There are four kinds of presumption.
1. Presumption of fact
2. Presumption of law
3. Irrebutable presumption
4. Rebbutable presumption
Presumption of factPresumptions of fact are also known as natural presumption. These are inferences that are naturally and logically drawn from experiences and observation from the course of nature, the constitution of human mind, the springs of human action and the habits of the society.
Presumption of lawWhen law with the quality of a rule that directs them vests presumption of fact how they must be drawn.
Irrebutable presumptionA pressumtion that cannot be overcome by any additional evidence or argument. It is known as a conclusive presumption. An example of this type of presumption is the child under the age of seven years is not capable of committing felony.
Rebbutable presumptionThese are certain presumption that are regarded as something more that mere maxims. It is not easy to say to what extent. A much familiar instance of this is that a person who is in possession of stolen goods is either a thief or a receiver.
Matrimonial offences are those offences that take place in the matrimonial house of a woman. The matrimonial home is the household a woman shares with her husband; whether it is rented, officially provided, or owned by the husband or his relatives. A woman has the right to remain in the matrimonial home along with her husband as long as she is married, though there is no definite law regarding this right. There are different types of matrimonial offences like dowry death, illegitimacy of the child, adultery. But there are presumptions relating to only some of the offences.
Presumption is very necessary in matrimonial offences. Presumptions are very essential in matrimonial offences because it is difficult to get evidence. There are three main provisions regarding the presumption in context of matrimonial offences.
1. Presumption as to abetment of suicide by a married woman which is dealt in section 113A of Indian Evidence Act
2. Presumption as to dowry death which is dealt in 113B of Indian Evidence Act
3. Birth during marriage conclusive proof of legitimacy dealt in section 112 of the Indian Evidence Act
Abetment of Suicide by a Married WomanThe Indian Evidence Act section 113A deals with the presumption as to the abetment of suicide by a married woman. Section 113A states that:
Presumption of abetment of suicide by a married woman. -When the question is whether the commission of suicide by a woman had been abetted by her husband or any relative of her husband and it is shown that she had committed suicide within a period of seven years from the date of her marriage and that her husband and such relative of her husband had subjected her to cruelty, the curt may presume, having regard to all other circumstances of the case, that such suicide had been abetted by her husband or by any such relative of her husband.
Explanation- For the purpose of this section, cruelty shall have same meaning as in section 498A of the Indian Penal Code.
The term cruelty shall mean the same as defined in 498A section of India Penal Code according to thisCruelty means-
(a) Any willful conduct which is of such a nature as is likely to drive the woman to commit suicide or to cause grave injury or danger to life, limb or health (whether mental or physical) of the woman; or
(b) Harassment of the woman where such harassment is with a view to coercing her or any person related to her to meet any unlawful demand for any property or valuable security or is on account of failure by her or any such person related to her to meet such demand.
The section 113A was inserted by Criminal Law (second amendment) Act 46 of 1983. This was introduced because there was increasing number of dowry death, which was in fact a matter of serious concern. This evil was commented upon the Joint Committee of the House to examine the work of Dowry Prohibition Act, 1961. the cases of cruelty by the husband or relative of husband which would result in suicide or murder only constituted a small fraction. In order to move this difficulty it was proposed to amend Indian Penal Code, Indian Evidence Act and Criminal Procedure Code that could efficiently deal with the cases of dowry death as well as cruelty to married woman by her husband or his relatives.
This amendment was necessitated to meet the changing social conditions, which would save the married woman from the clutches of husband or her in-laws generally demanding more dowry. If she refused to bring more dowry she was maltreated within the four walls of her house. As the woman's parental home was far away from the matrimonial one the prosecution had a little chance for getting evidence in favor of them.
The section 113A of the Indian Evidence Act has an retrospective effect. It applies to all pending action irrespective of the fact that when the offence was committed. This can apply to the offence relating to the abetment of suicide even if the incident took place before the act coming into force i.e. before 1983 by an married woman.
In the case of Harikumar v State of Karnataka the court has said that by a plain reading of the provision it permits to draw the instances of cruelty even to prior to the date of concealment of this provision. The legal provision provided that under this section clearly concludes the past instances of cruelty spread over a period of seven years from the date of marriage the victim. Therefore it is permissible to the court to inquire into a case and look into the past conduct prior to the commencement date of the amending provision.
In another case, Gurubachan v Saptal Singh the Supreme Court has held that s113A does not create any new offence, nor does it create any substantial right, but it is merely a matter of procedure and its retrospective operation will apply to the offence committed prior to the insertion of s113A of the Indian Evidence Act.
The beauty of law is that if a person wants to get some remedy done through the court he has to prove the existence of certain factual situation. In the same way in order to attract the provision of s113A of the Indian Evidence Act the burden of proving the fact lies on the person who affirms it. This principle of burden of proof is applicable to all matrimonial offences. For attracting the provision of 113A the following things has to be proved.
1. Suicide must be committed by a married woman
2. Suicide must have been abetted by husband or any relative of her husband
3. Suicide must be committed with in seven years of the marriage
4. She must have been subjected to cruelty (as defined in 498A of Indian Penal Code) by her husband.
Presumption under section l13A refers to one of the three ingredients of abetment as defined in section 107 IPC i.e. instigation, conspiracy and intentional aiding of the act. Where conduct of the accused indicated that he did not want her to die even though he might have treated her cruelly earlier, it cannot be presumed that he abetted the suicide.
The first requisite for attracting this section is that it should be proved that the wife was subjected to cruelty as defined in 498A of Indian Penal Code. 'Cruelty' does not embrace acts of physical torture alone. When the evidence shows that the scolding, which the victim received from her mother-in-law, made her commit suicide, it will have to be construed as a willful conduct of mother-in-law. It should be assumed that such a nature as had driven the victim to commit suicide. The case is covered by Explanation (a) to s 498A, Indian Penal Code and presumption under s 113A of the Evidence Act can be raised. Acts of cruelty are invariably committed within the four walls of a house and naturally, eyewitnesses to such incidents are not easily available. The meaning of 'cruelty' as assigned in s 498A of the Indian Penal Code has to be imported in s 113A of the Indian Evidence Act while deciding whether he victim has been subjected to any cruelty or not. In the under mentioned case , a newly wedded girl died in burn injuries. Their in-laws accused the deceased of carrying an illegitimate child. Besides, the sisters and father of the deceased gave evidence that the she was tortured for bringing insufficient dowry and there was delay in giving medical aid to the deceased. Information about the incident was also conveyed to the father after a delay. The Supreme Court held that the deceased had committed suicide by he instigation of her husband and in-laws and presumption under 113A can be raised.
In order to attract this provision the proof of all the four ingredients must be there. The prosecution must prove that her husband or her in-laws have meted out cruelty to the victim.
In Chhagan Singh v State of Madhya Pradesh the accused beat the victim in the house of third person for stealing rice. Victim committed suicide within four days of that incident. There was no evidence to show that she was subjected to cruelty. The court acquitted the accused.
If there is proof of cruelty and harassment soon before the death of the victim, then the presumption can be raised under s113A and 113B of the Indian Evidence Act. In the case of murder the legal presumption of 113A is not attracted. This is also not attracted in the case where the death of a woman is due to other reason. The presumption can only be raised if the husband or any relative of her husband has treated the woman with cruelty by demanding more dowry.
In the case of Ved prakash v State of Madhya Pradesh the accused intimidated the deceased to repay the loan. The deceased committed suicide. But the court held that the presumption under 113A was not attracted. So the curt acquitted the accused. The presumption of abetment of suicide by a married woman is rebuttable. If the accused is able to prove that the woman has committed suicide by other reason or she was not harassed in her matrimonial house by her in-laws in the name of demanding more dowry. This presumption can be rebutted.
In the case of Nilakantha Pati v State of Orissa the accused was married to the victim in April 1982dowty was given to the groom's party. Accused desired to purchase a house, he asked the victim to bring Rs 70,00 from her house. When her attempt failed she was tortured. On 1986 she died. The accused put up the claim that as the accused family was a complete vegetarian and the victim was not able ti coup up with them, as she liked non-vegetarian diet. They said that Rs.70, 000 is too less for the purchase of a new house. The prosecution failed to counter. So the accused was acquitted of the charges. The High Court said that they presumption available here is rebuttable and such presumption can be raised where it has been provided that the wife has committed suicide within seven years of marriage and her husband must have subjected to cruelty. Here the cruelty has not been meted out to the deceased either by the accused or any relative of the accused.
There is an interesting fact to note that the presumption of 113A is applicable only against the husband not against woman. This was revealed with an interesting case that came before the High Court in 2000. It is the case of Alka Grewal v State of Madhya Pradesh the husband committed suicide leaving a note stated about the immoral character of her wife. The court said that a case of mental cruelty of wife by her husband, but the legislature has not seen this aspect. So the presumption of 113A cannot be drawn against the wife.
In one of the very famous case of case of suicide by a married woman the court brought this presumption when the marriage was eight years old. The victim and her three children set herself fire on 1983there was a dispute regarding dowry with her husband. In 1977 she made a complaint to the DSP apprehending the danger of her life, but by the time the police came to enquire this matter there was a understanding between them. She told the police to take no action against them and keep her application in pending. On the day of committing suicide telling about the maltreatment she faced. The husband was convicted.
Presumption as to Dowry Death
The term "dowry death" and "dowry murder" first began to be used around 1977-78 when investigations revealed that deaths of married women, which for years had been camouflaged by the police as accidents or suicides, were actually murders or abetted suicides, preceded by prolonged physical and mental torture by the husband and in-laws in connection with dowry demand. Instead of describing them as "wife murders" or "abetted suicides" the women's organizations began calling them "dowry deaths".
The section 113B of the Indian Evidence Act deals with the dowry death. Section 113B states that:
Presumption as to dowry death. -When the question is whether a person has committed the dowry death of a woman and it is shown that soon before her death such woman has been subjected by such person to cruelty or harassment for, or in connection with, any demand for dowry; the court shall presume that such person had caused the dowry death.
Explanation- For the purposes of this section 'dowry death' shall have the same meaning as in section 304-B of the Indian Penal Code (45 of 1860)
This section and the section 304B of Indian Penal Code has been added by the Dowry Prohibition (Amendment) Act No.43 of 1986 which was with effect from 19th November 1986. This was done in order to solve the increasing problem of dowry death. The word dowry death has been defined in 304B Indian Penal Code and the term dowry has deen defined in section 2 of the Dowry Prohibition Act 1961.
Section 304B of the Indian Penal Code states thatDowry death - (1) where the death of a woman is caused by any burns or bodily injury or occurs otherwise than under normal circumstances within seven years of her marriage and it is shown that soon before her death she was subjected to cruelty or harassment by her husband or any relative of her husband for, or in connection with, any demand for dowry, such death shall be called "dowry death", and such husband or relative shall be deemed to have caused her death.
Explanation. - For the purpose of this sub-section, "dowry" shall have the same meaning as in section 2 of the Dowry Prohibition Act, 1961 (28 of 1961). (2)Whoever commits dowry death shall be punished with imprisonment for a term which shall not be less than seven years but which may extend to imprisonment for life.
The definition of dowry as stated in s2 Dowry Prohibition Act 1961 is- 'Dowry' means any property or valuable security given or agreed to be given either directly or indirectly-
(a) by one party to a marriage to the other party to the marriage; or
(b) by parents of either party to a marriage or by any other to either party to the marriage or to any person; at or before or any time after the marriage in connection with the marriage of the said parties, but does not include dower or mahr in the case of person to whom the Muslim Personal Law (Shariat) applies.
Explanation. I Omitted.
Explanation. II. The expression 'valuable security' has the same meaning as in s 30 of Indian Penal Code 1860 (45 of 1860).
In the case of Keshab Chandra Pandey v State the presumption under s 113B of the Indian Evidence Act shall be raised only on the proof of the following essentials:
(i) Whether the accused has committed the dowry death of a woman. So the presumption can be raised if the accused is being tried for an offence under s 304B, Indian Penal Code.
(ii) The woman was subjected to cruelty or harassment by her husband or his relatives.
(iii) Such cruelty or harassment was for or in connection with the any demand for dowry.
(iv) Such cruelty or harassment was soon before her death.
Nature of Presumption
Section 113B uses the word "shall" and not 'may' so it is a presumption of law .On proof of the essentials mentioned above, it becomes obligatory on the court to raise a presumption that the accused caused the "dowry death". The court has no discretion to draw the presumption under this section if the essential ingredients are proved then they are bound to draw this presumption under s113B of the Indian Evidence Act. The legislature has made this presumption a mandatory presumption of law, of course, rebuttable, Though this may sound to be a violent departure from the accepted norms of criminal law. The legislature thought that the presumption under Section 113B should be a mandatory presumption if the evil of dowry deaths is to be eradicated from the roots of our society.
If it is proved that soon before her death, the victim was subjected to cruelty or harassment in connection of a dowry demand, then the presumption under s 113B can be raised. If the prosecution has failed to prove the case under s 304B, IPC, even then, no presumption can be raised under 113B of the Indian Evidence Act. So 304B is an integral part of 113B of the Indian Evidence Act. Cruelty need not be physical. Even mental torture in a given case would be a case of cruelty or harassment under 304B and 498A. In Nem Chand v State of Harayana the parties were married on 24-5-1962. After staying at the matrimonial home for two months, she returned to her parents' house and told them that her husband wanted a television set and a fridge. Her father gave her a sum of Rs. 6,000 and she left for her matrimonial home. Her husband again demanded a sum of Rs. 25,000 for purchasing a plot. There after the husband took his wife to her parents' home saying that he would not take her back unless a sum of Rs. 25,000 was paid to him. After one year he took her back but he did not give up his demand for Rs. 25,000. Soon thereafter she left for her parents home and came back with a sum of Rs. 15,000 with a promised that the rest of the amount would be would be paid later on. She died of strangulation in her husband's home. The trial court found accused guilty. Supreme Court held that accused should be convicted.
In a Shanti v State of Harayana , where the death took place within seven years of marriage, the in-laws of the deceased did not inform deceased's parents about the death but hurriedly cremated the deceased. The prosecution succeeded in establishing cruel treatment towards the victim. The death could not be said to be natural death and the presumption under s 113B of the Evidence Act was attracted.
The cruelty or harassment should be meet to the victim soon before the victim's death to bring under this presumption. In a case , there was dispute between parties regarding dowry and that wife, was sent back to her parent's home and was again taken back to her matrimonial home after a 'panchayat' which was held to resolve the dispute. This event happened 10-15 days prior to the occurrence of the incident as the death of the deceased. However, there was no evidence, which indicate that she was treated with cruelty or harassed with the demand for dowry during the period of between her taken back home to and her tragic end. In these circumstances, the presumption for dowry death cannot be raised. The court held that the, presumption of 113B could not be brought in.
In another case Mangal Ram & Anor v State of Madhya Pradesh, the wife committed suicide within five years of her marriage. She was living with her parents for about two-three years. Within one month of returning to her matrimonial home, she jumped in to a well, and committed suicide. Harassment by husband and her in-laws during this month has not been proved beyond reasonable doubt. In these circumstances, the presumption cannot be raised against the husband.
In another example Prem Singh v State of Harayana, there was, unnatural death of married woman in her husband's house within seven years of her marriage. Evidence showed that the husband had harassed her for not bringing sufficient dowry. Further, the medical evidence showed that the deceased died due to asphyxia as a result of smothering which is an unnatural death. No explanation offered by the husband as to how the deceased sustained several injuries on her body. The Court held, in the circumstances, the presumption of dowry death could be raised against the husband. As a result the High Court was justified in reversing his acquittal.
In Pawan Kumar v State of Harayana the deceased and the appellant were married in 1985. After a few days of the marriage there was demand of scooter and fridge. On account of not satisfying the demand, she was repeatedly taunted, maltreated and mentally tortured. In April 1987 when deceased's maternal uncle died, she along with her husband visited Delhi to offer condolences. And by evening on the same day instead of returning to her husband's place came to her sister's house. She remained there for a few days. When her husband came to take her back she was reluctant but her sister brought her down and sent her with her husband. She went with the husband but with the last painful words that' it would be difficult now to see her face in the future'. On the very next day, she committed suicide.
While examining the constituents of dowry death the court held that:
(a) when the death of a woman is caused by any burns or bodily injury; or
(b) occurs otherwise than under normal circumstances;
(c) and the aforesaid two facts spring within seven years of girl's marriage;
(c) and soon before her death, she was subjected to cruelty or harassment by her husband or his relative;
Hem Chand vs. State of Haryana Victim was married to accused , a police officer, on 1982. She was sent back to her maternal home whenever the persistent dowry demands were not met. On 1984, accused left victim with her parents to get some money. 1997, victim died of strangulation in her matrimonial home. The husband took her body to -his village. Victim father alleged that his daughter had been murdered for dowry. The police sent the highly decomposed Since the husband had subjected the wife to cruelty before her death, the presumption that he had caused her death, offered by section 113 B of the Indian Evidence Act, could be made.
Birth During Marriage, Conclusive Proof Of Legitimacy
Section 112 deals with the legitimacy of a child. The section reads as follows:Birth during marriage, conclusive proof of Legitimacy. -The fact that any person was born during the continuance of a valid marriage between his mother and any man, or within two hundred and eighty days after its dissolution, the mother remaining unmarried, shall be conclusive proof that he is the legitimate son of that man, unless it can be shown that the parties to the marriage had no access to each other at any time when he could have been begotten.
This section lays rules in existence with the rules of natural justice. It also assumes the existence of legal marriage. The legal presumption of paternity is applicable only to the offspring of married couple. From ancient times, it is the presumption that if the husband was within the four seas, at any time during the pregnancy of wife, the presumption was conclusive that her children were legitimate. Under this section, there is a conclusive presumption that a child born during the continuance of a valid marriage is a legitimate issue of parents, no matter, how soon the birth is, after the marriage. The husband who is strongly disputing the point of legitimacy of the child, can only rebut on the issue of legitimacy, in every case, is deemed.
Where the father and mother were or are married, it is a presumption of law, which is binding until rebutted. It is assumed that a person born in a civilized nation is legitimate. Though it is a strong presumption, it is not a conclusive presumption. It can be rebutted also by proving that, at the time when the children or any of them could have been conceived, the husband could not have had access to his wife. Where a married woman had admittedly lived for year with a man other than her husband and they both had admitted that he was the father of her children born during that time, the presumption of legitimacy was held to have been rebutted. In the Roman law according to the well-known maxim Pater Est Quem Nuptioe Demonstrant (he is the father whom the marriage indicates) the presumption of legitimacy is that a child born of a married woman is deemed to be legitimate, and the person who says it is illegitimate has the burden of proving it. The section has no application over the dispute of maternity. The presumption under this section can be drawn in all courts-civil, criminal or revenue- governed by Indian Evidence Act. The presumption applied here is irrebuttable.
In a case , the fact of customary marriage between father and his first wife was difficult to prove because it was performed 40 years back, which was way long. There was evidence, which revealed the fact they lived together as wife and husband, and the appellant came to be born from such wedlock, the presumption of the marriage being a valid marriage and so, the appellant being born legitimately.
Blood test is an important piece of evidence to determine the paternity of the child. Though by a blood test it cannot positively establish the paternity of the child, it can certainly exclude a certain individual as the father of the child. Therefore, while the negative finding in a blood test is definite, the positive finding only indicates a possibility. Now the DNA fingerprinting test has been much advanced and resorted to by the courts of law to resolve the dispute of paternity of the child.
Article 21 of the Constitution confers the fundamental right of life and personal liberty. In India chastity of the woman and paternity of the child hold much value and are issues of honour. No person in India will ever tolerate, cherish or like to be called a bastard nor will a woman tolerate to be called unchaste. These are parts of the dignity and honour for each man and woman in law. Article 21 confers right to life and provides that no person shall be deprived of his life or personal liberty except according to the due procedure established by law. The right to personal liberty is also very important. To compel a person to undergo him or herself to a medical test would interfere with the fundamental right.
Where adultery is to be established merely on the basis of the birth of an illegitimate child, it must be proved that the child had been born, as a. result of adulterous intercourse. The presumption is always in favour of legitimacy. To brand a child as illegitimate, it must be satisfactorily established that the birth of the child was clearly the result of an adulterous intercourse. Presumption of legitimacy being highly favoured by law, the proof of adulterous attitude must be clear and satisfactory. The party who alleges it must prove it. It is highly unsafe to base a finding of adultery and illegitimacy in the absence of clear and satisfactory evidence. The standard of proof required for proving adultery and illegitimacy is similar to the standard required for proof of guilt in a criminal case.
According to Mohammedan Law, a Mohammedan child, born within six months of the parents' marriage, would be presumed to be illegitimate under the Mohammedan law, it would be presumed to be legitimate under this section, if it were born during the continuance of the parent's marriage. According to Hindu law, to render a child legitimate, the procreation should take place after marriage. Ti is enough that the birth takes place after marriage, though the procreation was before.
This section consists of two parts. The, first part deals with the birth of a child during the continuance of a valid-marriage between a man and a woman; and the second part deals with the birth of a child during 280 days after the dissolution of that marriage. For example if the pregnancy of a woman was concealed, and a child was born to her within about four months of her marriage and she had been-driven out by the husband within a few days after marriage, it was held that no presumption can be raised inside this section.
Where a child is born during the continuance of a marriage, and the husband disowning the child fails to establish non-access to his wife beyond all reasonable doubts, then the presumption of legitimacy is available. In Prem Singh v Dalla Devi Where the marriage subsisted between the parties and the wife said that she had sexual intercourse with her husband on 28 December 1979 and, the child was born on 2 August 1980, and the husband failed to prove non-access, it was held that the evidence by the husband for disproving legitimacy and that he did not have sexual intercourse with the wife on 28 December 1979 alleged by the wife, is barred.
In the case of Sharmila Devi v Shankar Das, the two spouses had access to each other after marriage for a number of days and the child was born after six months of the marriage. The Himachal Pradesh High Court held the child' as legitimate child. A Mohammedan child born during the continuance of a valid marriage between its parents would be presumed to be legitimate, even before the ruksati ceremony.
Where evidence of access is given, it requires the strongest evidence of non-intercourse or other proof beyond reasonable doubt to justify a judgment of illegitimacy. The presumption is rebbuttable. In Ganashyam Chaturvedi v Radha Devi Where the child is born marriage, after 175 days after first intercourse and access of husband to the wife before marriage is not proved, the presumption under s 112 of the Evidence Act is not available and the child must be held an illegitimate child.
The word 'begotten' used in s 112 of the Act means 'conceived' and not 'born'. The emphasis on birth during wedlock as against conception is there in s 112 for the reason that as a general rule, it is the birth after marriage, which confers legitimacy on a child until its contrary is not proved.
Under the second part of the section, a child born within 280 days from the dissolution of a valid marriage will be presumed to be illegitimate. So in the case of widowhood, though cohabitation is not possible, the law will presume in favour of chastity of a woman and legitimacy of a child.
Where a child born some 365 days after the last period at which he could have been begotten by the husband of his mother and 357 days after the death of the husband, was set as legitimate, it was held that although such period of gestation was perhaps not absolutely beyond the bounds of possibility, yet there being evidence that the mother had been married to her husband for 10 years without having had any children by him, and also evidence which pointed strongly to the conclusion of immorality on the part of the mother, the only reasonable finding was the illegitimacy of the child.
The presumption of a child born within 280 days of the dissolution of the marriage, being legitimate is subject to the condition that the woman remains unmarried. If the woman remarries before the birth of the child, the second part of the section would have no application. The child would be presumed to be the legitimate child of the second husband under the first part of the section unless it is shown that the second husband had no access to the woman at any time when the child could have been begotten.
When a child was born within 5 months after the disillusionment of marriage presumption of legitimacy of the child arises,. The burden shift on the husband to prove that it was impossible to have access with the divorced wife and so it is a illegitimate child.
In this rule 'access' and 'non-access' mean the existence or non-existence of opportunities for sexual intercourse; it does not mean actual cohabitation. The section has to be applied with reference to the facts and circumstances of each case .so it refers from one case to another. The word 'access' in this section means 'effective access'. Physical incapacity to procreate, if established, amounts to non-access within the meaning of this section. The presumption under this section is the conclusive presumption of law. It can be only displaced by the proof of non ?access between the parties to the marriage when the child could have begotten. One can prove non-access saying that he had no intercourse with his wife and he is impotent.
With the introduction of the above-mentioned section the court would to some extent stop the violence and the atrocities committed to women. The presumptions has helped a lot in solving the problem of dowry death because in such cases it difficult to get evidence. The presumption is favorable to men at the same the courts could se that the women folk did not misuse this presumptions because in order to attract these presumptions the existence of certain facts have to be proved. The credit of trying to eradicate this evil should not be given to court alone; the legislature has also done a considerable amount of work. While enacting this provision it did not leave any loophole in order the convict to escape.
1. M.C. Sarkar, Law on Evidence, 16th ed, wadhwa and company, Nagpur 1991
2. Sr. John Woodroffe & Syed Amir Ali, Law of Evidence, 17th ed.,Vol II, Sreepada Venkata Ganmga Rao, New Dellhi, India,2002
3. Vijayarao Mohite & Vandana Chavan, Law on Cruelty, Abetment of Suicide by a Married Woman 1st ed., 1993 Akshar Chintamani Pune
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