Assignment

Topic- FRAMING OF CHARGES UNDER CRPC

Submitted by

Dhiraj Darig

U.I.D – SM0121018

2nd year 4th sem

Submitted to

Dr. Amol Deo Chavhan

(Associate Professor of Law)

National Law University And Judicial Academy, Assam

Contents
Introduction ............................................................................................................................................ 3
Literature Review ................................................................................................................................... 4
Research Question ................................................................................................................................. 4
Research Methodology .......................................................................................................................... 5
2.1 BASIC RULES REGARDING FRAMING OF CHARGES AND ITS EXCEPTIONS...................................... 5
2.2 JOINDER OF CHARGES ...................................................................................................................... 6
2.3 DISTINCT OFFENCE AND SEPARATE OFFENCE ................................................................................. 7
2.4 SERIES OF ACTS AND SAME TRANSACTION ..................................................................................... 7
3.1 DUTY OF THE COURT IN THE FRAMING OF CHARGE ..................................................................... 10
3.2 DISCREPANCY DURING INVESTIGATION ........................................................................................ 11
3.3 PREJUDICE TO THE ACCUSED DUE TO ERRONEOUS FRAMING OF CHARGES ............................... 13
Conclusion ............................................................................................................................................ 14
BIBLIOGRAPHY...................................................................................................................................... 15
 Chapter 1

Introduction
One of the basic elements of Criminal Jurisprudence is fair trial. To ensure a fair trial, the
accused must be given appropriate opportunity to defend himself. There are various
constitutional safeguards within CrPC to ensure fair trial. Once the charges are framed,
they have to be read and explained to the person accused. The court can alter the charge
but it should not alter the charge to the prejudice of the accused person. Accused must be
given appropriate time to prepare his defence. In case, the accused cannot afford a legal
practitioner, the court must provide him an advocate to defend his case. The right to a fair
trial is a norm of international human rights law and also adopted by many countries in
their procedural law. Countries like U.S.A., Canada, U.K. and India have adopted this
norm and it is enshrined in their constitution. The right to a fair trial has been defined in
numerous international instruments. The major features of criminal trial are preserved in
the Universal Declaration of Human Rights 1948. One basic requirement of fair trial in
criminal cases is to give precise information to the accused as to the accusation against
him. This is vitally important to the accused in the preparation of his defence. In all trials
under the code the accused is informed of the accusation in the beginning itself. In case of
serious offences the Code requires that the accusations are to be formulated and to be
reduced into writing with great precision and clarity. The “charge” is then to be read and
explained to the accused person. Charge serves the purpose of notice or intimation to the
accused giving clear and unambiguous or precise notice of the nature of accusation that
the accused is called upon to meet in the course of a trial. In a criminal trial the charge is
the foundation of the accusation and every care must be taken to see that it is not only
properly framed but evidence is only tendered with respect to matters put in the charge
and not the other matters. Sections 211 to 214 deal with what charge should contain;
Sections 216 and 217 mention the power of the court to alter the charge and the procedure
to be followed after such alteration. Section 218 gives the basic rule that for every distinct
offence there shall be a separate charge and every charge shall be tried separately. Sections
222 deals with the circumstances which the accused can be convicted of an offence for
which he was not charged. Section 224 mentions the effect of withdrawal of the remaining
charges on conviction on one of the several charges. Section 215 and 464 mentions the
 effects of errors in stating the offence or other particulars in charge, and of omission to
frame, or error in charge.

Literature Review
Abhinav Mishra & D.K. Balkrisnan, CONSTITUTIONALITY IN THE ISSUE OF
FRAMING CHARGES, Journal of Legal Studies & Research, Vol 2 Issue 3.
The researchers in this project aim to critically analyse the practice of the courts regarding
the framing of charges. In addition to this the project will also be a critical analysis on the
method of investigation followed by the police. The scope of the study will be limited to
the discrepancies in framing of charges by the courts and the discrepancies regarding
investigation by the police officers. The article provided useful insights for the paper by
the mention of the duty of court in framing the charge which is essential and indispensable
in any criminal trial as based on that only any investigation is possible. The article also
provided information for the chapter discrepancies regarding police investigation as such
is a very important topic, if police investigation goes wrong then it would be very difficult
to frame a correct charge.
Sugandha Nayak (13 August 2013), India: Framing of Charges: An Overview, Singh
& Associates.
This paper provides information regarding a criminal charge which is said to be the
foundation of the accusation & every care must be taken to see that it is not only properly
framed but evidence is only tampered with respect to matters put in the charge & not the
other matters. The paper helps by providing information regarding framing of a charge
during a criminal trial which is said to be instituted upon a police report where the court
is required to confine its attention to documents referred to under Section 173. The judge
needs to be only convinced that there is a prime facie case, where there is no necessity to
adduce reasons for framing charges. The paper also greatly enhanced the quality of the
project by explaining the fact that the sections dealing with charge do not mention who is
to frame the charge. But it is said that provisions dealing with different types of trials
however provide that it is always for the court to frame the charge.

Research Question
 What are the basic ingredients involved in framing of a charge and how a joinder of
charge is effected?
 What is the duty of the court in framing of a charge?
 What are the loopholes in investigation and how does it affect the framing of a charge?
Research Methodology
The research method used for this project is based on doctrinal sources which are available
in the library and the internet. A study of various articles and research work available on
the internet has been utilised for the purpose.
Chapter 2

2.1 BASIC RULES REGARDING FRAMING OF CHARGES AND ITS

EXCEPTIONS
Section 218 of the Code says that for every distinct offence of which any person is accused
there shall be a separate charge and every such charge shall be tried separately. The object
of Section 218 is to save the accused from being embarrassed in his defence if distinct
offences are lumped together in one charge or in separate charges & are tried together.1
Another reason is that the mind of the court might be prejudiced against the prisoner if he
were tried in one trial upon different charges resting on different evidence. It might be
difficult for the court trying him on one of the charges not to be influenced by the evidence
against him on the other charges. The strict observance of Section 218 (1) may lead to
multiplicity of trials, therefore exceptions, in suitable cases, have been provided by Section
218 (2) in Sections 219, 220, 221 & 223. The effects of non – compliance with provisions
regarding charges would be considered later. It would however be useful to allude the
decision of the Supreme Court in context of non – compliance with Section 218. In every
case, in which a departure from the requirements of Section 218 has occurred, the question
before the court is, whether the omission to frame the required charge has or has not in
fact occasioned a failure of justice by prejudicing the accused in his defence & whether he
has thus been deprived of a fair trial.2 The object of section 216 is to secure fair trial to the
accused and it is the court to ensure that alteration or addition of charge has not caused
prejudice to him. Though the power is wide and extensive, it must be exercised extensively
and judiciously. The court cannot alter the charge to the prejudice of accused. Similarly,
such power cannot be exercised after the accused is discharged of all the charges inasmuch
as no charge exists against him section 216 will not apply.

1
Aftab Ahmed Khan v State of Hyderabad AIR 1954 SC 436
2
Willey Slaney v State of M.P., AIR 1956 SC 116
2.2 JOINDER OF CHARGES
Sections 218 to 222 of the code provide for the joinder of charges in one trial against the
same accused. Section 223 deals with joint trial against two or more accused persons. The
basic rule section 218 lays down the basic rule relating to trial of offences relating to trial
offences and enacts that for every distinct offence there must be separate charge and a
separate trial for each such charge.
Exception 1:
Three offences of same kind within year may be charged together. In creating this
exception, it was considered expedient to avoid multiplicity of the proceedings under the
circumstances mentioned in Section 219. The section provides that when a person is
accused of more offences than one of the same kind committed within the space of twelve
months from the first to the last of such offences, whether in respect of the same person or
not, he may be charged with, and tried at one trial for any number of them not exceeding
three. There are conflicting judicial opinions as to whether Sections 219 to 221 and 223
are mutually exclusive or whether they can be used to get a cumulative effect. In other
words, the question whether it is open to the prosecution to take help partly of one section
and partly of another section in order to justify the joinder of charges or whether the
intention of law is that sections should be mutually exclusive and only one of them can be
availed of at one time. The Allahabad High Court has pointed out in this connection that
each of the four Sections 219, 220, 221 and 223 mentioned in Section 218 can individually
be relied upon as justifying a joinder of charges in respect of any trial. Use cannot be made
of two or more of these sections to justify the joinder of charges in respect of any trial.
Use cannot be made of two or more of these sections together to justify a joinder.3 In other
words, it is not open to the prosecution to take help partly of one section and partly pf
another in order to justify the charges. Further it has been observed that the normal rule as
embodied in Section 218 has been made subject to the exceptions laid down in Sections
219 or 220 or 221 or 223. Each section is to be an exception individually. It is not the

3
Sri Ram Varma v State, AIR 1956 ALL 466
 intention of the legislature to group together different sections in order to constitute an
exception.4

Exception 2:
It speaks about offences committed in course of same transaction can be charged at one
trial. If, in one series of acts so connected together to form the same transaction, more
offences than one are committed by the same person, he may be charged with, and tried at
one trial for, every such offence.

2.3 DISTINCT OFFENCE AND SEPARATE OFFENCE

In the case of Banwarilal Jhunjunwala & Ors v Union of India5 the Supreme Court drew
the distinction between distinct offence and separate offence by stating that, “Section 233
of Cr. P.C. reads that “For every distinct offence of which any person is accused there
shall be a separate charge, and every such charge shall be tried separately, except in the
cases mentioned in sections 234, 235, 236, and 239." The expression 'every distinct
offence' must have a different content from the expression 'every offence' or 'each offence'.
A separate charge is required for every distinct offence and not necessarily for each
separate offence. The question is, what is meant by 'every distinct offence'? 'Distinct'
means 'not identical'. It stresses characteristics that distinguish while the word 'separate'
would stress the 'two things not being the same.' Two offences would be distinct if they
be not in any way inter-related. If there be some inter-relation, there would be not
distinctness and it would depend on the circumstances of the case in which the offences
were committed whether there be separate charges for those offences or not.”

2.4 SERIES OF ACTS AND SAME TRANSACTION

In Section 220 the word `transaction' means a group of facts so connected together as to
involve certain ideas, viz., unity, continuity and connection. In order to determine whether
a group of facts constitutes one transaction, it is necessary to ascertain whether they are so

4
D.K. Chandra v State, (1952)

5
Banwarilal Jhunjulwala & Ors. v. Union of India
 connected together as to constitute a whole which can properly be described as a
transaction.6 The real and substantial test by which to determine whether several offences
are so connected as to form the same transaction depends on whether they are so related
to one another in point of purpose, or as cause and effect, or as principal and subsidiary
acts as to constitute one continuous action. The fact that offences are committed at
different times does not necessarily show that they may not be so connected as to fall
within this section. The proximity of time, unity or proximity of place, continuity of action,
and community of purpose or design are elements for consideration, whether the alleged
facts form the same transaction.' Where two incidents constitute one series of facts
connected together as to form one transaction, even though more than one offences are
committed, the accused can be charged for all the offences in the same trial, joint trial
permissible. accused gave six cheques to the complainant for presentation to the bank for
encashment on one and all the cheques are dishonoured, all the acts of the accused of
giving these cheques merged to form the same transaction the accused can be tried at one
trial for such offence, S. 219 of CrPC , is not attracted in the case. Where the accused
persons fired shot on the complainant and when the complainant was going to police
station to lodge FIR, dragged him his house and caused injuries to him, the acts of the
accused were in the same series of acts so as to form the same transaction, the accused
could be tried for offences under Ss. 147, 148, 149, 323, 452 and 107, IPC at one trial.
Where a person is charged with some offences triable by Magistrate and others by Court
of Sessions entire case shall be committed for" to the Court of Sessions.
Same transaction.-
To constitute "same transaction" the series of acts alleged against the accused must be
connected together in same way as for instance by proximity of time, unity of place, unity
or community of purpose or design and continuity of action and the main test must really
be continuity of action by which is meant the following up of some initial act through all
its consequences and incidents until the series of acts or group of connected acts came to
an end. Where heroin was recovered from the possession of the accused, and further on
the basis of the disclosure statement made by the accused another packet containing heroin
was recovered from the house of the accused, the second recovery was during the same
transaction, both the recoveries can be subject-matter of one trial in view of the provisions
of S. 220. S. 220 applies where any one series of acts are so connected together as to form

6
Kashiram Jhunjhunwalla v. Emperor (1935)
 the same transaction and where more than once offence is committed, there can be a joint
trial. Where different people have been defrauded by the same accused, each offence is a
distinct offence, joint trial would not be ordered under S. 220.7
Series of acts.-
The offences which are committed in a series of acts are to be tried together. The sections
do not expressly state that all offences which can be charged and tried together or for
which various persons' can be charged and tried together must take place within the
jurisdiction of the Court trying them. The provisions are in general terms. This section
provides for the offences being charged with and tried at one trial and therefore provide
for the trial of those offences at one trial in any Court which has jurisdiction over any of
the offences committed in the course of the same transaction. All offences committed in
the course of the same transaction shall be tried together. When series of acts are so
connected together as to form the same transaction, all the offences may be tried together.
The question whether the acts are so connected has to be decided considering the proximity
of time and place, continuity of action and unity of purpose and design. But in all such
cases, it should be considered whether the alleged acts were, as a matter of fact, so
connected in one series as to form essentially and strictly the same transaction.
"Transaction" means "carrying through" and suggests not necessarily proximity in time-
so much as continuity of action and purpose. The Privy Council has held that identity of
time is not an essential element in determining whether certain events form the same
transaction within the meaning of this section. It is the continuity of action and the
sameness of purpose that determine whether the events constitute the same transaction.20
The word "transaction" has a synonym in the word "affair". Sir 'James Stephen defines it
as "a group of facts, so connected together as to be referred to by a single name, as a crime,
a contract, a wrong or any other subject of inquiry which may be in issue." If a man is
found in concealed possession of a diamond necklace of which each individual diamond
has been the subject of a separate theft and he knows that the diamonds have been stolen,
his dishonest possession of the necklace is one "transaction" in the sense that that word is
used in this section. Similarly, the simultaneous possession of a number of bullocks at a
fair and the offer of them for sale is one 'transaction'.

7
Naresh Kakkar v. State, 1995
 Chapter 3

3.1 DUTY OF THE COURT IN THE FRAMING OF CHARGE

The presiding officer of a Court of Session must take at intelligent part in the proceedings
and exercise due care while framing the charges or examining the accused persons as these
are not matters of empty formality. He should not merely be a disinterested auditor of the
context between the prosecution and the defence and should come to a clear understanding
of, the actual events that occurred and ensure that proper and necessary steps have been
taken to arrive at the truth. The adversary system of trial being what it is, there is an
unfortunate tendency for a judge presiding over a trial to assume the role of a referee or
an umpire and to allow the trial to develop into a contest between the prosecution and the
defence with the inevitable distortions flowing from combative and competitive elements
entering the trial procedure. If a criminal Court is to be an effective instrument in
dispensing justice, the presiding Judge must cease to be a spectator and a mere recording
machine. Once there is prima facie and satisfactory existence of sufficient grounds for
proceeding against the accused, the Court is obliged to evaluate such material evidence
instead of acquitting the accused from the very guilt itself, which may result in the failure
of justice.8 At the stage of framing the charges the Court is not expected to go deep into
probative value of the materials on record, the Court is obliged to see whether there is
prima facie evidence in support of the charge levelled against the accused. While framing
charges, there is no need to maintain the same standard to be adopted by the Court in
scrutinizing the evidence at the time of trial, but all due diligence should be taken even at
the stage of framing the charge as to whether the charges framed is supported with prima
facie and sufficient material evidence. When the Court of Session does not find the case
exclusively triable by it, it has to remit the case to the Chief Judicial Magistrate either after
framing charge or without framing charge and the word 'may' as occurring in clause (a)
does not convey a sense of compulsiveness or obligation. In the absence of proper hearing
and consideration at the time of framing charges there is every possibility that the charges
are framed inadequately or inappropriately defeating the ends of justice. The approach to
the issue of framing charge has to be pragmatic. Charge should not be framed in cases
where the available material does not disclose the ingredients of the offence with which
the accused is charged. Framing of charge in such cases is an exercise in futility and results

8
Asstt. Director, Enforcement Directorate v Khader Sulaiman
 in wasting valuable time of the Court. Where the material on the record did not disclose
abetment of suicide by the petitioners, petitioners were discharged of offence under S. 306
IPC. Charge in respect of same occurrence in two Sessions trials. The framing of charge
in respect of the same occurrence in two separate session’s cases offends Art. 20(3) of the
Constitute and also the spirit of S. 300 Cr.P.C. Defective charge.-When the complainant
was not shown to have been in actual possession, charge of common intention to oust him
from the said property cannot be framed. Once a case has been committed u/s. 228 or 209
the Sessions Court has power to try the case even though it is not a case which is
exclusively triable by a Court of Session.30 When the Assistant Sessions Judge finding
that a case committed to him is not exclusively triable by Court of Sessions transfers to
Additional District Judge who was designated as the Chief Judicial Magistrate, is valid.
With regard to committal of a case to the Court of Session there is no conflict between this
section and S. 306(5)(a)(i). The mechanical framing of charges on the draft charges given
in the Schedule to the Cr.P.C., is not permissible. Mere omission to mention S. 149 in the
charge may be considered as an irregularity, but failure to mention the nature of the offence
committed by the accused would not be regarded a mere irregularity, the accused would
not be convicted under S. 302/149 after reversing their conviction under S. 326, IPC, as
there was no charge framed against them for such offence. Where S. 354, IPC was
attributed to accused Al and A3, charge under S. 149, IPC framed only against the accused
A2 was not only contrary to the basic principles but also ignominious. The same
occurrence cannot be the subject-matter of charge in two Session trials.

3.2 DISCREPANCY DURING INVESTIGATION

The police in order to proceed with the case in his hand tries to force the accused to make
an incriminatory statement and thereby tries to use it against the accused under Section
161 of CrPC. However, this has been condemned in a lot of judgements by the Supreme
Court and the High Courts. Justice Krishna Iyer in the case of Nandiny Sathpathy v P.L.
Dalani had observed that, “The charge, it is so obvious, has a wide-ranging 'scope and
considerable temporal sweep, covering activities and acquisitions, sources and resources
 private and public dealings and nexus with finances, personal and of relatives. 9 The
dimensions of the offences naturally broadened the area of investigation, and to do justice
to such investigation, the net of interrogation had to be cast wide. Inevitably, a police
officer who is not too precise, too sensitive and too constitutionally conscientious is apt to
trample under foot the guaranteed right of testimonial tacitness. This is precisely the
grievance of the appellant, and the defence of the respondent is the absence of the 'right of
silence, to use the familiar phrase of 20th century vintage.” In addition to it the Court had
also observed that, “Whether we consider the Talmudic law or the Magna Carta, the Fifth
Amendment, the provisions of other constitutions or Art. 20(3), the driving force- behind
the refusal to permit forced self-crimination is the system of torture by investigators and
Courts from medieval times to modern days. Law is a response to life and the English rule
of the accused's privilege of silence may easily be traced as a sharp reaction to the court
of Star-Chamber when self-incrimination was not regarded wrongful. Indeed, then the
central feature of the criminal proceedings, as Holdsworth has noted, was the examination
of the accused. The horror and terror that then prevailed did, as a reaction give rise to the
reverential principle of immunity from interrogation for the accused. Sir James Stephen
has observed: For at least a century and a half the (English) Courts have acted upon the
supposition that to question a prisoner is illegal This opinion arose from a peculiar and
accidental state of things which has long since- passed away and our modem law is in fact
derived from somewhat questionable source though it may no doubt be defended (Sir
James Stephen (1857). "Two important considerations must be placed at the forefront
before sizing up the importance and impregnability of the anti-self-incrimination
guarantee. The first is that we cannot afford to write off the fear of police torture leading
to forced self-incrimination as a thing of the past. Recent Indian history does not permit
it, contemporary world history does not condone it.” He had stated that Section 161(2) is
subjected to the restrictions prescribed under Section 161 (2) of CrPC and that the accused
is not supposed to give self – incriminatory statements. Generally, the investigating officer
(IO) opts for the wrong method of investigation to the offence. The police officers tend to
initially go for a very superficial method of investigation. They compel the accused and
the other witnesses to give their statements and then they start their further investigation.
This is the reason which leads to erroneous framing of charges against the accused. The

9
Nandini Satpathy v. P.L Dalani 1978 AIR 1025
 accused is wrongly implicated whereas the real accused is shielded due to the faulty
investigation by the IO.

3.3 PREJUDICE TO THE ACCUSED DUE TO ERRONEOUS FRAMING

OF CHARGES
Supreme Court in the case of Ram Deo Prasad v State of Bihar10 had criticized the trial
court on the ground of erroneous framing of charges. In a case where a girl of 4 years was
kidnapped for the purpose of sexual intercourse, the court had failed to frame charges
under section 366 A or 367 of Indian Penal Code, 1860. The Court had also criticized the
examination of the accused by the trial court and had stated that, “This is all! The first
question was an empty formality and the second question was evidently asked even
without looking to the charge as there was no charge of abducting the child from her
father's house against that appellant. The whole of. 313 was, thus, squeezed into the third
and the last question.” In the case of Jainandan Prasad Singh v State of Bihar,11 Patna High
Court had stated that, “the appellant had deceitfully taken custody of his wife with an
intention to kill her. This was a distinct offence punishable u/s. 364 of the I.P.C., but no
charge was framed in this respect and that being so the facts in relation to such a charge
could not be permitted to be recorded.” The Supreme Court in the case of Sajjan Sharma
v State of Bihar12 had condemned the Trial Court by saying that they had committed huge
errors in the framing of charges. In a case where the facts of the case imply that there has
been a commission of an offence under Section 27 of Arms Act and Section 148 of IPC
the court had failed to put the same while framing of charges. The Court also said that the
Trial Court was in framing the charge of Section 302. In addition to this Supreme Court
had said that this copy of the judgement should be given to Bihar state judicial academy
so that they don’t commit this kind of errors in the future. The Supreme Court in the case
of Union of India v Prafulla Kumar Samal and Another had stated that, “The words 'not
sufficient ground for proceeding against the accused' clearly show that the Judge is not a
mere post office to frame the charge at the behest of the prosecution, but has to exercise
his judicial mind to the facts of the case in order to determine whether a case for trial has
been made out by the prosecution. In assessing this fact, it is not necessary for the court to
enter into the pros and cons of the matter or into a weighing and balancing of evidence

10
Ram Deo Prasad v State of Bihar 2013
11
Jainandan Prasad Singh v State of Bihar
12
Sajjan Sharma v State of Bihar
 and probabilities which is really his function after the trial starts. At the stage of s. 227,
the Judge has merely to sift the evidence in order to find out whether or not there is
sufficient ground for proceeding against the accused. The sufficiency of ground would
take within its fold the nature of the evidence recorded by the police or the documents
produced before the court which ex facie disclose that there are suspicious circumstances
against the accused so as to frame a charge against him.

Conclusion
To sum up the above discussion, Section 218 of the Code states for every distinct offence
of which any person is accused there shall be a separate charge and every such charge
shall be tried separately where the object being to save the accused from being
embarrassed in his defence if distinct offences are lumped together in one charge or in
separate charges & are tried together. Further, sections 218 to 222 of the code provide for
the joinder of charges in one trial against the same accused. Section 223 deals with joint
trial against two or more accused persons. The Presiding officer of a Court of Session must
take at intelligent part in the proceedings and exercise due care while framing the charges
or examining the accused persons. He should not merely be a disinterested auditor of the
context between the prosecution and the defence and should come to a clear understanding
of, the actual events. Also, in cases the police in order to proceed with the case in his hand
tries to force the accused to make an incriminatory statement and thereby tries to use it
against the accused under Section 161 of CrPC which has been condemned in a lot of
judgements by the Supreme Court and the High Courts point to the problems in the
investigation mechanism. Lastly, Supreme Court in the case of Ram Deo Prasad v State
of Bihar had criticized the trial court on the ground of erroneous framing of charges where
a girl of 4 years was kidnapped for the purpose of sexual intercourse and the court had
failed to frame charges under section 366 A or 367 of Indian Penal Code, 1860. The Court
had also criticized the examination of the accused by the trial as the first question was an
empty formality and the second question was evidently asked even without looking to the
charge as there was no charge of abducting the child from her father's house against that
appellant. Thus, it is the duty of the court to examine the evidences properly and then
frame a charge.
BIBLIOGRAPHY
 Abhinav Mishra & D.K. Balkrisnan, CONSTITUTIONALITY IN THE ISSUE OF
FRAMING CHARGES, Journal of Legal Studies & Research, Vol 2 Issue 3.

 Sugandha Nayak (13 August 2013), India: Framing of Charges: An Overview,

Singh & Associates.

 https://districts.ecourts.gov.in/sites/default/files/Worksho
p-II%20Material%201_0.pdf
 https://www.legalservicesindia.com/article/1122/Framing
-of-Charge-In-Criminal-Cases.html
 https://www.legalhelplineindia.com/framing-of-charge-
in-crpc/