Open Access Research Article
HARSHAD MEHTA VS CBI AND FACTS WHICH NEED NOT BE PROVED
Published Paper
Article Details
HARSHAD
MEHTA VS CBI AND FACTS WHICH NEED NOT BE PROVED
AUHTORED BY
- ASHISH SHUKLA
1. INTRODUCTION:
Harshad Shantilal Mehta, along with
other bankers and politicians, engaged in manipulating the markets on the
Bombay Stock Exchange, which culminated in the 1992 Indian stock Market
deception. The scam duped investors of more than 10 Million USD and severely
impacted stock-market.
Mehta employed a variety of
strategies, such as manipulating market vulnerabilities, having dishonest officials sign fictitious
checks, and fabrication, to inflate stock values up to forty times their initial value. Stock traders
who profited handsomely from the scheme were able to deceitfully apply for bank unsecured
loans. The Indian
stock market crashed
in April 1992, the same banks found themselves holding
millions of Indian rupees (INR) in worthless debt, and this was before the scheme
was exposed.
SEBI was given less jurisdiction in
1988. Its primary duties included overseeing the securities industry and ensuring its steady
expansion. SEBI had no authority over the transactions that took place between
brokers and investors. But things changed
with the Harshad
Mehta Securities scam.
In 1990, stockbroker Harshad Mehta
founded "Grow More Research & Asset Management Limited," a securities company. In the marketplaces, he was well-known and respected. Mehta was
regarded as the "Sultan of Dalal Street," and investors dutifully
followed in his footsteps. Mehta manipulated the stock prices
of specific shares
on the scrip for his own financial
benefit by abusing his position.
Essentially, Harshad Mehta made
significant financial investments in a specific share. The other investors and shareholders made an
investment in the same shares after witnessing him make one. This led to an abnormal inflow of capital into the
stock markets, which raised the price
of these shares on the script. The Bull Run, an artificial increase in stock
values, was the outcome. During the course of one year (1991–1992),
this Bull Run[2] caused the share price
of companies like Associated Cement Company (ACC), the first company in
which Mehta made an investment in the stock markets, to soar by 4400% from Rs. 200 to Rs. 9000.
The aforementioned activity, while unethical, was not unlawful;
rather, the issue
stemmed from Mehta's
usage of bank funds to obtain capital
for stock market
investments. Mehta invested
the money that banks granted
him to buy government securities that were held by other banks. (Issuance of bogus Bank Receipt in exchange of securities with the bank and manipulation in SGL, i.e. Subsidiary General Ledger.)
Furthermore, some banks were using
these receipts for forward transactions, meaning that When the crash happened, the securities that Bankers' Receipts
were scheduled to be issued against
could not be squared. Even if the number of people arrested appears to be
small, it is now evident
that these activities were common, involving
not only a small number of institutions but the majority
of the banking industry, with a disproportionate number of foreign
and private sector banks implicated. (CitiBank and Kolkata Mandi Group, i.e. Manu Mandra & ORS.)
On a different note, banks were able
to secure substantial funding for their trading operations, as well as to increase deposits from
public sector organisations and the corporate sector, through the Portfolio Management Schemes (PMS) administered by
the government, which allowed short-term deposits to be transferred to banks. Due to government economic dominance,
private capital is now somewhat reliant on bureaucratic and political
favouritism. The financial markets were well aware of the political
influence and kickback
scheme in place to get the majority of these deposits.
It
is now established that these actions have been carried
out for a considerable amount
of time in defiance of RBI regulations to on the other hand. There is a
few-day lag between the registration
of security transfers between banks and the movement of funds against bankers' receipts
since accounting in securities transactions is done manually. This gave brokers
and the banks they represented a motivation as
well as the opportunity to benefit from the cash in the interim. (Concept of Bankrage.)
Mehta possessed 50 lakh shares in
over 130 businesses. He sold the majority of his shares to avoid prosecution after the well-known
journalist of the day, Sucheta Dalal, exposed his swindle. The investors sold their shares because they
believed Mehta had deceived them.
Because of this relentless selling,
the markets lost Rs. 0.1Million in 1day.
Due to its lack of jurisdiction to
control the exchange of information between brokers and investors, SEBI was limited. The Central Bureau of Investigation was the sole agency with the authority to investigate the situation.
Mehta established the Damayanti
Group, a network
of front firms,
in an attempt to re-enter
the markets in 1997. The 1990 securities company owned by Mehta was housed in the same office as this
group.
Mehta hired brokers and agents to purchase and sell shares
on his behalf at the stock exchange. in order to get paid. Harshad Mehta even succeeded in locating
businesses (such as BPL, Videocon, and Sterlite Industries).
Mehta continued to
invest significant sums of money in particular stocks in an attempt to trigger a bull
run. But SEBI and investors were now
too savvy to be duped by Harshad
Mehta.
Due
to Suspicious activity
surrounding the abrupt
rise in some scrip share prices in 1998, SEBI
launched an investigation. Through phone
bills, payments to solicitors, investment information and other
means, they were able to connect Damayanti Group to Harshad Mehta and his accomplice.
Court associates Harshad Mehta
and others. Before
he could hurt investors and manipulate the markets,
Harshad Mehta was restrained by SEBI. After a decade of significant expansion, SEBI was well
positioned to assume the role of market watchdog.
4. Janikiraman Report Of RBI:
i.
On the basis of the preliminary examination made by
the RBI officials, it has been found that:
ii.
The following banks, subsidiaries of banks and
institutions have made payments for purchase of investments for which they do
not hold either Securities, SGL forms or BRs to the extent indicated below:
iii.
National Housing Bank (NHB) 1199.39 State Bank of
Saurashtra SBI Capital Market Ltd. 175.04 121.23, Standard Chartered Bank
300.00, Total Amount in Crores.1795.66.
iv.
The transactions that were put through NHB's
intermediary and are still pending have, at least on the surface, something to
do with the broker, Shri Harshad S. Mehta, and/or Growmore Research and Assets
Management Ltd., his associate company. This is demonstrated by the fact that
nearly all of the A/C payee checks that NHB used to make payments to the
company banks were collected and credited to Shri Harshad Mehta's current
accounts at SBI and ANZ Grindlays Bank. The payee checks were drawn on the RBI.
v.
Shri Harshad Mehta has been involved in a significant
amount of SBI transactions on its own investment account, totaling over Rs.
17,000 crores between July 1, 1991, and April 6, 1992. Furthermore, it appears
that a number of Shri Harshad Mehta's transactions in his current SBI account
were processed improperly. A connection exists between the broker Shri Harshad
Mehta and the transactions processed by Stale Bank of Saurashtra and SBI Caps.
vi.
In the instance of UCO Bank, the bank discounted debts
totaling Rs. S0.40 crores. These bills most likely dealt with the shares that
the broker, Mrs. Jyothi H. Mehta, who is the wife of Shri Harshad Mehta, sold
to affiliate companies. It is evident from the way this transaction was handled
that it was a definite advancement towards resolving the related issues. These
worries seem to have been transferred into funds upon maturity in order to pay
off the debts through UCO Bank's acquisition of shares from Shri Harshad Mehta
at a total cost of Rs. 49.S0 crores. On April 8, 1992, the UCO Bank had already
acquired shares from his holdings at a total cost of Rs. 12.2S crores. In
contrast to the current market value is only about Rs. 40 crores, despite the
total cost of Rs. 61.75 crores
·
Second Interim Report
July’1992[5]:
A. The total
value of investments made by banks and institutions for which they do not hold
either securities, SGL transfer forms or BRs has on further scrutiny been
determined to be as under :
B. To put it
briefly, the following formula can be used to determine the overall extent of
the problem exposure in securities transactions:
C. Total value
of investments made by banks and institutions for which they do not hold any
securities, SGL transfer forms or BR is of Rs. 1967.84 Crore as per Bifurcation
mentioned below.
|
1.Bank/Institutions.
|
2.Acquisition cost. (crs.)
|
3.Bank/Institutions To whom
payment was made.
|
4.Account to which
Amount Received was credited.
|
|
National Housing Bank
(NHB)
|
1271.20
|
1.SBI-707.56
2.ANZ-506.55
Grindlays Bank 3.Standard Charted- 55.18
4.Canfina-1.91
|
Harshad Mehta and Growmore Asset
management Co.ltd
|
|
State Bank Of Saurashtra (SBS)
|
174.93
|
1.SBI -99.11
2.NHB- 75.82
|
Harshad Mehta (through SBI)
|
|
SBI Caps
|
121.36
|
SBI-121.36
|
Harshad Mehta
|
|
Stanchart
|
400.35
|
Under Investigation
|
|
A. The bank's
preparation of the SBI's investment reconciliation has shown a deficiency in
investments totaling Rs. 650 crores. In response, the bank obtained from Shri
Harshad Mehta Rs. 622.52 crores, which it then used to buy securities worth Rs.
624 crores and treasury bills for Rs. 21 crores. Thus, there is a Rs. 5 crore
unresolved shortfall. An investigation is being conducted on the bank's
reconciliation.
B. At the
request of Shri Harshad Mehta, SBI issued SGLs on its account with the PDO and
deposited SGLs that were delivered by Shri Harshad Mehta into the same account.
The money received for SGLs issued and the payments made for SGLs received have
been credited and debited from Shri Harshad Mehta's account; there is no record
of these transactions in the SBI books. To this sense, it appears that Shri
Harshad Mehta used the funds created by the SBl's investment—which is
represented in its SGL balance with the PDO to finance ready-to-close
agreements with other banks. From April 1, 1991, to June 22, 1992, the entire
face value of SGL forms that were delivered from the entire face value of SGL
forms put in the SGL account in this way added up to Rs. 6712.67 crores and Rs.
7282.89 crores for the SGL account. The Rs. S70.22 crore deficiency most likely
makes up a portion of
the Rs. 622.52 crores that SBI was able
to retrive. The SGL account's entries are still being looked into;
·
Strict guidelines for full transparency were
implemented. The complete disclosure guidelines concerned significant
information, particular risk considerations, prudential guidelines, etc.
·
All listed firms were required to abide by the Listing
Agreement, which was introduced.
·
When a company makes a public offer to buy stocks, a
code of advertisement was developed to make sure that investors are given all
the facts in a trustworthy and honest manner.
·
To improve operational transparency, the National
Stock Exchange (NSE) with its online, screen-based, nationwide electronic
trading was established.
·
The Bombay Stock Exchange (BSE) switched over to
online, screen based trading.
·
A revised “carry forward” system replaced the “badla[6]” system.
·
There were developed guidelines pertaining to the
necessity of full disclosure to SEBI.
·
There were also introduced prerequisites that had to
be met in order to make public offers to buy equities.
6.
Cases on Harshad Mehta after the Scandal got exposed:
·
Harshad Mehta V. C.B.I[7]:
Facts:
Since the
petitioner was detained at Byculla jail in Bombay during the pertinent period,
C.B.I. filed an application for the petitioner's production before Special
Judge Delhi on August 12, 1992, in accordance with Section 267 of the Criminal
Procedure Code. In an order dated August 12, 1992, the Special Judge of Delhi
ordered the Subdt. Jail in Byculla, Bombay, to bring Mr. Harshad S. Mehta
before the court so that he might be questioned in relation to the case's
investigation.
That
on August 17, 1992, the petitioner appeared
before the Special
Judge in Delhi as required
by the aforementioned order. On August 17, 1992, the petitioner in this
case was formally arrested upon production. Remand
from the police
was requested and granted until
August 20, 1992. Police remand was then extended
until August 22, 1992. However, by decision dated August 22, 1992, Mr. Kuldip Singh, Special Judge, Delhi,
remanded the petitioner to judicial custody in Central Jail, Tihar, until
August 25, 1992, instead of granting police remand.
That
on August 17, 1992, the petitioner appeared
before the Special
Judge in Delhi as required
by the aforementioned order. On August 17, 1992, the petitioner in this
case was formally arrested upon production. Remand
from the police
was requested and granted until
August 20, 1992. Police remand was then extended
until August 22, 1992. However, by decision dated August 22, 1992, Mr. Kuldip Singh, Special Judge, Delhi,
remanded the petitioner to judicial custody in Central Jail, Tihar, until August 25, 1992, instead
of granting police remand. That after being transported to Bombay on
August 24, 1992, the petitioner was never seen in front of the Special Judge in Delhi. After August 25, 1992, the
petitioner did not request or receive the remand.
However, Mr.
Saxena, representing the C.B.I., argued that the Supreme Court had held in The Central
Bureau of Investigation, Special Investigation Cell-1 Vs. Anupam J. Kulkarni
1992(2) Crimes that a person
may be formally arrested in a second case if they are already in judicial custody in the first. Therefore, by
notifying the court that accused Harshad S. Mehta has been placed under arrest in this matter,
remand for police custody was requested for a period of seven days. On the CBI's motion, the Court issued an order
remanding the petitioner to police custody
until August 20, 1992. On August 17, 1992, the Court issued a detailed
decision, in which Shri Kuldeep
Singh, Special Judge, stated that after Harshad S. Mehta was brought before him in his court,
the C.B.I. officially arrested him for this crime. Mr. Saxena
argued that the CBI's action was appropriate in light
of the ruling in CBI v. Anupam J. Kulkarni. Because no legal provision prohibits the following arrest in a
different case if there are many cases against
the accused. Furthermore, the petitioner was officially arrested in this case
when he appeared before Shri Kuldeep
Singh, Special Judge, and it was only after his arrest that the court ordered a police remand. As a
result, the clauses under Section 57 of the Cr.P.C. are not being
violated.
It must be acknowledged
that in this instance, neither the remand request nor the necessary police diary was presented to the magistrate after August 25, 1992. Not a single
CBI application explaining why the petitioner wasn't produced after
August 25, 1992. It was therefore unlawful
for him to be detained after August 25, 1992. However, the question that
emerges is whether he was
automatically entitled to bail given the illegality of his incarceration. As
stated in the case of Mahesh Chand Vs. State of Rajasthan, the law is now well established that, in the event that the imprisonment is unlawful, the remedy is a petition
for habeaus corpus
rather than bail.
Even yet, our own High Court's Single Bench Judgement in the Prof.
Darshan Singh case Vs. State in, determined by M.K. Chawla,
J. on October 10, 1986,
wherein bail was granted, taking
this into consideration as a contributing element, however it was not
the primary one. There is no
disagreement with the idea that this may also be taken into account while
determining whether to grant bail.
As far as the legal position is concerned, this is it. In terms of bail, it can only
be given while the subject is being held in custody. However, Mr. Harshad S.
Mehta is not being held in this
matter. Consequently, it was reasonably acknowledged by Mr. Saxena, who was representing the C.B.I., that an
individual who is not in custody cannot be given
bail.
the bail has reached
the point of in-fructuousness.
In light of these observations, the petition is dismissed.
·
R.Venkatakrishnan. V. Crime Branch
Of Investigation[8]:
Facts:
Atul M.
Parekh, Harshad Shantilal Mehta, S.V. Ramanathan, R. Venkatkrishnan, and S.V.
were charged with conspiring to conduct criminal breach of trust and
corruption. Harshad Shantilal Mehta, the fourth accused, was said
to be the
mastermind behind the
scheme. The Indian Penal Code and the Prevention of Corruption Act had
several sections that the accused were charged under. Defendants 6 and 7 were
workers of National Housing Bank and were accused with violating the 1988
Prevention of Corruption Act. In the lower courts, Accused Nos. 1 through 7
contested the legality of the sanction orders.
Issues:
1. Whether the
offence of conspiracy has been proved against the accused? Whether the call
money transactions fall within the scope and ambit of the definition of the
term "securities"?
2. Whether the
routing of call money from National Housing Bank to the account of the deceased
Shri Harshad Mehta who was a stockbroker was contrary to the provision of the
National Housing Bank Act, 1987?
3. Whether the
orders of sanction issued against the accused were valid? Whether the accused
committed criminal breach of trust and corruption?
Decisions:
Accused
number two, R. Venkatkrishnan, was given a six-month term of RI and a two-month
default SI punishment of Rs. one million. S.V. Ramanathan, the third accused,
was given a one-month RI sentence as well as a fine of Rs. 10,000 and a 15-day
SI. Atul M. Parekh, the fifth accused, was fined Rs 10,000 and ordered to
participate in RI for 15 days. lasting fifteen days in default SI. The fourth
accused, the accused Harshad Shantilal Mehta (Harshad Mehta), was said to be
the mastermind behind the entire scheme. In the lower courts, Accused Nos. 1
through 7 contested the legality of the aforementioned penalty orders.
The
Bank's officers were found guilty
of the crime of criminal
breach of trust.
Accused 5 could
not have been found guilty of participating in the conspiracy as claimed
by the prosecution based on the
evidence presented in court, as they were cleared of all criminal accusations
of breach of trust. The National
Housing Bank Act, 1987, clause was broken when call money was transferred from the bank to the stockbroker's account
of the late Shri Harshad
Mehta. The sanctions imposed on the accused were
legitimate and lawful. The defendants engaged in criminal deception
and misconduct.
7. Conclusion on Harshad Mehta Securities Scam:
The Securities Scam of 1992, also
referred to as the Harshad Mehta scam, was a significant financial fraud in the Indian stock market. Stockbroker Harshad
Mehta utilised dishonest techniques
to manipulate the stock values of several firms, and he profited handsomely
from the scheme. In response
to the scam, the Indian
government and regulatory bodies implemented a number of legislative and judicial actions.
·
The
SEBI Act; The Act also gave SEBI the authority
to look into and punish people and
companies that engage in insider trading, price manipulation, and other stock market
fraud.
·
Banking
Regulation Act 1949; By using this Act, the RBI was able to look into and punish banks that had given loans to
Harshad Mehta and his friends without the necessary
collateral. Additionally, the RBI strengthened bank regulations in an effort to stop
such lending practices in the future.
·
The Securities Scam (1992) and the subsequent investigation by the JPC: The JPC was established to look into the Harshad
Mehta scam and suggest ways to stop similar
scams in the future. Following the JPC's 1993 report submission, the Indian
stock market saw a number of
improvements, including the creation of the NSE and the adoption of electronic trading.
·
The
IPC and PCA: Under
these Acts, a number of people connected to the Harshad Mehta scam were prosecuted for a variety of crimes, such as
fraud, criminal breach of trust, and corruption.
All things
considered, the Harshad Mehta scam was a terrible chapter in the Indian financial system's history, but it also
sparked much-needed reforms and adjustments that
have strengthened the system and increased its resistance to future scams of
this kind.
“Fact[9]” can be defined as: Any- thing , state of things , relation
of things , that can be sensed
(External facts).
“Fact in issue” can be defined as: The
facts that are being contested are known as "principal facts" or factum probandum, and they
are the facts that need to be established. A fact is in question when it is the subject of disagreement or controversy
and impacts the parties' rights and obligations.
The arguments made by the defendants and plaintiffs are determined by the facts at hand. To influence the court's
decision in their favour, the parties must demonstrate that the relevant facts support their pleas. What comprises the
relevant facts depends on the substantive law that applies
to the offence. While the framing of issues occurs
in civil proceedings, the facts in question in criminal cases are determined by the information contained in the charge sheet.
“Relevant fact” can be defined as: The
facts required to support or refute a particular claim are known as relevant facts. Another name for pertinent facts is
evidential facts (factum probans).
The primary point of contention or disagreement between the parties is not
these facts, so they are not in
dispute. Instead, pertinent or evidentiary facts provide further context or insight into the events
at hand, allowing
for the drawing
of conclusions about them. Relevant
facts show a relationship between facts that, based on a reasonable sequence
of reasoning and common sense, either support
or refute each other's existence. Relevant facts serve as supplemental evidence to influence the
court's decision in favour of the party presenting the case based on the
facts at hand.
Chapter III of
the Evidence Act discusses Facts which need not be proved. Section 56 deals with facts judicially noticeable need not
be proved. Section 57 is concerned with facts which court must take judicial notice (clause 1 to 13). Section 58 discusses about facts admitted
need not be proved.
As a general rule,
all facts in issue must be proved
and any condition
precedent must be proved and any condition
precedent must be proved by the person who seeks to adduce
such evidence.
However, some matters need not
be proved in evidence because:
·
They are well known or they have bee already admitted
by the parties.
·
Proving some matters may jeopardize national security
especially matters which are considered as classified.
·
Proving some matters may be prejudicial to a fair
trial in the way likely to mislead the court and thereby jeopardize the
justice.
·
The Following facts are presumed to be true in the
absence of proof and no evidence is required to prove them: a) Judicial Notice,
b) Presumptions, c)A dmissions.
9. What is Judicial Notice[10]
?
The Doctrine of Evidence applied by the court that allows it to recognise
and accept the existence of a
particular fact commonly known by persons of average intelligence without establishing its existence by
admitting evidence.
·
S.57 not an exhaustive list.
·
Merely provides that the courts must take judicial
notice of the facts enumerated therein.
·
Does not prohibit the courts from taking judicial
notice of other facts, not to be found in list
·
For example: In England, the court takes judicial
notice of matters appearing in its own proceedings, and there is no reason why
Indian courts also would not take judicial notice of such proceedings.
Section 58: Lays down that if the parties to
the proceedings or their agent agrees to admit a fact at hearing or which they
agree to admit by writing under their hands before hearing or which by any rule
of pleading in force at the time, they are deemed to have admitted by their
pleading if need not be proved. Although u\s 58, admission made by the parties
and their agents need not be proved: it is not conclusive proof of the fact
admitted. The section also postulates that things admitted need not be proved.
Under Order 12, Rule 6 of the CPC the court is not bound by admissions of the parties
and their agents. The court may exercise its discretion to demand some other
proof.
·
In
criminal cases the rules of evidence are that the prosecution is under duty to
prove the case against the accused
and that they should not rely upon admissions made by him in the course
of the trial for convicting him.
·
An
accused cannot be convicted upon the admission of his pleader. AN admission by the accused in answer to question put by
the court u\s 313, Cr.PC cannot be utilised to
fill up gap in the evidence
for the prosecution.
·
The court
by its discretion requires some order evidence
to support the admitted facts.
·
If
the court is convinced that the admission was obtained by fraud, collusion or
there is suspicion about admission it may require
the fact to be proved otherwise than by such admission.
A.
M.S.Narayanan
Menon .V. State of Kerala[11]:
It is not
in dispute that transactions comprising purchase and sales of shares by
investors is a matter of confidence . Both parties would have to rely upon one
another. For the said purpose, the courts of law may also take judicial notice
of the practice prevailing in such business.
B.
Steel Authority
of India .V. UOI[12]:
The effect
of an admission in the context of Sec.58 of the Indian Evidence Act has been
considered by this court in Sangramsinh P. Gaekwad & Ors. V. Shantadevi P
Gaekwad. Wherein it was categorically held that judicial admission by
themselves can be made the foundations of the rights of the parties and
admissions in the pleadings are admissible proprio vigore against the maker
thereof.
A fact may be admitted into evidence under the rules of judicial notice
in the law of evidence if its
veracity is so well-known, renowned, or authoritatively established that there
is no reasonable basis for doubting
it. The notoriety of the fact, its accuracy and ease of determination, and its suitability for judicial notice
are among the elements that courts typically
take into account. The party wishing to depend on the fact in question
requests that this be done. Without
the need for a formal witness introduction or other rule of evidence, facts and materials admitted under judicial notice
are accepted. In fact, they are admissible even if one party wants to lead
the witness in testimony.
·
The Indian
Evidence Act,1872.
·
Law of Evidence – Ratanlal&Dhirajlal
·
Law of Evidence – Woodroffe , Amir Ali
·
1992-93 Janakiraman Committee Report
·
Judgements.ecourts.com- Bombay
High Court
·
Aironline.in
·
Taxguru.in
·
Main.sci.gov.in
·
Harshadmehta.in
·
“The Scam” Who Won, Who lost and Who got away-
Debhasis Basu & Sucheta Dalal
[1] Debhasis Basu & Sucheta Dalal,
“The Scam, Who Won , Who lost, Who got away”-1 May 1993.
[2]
The Bull Run phenomenon
is defined as the large scale purchase of securities resulting in the increase
in price on the scrip.
[3]
Debhasis Basu &
Sucheta Dalal, “The Scam , Who Won , Who lost, Who got away”-1 May 1993.
[4]
Janakiraman
Committee-“Report of the committee to enquire into securities transactions of
banks and financial institutions”-R.B.I , 1992-93
[5]
Second Interim Report
,Janakiraman Committee-“Report of the committee to enquire into securities
transactions of banks and financial institutions”-R.B.I , 1992-93
[6]
“Badla” system was
introduced in the Bombay stock exchange to combat the shortage of funds in the
secondary market. It was system of borrowing money from various brokers.
[7]
1992(24) DRJ392,
ILR1993DELHI274
[8]
AIR 2010 SUPREME COURT
1812, 2009 (11) SCC 737
[9]
Section 3, The Indian
Evidence Act,1872.
[10]
Section 57, The Indian
Evidence Act,1872.
[11]
AIR, 2006 SC 3366.
[12]
AIR,2006 SC 3229.
Article Information
HARSHAD MEHTA VS CBI AND FACTS WHICH NEED NOT BE PROVED
Authors: ASHISH SHUKLA
- Journal IJLRA
- ISSN 2582-6433
- Published 2024/03/14
- Issue 7
About Journal
International Journal for Legal Research and Analysis
- Abbreviation IJLRA
- ISSN 2582-6433
- Access Open Access
- License CC 4.0
All research articles published in International Journal for Legal Research and Analysis are open access and available to read, download and share, subject to proper citation of the original work.
Disclaimer: The opinions expressed in this publication are those of the authors and do not necessarily reflect the views of International Journal for Legal Research and Analysis.