urgent attention.
[1] See, the statutory definition of “banking’ under the Banking
Regulation Act, 1949,
Section 5 (b).
[2] See, The Contract
Act, 1872, Section
17. Define Fraud
[4] The Indian Penal Code,
1860, See Section.
378.
[5] he Indian Penal
Code, 1860, Section
390; for more details. See infra Chapter
IV Of the study.
[6] The Negotiable Instruments Act, 1881, Section
10 provides that ‘paymet in due Course’ means
payment in accordance with the apparent tenor of the instrument In good
faith and without negligence to any
person in possession thereof under Circumstances which do not afford a reasonable ground for believing that he is
Not entitled to received payment of the amount there in mentioned.
[7] Sanjeev Sharma, “Banks Face
Growing Pressure to Clean Up their NPAs”, The tribune, April, 2013: sidhartha, “Banks Prefer Settling
Dues to Recovery”, The Times of India,
March 23, 2013:
anshul Dhamija, “Banks Test Personal Guarantees”, The Times
of India, April 6, 2013.
[8] Ibid
[9] “Beware Loan Defaulters! Banks to Publish
Photos in Newspapers”, The Tribune, March 11, 2013; “PS Banks Asked to Take Steps to Recover
Loans”, Stalled Projects Cause of Concern, Says
Finance Minister”, The Tribune,
March 19, 2013.
[10] For more details See; The Negotiable Instruments Act, 1881, Section 4.
[11] Ibid – Sec.5
[12] Ibid- Sec.6
[13] PrafuUa Marpakwar, “Cyber
Fraud Costs Banks Rs. 130 Crore
in 3 Years”, The Times of
India, February 28, 2013.
[14] R. N. Chaudhary, Banking
Laws, 10-1 l(Central
Law Publication, Allahabad, 1ST edition 2009).
[15] This Act has made various
provisions to control money-laundering and Government initiatives have set up the Financial Intelligence Unit (FIU) to trace any
financial transaction up to one Crore rupees
in a month or cash
transactions upto ten lakh rupees
in a month.
[16] “Laundering Charge stings
three top banks”,
The Times of India, March 15, 2013
[17] In case of a Civil Wrong,
the injured party i.e. the plaintiff brings the suit again the wrongdoer
i.e. the defendant for the main remedy namely damages.
[18] In case of Criminal Wrong, the
State initiates the action against the accused for punishing him. The injured party i.e. the victim however
does not get any compensation.
[19] Criminal Law
is that part of the law which
deals with the definition, and punishment of crime and with accused of crime; that branch
or division of law which defines crimes, treats of their nature, and provides for their punishment their nature,
and provides for their
punishment.
[20] Id., Sections 23, 24, 25,
28, 29, 29A, 30
[21] Id., Sections
230-254.
[22] Id., Sections 378, 383, 390, 391, 405, 415, 463.
[23] Id., Sections
489A-489E.
[24] Quoted by V. Krishnamchari et al, (Rev. and Enlarged), T.S. Venkatesa Iyer’s
The Law of Contracts &
Tenders, Vol. 1, 3 {S. Gogia & Company, Hyderabad, 6th edn., 1994).
Article Information
BANKING FRAUDS IN INDIA
Authors: TANVI GOYAL
- Journal IJLRA
- ISSN 2582-6433
- Published 2023/06/14
- Issue 7
About Journal
International Journal for Legal Research and Analysis
- Abbreviation IJLRA
- ISSN 2582-6433
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