Introduction
For many decades now, India’s criminal justice system has focused on the punishment of criminals and rendered the victims of crime as passive spectators to their own fate. In contrast, a completely different story has slowly evolved where there is a clear constitutional mandate for a broader and more humane concept of justice. The core of this change is the victims of crime as its citizens are worthy of dignity, their rights and constitutional protection, instead of being treated as mere witnesses to the proceedings.
Article 21, the heart of the Indian Constitution, is at the center of this evolving discussion. Initially read solely as a prohibition against the willful restriction of freedom, Article 21 is today the cornerstone of the Constitution for a human existence that is worthy of dignity. The right to life has expanded to include aspects of relief and rehabilitation for people whose lives have been shattered by crime as a result of a bold and compassionate court ruling. Victim compensation, once a peripheral or optional gesture, is now increasingly seen as a duty and a crucial way for society through the government, attempting to restore respect and honor an individual’s worth.
This article navigates the constitutional metamorphosis of victim compensation. It highlights not only legislative changes but also shifts judicial perspectives that have encouraged a more restorative approach to justice. This approach places compensation at the heart of our constitutional conscience as a right linked with the principles of justice, equality and humanity instead of portraying it as a minor benefit.
- Shift from punishment-centric to victim-centric justice
- Expansion of Article 21 to include dignity and rehabilitation
- Recognition of compensation as a constitutional duty
- Restorative justice over retributive justice
The law surpasses simple retribution and enters the sphere of social solidarity by making victim compensation a constitutional necessity. The Indian State is carrying the trust of the people by offering genuine redress for the injured as well as retribution for the guilty. In a nation working to mend scars, bridge inequalities and rebuild lives after crime, this change is essential. A legal system that truly seeks to honor every victim’s individuality must make the very challenging but necessary shift from statutory privilege to constitutional promise.
Historical And Statutory Trajectory Of Victim Compensation In India
India’s victim compensation history illustrates an astounding transition from traditional redressal practices to modern constitutional legal standards of redressal. From indigenous victim-centric approaches to colonial disruption to the contemporary constitutional recognition of victims as stakeholders with fundamental rights, this trajectory encompasses millennia of legal development.
| Period | Key Characteristics |
|---|---|
| Ancient India | Restorative justice, compensation-focused, victim dignity emphasized |
| Medieval Period | Continuation of local systems, Panchayat-based compensation |
| Colonial Era | State-centric justice, victims reduced to witnesses |
| Modern India | Constitutional recognition, victim rights emphasized |
Ancient Indian Foundations: The Golden Age Of Victim Rights
The intricate victim compensation mechanisms found in India’s early legal systems placed more emphasis on restoration than retribution. Modern restorative justice thinkers would effortlessly acknowledge the extensive frameworks for victim redress established by the ancient scriptures of Manusmriti and Arthashastra. The Manusmriti stated unequivocally that ‘if the limb is injured, the wound (inflicted) or the blood (flown from the attacker) must be repaired (to the victim) or paid in full, the usual penalty and the kings fine’.[1][2] This dual duty of the state punishment along with compensation to victims reflected a complex idea of justice that took into consideration both social order as well as personal damage.
Even more progressive rules for state accountability in victim compensation were found in Arthashastra, which is attributed to Kautilya. Most remarkably, it is said that the state treasury was responsible for compensating victims in cases where thieves could not be apprehended. This idea foreshadowed contemporary victim compensation schemes by more than two millennia.[3] According to R. Shamasastry, ‘ it was the duty of the King to protect the property of his people and if he could not restore stolen articles by apprehending the thief, it was deemed his duty to pay the price to the owner out of his own treasury’.[4]
- Compensation alongside punishment
- State responsibility in absence of offender
- Restorative justice principles embedded in law
In comparison to contemporary colonial impositions, these ancient systems operated on largely distinct foundations. The Dharmashastra traditions placed a strong emphasis on “Nyaya” (justice) through equitable restoration, in which compensation was determined to restore victims to their pre-punishment state rather than only punish them.[5] The amount of compensation varied according to the victim’s socioeconomic status with larger compensation required for offences against more vulnerable citizens of the society being an early recognition of inequitable vulnerability that is now promoted by victim rights advocates. [6]
Medieval Continuity And Islamic Influences
These restorative customs were upheld within native legal systems during the Islamic medieval period. Village councils or Panchayats were required to make use of local resources to compensate theft victims and address their losses during Sher Shah Suri’s rule.[7] While conforming to new administrative frameworks, these institutional procedures exhibited a striking continuity with traditional legal ideas.
Victim compensation techniques where further refined throughout the Mughal era, especially in rural areas where victim satisfaction and communal harmony were still prioritized by traditional dispute settlement mechanisms. These systems often entailed direct interactions between victims and offenders, enabling victims to voice their grievances. These techniques were later revived as novel approaches by contemporary restorative justice movements.7
- Panchayat-led compensation systems
- Community-based dispute resolution
- Victim participation in justice process
Colonial Disruption And Marginalization Of Victims
India’s approach to criminal justice was radically altered by British colonial administration that gradually superseded victim-centric customs with an adversarial system that placed the interests of the State ahead of the needs of individuals. Victims were confined to supporting roles as merely witnesses while the colonial legal system reinterpreted crime primarily as in offence against the Crown rather than against individual victims. [8]
Section 545(1)(b) of the Code of Criminal Procedure, 1898 was the first colonial rule to officially recognize victim compensation. It offered magistrates the authority to order ‘payment to any person of compensation for any loss or injury caused by the offence when substantial compensation is in the opinion of the court’. 9 However, owing to its emphasis on ‘substantial’ compensation and the limited judicial interpretation that denied relief to several meritorious instances, this clause remained ineffective.
| Aspect | Colonial Impact |
|---|---|
| Nature of Crime | Offence against Crown |
| Role of Victim | Mere witness |
| Compensation | Limited and discretionary |
| Legal Approach | Adversarial system |
Post- Independence Awakening And Judicial Activism
Victim rights received very little attention in early decades after independence since the criminal justice system was still focused on crime-control measures that carried on the colonial tradition of state-centric justice. Groundbreaking rulings that questioned the system’s disregard for those directly impacted by crime sparked a judicial awakening to victim concerns in the 1970s.
Justice Krishna Iyer made a foresighted statement in Rattan Singh v. State of Punjab (1979) that would resonate throughout decades of later jurisprudence, he said ‘victim reparation is still the vanishing point of our criminal law.’[9] The gradual process of redirecting criminal justice towards a more balanced approach that recognized both retribution and restoration as crucial elements of justice began by this judicial recognition.
Key Judicial Insight
- Shift from state-centric justice to victim-centric considerations
- Recognition of victim reparation as an essential component of justice
- Beginning of balance between retribution and restoration
Legislative Evolution: From Section 357 To 357a
The idea behind introducing victim compensation to statutory criminal procedure originated in the Law Commission of India’s 41st Report (1969). Section 357 of the CrPC 1973 created a major step forward by enacting these recommendations. It eliminated the restrictive ‘substantial compensation’ requirement and enhanced the court’s authority to grant compensation ‘irrespective of whether the offence is punishable with fine or fine is actually imposed. [10]
The 2009 modification that incorporated Section 357A marked a turning point in India’s victim compensation jurisprudence. The 154th Law Commission Report recommended this provision that essentially changed victim compensation from discretionary judicial power based on offender conviction to a state subsidized entitlement provided in four different situations i.e. conviction, acquittal, discharge and situations in which offenders are unidentified or untraced. 12
Comparison: Section 357 Vs Section 357a
| Aspect | Section 357 | Section 357A |
|---|---|---|
| Nature | Discretionary Judicial Power | State-Sponsored Entitlement |
| Applicability | Primarily upon conviction | Conviction, acquittal, discharge, unidentified offenders |
| Compensation Source | Offender-based | State-funded scheme |
Section 357A mandated every state government to ‘prepare a scheme for providing funds for the purpose of compensation to the victim or his dependents who have suffered loss or injury as a result of the crime and who require rehabilitation.’ [11] This clause recognized that the State’s duty to its citizens extends beyond mere prosecution to include active restoration and rehabilitation, indicating a paradigm shift towards state accountability for victim welfare.
Contemporary Developments And Institutional Framework
By enacting Section 357C that requires no-cost medical treatment for victims of sexual offences, subsequent legislative advancements such as the Criminal Law (Amendment) Act, 2013 have further enhanced victim compensation.[12] Federal recognition of compensation as a national issue demanding coordinated state-by-state execution is observed in the formation of Central Victim Compensation Fund Scheme (2015). [13]
Recent Developments
- Introduction of Section 357C for free medical treatment
- Criminal Law (Amendment) Act, 2013 strengthening victim rights
- Central Victim Compensation Fund Scheme (2015)
Trouble with implementation still exists in spite of these developments. Only 1% of cases received interim compensation, according to Supreme Court remarks in recent instances and final compensation was similarly infrequent. 16 These figures demonstrate the persistent discrepancy between legal promises and actual implementation, underscoring the importance of ongoing reform initiatives in order to fully realize the potential of India’s victim compensation system.
Implementation Challenges
| Issue | Observation |
|---|---|
| Interim Compensation | Only 1% of cases received it |
| Final Compensation | Rarely awarded |
| Gap | Mismatch between legal framework and implementation |
The evolution of victim compensation from an ancient constitutional obligation to colonial neglect and back to contemporary constitutional imperative appears by this historical trajectory that reflects broader changes in legal philosophy and the growing recognition of victims as stakeholders with rights who ought to be protected and supported by the State.
Comparative Constitutional Approaches to Victim Compensation
Different methods enshrining victim rights within legal systems can be observed by comparing victim compensation schemes among constitutional democracies. Studying overseas models offers significant insights for bolstering implementation and resolving persistent deficiencies in the Indian framework even though India’s constitutional journey towards recognizing victim compensation under Article 21 constitutes tremendous progress.
1. Canada: The Canadian Victims Bill of Rights
The Canadian Victims Bill of Rights (CVBR), which was passed in 2015 provides victims federal rights including knowledge, security, participation and restitution and serves as the framework for Canada’s victim compensation policy. In contrast to India, where Article 21 functions as the constitutional underpinning, Canada’s framework declares that ‘every victim has the right to have the court consider making a restitution order against the offender.’[14] However, there is no uniform constitutional provision that is comparable to India’s Article 21 structure and victim compensation levels in Canada nevertheless vary by province. [15]
By compelling courts to take reparation orders into thought while determining sentences, the CVBR establishes mandatory judicial consideration in contrast to discretionary relief. As a result, Section 357 CrPC in India still continues to face challenges being implemented even after amendments. Though this has given rise to provincial discrepancies similar to those observed in Indian state-wise compensation schemes, Canada’s approach indicates how legislative frameworks can generate effective victim rights despite no explicit constitutional entrenchment. [16]
Key Takeaways from Canada
- Statutory rights framework (CVBR) instead of constitutional provision
- Mandatory judicial consideration of restitution
- Provincial variation in compensation schemes
- Effective victim protection without constitutional entrenchment
2. European Union: Directive-Based Harmonization
The EU model requires member states to establish compensation plans for victims of violent intentional crimes, emphasizing harmonization while upholding national sovereignty.20
The notion of ‘victim’ now encompasses both direct victim and close relatives as indirect victims that ensures broader protection than many national systems initially offered. 21 The EU’s focus on ‘fair and appropriate compensation’ establishes legally binding guidelines while providing member states flexibility in how they prefer to execute them. [17] This balanced strategy tackles India’s issues with subsidiarity and homogeneity in integrating federal and state compensation programs.
Key Features of EU Model
- Directive-based harmonization across member states
- Broad definition of victim (direct + indirect)
- Flexible implementation with binding standards
- Balance between central coordination and national autonomy
3. Germany: Comprehensive Statutory Framework
The Opferentschädigungsgesetz (Victim Compensation Act) of 1976 created Germany’s victim compensation system that offers unconditional compensation within a social security framework. [18] Germany’s system ensures long-term victim support rather than one-time relief by providing recurring compensation linked with social security benefits in contrast to the lump-sum payments customary in other jurisdictions.
The German approach places a strong emphasis on both rehabilitation and compensation. Benefits are calculated using the ‘Grad der Schädigungsfolgen’ (degree of harm consequences) that measures functional impairments in various spheres of life. [19] This approach indicates how systematic evaluation can guarantee equitable relief in contrast to India’s occasionally inadequate lump-sum compensation amount.
The 2017 psychological support laws in Germany offer thorough victim help prior to, during and post criminal procedures. [20] This comprehensive approach strategy extends beyond India’s large financial emphasis arguing that constitutional victim compensation must cover more than mere monetary assistance.
Highlights of German Model
- Social security-linked compensation system
- Recurring benefits instead of lump-sum payments
- Scientific evaluation of harm
- Strong focus on rehabilitation and psychological support
4. South Africa: Constitutional Recognition and Implementation Challenges
Given that South Africa and India share constitutional traditions, the country’s approach provides pertinent lessons. Although victim compensation is not expressly guaranteed by the constitution, the Bill of Rights in South African Constitution recognizes access to justice and human dignity as fundamental elements. [21] Despite constitutional protection for dignity and access to justice, South Africa has struggled to establish comprehensive victim compensation schemes with the South African Law Reform Commission declaring in 2001 that full implementation remained unfeasible due to resource constraints. [22]
The history of South Africa indicates that the absence of adequate institutional frameworks and funding sources, constitutional recognition is insufficient on its own. This is akin to India’s implementation difficulties in spite of the constitutional basis of Article 21 highlighting the necessity of robust administrative frameworks to transform constitutional commitments into concrete assistance.
Lessons from South Africa
- Constitutional recognition alone is insufficient
- Resource constraints hinder implementation
- Need for institutional and financial support systems
- Parallel challenges with India’s framework
5. New Zealand: Integrated No-Fault Network
The distinctive strategy implemented in New Zealand incorporates victim compensation within a thorough no-fault accident compensation program that covers all personal injuries regardless of the cause. [23] By offering universal coverage through Accident Compensation Corporation which is financed by a variety of sources including premium payments and government contributions, this system deals with the distinction between victims of crimes and victims of accidents. [24]
The New Zealand model indicates how victim compensation can be addressed through comprehensive social insurance without the stigmatization and convoluted eligibility requirements that are inherent with fault-based systems. Although, culturally specific, this strategy raises the possibility of a deeper social security integration, that could potentially close the coverage and consistency gaps that exist in India at this time.
Key Features of New Zealand Model
- No-fault compensation system
- Universal coverage for all personal injuries
- Funded through mixed sources (premiums + government)
- Eliminates distinction between crime and accident victims
Lessons for India’s Constitutional Framework
Several significant insights regarding the development of victim compensation in India are indicated by these comparative examples. First, robust institutional procedures are necessary for the efficient execution of constitutional entrenchment despite it being essential for establishing fundamental principles. Second, central coordination while maintaining local authority is necessary for harmonization amongst jurisdictions whether they are Indian or EU member states. Third, comprehensive victim support that includes social services, counselling and rehabilitation works efficiently than just monetary compensation. Finally, sustainable finance mechanisms and professional administrative structures remain vital regardless of constitutional status.
Though implementation issues indicate the need for institutional reforms guided by international best practices to realize the potential of constitutional victim guarantees, India’s Article 21 offers a stronger constitutional foundation than many jurisdictions.
Comparative Overview Table
| Jurisdiction | Approach | Key Feature | Limitation |
|---|---|---|---|
| Canada | Statutory Rights (CVBR) | Mandatory restitution consideration | Provincial variation |
| European Union | Directive-Based | Harmonization with flexibility | Implementation varies by state |
| Germany | Social Security Model | Long-term recurring compensation | Complex assessment system |
| South Africa | Constitutional Recognition | Dignity & access to justice | Weak implementation due to resources |
| New Zealand | No-Fault System | Universal injury coverage | Culturally specific model |
The Future Trajectory: Technology, Transformation and Constitutional Fulfillment
India’s victim compensation scenario is at a turning point as constitutional requirements, legal change and technology development work together to reshape the fundamentals of restorative justice. Following the complete implementation of the Bhartiya Nagarik Saraksha Sanhita (BNSS) 2023, India’s victim compensation system shall soon undergo a revolutionary overhaul that will ultimately bridge the gap between constitutional ambition and real-world application.
Digital Revolution in Victim Compensation
Section 396 of the BNSS 2023 provides revolutionary elements that radically rethink the way victim compensation is delivered. [25] The new law requires digital platforms for smooth coordination between the Central and State Governments, in contrast to the conventional paper-based CrPC architecture. This creates an integrated ecosystem where victims can monitor their compensation claims in real-time. [26]
- Digital platforms for coordination between Central and State Governments
- Replacement of conventional paper-based CrPC system
- Real-time monitoring of compensation claims by victims
Early trial investigations in five states have indicated remarkable outcomes with blockchain-enabled tracking systems improving transparency and reducing processing times by 35%. [27]
| Technology Used | Impact |
|---|---|
| Blockchain Tracking Systems | Improved transparency and 35% reduction in processing time |
Artificial Intelligence Integration
Another paradigm shift in the evaluation of victim compensation is the incorporation of artificial intelligence. The BNSS architecture anticipates AI-powered preliminary eligibility screening that can immediately analyze victim claims based on FIR data, medical records and socio-economic characteristics.[28]
- AI-powered eligibility screening
- Analysis based on FIR data, medical records and socio-economic factors
- Faster processing and prioritization of vulnerable victims
By addressing the system’s previous chronic delays, this technology intervention assures that vulnerable victims, especially those from marginalized communities get priority attention and swift assistance.
Enhanced Victim-Centric Provisions Under BNSS 2023
Beyond its predecessor, Section 357A CrPC, Section 396 of BNSS introduces novel measures that places victim accessibility and dignity first.[29]
Immediate Medical Assistance
The provision of free first-aid and medical assistance instantly, supported by certification from the police or magistrate, guarantees that victims receive vital care without spending time waiting for bureaucratic procedures. [30]
Expanded Definition of ‘Victim’
Furthermore, Section 2(1)(y) BNSS recognizes the impact of crime on entire families by extending the concept of ‘victim’ to include guardians and legal heirs. 36
| Provision | Key Feature |
|---|---|
| Section 396 BNSS | Victim-centric compensation and accountability |
| Section 2(1)(y) BNSS | Expanded definition of victim to include family |
| Medical Assistance Provision | Immediate free first-aid and treatment |
Accountability and Timeframe
In contrast to the discretionary system, the mandated two-month timeframe for compensation enquiries established by BNSS Section 396(5) establishes enforceable accountability mechanisms. [31]
- Two-month mandatory enquiry timeline
- Legal obligation on Legal Assistance Authorities
- Performance indicators linked to compensation delivery
Legal Assistance Authorities are now required by law to finish investigations within certain constraints and performance indicators are being connected progressively to the effectiveness of compensation delivery.
Emerging Jurisprudential Trends and Future Decisions
Recent rulings by the Supreme Court indicate an apparent choice from discretionary to mandatory payments. The evolving jurisprudential interpretation of the reach of Article 21 is demonstrated in the Court’s statement in Mahabir & Ors v. State of Haryana (2024) that victim compensation is ‘constitutional empathy’ rather than judicial discretion. [32]
- Shift from discretionary to mandatory compensation
- Expansion of Article 21 interpretation
- Recognition of compensation as a constitutional obligation
This pattern indicates that rather than perceiving compensation denial as a procedural oversight, future court rulings will progressively observe it as a constitutional violation.
Expanding Scope Of Restorative Justice
In India, the future of victim compensation extends beyond financial assistance to include entirety of restorative frameworks that encompasses reintegration, vocational training and psychological rehabilitation. The algorithm for this comprehensive strategy is the Compensation Scheme for Women Victims/Survivors of Sexual Assault that incorporates rehabilitation assistance, legal aid and counselling services into compensation plans. [33]
- Reintegration of victims into society
- Vocational training for sustainable livelihoods
- Psychological rehabilitation and counselling support
- Legal aid integrated within compensation frameworks
Integration of Corporate Social Responsibility (CSR) is an additional funding mechanism that has the potential to significantly increase the amount of resources accessible. Gujarat and other states have effectively increased victim compensation funds through CSR contributions, establishing persistent public-private partnerships that supplement government funding. 40 According to this concept, future initiatives may rely heavily on a variety of funding resources than merely governmental financial provisions.
| Component | Description |
|---|---|
| CSR Integration | Enhances funding through private sector contributions |
| Public-Private Partnerships | Supports long-term sustainability of compensation funds |
| Government Funding | Primary financial backbone of victim compensation schemes |
International Integration And Best Practices
International cooperation and the adoption of best practices are becoming important in India’s victim compensation future. The nations adherence to the UN Basic Principles and Guidelines on Victim Compensation indicates that it is in accordance with international norms and while preserving customs the date back to ancient restorative practices. [34]
- Alignment with UN Basic Principles and Guidelines
- Preservation of traditional restorative practices
- Adoption of global models for improvement
Future initiatives may include aspects of effective foreign models like the no-fault system in New Zealand or the harmonization based on EU directives for the constitutional and cultural circumstances of India.
| International Model | Key Feature |
|---|---|
| No-Fault System (New Zealand) | Compensation without proving fault |
| EU Directives | Harmonized victim compensation frameworks |
India’s victim compensation system is poised for an unparalleled revolution due to the convergence of technical innovation, constitutional interpretation and worldwide standards. To guarantee that technology advancements result in significant assistance for people in dire need of justice and dignity, success hinges on persistent political will, judicial leadership and civil society involvement. India has the opportunity to become a world leader in victim-centric justice as the BNSS framework develops, demonstrating how constitutional principles may be implemented through creative legal and technological innovations that fulfil Article 21’s promise.
Conclusion: Towards A Constitutional Renaissance In Victimcentric Justice
A significant shift in our conception of justice could be witnessed in the development of victim compensation in India which began with the restoration principles of the ancient Dharmashstra and progressed through colonial marginalization to a robust constitutional guarantee under Article 21. This journey serves as a reminder that effective justice must include both the active restoration of victims’ well being and dignity along with retribution to the perpetrators.
A key factor in this change has been judicial activism. The state’s affirmative duty to compensate victims was mandated by landmark decisions in Rudul Shah v. State of Bihar and State of Punjab v. Gurmit Singh which constitutionalized victim compensation as a component of the right to life. Through Section 396, the Bhartiya Nagarik Suraksha Sanhita 2023 further institutionalizes this constitutional commitment by implementing blockchain monitoring, digital platforms and AI-enabled assessments to improve transparency and speedy compensation.
- Judicial activism as a catalyst for reform
- Recognition of compensation as part of the right to life
- Technological integration: blockchain, AI, digital platforms
India’s Article 21 structure offers a robust constitutional foundation, despite the fact that many democracies rely on statutory or directive-based frameworks according to comparative analysis. This places India in a position to lead the world in victim-centered justice. However, there remain concerns with implementation such as differences across states, lengthy processing moments and low victim awareness. Absence of corresponding shifts in finance, institutional capability and outreach, technological innovation by itself is unable to bridge these gaps.
| Challenges | Impact |
|---|---|
| Inter-state Differences | Unequal access to compensation |
| Processing Delays | Delayed justice and support |
| Low Awareness | Underutilization of compensation schemes |
By adopting a holistic approach, victim compensation will be transformed from a discretionary clause to a constitutional requirement that represents societal cohesion. India can guarantee that every victim of crime receives timely, sufficient and dignified remedy by operationalizing Article 21’s promise of life with dignity. This will mend both individual lives and the societal fabric that has been torn apart by crime. End Notes:
- Cries for Justice: Analyzing the Plight of Crime Victims in India (2025), Indian Journal of Advanced Research, Vol [2].
- Kautilya, Arthashastra, Book IV, Chapter 1; R. Shamasastry (trans), Kautilya’s Arthashastra (1915).
- Id.
- Victimology in India: Historical Roots and Modern Developments, The Law Institute (2025).
- Analysis of Hindu Law and its Implications on Crime and Justice in Ancient India (2024), International Journal of Humanities and Social Sciences, Vol 13(12).
- Concept of Victimology, in Indian Criminal Justice Administration (2024), Indian Journal of Integrated Research, Vol IV(I).
- The Growth of Victim Compensation in India (2019), International Journal of Research in Social Sciences, Vol 9(3); Section 545(1)(b), Code of Criminal Procedure, 1898.
- Rattan Singh v. State of Punjab, (1979) 4 SCC 719, Para 6.
- Code of Criminal Procedure, 1973, Section 357; Statements of Objects and Reasons, CrPC Bill 1970; Law Commission of India, 154th Report (1996); Section 357A, CrPC (Amendment Act, 2009).
- Section 357A(1), Code of Criminal Procedure, 1973.
- Criminal Law (Amendment) Act, 2013, Section 357C.
- Ministry of Home Affairs, Central Victim Compensation Fund Scheme, Notification dated October 14, 2015; In Re Alarming Rise in the Number of Child Rape Incidents, Suo Moto Writ (Crl) 1 of 2019.
- Canadian Victims Bill of Rights, SC 2015, Ch 13, S2.
- Id., Section 16.
- Council Directive 2004/80/EC; Directive 2012/29/EU of the European Parliament and of the Council; European Parliament, Revision of the Victim’s Rights Directive (2023); Case C-129/18, SM v. Entry Clearance Officer (2019).
- Compensation for Victims of Violent Crimes, VerfBlog (Nov 28, 2024). URL: https://verfassungsblog.de/
- Opferentschädigungsgesetz (OEG) Victim Compensation Act, July 11, 1976, BGBI. I S. 1976.
- Differences between Victims of Domestic Violence and Victims of Violence in Public Spaces, Deutsches Ärzteblatt (2024).
- Id.
- Constitution of the Republic of South Africa, 1996, Chapter 2.
- South African Law Reform Commission, Discussion Paper: A Compensation Scheme for Victims of Crime (2001).
- Compensating Crime Victims Within New Zealand’s No Fault Accident Compensation Scheme, 169 NCJ (1996).
- Id.
- Bhartiya Nagarik Suraksha Sanhita, 2023, Section 396.
- Victim Compensation in The Criminal Judicial System in India, International Journal of Novel Research and Development, Vol 10, p. 566 (2025).
- NALSA, Digital Integration Pilot Results (Dec 2024).
- How to Apply for Victim Compensation Scheme Under BNSS 2023, Bharat Law AI (Nov 4, 2024). URL: https://bharatlaw.ai/
- Legal Regime on Victim Compensation in Britain, USA and India, Dehradun Law Review (2025).
- BNSS Section 396(6); BNSS Section 2(1)(y).
- BNSS Section 396(5).
- Mahabir & Ors v. State of Haryana, reported in Factsheet: Victimology, CJP (Feb 18, 2025). URL: https://cjp.org.in/
- NALSA, Compensation Scheme for Women Victims/Survivors of Sexual Assault and Other Crimes (2018); Gujarat State Legal Services Authority, CSR Integration Annual Report (2024).
- UN Basic Principles and Guidelines on the Right to Remedy and Reparation. URL: https://www.ohchr.org/
