FACULTY OF LAW, JAMIA MILIA ISLAMIA

INDIAN PENAL CODE - 1

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ABETMENT
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SUBMITTED BY SUBMITTED TO
MOHAAMMAD ARISH MR .AQUIB HUSSAIN
SEMESTER - IV

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 AKNOWLEGEMENT

The success and final outcome of this assignment required a lot of guidance and
assistance from many people and I extremely fortunate to have got this along the
completion of our assignment work. Whatever I have done is only due to such
guidance and assistance and I would not forget to think them. I respect and
thank Mr. Aquib Hussain for giving me an opportunity to do this assignment on
time. I extremely grateful to him for providing such support and guidance.

I am really grateful because I managed to complete this assignment within the

time given by Mr.Aquib Hussain. This assignment cannot be completed without
the effort and co- operation from our group members. I would like to express my
gratitude to my friends for support.

Yours sincerely,
Mohammad Arish

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 TABLE OF CONTENTS



1. INTRODUCTION ____________________________________________ [4]


2. CRIMINAL INTIMIDATION___________________________________ [5]


3. ABETMENT BY INSTIGATION_________________________________ [5]

4. ABETMENT BY CONSPIRACY_________________________________ [9]

5. ABETMENT BY AID__________________________________________ [9]

6. ABETMENT OF OFFENCES OUTSIDE INDIA___________________ [11]

7. CONCLUSION_________________________________________________[15]

8. BIBILOGRAPPHY______________________________________________[15]

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 INTRODUCTION
Under the Penal Code a person becomes liable as an abettor if he instigates another to commit a
crime, or engages in a conspiracy with another to commit a crime and some act is done in
furtherance of such conspiracy or if he intentionally aids another in order to facilitate the
commission of a crime. The term 'abet' in general usage means to assist, advance, aid, conduce, help
and promote. The word 'abet' has been defined as meaning to aid; to assist or to give aid; to
command, to procure, or to counsel; to countenance; to encourage; induce, or assist, to encourage or
to set another one to commit.

The term 'abetment' in criminal law indicates that there is a distinction between the person abetting
the commission of an offence (or abettor) and the actual perpetrator of the offence or the principal
offence or the principal offender. Chapter V of the IPC on 'Abetment' provides for the law covering
the responsibility of all those considered in law to have abetted the commission of offence. The
chapter on abetment contains 15 sections. Section 107 which defines abetment generally speaks of
three kinds of abetment, viz., abetment by instigation, abetment by conspiracy and abetment by aid.
Section 108 explains as to when an abetment of an offence takes place, and S. 108-A provides for
the case of abetment in India of an offence committed in a foreign country. Section 109 prescribes
the punishment for the offence of abetment when the offence abetted is committed, while S. 110
prescribes the punishment for abetment where the person abetted commits the act with a different
intention or knowledge from that of the abettor. Section 111 provides for cases of abetment resulting
in a different offence but which is a probable consequence thereof. Section 112 provides for
cumulative punishment in cases covered by S. 111. Section 113 which is supplementary to S.111
provides for punishment in cases where the act abetted causes a different effect from that intended
by the abettor. Section 114 provides for cases where the abettor is present at the time of the offence,
and makes him liable for the main offence and not merely as an abettor. Sections 115 and 116
prescribe for the punishment in cases where the offence abetted is not committed. Section 117 deals
with abetment of offences by the public generally or large groups of persons. Section 118 prescribes
the penalty for concealing the existence of a design in another to commit a grave offence. Sections
119 and 120 provide for punishment in the case of public servants and others respectively for
concealment of a design in another person to commit the offence not covered by S. 118.

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 Criminal Intimidation
According to S. 107, IPC, a person abets the doing of a thing when he:
(i) Instigates a person to commit an offence; or
(ii) Engages with one or more persons in a conspiracy to commit an offence; or
(iii) Intentionally aids a person by any act or illegal omission to commit an offence or illegally
omits the doing of an act which would prevent the commission of the offence.

An act done under criminal intimidation cannot constitute an abetment. Thus, where money was
obtained by extortion, by way of bribe, the person who gave the money would not be an abettor of
the offence of taking bribe. But the offence of abetment will not require any kind of mens rea where
the provision relating to the substantive offence itself makes no reference to mens rea and abetment
of the offence is coupled together with the main offence itself in the same provision. It was held by
the Orissa High Court that the giver of a bribe would be an abettor even if he gave it in response to
a demand accompanied by threats. This view cannot be considered good law. There can be no
criminal intention or mens rea on the part of the giver in such a case as held in Dulpat Singh v. State
of Rajasthan wherein the Supreme Court observed that those who gave illegal gratification to the
appellants (Reserve Police constables) cannot be considered as accomplices as the same (bribe) was
extorted from them.
The Supreme Court while considering the validity of TADA, 1987,n stated that 'when mens rea is
not essential in the substantive offence, the same is also not necessary in the abetment thereof.

Abetment by instigation

The word 'instigate' literally means to goad, urge forward, provoke, incite, or encourage to do an act
and a person is said to instigate another when he actively suggests or stimulates him to the act by
any means, or language, direct or indirect, whether it take the form of express solicitation or of
hints, insinuation or encouragement or a willful misrepresentation or willful concealment of a
material fact. It is not necessary that express words should be used to indicate what should be done
by the person to whom the directions are given. While there has to be a reasonable certainty in
regard to the meaning of the words used in order to decide whether there was incitement, it is not
necessary in law to prove the actual words used. Advice amounts to instigation only when intended
to actively suggest or stimulate the commission of an offence. Mere acquiescence does not amount

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to instigation. Thus the word denotes incitement or urging to do some drastic or unadvisable action
or to stimulate or incite. Presence of mens rea, therefore, is the necessary concomitant of
instigation. It is common knowledge that the words uttered in a quarrel or in a spur of the moment
cannot be taken to be uttered with mens rea required to constitute instigation as they are uttered in a
fit of anger and emotional state. In Queen v. Mohit the persons who followed a woman preparing
herself to be a sati on the pyre of her husband and chanted, Rama, Rama were held guilty of
abetment by instigation to lead that woman to commit suicide. Their approval of the woman's act by
participation in the procession gave encouragement to the lady to commit suicide.
A person may incite another by threats or pressure as well as by persuasion. Incitement may be by
expression or implication. The mere incitement of another to commit an indictable offence is a
common law misdemeanour, whether the incitement is successful in persuading the other to
commit, or to attempt to commit the offence or not. It is argued, that a mere intent to commit evil is
not indictable, without an act done; but is there not an act done, when it is charged that the
defendant solicited another to commit a felony? The solicitation is an act: and the answer given at
the bar is decisive, that it would be sufficient to constitute an overt act of high treason.

Incitement to commit any criminal offence, even an offence triable only summarily, amounted to a
misdemeanour at common law. It was highly anomalous that the mere incitement should be
regarded as more serious than the actual commission of the offence, even though the use of the
greater powers of sentencing might be defensible where the incitement was to commit a large
number of summary offences.
For the purpose of the first two clauses of the S. 107, it is immaterial whether the person instigated
commits the offence or not or the persons conspiring together actually carry out the object of the
conspiracy or the act abetted must be committed. The offence of abetment is a separate and distinct
offence. As observed by the Supreme Court in Jamuna Singh v . State of Bihar
The offence of abetment is complete when the alleged abettor has instigated another or engaged
with another in a conspiracy to commit the offence. It is not necessary for the offence of abetment
that the act abetted must be committed.

Similarly in Madan Raj v. State ofRajasthan, the Supreme Court observed

As a general rule a charge of abetment fails when the substantive offence is not established against
the principal but there may be exception. Abetment of an offence being a distinct offence by itself,
the question whether a conviction for abetment can be made in a case where the accused is charged
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with the substantive offence only and no separate charge for abetment has been framed will depend
upon the circumstances of each case. If the accused had notice of the facts, which constituted
abetment, and if there had been no prejudice to the accused by the omission to frame a separate
charge for abetment, he can be convicted for abetment even though the charge for the main offence
fails.
It is only in the case of the person abetting an offence by intentionally aiding another to commit that
offence that the charge of abetment against him would be expected to fail when the person alleged
to have committed the offence is acquitted of that offence. Where, several persons constituting an
unlawful assembly, some only were armed with sticks, and one of them was not so armed, but
picked up a stick and used it, the person who gave a general order to beat, was held guilty of
abetting the assault made by them.In cases where the abetment consists of instigation or conspiracy,
it is immaterial for the conviction of the abettor whether the person instigated commits the offence
or not.
Where a forged receipt had been brought into existence and it was intended by the parties that it
should be attested by a certain person and that person attested it subsequently, it was held that in
view of the said intention, the offence of forgery was complete once it was so attested. Therefore,
the person was held guilty of abetment.
Instigation as a form of abetment has generally been one of the essential considerations in cases
involving death of young brides or women within seven years after marriage, as a consequence of
dowry harassment. The apex court has laid down that before anybody can be punished for abetment
of suicide, it must be proved that the death in question was a suicidal death. In Protima Dutta v.
State of WB a charge under S. 306 read with S. 34, IPC was laid against the mother-in-law of the
deceased and her husband of having abetted the commission of suicide by instigating and inciting
her. The evidence revealed many circumstances which showed that the mother- in-law suggested to
the deceased by conduct, language direct or indirect expressions to commit suicide. Although, it did
not amount to express solicitation, but her cruel conduct towards the deceased over the months
made the deceased suffer mentally. Therefore, the series of conduct amounting to actively
suggesting or stimulating the deceased to commit suicide, it was held, clearly amounted to
instigation. Where one person instigates another to the commission of an offence by means of a
letter sent through the post, the offence of abetment by instigation is completed as soon as the
contents of such letter become known to the addressee. If the letter never reaches him the act is only
an attempt to abet.

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In the context of bride-burning and dowry related deaths, S. 306 which provides for abetment of
suicide, is often pressed into service. Here too, abetment is in terms of promoting, encouraging and
thereby instigating suicides. The husband had been convicted by the trial court for abetting the
suicide under S. 306, IPC and sentenced to four years rigorous imprisonment and fine of Rs 1000.
The high court held that while asking for divorce by itself cannot be called provocation to commit
suicide, it is the cruelty and the overall atmosphere created by cruelties precedent and antecedent of
such demands of divorce, which are material and which had the effect of leading the deceased
person to take poison to end her life. The word 'instigate', it was held, should not be given restricted
meaning to actual words spoken, but ought to be given a wider meaning commensurate with the
'ordinary experiences of life'. While every case has to be examined against the specific
circumstances and facts of that case, in the present case, it was the cruel conduct of the accused-
husband which provoked his wife to commit suicide. Hence, he was rightly convicted of abetment
to commit suicide under S. 306 IPC, and the sentence was not interfered with.
In Ram Kumar v. State of HP, the Supreme Court considered the case of a constable who dragged a
young newly married 19-year-old girl and her husband from the latter's brother's house. In the
police station, the head constable took the girl to a room, repeatedly beat her and committed rape on
her, while the other constable kept watch in outside holding the hapless husband, who was
helplessly hearing the frantic screams of his wife. The Supreme Court held that the constable by his
conduct had abetted rape and therefore, did not merit acquittal.
In Saju v. State of Kerala, a young woman, Jameela, was found killed. At the time of her death, the
deceased was in advance stage of pregnancy. Upon trial the two accused were found guilty of the
offences punishable under Ss. 120-B and 302 besides S. 109 of the Indian Penal Code. Aggrieved
by the judgment of the Sessions Court, both the accused persons filed appeal before the High Court,
which was dismissed. The apex court held that there is no direct evidence either regarding abetment
or the criminal conspiracy attributable to the appellant. Both the offences are held to be proved on
the basis of circumstantial evidence. Hence, the appellant could not have been convicted and
sentenced with the aid of S. 120-B or S. 109 IPC. The court further held that to prove the charge of
abetment, the prosecution is required to prove that the abettor had instigated for the doing of a
particular thing or engaged with one or more other person or persons in any conspiracy for the
doing of that thing or intentionally aided by an act of illegal omission, doing of that thing. The
prosecution failed to prove the existence of any of the ingredients of S. 107 IPC.

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 Abetment by conspiracy

A person is said to abet the commission of an offence by conspiracy, if he enters into an agreement
with one or more persons to do a legal act by illegal means, or to do an illegal act, and some act is
done in pursuance thereof. A conspiracy to do a thing is a combination of two or more persons with
a common design of doing a specific thing. It has been held that where a criminal conspiracy
amounts to an abetment under S. 107, it is unnecessary to invoke the provisions of Ss. 120-A and
120-B, as the Code has made a specific provision for the punishment of such a conspiracy.

Abetment by aid

A person is said to abet the commission of an offence, if he intentionally renders assistance or gives
aid by doing an act or omitting to do an act. Mere intention to render assistance is not sufficient.
There must be some active conduct on the part of the abettor and the act must be accomplished in
pursuance thereof.
Aid may be given both by an act of commission as well as by an act of illegal omission. For
instance, if a police officer knowing that certain persons were likely to be tortured for the purposes
of extorting confession, keeps himself away from the place, he is liable for abetment to the offence
of extortion by an act of omission.
a) The act or omission which constitutes the aid must have been done intentionally;
b) The aid must have been given either prior to or at the time of the commission of the offence
abetted. It was held that unless it is shown that the commission of the crime was not possible
without the specific aid rendered by a person, he would not be liable for an offence under this
section.
Aiding and abetting of an offence are different from actual participation in a crime. Hence, where
the accused have been charged with actual participation in a crime but are only found to have aided
and abetted the commission of the crime, they cannot be convicted of the crime charged.However,
insignificant the aid may be, it would be abetment if it was given with the requisite intention or
knowledge. The test is not to determine whether the offence would or would not have been
committed if the aid had not been given but whether the act was committed with the aid of the
abettor in question.

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 Abettor

It is not necessary to make the abettor liable that the crime abetted should be committed or the
effect desired should be produced. However, as the Supreme Court pointed out in Fagunanath v.
The Stated in the case of abetment by intentional aid, unless the person who is abetted is found
guilty of the offence charged the abettor cannot be punished. Explanation 2 to S. 107 of the Penal
Code provides: "whoever either prior to or at the time of the commission of an act, does anything in
order to facilitate the commission of that act and thereby facilitates the commission thereof is said
to aid the doing of that act." The liability of the abettor extends to all acts which are probable
consequences of the act abetted and even to consequences which though not intended were
nevertheless known to be likely to ensue.
Section 108 IPC defines abettor as a person who abets:
(i) the commission of an offence, or
(ii) the commission of an act which would be an offence, if committed by a person capable of
committing an offence in law.
An abettor may be either an instigator, or a conspirator, or helper in the commission of a crime as
defined in S. 107 of the Penal Code. The abetment must be an offence or an act, which would be an
offence, if committed by a person capable in law of committing the offence with the same intention
or knowledge as that of the abettor.
The abetment of an illegal omission of an act may amount to an offence although the abettor may
not himself be bound to do that act.To constitute
an offence of abetment, it is not necessary that the act abetted should be committed or that the effect
requisite to constitute the offence should be used. It is not required for abetment that the person
abetted should be capable by law of committing an offence, or that he should have any guilty
intention or knowledge or should commit an offence. Abetment of an offence being an offence, the
abetment of such an abetment is also an offence. It is not necessary in abetment by conspiracy that
the abettor should plan the offence with the person abetted.

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 Abetment of offences outside India
Section 108A was added in the Penal Code in 1898 with a view to overrule a decision of the
Bombay High Court in the case of Queen Empress v. Ganapatrao Ramachandra, in which it was
held that the abetment in India by an Indian citizen of an offence committed in a foreign country
was not punishable under the Code. The section states that a person would be guilty of an abetment,
if he abets the commission of an act outside India, which if done in India, would constitute an
offence.
Sections 109 to 120 prescribe certain rules as to punishment for different kinds of abetment.
Sections 109 and 110 prescribe punishment of abetment, if the act abetted is committed in
consequence of abetment, whereas Ss. 115 and 116 provide for punishment where the offence is not
committed in consequence of the abetment. Sections 109 and 110 provide for punishment in cases
in which the act done is the act abetted. In Jai Narain Mishra v. State of Bihar the Supreme Court
considered the case of an accused who was accused of instigating others belonging to the Mishra
community to attack members of the Tiwari family of village Bareja in Chapra district. The trial
court had originally acquitted all the accused. On appeal by the state government, the Patna High
Court convicted them for offences under Ss. 147, 148, 323, 324, 326 and 307 read with S. 109 IPC.
However, when the Supreme Court examined the evidence, it found that the witness while tendering
evidence during trial had stated that the accused had instigated others to kill him, in the statement
made by him recorded as dying
declaration, he had stated that the accused had only instigated others to 'assault the rascal'. This, the
court felt, warranted a substitution of conviction from S. 307 to S. 324 read with S. 109 IPC. The
sentence of two years imposed by the high court was, however, not disturbed, as it was felt
appropriate for the offence committed.In Harabailu Kariappa v. State of Karnataka,there was a
dispute between the deceased Kushalappa and two other persons over cutting of trees from the
forest land near the land of the accused, which resulted in the murder of the deceased. However, the
court held that while the evidence proved clearly the direct role of the accused and there was no
evidence to prove that the offence committed by him was with the abetment. Hence, the person
charged with abetment was acquitted.
However, the Supreme Court in Mahendra Rai’s case set aside the judgment of the Patna High
Court acquitting the first accused and second accused of murdering a 12-year-old boy as there was
discrepancy in timings in preparation of the inquest report and the absence of names of the
assailants in the same. After reassessing the evidence, the Supreme Court observed that the high
court was in error on coming to a finding of innocence, as the facts established clearly that while the
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second accused held the boy who was sleeping in a cot under a mango tree in an orchard near his
house, the first accused cut his neck with a kakut (chaff cutter). Thus, the Supreme Court affirmed
the conviction of the trial court of offence under S. 302, IPC against Al and under S. 301 read with
S. 109, IPC against A2.
In Joseph Kurian v. State of Kerala the apex court held that S. 109 of IPC is by itself an offence
though punishable in the context of other offences. When his direct involvement in these crimes
could not be established, it is difficult to uphold the view of the high court that he could lopsidedly
be taken to have answered the charge of abetment and convicted on that basis. There would, as is
plain, be serious miscarriage of justice to the accused in causing great prejudice to his defence. The
roles of the perpetrator and abettor of the crime are distinct and stand apart from each other. Further,
in
Wakil Yadav v. State of Bihar, the Supreme Court laid down that an offence under S. 109 is a
distinct offence.
Section 111 holds the abettor liable when the act done is different from the act abetted. The section
enunciates the principle of constructive liability. As the person abetted is working as an agent of the
principal, the abettor is responsible in law for his deeds. The liability of the abettor under this
section is based on the well-established principle of criminal law that 'every man is presumed to
intend the natural and probable consequence of his act'. A natural and probable consequence of an
act is one which is likely or which can reasonably be expected to follow from such an act. Section
111 extends the liability of an abettor in respect of an act done, which was not contemplated by the
abettor, provided the later act was the probable consequence of the act abetted, and is committed
under the influence of the abetment. But an unusual act, which could not be expected to ensue as a
result of abetment cannot be said to be the probable consequence of an act abetted. In other words,
the abettor is liable for the act committed, if:
(i) it was a probable consequence of the abetment, and
(ii) it was committed-
(a) under the influence of the abetment, or
(b) in pursuance of the conspiracy which constituted abetment.
Whenever any person, who if absent would be liable to be punished as an abettor, if present when
the act or offence for which he would be punishable in consequence of the abetment is committed,
he shall be deemed to have committed such act or offence.

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There are three essential ingredients of S. 114:
1) The abetment should be prior to the commission of the offence;
2) The abetment must be complete by itself;
3) The abettor must be present at the time of the commission of the act.
If these ingredients are present, the section provides that the abettor shall be deemed to be liable for
the punishment as if he had himself committed the offence. Thus, the section applies to a case
where a person abets the commission of an offence sometime before it takes place and happens to
be present at the time when the offence takes place and the abettor helps in the commission of the
offence. In such a case, the person is guilty of committing the offence itself and not merely of
abetment.
Based on this principle, the Supreme Court in State of Karanataka v. Hemareddy, set aside the
judgment of the Karnataka High Court and acquitted the appellant who was charged with offences
under S. 467 read with S. 114, IPC, for forging some documents in respect of an alleged sale of
some agricultural land. The appellant was alleged to have helped the other accused Pyatal
Bhimakka, to impersonate another person. Bhimakka, wife of Nagappa, the real owner of the land
in question who had died in 1953, forged a document and took her to the sub-registrar's office
(where documents of sale, mortgage etc., are registered), helped her affix the thumb to the
document and get it registered. The High Court had acquitted the appellant, although on facts it held
that the offence under S. 457 read with S. 114, IPC had been proved on a technicality, namely, on
the question whether a private complaint could have been filed or whether the criminal complaint
should have been filed under S. 195(l)(b) of Criminal Procedure Code, by the court before which a
civil dispute over the same land had been instituted. The Supreme Court, however, confirmed the
conviction under S. 467 read with S. 114, IPC against the appellant and sentenced him to one year's
rigorous imprisonment.
It should be noted that S. 114 is evidentiary in nature and not punitive because it established a
presumption which is irrebuttable that actual presence plus prior abetment can mean nothing else
but prior participation.
The effect of the provision is that if a person is present at the commission of the offence, he is
deemed to have committed it, not that he has actually committed it. Thus, actual presence plus prior
abetment can mean nothing else but participation.

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Distinction between conspiracy in Ss. 34, 107, clause (2) and S. 120A, IPC: To constitute an offence
under clause (2) to S. 107, IPC-(abetment by conspiracy)-an act or illegal omission must take place
in pursuance of the conspiracy, whereas under S. 120A, IPC, a mere agreement is enough if the
agreement is to commit an offence.
The Supreme Court elaborated on the difference between Ss. 34, 109 and 120-B, IPC in the case of
Noor Mohammad Mohd Yusuf Monin v. State of Maharashtra. This case involved the conviction of
the appellant along with three others to a conspiracy to kill a neighbour Mohammand Yahya, with
whom the appellant had been having a dispute over the right of passage and the right to collect
water from a tap nearby. The trial court originally found only the person who was alleged to have
stabbed the deceased, guilty of offence under S. 302 and acquitted the other three. However, on an
appeal against the acquittal filed by the state, the appellant and two others were convicted for
offences under S. 302 read with S. 34, IPC, and additionally, the appellant in the above case for
offence under S. 302 read with S. 109, IPC and sentenced to life imprisonment. Since the conviction
under S. 302 read with Ss. 34 and 109, IPC was challenged on the ground of insufficiency of
evidence because of which grave injustice was done to the appellant, the Supreme Court entered
into a detailed examination of the evidence on record. While discussing the manner in which the
appellant had instigated the killing of the deceased and other circumstances, the court elaborated the
distinction between the various sections as under:
So far as S. 34, Indian Penal Code, is concerned, it embodies the principle of joint liability in the
doing of a criminal act, the essence of that liability being the existence of a common intention.
Participation in the commission of the offence in furtherance of the common intention in its
application. Section 109, Indian Penal Code on the other hand may be attracted even if the abettor is
not present when the offence abetted is committed, provided that he has instigated the commission
of the offence or has engaged with one or more persons in a conspiracy to commit an offence and
pursuant to that conspiracy some act or illegal omission takes place or has intentionally aided the
commission of an offence by an act or illegal omission.
Turning to the charge under S. 120-B, IPC, criminal conspiracy was made a substantive offence in
1913 by the introduction of Chapter VA in the Indian Penal Code. Criminal conspiracy postulates an
agreement between two or more persons to do, or cause to be done, an illegal act, or an act, which is
not illegal, by illegal means. It differs form other offence in that mere agreement is made an offence
even if no step is taken to carry out that agreement.

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 CONCLUSION
Though there is close association of conspiracy with incitement and abetment, the substantive
offence of criminal conspiracy is defined in S. 107, IPC. A conspiracy from its very nature is
generally hatched in secret. It is, therefore, extremely rare that direct evidence in proof of
conspiracy can be forthcoming from wholly disinterested quarters or form utter strangers. But, like
other offences, criminal conspiracy can be proved by circumstantial evidence. Indeed, in most
cases, proof o conspiracy is largely inferential thought the inference must be founded on solid fact.
Surrounding circumstances and antecedent and subsequent conduct, among other factors, constitute
relevant material. In fact because of the difficulties in having direct evidence of criminal conspiracy,
once reasonable ground is shown for believing that two or more persons have conspired to commit
an offence then anything done by anyone of them in reference to their common intention after the
same is entertained becomes, according to the law of evidence, relevant for providing both
conspiracy and the offences committed pursuant thereto.81 The requirement under S. 34 of the
Code is something more than what Section 109 contemplates. Actual participation in the offence in
addition to other ingredients that go to make an offence under S.109 is necessary to attract the
provisions of S. 34.

BIBILOGRAPPHY :-

1. The Indian Penal Code 1860 - 2012

2. PSA Pillai’s Criminal Law, Tenth Edition.
3. lawctopus.com

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