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A Critical Study On Victim Compensation Under Various Laws Of India

Victim compensation was a unique concept formulated by the Indian Judiciary in order to secure justice. The modern concept of justice has shown immense concern by providing relief mechanisms to compensate victims. Hence, provisions and legislations catering to victim compensation have been evolving ever since the formulation of the Indian Constitution.

The genesis of rights of the victims started fostering during the last few decades following the UN Declaration of Basic Principles of Crime and Abuse of Power, 1985. Since then, the acknowledgement that the victim comes under the under the centre of the criminal justice system arose, and consistent efforts were made in order to improve their conditions.[1]

One primary aspect to reassure and assist the victim would be compensating for the damage caused, this was considered as an essential proponent of ‘Right to life’ under Article 21 of the Indian Constitution.[2] Later, Section 357A of the Code of Criminal Procedure, 1973 made it mandatory for the state to provide compensation for the victims and their dependent who has been injured as a consequence of the damage caused. Victim Compensation Schemes were formulated by almost all states of the country, to provide for appropriate compensation.[3]

The discovery of restitution in Indian law can be traced back to the era of British Colonisation. Section 545, sub-clause (1) (b) of Code of Criminal Procedure of 1898, imparts that court may give directions to pay an individual, compensation for losses incurred or injury caused due to the offence, where substantial compensation is rightful, in the opinion of the court, considered recoverable by such individual in the civil courts.[4]

In the 41st Report of the Law Commission of India submitted in the year 1969, the importance of compensability was initially distinguished by the word ‘substantial ‘which alienated the cases of recovery of nominal charges. The Government of India formulated the Code of Criminal Procedure Bill, 1970 on the recommendations made in the report of the Law Commission, Section 545 was revised and was re-introduced in the manner of Section 357, which is currently working and brought forth significant changes in the framework.[5]

The legislative framework regarding compensatory relief to victim of crime in India may be traced to the code of Criminal Procedure. The Probation of Offenders Act, 1985, The Motor Vehicles Act, 1988, Consumer Protection Act, 1986, Indian Railways Act, Protection of Women from Domestic Violence Act, 2005, Sexual Harassment (Prevention, Protection and Redresses) Act, 2013, Fatal Accidents Act, 1855 also contain provision for award of compensation to victims of crime. Beside these legislations, the Constitutional scheme for compensatory victim is to be found in the form of decisions of the Supreme Court while interpreting fundamental rights or directive principles of State Policy or Articles 32, 136 and 142, when the court may direct payment of compensation to victims of crime.[6]

Research Methodology
Whereas the current study work of all the existing literature available in shape of reports, judgments, books, research papers, Google etc. has been consulted. In brief, Doctrinal approach has been adopted.

Hypothesis
There must be the provision of all facilities which help in the positive development of the Victim compensation scheme. There is a need for public awareness regarding victim compensation because many people are unaware of such a scheme and will not take advantage of it.

Aims and Objective
Victim compensation is a direct financial reimbursement to a victim for an expense that resulted from a crime, such as medical costs or lost wages. Each state has a crime victim compensation program that allocates funds to survivors of sexual assault and other violent crimes.

Who Is Called Victim India?

Victims means persons who, individually or collectively, have suffered harm, including physical or mental injury, emotional suffering, economic loss or substantial impairment of their fundamental rights, through acts or omissions that are in violation of criminal laws operative within Member States, including those laws proscribing criminal abuse of power.

The following people can exercise a victim’s rights if the victim is dead or not able to act on his or her own behalf:
A victim’s spouse
A common law partner who has lived with the victim for at least one year prior to the victim’s death
A relative or dependant of the victim
Anyone who has custody of the victim or of the victim’s dependant

A person who has been charged, convicted, or found not criminally responsible due to a mental disorder for the offence that resulted in the victimization is not defined as a victim. For example, if a parent has been charged with abuse of a child, that parent will not be allowed to exercise the child victim’s rights or their own rights as a parent.[7]

Within the Indian legal framework, the term victim is defined under Section 2(wa) of the CrPC[8], 1973 as a person who has suffered any loss or injury caused by reason of the act or omission for which the accused person has been charged and the expression victim includes his or her guardian or legal heir.

Scheme behind Victim Compensation
The purpose of the criminal justice is to protect the rights of the individuals, society and state from the criminals by punishing the accused for violating the law. In case the accused is found guilty, he/she is punished with imprisonment and kept in prison with an object of reforming him/her.

While the entire focus of the law is on the offender, to protect his/her rights, to punish him/her and thereby bring about his/her reformation and rehabilitation with all the resources and goodwill available through courts and other agencies, the victim, more often, is left to fend for himself/herself with little or no assistance coming his/her way.

The violation of his/her rights, the invasion of his/her dignity, the actual losses incurred by him/her do not constitute matters of concern for anyone, but himself/herself. His/her role is limited to reporting the crime to officials who decide whether to prosecute the case, how to proceed, and what type of punishment to recommend.

Strange but true, justice fails to redress the wrong perpetrated by the offender on the victim; on the contrary, it aggravates the injustice by focusing solely on the offender, side-lining the victims’ minimum needs and requirements. The victims have right to get justice, to remedy the harm suffered as a result of crime.

This right is different from and independent of the right to retribution, responsibility of which has been assumed by the state in a society governed by Rule of Law. But if the state fails in discharging this responsibility, the state must still provide a mechanism to ensure that the victim's right to be compensated for his injury is not ignored or defeated.

History Of Victim Compensation In India

The ancient Indian History is a witness to the fact that the victims of crimes have sufficient provisions of restitution by way of compensation to injuries. Author of the book, General Principle of Hindu Jurisprudence Dr. Priyanath Sen has observed:
It is, however, remarkable that in as much as it was concerned to be the duty of the King to protect the property of his people, if the King could not restore the stolen articles or recover their price for the owner by apprehending the thief, it was deemed to be his duty to pay the price to the owner out of his own treasury, and in his turn he could recover the same from the village officers who by reason of their negligence, were accountable for the thief’s escape.

Reparation or compensation as a form of punishment is found to be recognized from ancient time in India. In ancient Hindu law, during Sutra period, awarding of compensation was treated as a royal right. The law of Manu, requires the offender to pay compensation and pay the expenses of cure in case of injuries to the sufferer and satisfaction to the owner where goods were damaged. In all cases of cutting of a limb, wounding or fetching blood, the assailant shall pay the expenses of a perfect cure or in his failure, both full damages and a fine.

It shows that the victim compensation was never an alien concept in the justice delivery systems of the country. The edifice of the law in our present day legal systems relating to the victim compensation are provisions contained in the Criminal Procedure Code, 1973 and various judgments of the Hon’ble Supreme Court. The question that arises for consideration is that despite having laws for victim compensation are these laws being satisfactorily used by those on who lies the duty of the execution of these laws and to give beneficial effects to it. Answer is very infrequently.

The reasons are many. Some more prominent are like the 12th century distinction of English law of wrongs into civil wrongs and criminal wrongs which leads to misconception that the area of compensation is something exclusively belonging to the domain of civil law and others less obvious like the ignorance of those who can give effect to these benefactions. The present criminal justice system is based on the assumption that the claims of a victim of crime are sufficiently satisfied by the conviction of the perpetrator.

It is a truth that in our present day adversarial legal system between the state and the accused, the victim is not only neglected but is lost in silence. The role of the victim is limited to report the offence and depose in the court on behalf of prosecuting party, which is the State.

That’s all. The Malimath Committee reflected on the present criminal justice system that not only the victim’s right to compensation was ignored except as token provision under the Criminal Procedure Code but also the right to participate as the dominant stakeholder in criminal proceedings was taken away from him. He has no right to lead evidence, he cannot challenge the evidence through cross-examination of witnesses nor can he advance arguments to influence decision-making.

The Malimath Committee Report

In order to revisit the machinery of criminal justice in India, in 2003, the Committee on Reforms of Criminal Justice System was constituted under the Chairmanship of Justice V.S. Malimath. The Malimath Committee Report made observations regarding the history of the criminal justice system and how it was apparent that it mostly protected the ‘power, the privilege and the values of the elite sections in society’.

It evaluated the way crimes are defined in the modern era. The administration of the system demonstrated that there is an ingredient of truth of such a narrow perception. The primary assumption in the functionality of a criminal justice system is that it is the prerogative and dominant function of the State to protect all citizens from harm to their person and property.

The State is believed to actualize this by ‘depriving individuals of the power to take law into their own hands and using its power to satisfy the sense of revenge through appropriate sanctions.’ The Committee Report argued that the State itself becomes a victim when a citizen commits a crime, and as a consequence undermines its authority and contravenes norms in society.

It is this victimization that shifted the focus of attention from the real victim who suffered the actual injury to the offender and how he is handled by the State. It was this failure of the State to adequately protect the interests of its citizens that led to the transformation of torts to crimes. With respect to the criminal, the Report noted that criminal justice has matured to comprehend the intricacies of the vehicle of crime: the criminal and the process of ascertaining his guilt, proving it in a court of law and punishing him. Civil law dealt with the Published in Articles section of 97 monetary and other losses suffered by the victim.

Since victims were marginalized and vulnerable, the State stood forth in the shoes of the victim to prosecute and punish the perpetrator. With respect to the rights of the victim, the Report pondered - 6.7.2. What happens to the right of victim to get justice to the harm suffered? Well, he can be satisfied if the State successfully gets the criminal punished to death, a prison sentence or fine. How does he get justice if the State does not succeed in so doing?

Can he ask the State to compensate him for the injury? In principle, that should be the logical consequence in such a situation; but the State which makes the law absolves itself. The principle of compensating victims has been recognized more often as a token relief than as a punishment to the offender, or substantial remedy to the victim offered by law.

However, provisions in the procedural law of crime in India provides for sentence of fine imposed both as a sole punishment and as an additional punishment according to the wisdom of the court. However, this provision is only invited when the perpetrator is convicted of the charges he is accused of. In 2008, significant amendments were made to the CrPC that focused on the rights of victims in criminal trial, particularly relating to sexual offences.

Although the amendments left Section 357 unaffected, they introduced Section 357-A which empowers the court to direct the State to pay compensation to the victim in cases where ‘the compensation awarded under Section 357 is not adequate for such rehabilitation, or where the cases end in acquittal or discharge and the victim has to be rehabilitated’. Section 357A subtly recognizes compensation as one of the methods to protect the interest of victims.

The provision was incorporated on the recommendation of the 154th Report of the Law Commission. The focus of the provision is on the rehabilitation of the victim even if the accused is not tried. In such instances, the victim is required to make an application to the State or District Legal Service Authorities as the case may be, for the purpose of Sec. 357, CrPC. Inserted by Code of Criminal Procedure Amendment Act (2008). Sec. 357A, CrPC. Published in Articles section of 98 compensation.

The jurisprudence of this provision and the obligation of courts have been defined by the Hon’ble Supreme Court:
While the award or refusal of compensation under Section 357 of Code of Criminal Procedure, in a particular case may be within the court's discretion, there exists a mandatory duty on the court to apply its mind to the question in every criminal case. Application of mind to the question is best disclosed by recording reasons for awarding/refusing compensation.[11]

Compensatory Provision Under The Code Of Criminal Procedure, 1973

Section 357: Order to Pay Compensation
The extent and application of Section 357 extend to any order in relation to compensation which is passed by the trial court, a court of the session or any appellant or High court while applying their revision jurisdiction. The Apex court is also empowered under this section to order compensation. The implementation of this Section is restricted in the application under four specific instances.

These compensations can be claimed by the complainant to satisfy and meet the expenses that were incurred during prosecution. A person who has suffered damage or injury by the offence can also recover the amount in these competent courts. These courts are empowered to provide such compensations to the individual who is entitled to recover damages under the Fatal Accidents Act, where there has been a conviction in relation to causing death or abatement.

Section 357 also extends to cases where there has been injury done to a property. In such cases, courts can order compensation to the authentic purchaser of the property, which has been the subject of theft, criminal breach of trust, cheating, misappropriation or acquiring or retaining or disposing of the stolen property and which is ordered to be restored to the genuine owner. Section 357, Subsection empowers the court to order payment of compensation, even in cases where the punishment Section 357, Subsection mentioned does not comprise of payment of any fine.

Section 357A: Victim Compensation Scheme
In the 154th amendment, it was observed by the Law Commission that the earlier recommendations have not been considered or given effect by the government. In order to achieve the practical application of the previous provision of Section 357, an additional provision of Section 357A was added. Earlier in the absence of 357A, there was no duty towards the victim and compensation could be availed only after the accused was convicted.

Section 357A was formulated in the year 2009, where the Central and the State Governments made Victim Compensation Schemes (VCS). The scheme was in order to provide compensation to the victim and his/her dependents for the losses and damage caused by the offender; the responsibility to generate and sustain the fund is upon the State Government. In cases, where the Victim Compensation Scheme can be availed is when there is inadequate compensation paid by the accused or discharged of the accusations or offender not traceable or identifiable, in addition to compensation pay

Section 358: Compensation to persons groundlessly arrested
This section provides for compensation to any individual, who without any reason has become a victim of an arrest. In order to apply this section, there needs to exist a direct connection between the complainant and the arrest. The arrest must be caused by a certain piece of information in the absence of any sufficient ground. It has been stated that in such a situation, the Magistrate may provide compensation to the extent of Rs 1,000 to the individual who has been the victim for the same.

Section 359: Order to pay costs in non-cognizable cases
This section deals with situations where there exists a complaint for a non-cognizable offence, made to a court and the accused is convicted. The section propounds that the Court of Session, an appellant court or High Court while applying their revision jurisdiction can order for payment of costs. In addition to the penalty imposed, the court can also order the accused to pay in whole or in part, to the complainant, the cost incurred during the prosecution. The court along with this also possesses the power to sentence the accused to imprisonment for a time span not more than 30 days in cases where he fails to make the payment.

Central Victim Compensation Scheme
The Ministry of Home Affairs introduced the Central Victim Compensation Scheme (with effect from August 2015) in addition to the existing Victim Compensation Scheme which further increased the quantum of compensation in cases of rape and sexual assaults. In addition to this, women of cross border suffering partial or permanent disability were also addressed.

Uniform compensation was determined for all states, including Rs. 3 lakes for acid attack and rape victims, Rs. 1 lakes for rehabilitation for victims of human trafficking etc. Cases where the victim was below 14 years of age, the compensation had to be increased by 50% over the amount specified. Various states have amended the scheme in analogy to the directions given by the centre except for Arunachal Pradesh, Assam, Chhattisgarh, Himachal Pradesh, Karnataka, Tamil Nadu, and Uttar Pradesh

Other Legal Provision In Relation Of Victim Compensation Under Verious Law In India

The Protection of Women from Domestic Violence Act, 2005
The Protection of Women from Domestic Violence Act, 2005 has been a massive success in relation to the revolution of women rights, towards victims who were suffering from domestic violence after 16 years of struggle. The definition of domestic violence includes physical, sexual, verbal and emotional abuse.

The aspect of trauma arising out of physical abuse in the absence of any medical reports was addressed and compensated for, in the recent case of Smt. Haimanti Mal v. The State of West Bengal (2019). The Calcutta High Court awarded a compensation of Rs. 1,00,000 for mental torture and emotional distress on the basis of Section 22 of the Protection of Women from Domestic Violence Act, 2005.

The unique feature of this Act is that the victim can get continued access to the facilities or resources which the victim is entitled to use or enjoy as a result of an existence of a domestic relationship, which would be inclusive of the access to the shared householder. The police officer or magistrate who acquires the complaint has an obligation to inform the victim about her right to obtain a protection order or order of monetary relief, custody order, residence order, compensation order or more than one such order. This Act deals with the protection of the rights of the women which is guaranteed under the constitution.

Prevention of Caste-Based Victimization and Protection for Victims: The Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989

This Act is formulated to eradicate the atrocities against the members of the Scheduled Castes and Scheduled Tribes. Under this Act, compensation of victim is mandatory, apart from several other reliefs which depend upon the condition and kind of atrocity caused. Monetary compensation varying from Rs. 25,000 to 2,00,000 is determined according to the severity of the offence.

The Maintenance and Welfare of Parents and Senior Citizens Act, 2007
This unique law is targeted towards the protection of elders and the prevention of any kind of elder abuse and victimization, which is a growing concern in many countries including India. Under this Act, there is a duty instilled among the children or adult legal heirs for maintaining their parents, or senior citizens above the age of 60 years, who are incompetent to maintain themselves from their own earnings, in order to allow them to lead a normal life. In cases where the children or legal heirs disregard to maintain the senior citizen, it gives the power to the Tribunal to pass an order to ask the children or legal heirs to supply monthly allowance.

Compensation under Probation of Offenders Act, 1958
The Probation of Offender Act, 1958 also contains provision for compensatory relief to Victim of crime under Section 5(1) of the Act. The Section provides that the court directing the release of an offender under Section 3 or Section 4 of the Act, may if it deems fit, further direct the accused to pay such compensation to the victim, as the court think reasonable for the loss or injury caused to the latter, as also the cost of the proceedings.

Compensation of Victim under Motor Vehicle Act 1988
The victim of vascular accidents or their legal representative in case of death of victim are entitled to claim compensation from the offender under section 5 of the Motor Vehicle Act, 1988. However, the power in this regard is vested only with the court and non else.

Compensatory Relief To Victim-Judicial Trend

Compensatory Relief to Victim-Judicial Trend (on the violation of provisions of Constitution)

The Indian Constitution, the supreme law of the land, enunciates no specific provision for victims. However, Part IV, Directive Principle of State Policy, Art 41 and Part V, Fundamental Duties, Art 51A lay down the duty of the state to secure the right to public assistance in cases of disablement and in other cases of undeserved want and to have compassion for living creatures and to develop humanism respectively. These articles have been interpreted in an expansive manner to find support for victims of crimes . The right to compensation has also been interpreted as an integral part of right to life and liberty under Art. 21 of the Constitution.

The contribution or judiciary to redress the claim of victim of crime is no less significant. The higher courts have played a dominant role in assuring compensatory justice to the victim of crime. While awarding such compensatory relief, they have exercised due care and caution to ensure that people’s faith in judicial process in not shattered and the victim protective rights are not denied to them. Some of the landmark judgement of the Supreme court ensuring restorative justice to victim of crime reflect the growing concern of judiciary to protect the right of victims.[13]

The principle of payment of compensation to the victim of crime was evolved by Hon'ble S.C. on the ground that it is duty of the welfare state to protect the fundamental rights of the citizens not only against the actions of its agencies but is also responsible for hardships on the victims on the grounds of humanitarianism and obligation of social welfare, duty to protect its subject, equitable Justice etc.

It is to be noted that compensation by the State for the action of its official was evolved by the Hon'ble Court against the doctrine of English law:
King can do no Wrong" and clearly stated in the case of Nilabati Behra v State of Orissa (AIR 1993), that doctrine of sovereign immunity is only applicable in the case of tortuous act of government servant and not where there is violation of fundamental rights and hence in a way stated that in criminal matters (of course if there is violation of fundamental rights) this doctrine is not applicable.

Rudal Sah v State of Bihar (AIR 1983) is the most celebrated case where the Hon'ble S.C. directed the state to pay compensation of Rs 35,000 to Rudal Sah who was kept in jail for 14 years even after his acquittal on the ground of insanity and held that it is violation of Article 21 done by the State of Bihar.

The case of Bhim Singh v State of J&K(1986) is another important case where Bhim Singh an MLA was arrested by the police only to prevent him to attended the Legislative Assembly, the Hon'ble Court not only entertained the writ petition of his wife but also awarded the compensation of Rs 50,000 to be paid by the state.

The case of Meja Singh v SHO Police Station Zira is another unfortunate case where this time High Court of P&H took the cause of victim and awarded the compensation of Rs 25,000 for illegal detention of son of the petitioner. This time it was High Court Bombay, which took the cause of the victim in the case of Ravikant Patil v DG Police, State of Maharashtra where the petitioner was taken handcuffed to court in clear violation of Judgment of Hon'ble S.C. that is law, as decided in the case of Prem Shanker Shukla v Delhi Administration. Custodial Death is another burning issue where the courts have awarded compensation to the victims of crime and the most important case under this heading is of Mrs. Cardino v UOI where although the accuse was arrested on the charge of misappropriation of some plastic ware and hospital; utensils worth Rs1500 but tortured like hard core criminal and hence he succumbed to the torture. Here when the matter was brought before the Hon'ble High Court of Bombay which gave the compensation of Rs 2,00,000 to be paid by the state.

In the case of Nilabati Behra v State of Orissa where the son of petitioner was arrested by the police and next morning his body was found laying down with several injuries on the railway track, the Hon'ble S.C. awarded the compensation of Rs 1, 50,000 that is to be paid by the State.

On the issue of brutal use of force and misuse of authority by the police outside the police station case of SAHELI v Commissioner of Police (AIR 1990) is land mark where the son of Kamlesh Kumari died due to ill treatment by a S.I. of Delhi Police, the Hon'ble S.C. directed the Delhi Adm. to pay the compensation of Rs 75,000.

The next important case is of Gudalure Cherian v UOI where Hon'ble S.C. following an innovative approach first directed the whole matter to be investigated by the CBI afresh and completion of investigation directed the Govt. of U.P. to first suspend the police officials and medical officers who tried to save the accuse but also directed the state to pay compensation of Rs 2,50,000 to the victim of rape and Rs 1,00,000 to victim of other crime.

The next in the line is the case of Bodhi Satta Gautam v Subhra Chakraborty (AIR 1996) where the Hon'ble S.C. invented the concept of interim compensation and enforced the part third right against an individual by saying that:
This decision recognises the right of the victim for compensation by providing that it shall be awarded by the Court on conviction of the offender subject to the finalisation of Scheme by the Central Government. If the Court trying an offence of rape has jurisdiction to award the compensation at the final stage, there is no reason to deny to the Court the right to award interim compensation, which should also be provided in the Scheme.

On the basis of principles set out in the aforesaid decision in Delhi Domestic Working Women's Forum, the jurisdiction to pay interim compensation shall be treated to be part of the overall jurisdiction of the Courts trying the offences of rape which, as pointed out above is an offence against basic human rights as also the Fundamental Right of Personal Liberty and Life.

The court also stated that:
Having regard to the facts and circumstances of the present case in which there is a serious allegation that Bodhisaltwa Gautam had married Subhra Chakraborty before the God he worshipped by putting Vermilion on her forehead and accepting her as his wife and also having impregnated her twice resulting in abortion on both the occasions, we, on being prima facie satisfied, dispose of this matter by providing that Bodhisattwa Gautam shall pay in Subhra Chakraborty a sum of Rs. 1,000/-every month as interim compensation during the pendency of Criminal Case… in the Court of Judicial Magistrate, Ist Class, Kohima, Nagaland. He shall also be liable to pay arrears of compensation at the same rate from the date on which the complaint was filed, till this date.

Therefore it can be observed that the Hon'ble Courts have taken little softer view ( with regard to monetary aspect) when question of the award of compensation come under Cr.P.C. as compare to when it come under Constitution.

Conclusion
All states have put forward one simple object- for providing funds for compensation to the victims or their dependents, who have suffered loss or injury as a result of the crime and who require rehabilitation. This is in tune with s. 357A which is similarly worded with regard to the constitution of the VCS.

However, It lays down two objectives:
  1. to provide financial assistance to the victims and
  2. support services such as shelter, counselling, medical aid, legal assistance, education and vocational training depending upon the needs of the victim.
Thus, so far as is concerned, the VCS is not merely to provide compensation to victims of crime, but also makes an effort to provide holistic support to these victims. It offers a one- stop facility to the victims to ameliorate their conditions arising from the crime, ranging from financial assistance to restorative support services.

Bibliography
  1. Book- Criminology and penology with victimology(written by Prof. N.V.PARANJAPE
  2. Bare Act
  3. International Journal of Criminal Justice Sciences, Vol 13 Issue 2, Dipa Dube, Victim Compensation Schemes in India: An Analysis (2018)
  4. The Supreme Court has in many cases address this right to compensation as an indispensable right; Rudal Shah v. State of Bihar (1983 AIR 1086), the courts acknowledged and acted upon the claim of the petitioner who was unlawfully detained and thereby awarded compensation of a sum total of Rs. 35000
  5. International Journal of Criminal Justice Sciences, Vol 13 Issue 2, Dipa Dube, Victim Compensation Schemes in India: An Analysis (2018)
  6. Manupatra, Vibha Mohan, Article on Revisiting Victim Compensation in India.
End-Notes:
  1. International Journal of Criminal Justice Sciences, Vol 13 Issue 2, Dipa Dube, Victim Compensation Schemes in India: An Analysis (2018)
  2. The Supreme Court has in many cases address this right to compensation as an indispensable right; Rudal Shah v. State of Bihar (1983 AIR 1086), the courts acknowledged and acted upon the claim of the petitioner who was unlawfully detained and thereby awarded compensation of a sum total of Rs. 35000
  3. International Journal of Criminal Justice Sciences, Vol 13 Issue 2, Dipa Dube, Victim Compensation Schemes in India: An Analysis (2018)
  4. Manupatra, Vibha Mohan, Article on Revisiting Victim Compensation in India.
  5. Ibid.
  6. International Journal of Criminal Justice Sciences, Vol 13 Issue 2, Dipa Dube, Victim Compensation Schemes in India: An Analysis (2018)
  7. Manupatra, Vibha Mohan, Article on Revisiting Victim Compensation in India.
  8. The Code Of Criminal Procedure, 1973
  9. Book- Criminology & Penology with Victimology by Prof. N.V.Paranjape
  10. Indianlawwatch.com
  11. Book- Criminology & Penology with Victimology by Prof. N.V.Paranjape
  12. Manupatra, Vibha Mohan, Article on Revisiting Victim Compensation in India. http://docs.manupatra.in/newsline/articles/Upload/6F5E12E5-2A56-49A9-BF1B-CBE1DF4F8726.2- F__criminal.pdf 8
  13. Book- Criminology & Penology With Victimology By Prof.N.V.Paranjape
Written By: Aakriti Sharma, LLM (General), Banaras Hindu University, Varanasi

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