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EVALUATING THE REVERSE ONUS CLAUSE AND REFORMATIVE ASPECT IN NDPS ACT,1985
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EVALUATING
THE REVERSE ONUS CLAUSE AND REFORMATIVE ASPECT IN NDPS ACT,1985
AUTHORED BY
- PRIYANKA. C
LLM- I Year
(Criminal law and criminal justice administration)
Tamil Nadu
Dr. Ambedkar Law University- School of Excellence in Law
Abstract
The most sacred principle of criminal
jurisprudence remains undisputed for aeons. It is many criminals may escape the
clutches of law but not even one innocent shall be punished. In a recent
judgment, the honourable high court has stressed upon the principle stating,
“99 culprits can escape but not one innocent shall be punished.”[1] The
rationale behind the principle is to protect the accused person from the powers
of the state. To prevent the suppression of the accused by the mighty state,
the burden of proof is always upon the shoulders of the State. This principle
can be understood by the Latin maxim “actori incumbit onus probandi.” One of
the recent developments in the criminal jurisprudence arena is the contravention
of the above said principle – reverse onus clause. The burden of proof is
shifted on the accused to prove his innocence. From the commencement of the
trial, the presumption is that the accused is guilty. Narcotic Drug and
Psychotropic Substance ,1985 is one of such legislation which incorporates
reverse onus clause. This article evaluates reverse onus clause and the
reformative approach adopted by the Narcotic Drug and Psychotropic
Substance,1985.
Keywords: burden of proof, reverse onus clause, reformation,
rehabilitation, constitutionality
INTRODUCTION
Presumption of innocence is one of
the fundamental principles followed across the globe which ensure fair and just
trial in criminal jurisprudence. This principle can be seen in many
international conventions such as International Covenant on Civil and Political
Rights[2]
and the European Convention on Human Rights[3].
It is most important because it is better to allow a man who is guilty to walk
free than convicting and punishing an innocent. This principle is invaluable as
it protects an accused in an unequal playing field opposed against the mighty
state and its system. The state is under an obligation to prove the crime and
guilt beyond any reasonable doubt. It can be, in other words, termed as burden
of proof. Simply explained as, this principle dictates the party who bears the
burden to prove certain facts during the trial. The ultimate burden of proof
lies on the prosecution to prove their claim beyond any reasonable doubt and not
preponderance of probability. Conviction in a criminal trial result in
depravity of life and personal liberty, thus this principle acts as a cautious
step to prevent any erroneous conviction. With the introduction of reverse onus
clause, the intent behind this principle is defeated. This paper evaluates the
reverse onus clause to Narcotic Drug and Psychotropic Substance Act,1985, its
constitutionality and reformative approach in the said Act.
GENERAL
PRINCIPLE OF CRIMINAL JURISPRUDENCE
The principles followed in criminal
jurisprudence can be summarised as following:
1. Innocence until proven guilty.
2. Burden of proof on prosecution to
prove beyond reasonable doubt.
3. When not proved beyond any reasonable
doubt, benefit of doubt given to the accused.
4. Onus of proving general or special
exception is on the accused. Only preponderance of probability enough.
5. Nine criminals go unpunished but not
one innocent be punished.
It can be observed that the prime
principle followed is the presumption of innocence of the accused. The burden
is on the prosecution to prove a rational nexus between the actus reus and
mens rea on the part of the accused beyond the reasonable doubt to ensure
conviction of the accused. It must be noted that the prosecution must prove
beyond any reasonable doubt and the accused must create a reasonable doubt in
the minds of the court to rebut the claims charged against him.[4]
This principle can be seen as the balance to limit the limitless power of the
state in convicting any accused without confirming his guilt. Most of the
criminal trial system tend to adhere to the above-mentioned principle to
warrant for fair, just and even-handed trial between the accused and the
influential state.
When it comes to India, the
presumption of innocence is a human right[5]
and more specifically told, the presumption of innocence is a fundamental right
guaranteed under Part III of the Constitution of India[6].
It is highly difficult to separate the presumption of innocence from the right
to fair trail which is incorporated in the Article 21[7] of
Constitution of India[8]. In
D. Rama Subba Reddy v. P.V.S. Rama Das, the court emphasised on the onus
to prove everything being on the shoulders of the prosecution. The court
quoted,” it is the fundamental doctrine of
criminal law relating to onus of proof that the prosecution must establish all
the ingredients of the offence with which the accused was charged, by
independent evidence for convicting the accused, irrespective of the fast
whether the accused is able to adduce evidence bringing his case within any one
of the exceptions, or not. The nature and the extent of the onus of proof that
lies on the prosecution to prove the guilt of the accused is absolute”[9]
the following list of cases decided by the Indian Judiciary highlights the
presumption of innocence of accused until proven guilty. Like
England, India too has a presumption of innocence for the accused, and as the
court noted in K.M. Nanavati v. State of Maharashtra[10],
it is the prosecution's responsibility to establish the accused's guilt. Similarly
in Babu v, state of Kerala[11]
restated that the principle of presumption of innocence is a human right[12]. “For
this purpose, the nature of the offence, its seriousness and gravity thereof must
be taken into consideration. The courts must be on guard to see that merely on
the application of the presumption, the same may not lead to any injustice or
mistaken conviction.”[13]
In every legal society, wrongful conviction is seen as far searing injustice
than acquitting a criminal[14]. The
presumption of innocence until proven guilty is constitutionalised in many
countries like Canada and South Africa. The Canadian Charter of Rights and
Freedoms has recognised the presumption as s fundamental right[15].
The Constitution of South Africa in Section 35(3)(h) [16] has given the presumption, the constitutional
status as fundamental right. In United States, there is no clear mention of
presumption of innocence in the Constitution but the court in Samuel Winship[17]
held that for compelling reasons, the burden of proof must be proven beyond a
reasonable doubt to proceed with a criminal case. The accused is one of the
most important parties involved in a criminal case, not only because he stands
to lose his freedom if found guilty but also because a conviction would
undoubtedly result in stigma. As a result, a society that respects each
person's integrity and right to privacy should not hold someone accountable for
a crime they have committed if there is a legitimate basis to suspect their
guilt. It incorporated the presumption of innocence-implying due process of law
requirement of proving anything beyond a reasonable doubt. When India is
concerned, the Supreme Court in Maneka Gandhi v. Union of India[18], the
court asserted that the ‘procedure established by the law’ as encompassed under
Article 21 of the Constitution of India, deprivation of life and personal
liberty must be ‘just, fair, reasonable and right’. In the later period of
Indian Judiciary, the court verified that ‘procedure established by the law’
includes due process of law as recognised in the US Constitution.
REVERSE
ONUS CLAUSE
The Supreme Court of
United States in the case of Coffin v. United States[19]
highlighted the following to show that it was substantially embodied in the
law of Sparta and Athens, "Let all accusers understand that they
are not to prefer charges unless they can be proven by proper witnesses or by
conclusive documents, or by circumstantial evidence which amounts to
indubitable proof and is clearer than day”[20].
There are many references which supports the presumption of the innocence and
milder construction in case of doubts. "A passionate man,"
Delphidius, could not contain his emotions when he saw the allegation would not
succeed. He cried, "Oh, illustrious Caesar, if it is sufficient to deny,
what hereafter will become of the guilty?". To which Julian retorted,
"If it suffices to accuse, what will become of the innocent?"[21]
this exchange shows two polar ends of how an accused can be brought to justice.
Even though the presumption lies on the prosecution, there is a reverse onus
clause which places the burden of proof on the accused to prove his innocence.
He is presumed to be guilty until he proves his innocence. Like presumption of
innocence, the presumption of guilt is also recognised in the statute of Indian
Law. The presumption of innocence is so highly regarded that it is hard to
imagine the "golden thread[22]"
norm ever being broken. When the presumption of guilt is recognised, it also
results in the dilution of prosecution’s burden to only establish a minimum
threshold of actus reus. The burden of proof shifts to the accused, who
is tasked with proving the lack of mens rea once he presents enough evidence.
The accused will be found guilty if this reverse persuasive burden is not met.
This means that, unlike a reverse evidential burden, where the prosecution's
duty does not finish with the shift of the burden to the accused, a reverse
persuasive burden does.[23]
JUSTIFICATION
OF REVERSE ONUS CLAUSE
The ultimate desire of any civilised
society is to ensure the punishment of guilty person as it satisfies the starvation
for the justice and shows compassion to the victims of the crime. To achieve
this, we now and then, take on short route which is legalised based on
increasingly lower conviction rates. There are seen at first in socio economic
crimes where the victim is not identified as a single individual but the entire
society who is affected. Other statutes
which have reverse onus clauses are those of anti-national themes. Some
statutes which employ reverse onus clause on the pretence are Food Adulteration
Act, 1954, Section 10(7-B); the Customs Act, 1962, Section 123,138A and 139;
the Essential Commodities Act, 1955, Section 10C; the Foreign Exchange
Management Act, 1999, Section 39; the Narcotic Drugs and Psychotropic
Substances (NDPS) Act, 1985, Section 35, 54 and 66; the Wealth Tax Act, 1957,
Section 35-O; and the Prevention of Corruption Act, 1988, Section 20; the
Indian Evidence Act, 1872, Section 113A and 113B. The justification given to
the presumption of guilt is always based on the magnitude of crime that is
expected to suppress and the effect it has the society. public interest and
swift delivery of justice is the key arguments advanced to justify the reverse
onus. The law commission report,1972 suggested that certain offences obliterate
health and material welfare of the society in its entirety such as drugs
related offences and many more [24]. The
injury a society facing due to these offences are far greater than traditional
crimes. Therefore, adhering to traditional methods to incriminate the criminal
and regulate the crimes may become difficult. The supporters of this principle
often take shade in the shadow of the idea, it will be difficult to prove facts
which are within exclusive knowledge of the accused. The ultimate object of the
principle of reverse onus clause is same as that of presumption of innocence in
its ordinary course i.e., “fair balance between the general interest of the
community and the personal rights of the individual”[25].
The presumption of innocence ordinarily places far greater responsibility on
the prosecution and favours accused’s rights. But the presumption of guilt
favours law enforcement and that state. There are required to establish the actus
reus and the burden shifts on the accused to prove the absence of mens
rea.
EVALUATION
OF REVERSE ONUS CLAUSE IN NDPS ACT
Narcotic Drug and Psychotropic
Substance Act,1985 (NDPS) contains reverse onus clause in Section 35, 54 and 66
legalising the presumption of the guilt. The provisions can be summarised in
following words;
SECTION 35: PRESUMPTION OF CULPABLE
MENTAL STATE; The court
presumes the existence of a culpable mental state in any prosecution for an
offense requiring it, but the accused can defend themselves by proving they did
not have such a mental state in relation to the charged act. "Culpable
mental state" includes intention, motive, knowledge of a fact, and belief
in a fact. A fact is proven only when the court believes it exists beyond a
reasonable doubt, not just by a preponderance of probability.
SECTION 54[26]:
PRESUMPTION FROM POSSESSION OF ILLICIT ARTICLES; In trials under this Act, it is
presumed that the accused has committed an offense related to a narcotic drug,
psychotropic substance, or controlled substance, an opium poppy, cannabis
plant, or coca plant growing on their land, a specially designed apparatus or
group of utensils for the manufacture of such substances, or any materials that
have undergone any process towards the manufacture of such substances or
residue left of the materials, for which the accused fails to account
satisfactorily.
SECTION 66: PRESUMPTION AS TO
DOCUMENTS IN CERTAIN CASES; If a document is produced, furnished, seized, or
received from outside India during an investigation of an offense under this
Act or any other law, and is tendered in a prosecution as evidence against the
person or another person who is tried jointly, the court must presume that the
signature and other parts of the document are in the handwriting of the person,
unless the contrary is proven. If the document is executed or attested, the
court must assume it was executed or attested by the person by whom it purports
to have been executed or attested. If the document is not duly stamped, it can
be admitted in evidence. The court must also examine the document's contents if
circumcontrary is proved.
It can be
understood from the words of the statute that the intention of the legislature
to make stringent measures to prevent drug related offences and ensure
conviction. The constitutionality of these provisions has been raised in the
past where the court has upheld its constitutionality. The presumption of
innocence is a human right as defined by Article 14(2) of the international
covenant on civil and political rights, according to the Supreme Court's ruling
in Noor aga v. State of Punjab[27].
It cannot, by itself, be equated with the fundamental right to liberty
guaranteed by Article 21 of the Indian Constitution. Considering its scope, it would
not conflict with other legal requirements (which, naturally, must be
interpreted in the context of the fundamental rights outlined in Articles 20
and 21 of the Indian Constitution). Regarding sections 35 and 54 of the NDPS
Act of 1985, the Supreme Court ruled in Noor aga v. State of Punjab[28]
that the reverse onus provision does not go beyond the bounds of the constitution.
The court determined that reverse burdens are constitutional and that they are
supported by social control issues as well as policy considerations. although
it was acknowledged that the presumption of innocence was a component of
individual liberty, Sinha. J held that to ensure the security of the state,
individual liberty must be subject to social interest. He believed that the
constitutionality of a penal provision should be examined considering the
state's obligation to protect innocent citizens, and that, as a result, the
accused's right and the interests of society should be balanced. The court has
clearly stated that “An initial burden exists upon the prosecution and only
when it stands satisfied, the legal burden would shift. Even then, the standard
of proof required for the accused to prove his innocence is not as high as that
of the prosecution. Whereas the standard of proof required to prove the guilt
of accused on the prosecution is "beyond all reasonable doubt" but it
is `preponderance of probability' on the accused. If the prosecution fails to
prove the foundational facts to attract the rigours of Section 35 of the Act, the actus reus
which is possession of contraband by the accused cannot be said to have been
established. With a view to bring within its purview the requirements of Section 54 of the Act, element of
possession of the contraband was essential to shift the burden on the accused.
The provisions being exceptions to the general rule, the generality
thereof would continue to be operative, namely, the element of possession will
have to be proved beyond reasonable doubt. Whether the burden on the accused is
a legal burden or an evidentiary burden would depend on the statute in
question. The purport and object thereof must also be taken into consideration
in determining the said question. It must pass the test of doctrine of
proportionality. The difficulties faced by the prosecution in certain cases may
be held to be sufficient to arrive at an opinion that the burden on the accused
is an evidentiary burden and not merely a legal burden. The trial must be fair.
The accused must be provided with opportunities to effectively defend himself.”
Section 35 & 54 of the N.D.P.S Act outlines the rule of conscious
possession in prosecutions for offences where the mental element is of primary
importance. The court presumes a mental state, which is open to the accused to
rebut by proving they had no such mental state in relation to the offense. The
court must prove a fact that will only be proven when the prosecution can prove
its case beyond a reasonable doubt.
The court is bound to presume a mental state, such as intention, knowledge, or motive, in prosecutions for offences where culpable mental state is required. The accused could rebut this presumption by adducing evidence in their favour. The prosecution is only required to prove physical possession, or control over the illicit article, beyond a reasonable doubt. The onus shifts to the accused to prove their innocence, as it is on the accused as to how they came to possess the article. The Supreme Court observed that it is practically impossible for the prosecution to prove the 'knowledge', as the accused's knowledge of how they came in the physical custody of the contraband is within their knowledge[29]. Section 35 only applies when the prosecution has proven all essentials beyond reasonable doubt against the accused. In Madan Lal and Ors. V. State of Himachal Pradesh[30], the court held that once the possession of substances prohibited under NDPS Act was established, it would be presumed as conscious possession.
The court is bound to presume a mental state, such as intention, knowledge, or motive, in prosecutions for offences where culpable mental state is required. The accused could rebut this presumption by adducing evidence in their favour. The prosecution is only required to prove physical possession, or control over the illicit article, beyond a reasonable doubt. The onus shifts to the accused to prove their innocence, as it is on the accused as to how they came to possess the article. The Supreme Court observed that it is practically impossible for the prosecution to prove the 'knowledge', as the accused's knowledge of how they came in the physical custody of the contraband is within their knowledge[29]. Section 35 only applies when the prosecution has proven all essentials beyond reasonable doubt against the accused. In Madan Lal and Ors. V. State of Himachal Pradesh[30], the court held that once the possession of substances prohibited under NDPS Act was established, it would be presumed as conscious possession.
REFORMATIVE
ASPECT IN NDPS
The NDPS
Act, 1985 aimed to control and punish drug traffickers while providing health
and welfare services for users, but many provisions hinder their
implementation, leading to excessive time and resources spent by law enforcement.
Whenever reformation
aspect of NDPS Act,1985 is to be evaluated we need to analyse the history of
enactment of the Act and its objective. Narcotic Drugs and Psychotropic
Substance Act, 1985 was enacted after 25 years into India signing the Single
Convention on Narcotic Drug treaty, 1961. When the act was ratifies by India,
the ultimate objective of the Legislative enactment is to deter the use of drug
and its trafficking. Thus, it casted a blanket prohibition on any activities
related to drug such as manufacture, production, use, trade, sell and
consumption except for medical purposes. The 1985 Act prescribed minimum
punishment of six-month imprisonment for all the individual who had found in
possession of Narcotic drugs and may extend to 30 years. The Act also
prescribed mandatory capital punishment for repeated offenders. However, in
2011, in an unprecedented judgment, the Hon’ble High Court struck down the
mandatory capital punishment for drug offences becoming the first Court in the
world to do so. In the Indian Harm Reduction Network v. Union of
India case, Ghulam Mohammad Malik was sentenced to death for smuggling
charas in 2008. The IHRN challenged the mandatory death penalty, arguing it was
arbitrary, excessive, and disproportionate to drug dealing. The Mumbai High
Court declared Section 31A of the NDPS Act unconstitutional, indicating the
court's recognition of human rights principles and harm reduction in relation
to drugs. The President of IHRN praised this positive development. However,
Narcotic Drug and Psychotropic Substance Amendment Act,2014 has made capital
punishment as discretion of the court to award in rarest of rare cases[31].
Death cannot be seen as the reformative approach to drug related offences. But
the Act is not void of rehabilitation and reformation to drug addicts.
·
Section 64A[32]:
The provision can be understood as an addict charged with a small quantity of
narcotic drugs or psychotropic substances can voluntarily undergo medical
treatment for de-addiction from a recognized institution, but this immunity
from prosecution can be withdrawn if the addict does not complete the
treatment.
Section 71[33]:
The government has the authority to establish and approve centres for the
identification, treatment, management, education, after-care, rehabilitation,
and social re-integration of addicts. These centres may also supply narcotic
drugs and psychotropic substances to registered addicts and others as medical
necessity. The government can establish rules for the establishment,
appointment, maintenance, management, and superintendence of these centres, as
well as the appointment, training, powers, duties, and personnel employed.
The NDPS
Act's foundation is flawed in its assumption that punitive measures deter drug
trafficking and use, leading to individuals being pushed to the margins of
society due to their wrong side of the law. therefore, they still lack adequate
reformative measures to reduce drug related offenders and facilitate
rehabilitation.
SUGGESTION
TO FACILITATE REFORMATION
The
following can be implemented to achieve the objective of drug free society
1.
The decriminalisation of Section 27 from the Narcotic
Drugs and Psychotropic Substance Act (NDPS Act) is a response to the increasing
prevalence of drug use and addiction, particularly in India. The NDPS Act,
which provides stringent penalties for drug use, has not effectively deterred
drug use. India has the largest number of repeat offenders, with 63% of
prisoners having a history of drug use and 23% apprehended for drug-related
offenses. In contrast, countries have moved towards full decriminalization of
drug use and possession, with no reported negative consequences on individuals
and society. Studies show a significant decline in petty crimes related to drug
consumption, HIV incidence among injecting drug users, and reduction in
recidivistcrimes.
India also faces an alarming spike in the consumption and injection of illicit drugs among young adults and teenagers, particularly synthetic drugs like heroine, ephedrine, and methaqualone. Incarceration of drug users and subsequent criminal charges destroys their rehabilitation or re-integration into society. The proposal recommends the deletion of Section 27, which prescribes incarceration for drug consumers, and advocates for evidence-based harm-reduction approaches and counselling as an alternative to incarceration. One viable alternative is to divert nonviolent felony drug offenders to community-based residential treatment facilities.
India also faces an alarming spike in the consumption and injection of illicit drugs among young adults and teenagers, particularly synthetic drugs like heroine, ephedrine, and methaqualone. Incarceration of drug users and subsequent criminal charges destroys their rehabilitation or re-integration into society. The proposal recommends the deletion of Section 27, which prescribes incarceration for drug consumers, and advocates for evidence-based harm-reduction approaches and counselling as an alternative to incarceration. One viable alternative is to divert nonviolent felony drug offenders to community-based residential treatment facilities.
2.
The NDPS Act currently uses the term
"addict," which is considered stigmatizing by the scientific
community. However, all provisions for "addicts" equally apply to
those who consume narcotic drugs and psychotropic substances without addiction.
The term should be replaced with generic terms like "people affected by
drug," "person with drug disorder," and "drug user."
3. Section 35 which deals with
presumption of culpable mental state, the burden of proof can be justifies on
the effective measure to control illicit trafficking. However, there can be an
exception to individual drug users where prosecution has burden of proof to
prove guilt.
4. Section 64A provides immunity from
prosecution to addicts volunteering for the treatment. This proves reformative
only for drug addicts and initial drug user who is convicted under this Act may
be send to prison where it is hardly a place for reformation. There are
instances where a separate drug cartel running inside the prison. In such
circumstance the convict may be influenced by hardcore criminals and develop
severe drug addiction and related illicit activities. Therefore, the section
should also include drug user and those with drug disorder.
5. Referring a person having drug disorder
to treatment by any authorised officer under the Act.
CONCLUSION
Whenever the validity of reverse onus
clause is questioned, the Supreme Court tried to employ Ronald Dworkin[34]’s
adjudicative principle of integrity which signifies the fairness and justice in
determining the rights of the citizens. He tests legislation from society’s
current commitment to a political morality and legal principles. On such basis,
the reverse onus clause contravenes the fundamental principles of the criminal
jurisprudence. The reformative measures adopted by the Act is inadequate and
requires further amendments. Presumption of culpable mental state should be
toned down and reformation must be the goal and not punishing the offender.
Punishments fail to create the desired deterrent effect among the society as
the crime rate of drug related offences tend to increase every day.
[1] Pinkoo alias Jitendra v. State of
UP (2022)
[3] Article 6(2): Everyone charged
with a criminal offence shall have the right to be presumed innocent until
proven guilty according to the law. The words are identical to that of ICCPR.
[4] Victor Tadros & Stephen
Tierney, The Presumption of the innocence and the Human Rights Act, 2004
[5] Narendra Singh v. State of Maharashtra
2004 SCC (Cri) 699
[6] Noor Aga v. State of Punjab (2008)
16 SCC 417
[7] Constitution of India, Article 21:
No person shall be deprived of their life except according to procedure established by law.
[9] D. Rama Subba Reddy v. P.V.S. Rama Das 1970 Cr.L.J.
83
[10] AIR 1962 SC 605
[11](2010) 9 SCC 189
[12] Narendra Singh v state of MP
(2004) 10 SCC 699
[13] Binoy Kumar Mishra v State of
Jharkhand (2017) 13 SCC 636
[14] Van der Meer v. The Queen (1988)
82 A.L.R. 10, 31
[15] Canadian Charter of Rights and
Freedoms,1982 Art 11(d)
[16] Every accused person has a right
to a fair trial, which includes the right to be presumed innocent, to remail
silent, and not to testify during proceedings.
[17] 25 L Ed (2d) 368
[18] (1978) 1 SCC 248
[19] 156 U.S. 432 (1895)
[20] Quote by Mascardius Do
Probationibus
[21] Coffin v. United States 156
U.S at page 455
[22] Woolmington v. Director of
Public Prosecutions (1935) UKHL 1
[23]Bryon M. Sheldrick, “Shifting
Burdens and required Inferences: The Constitutionality of Reverse Onus Clauses,”
Univ. Toronto Fac. L. Rev (1986) 44(2) at pages 181-182
[24]Law Commission on India, “47th
Report- The Trial and Punishment of Social and Economic Offences”
[25] Brown v. Scott (2003) 1
A.C. 681
[26] Subs, by Act 9 of 2001, s.25, for sec.
54 (w.e.f. 2-10-2001)
[27] 2008 AIR SCW 5964
[28] ibid
[30] 2003 7 SCC 465
[31] AIR 1980 SC 898
[32] Immunity from prosecution to
addicts volunteering for treatment
[33] Power of Government to establish
centres for identification, treatment, etc., of addicts and for supply of
Narcotic drugs and psychotropic substances.
[34] Ronald Dworkin, LAW’S EMPIRE 218 –
219, 225-254 (1986)
Article Information
EVALUATING THE REVERSE ONUS CLAUSE AND REFORMATIVE ASPECT IN NDPS ACT,1985
Authors: PRIYANKA. C
- Journal IJLRA
- ISSN 2582-6433
- Published 2024/04/01
- Issue 7
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