Critical Study on procedure post FIR registration

Submitted by:

Chinmayi Patil

UID- UG21-34

Academic Year:2022-2023

B.A.LL.B. (Hons.) 3rd Year, 5th Semester

Submitted to:

Prof. Sanya Agarwal

Prof.

Professor of Civil Procedure of Code

January 2024

Maharashtra National Law University

SR TABLE OF CONTENTS PG
NO. NO.

1. INTRODUCTION 3

2. RESEARCH OBJECTIVES 4

3. RESEARCH QUESTIONS 4

4. RESEARCH METHODOLOGY 4

5. REGISTRATION OF FIR 6

6. PROCEDURE POST REGISTRATION 10

7. JUDICIAL PRECEDENTS 11

8. POLICY SUGGESTIONS 12

9. CONCLUSION 13

10. BIBLIOGRAPHY 14

1
INTRODUCTION

The Bharatiya Nagarik Suraksha Sanhita (BNSS) has ushered in a new era in the procedural
framework governing the registration and handling of First Information Reports (FIRs) in
India. Designed to streamline processes, enhance accountability, and promote transparency in
the criminal justice system, the BNSS introduces a range of reforms aimed at modernizing
the FIR registration process and subsequent investigative procedures.

Under the BNSS, the concept of "Zero FIR" has emerged as a pivotal reform, allowing
individuals to lodge complaints at any police station, regardless of jurisdiction, for cognizable
offenses. This move addresses longstanding challenges faced by victims of serious crimes
who previously encountered obstacles in filing complaints, particularly when incidents
occurred outside their local police station's jurisdiction. By enabling swift initiation of
investigations, the Zero FIR provision seeks to ensure timely action and prevent delays that
could impede the pursuit of justice.

Furthermore, the BNSS embraces electronic communication as a means of reporting offenses,

marking a significant departure from traditional paper-based processes. Through this
provision, individuals can submit FIRs electronically, with stringent requirements mandating
the informant's signature within three days to authenticate the complaint. This shift towards
digitalization not only enhances accessibility and convenience for complainants but also
facilitates efficient data management and record-keeping within law enforcement agencies.

In addition to these procedural reforms, the BNSS introduces statutory provisions for
preliminary inquiries, particularly for offenses punishable with imprisonment ranging from
three to seven years. This empowers police officers to conduct swift assessments of reported
offenses, establishing prima facie cases before embarking on full-fledged investigations.
While aimed at optimizing resource allocation and expediting case disposition, the provision
for preliminary inquiries raises questions regarding its alignment with judicial precedents and
constitutional safeguards, particularly concerning the right to fair and expeditious trial.

Against this backdrop, this critical study aims to dissect and analyze the procedural landscape
post-FIR registration under the BNSS. By examining recent judicial precedents, identifying
key criticisms, and offering concluding reflections, this study seeks to shed light on the
strengths, weaknesses, and potential areas for improvement within the procedural framework
governing post-FIR processes in India.

2
 1. REGISTRATION OF AN FIR

The procedure for lodging complaints and initiating FIRs has undergone significant changes
under Section 173 of the BNSS. This section permits the registration of FIRs for cognizable
offences irrespective of the jurisdiction of the concerned police station. Information can be
conveyed orally or electronically to any police station's officer in charge, ensuring
accessibility and prompt action. However, the provision lacks explicit guidance regarding the
transfer of Zero FIRs to the appropriate jurisdiction for further investigation, raising potential
procedural ambiguities.1

Additionally, the incorporation of e-FIRs introduces a modernized approach to FIR

registration, mandating the collection of the informant's signature within three days before the
formal recording of the FIR. This requirement ensures the authenticity and accountability of
electronically submitted complaints. Notably, while Section 154(2) of the CrPC previously
stipulated the provision of a copy of the information at no cost to the informant, Section
173(2) of the BNSS extends this benefit to both the informant and the victim, enhancing
transparency and accessibility in the complaint registration process.2

Section 173:

Section 173 outlines the formal procedure for reporting serious criminal offenses to law
enforcement authorities. It establishes that individuals can convey information about such
offenses to the police verbally or via electronic communication. In the former case, the police
are obligated to transcribe the information into a written format, which must be signed by the
informant. For electronic communication, the informant must provide a signature within three
days. The police maintain meticulous records of these reports in accordance with prescribed
guidelines. Special provisions are made to ensure that individuals who report crimes,
particularly women or those with disabilities, are treated with appropriate sensitivity and
respect.3

Moreover, Section 173 grants the police authority to either conduct a preliminary inquiry or
initiate a full investigation based on the severity of the reported offense, subject to approval
from a superior officer. If an individual feels dissatisfied with the response of the initial
1
Raghavan, Vijay, and Cr PC FIR. "Registration of First Information Reports by Police: An Agenda for
Change." Editorial Board (2010): 65.
2
Iyer, Archana, et al. "E-Police System-FIR Registration and Tracking through Android
Application." International Research Journal of Engineering and Technology 3.2 (2016): 1176-1179.
3
Dhawan, Harish, and Paramjeet Singh. “Framed by Police.” Economic and Political Weekly, vol. 46, no. 8,
2011, pp. 5–5. JSTOR, http://www.jstor.org/stable/41151778. Accessed 14 Mar. 2024.

3
police contact, they have recourse to escalate the matter to a higher-ranking police official,
who will either investigate personally or direct another officer to do so. Should the individual
remain discontented, they retain the option to seek redress through legal channels4

Advancements in FIR Procedures under the Bharatiya Nyaya Sanhita Sangathan 2.0

The Bharatiya Nyaya Sanhita Sangathan 2.0 (BNSS2) introduces significant changes in the
process of filing First Information Reports (FIRs), notably incorporating the concept of "Zero
FIR." This innovation allows the registration of FIRs at any police station, irrespective of
jurisdiction. Following registration, the responsibility lies with the concerned station to
transfer the FIR to the appropriate jurisdiction for further investigation. The genesis of Zero
FIR can be traced back to the recommendations of the Justice J.S. Verma Committee, which
advocated for its adoption in the aftermath of the Nirbhaya incident. Although an advisory in
2023 urged the implementation of Zero FIR, it lacked statutory backing. However, the
BNSS2 now mandates Zero FIR registration, aiming to streamline investigations and prevent
delays, particularly in cases involving forensic evidence or potential document tampering. 5

Another significant amendment introduced by the BNSS2 is the provision for FIR registration
through electronic communication channels. This advancement enables individuals to file
FIRs electronically, with confirmation required through the informant's signature within three
days. While this provision offers convenience and expediency, its successful implementation
necessitates the modernization of police stations with robust IT infrastructure. Additionally,
ensuring public access to station email IDs and designating government email addresses for
officers are crucial steps in this process. However, challenges remain regarding the
immediate action upon receipt of electronic information, as its validity hinges on the
informant's subsequent signature. To address this, proposed safeguards include mandating
informant details submission, including identity card verification.6

The BNSS2 also addresses the procedural aspect of preliminary inquiries, granting them
statutory recognition under Clause 173(3). Preliminary inquiries are now mandated for

4
Siwach, Twinkle. “HISTORY OF FIRST INFORMATION REPORT IN INDIA: A READING OF DELHI
POLICE RECORDS (1960).” Proceedings of the Indian History Congress, vol. 79, 2018, pp. 839–47. JSTOR,
https://www.jstor.org/stable/26906323. Accessed 14 Mar. 2024.
5
Deswal, Vageshwari. “BURKING OF CRIMES BY REFUSAL TO REGISTER FIR IN COGNIZABLE
OFFENCES.” Journal of the Indian Law Institute, vol. 55, no. 3, 2013, pp. 361–75. JSTOR,
http://www.jstor.org/stable/43953675. Accessed 14 Mar. 2024..
6
Raperia, Saurabh. "Ingredients and Law of Registration of FIR in India under the Criminal Procedure
Code." Available at SSRN 4120080 (2022).

4
cognizable offences punishable with imprisonment ranging from three to seven years, with a
strict timeframe of 14 days for completion. However, this provision deviates from the
Supreme Court's Lalita Kumari judgment, which emphasized the mandatory registration of
FIRs upon receiving information regarding cognizable offences. The BNSS2 allows
preliminary inquiries to determine prima facie cases for FIR registration, contrary to the
Supreme Court's stance.

PROCEDURE FOR INVESTIGATION POST REGISTRATION OF FIR:

Section 176:

(1) If an officer in charge of a police station receives information or suspects the occurrence
of an offense within their jurisdiction, as defined by Section 175, they must promptly report it
to a Magistrate authorized to handle such cases. The officer should then personally
investigate the matter or assign a subordinate officer, of a rank specified by the State
Government, to do so. Exceptions apply: (a) If the offense is non-serious and identified by
name, personal investigation or delegation is not required; (b) If the officer finds insufficient
grounds for investigation, they should refrain from doing so. For cases of rape, the victim's
statement should be recorded at their residence or preferred location, preferably by a female
police officer and in the presence of their family or a social worker. Recording may be done
through audio-video electronic means, including mobile phones.7

(2) In instances mentioned in clauses (a) and (b) of the first proviso, the officer must state
reasons for non-compliance in their report and submit a fortnightly diary report to the
Magistrate. Additionally, in cases outlined in clause (b), the informant should be promptly
notified as per rules set by the State Government.8

(3) For offenses punishable by seven years or more, the officer must, upon receipt of
information, arrange for a forensic expert to visit the crime scene for evidence collection and
videography using electronic devices. If forensic facilities are lacking, the State Government
must notify the utilization of facilities from another state until local facilities are available.

Procedure under 176:

7
Raghavan, Vijay, and Cr PC FIR. "Registration of First Information Reports by Police: An Agenda for
Change." Editorial Board (2010): 65.
8
Deb, R. “NEED FOR MAKING INVESTIGATION A PRE-TRIAL JUDICIAL PROCESS.” Journal of the
Indian Law Institute, vol. 41, no. 1, 1999, pp. 95–102. JSTOR, http://www.jstor.org/stable/43951699. Accessed
14 Mar. 2024.

5
Section 176 of the Bharatiya Nyaya Sanhita (BNSS) delineates the procedure to be followed
when an officer in charge of a police station receives information, either directly or indirectly,
suggesting the potential occurrence of an offense that falls within their investigative authority
as defined in Section 175. In such cases, the officer is obligated to promptly transmit a report
to a Magistrate empowered to take cognizance of such offenses based on a police report.
Furthermore, the officer must personally conduct an inquiry into the matter or assign a
subordinate officer, of a rank not lower than that specified by the State Government through
general or special orders, to investigate the facts and circumstances surrounding the case.

If necessary, measures should be taken to uncover and apprehend the perpetrator. However,
certain exceptions apply: (a) If the offense is reported against a named individual and is
deemed non-serious, the officer need not conduct a personal investigation or delegate the task
to a subordinate. (b) If the officer concludes that there is insufficient basis for commencing an
investigation, they are not obliged to proceed further. Notably, in cases of rape, specific
provisions dictate that the victim's statement must be recorded with sensitivity, preferably by
a female police officer, and in the presence of her parents, guardian, close relatives, or a
social worker, with the option of utilizing audio-video electronic means, including mobile
phones, for recording purposes.

In each scenario outlined in clauses (a) and (b) of the first proviso to sub-section (1), the
officer in charge of the police station must explicitly state the reasons for not fully adhering
to the stipulations of the aforementioned sub-section in their report. Additionally, they are
required to submit their daily diary report to the Magistrate fortnightly. In instances falling
under clause (b) of the proviso, the officer must also promptly inform the informant, if
applicable, through a method prescribed by rules established by the State Government.

Furthermore, Section 176(3) of the BNSS mandates forensic investigation in cases where the
prescribed punishment is seven years or more. Upon receiving information pertaining to such
offenses, the officer in charge of a police station must, from a specified date notified by the
State Government within a period of five years, ensure that a forensic expert visits the crime
scene to collect evidence and conducts videography of the process using a mobile phone or
any other electronic device. In situations where forensic facilities are unavailable, the State
Government must notify the utilization of such facilities from another state until the requisite
infrastructure is developed or established within the state's jurisdiction.

6
Additionally, the BNSS allows for the recording of the victim's statement, including through
audio-video electronic means like cell phones, as well as the recording of witness statements,
contributing to comprehensive evidence documentation. Another notable provision
introduced under Section 176(3) of the BNSS is the requirement for the officer in charge of a
police station to arrange for a forensic expert to visit the crime scene and conduct
videography of the process in cases where offenses are punishable by seven years or more.
Moreover, this provision empowers the State Government to utilize forensic facilities from
another state until such facilities are available within its jurisdiction.

The procedure post investigation as mentioned in bare act is given below:

Investigation Procedure Specific Investigative Actions

Section 177 - Submission of Reports to This section mandates the submission of
Magistrate investigation reports to a Magistrate through
a designated superior police officer if
directed by the State Government. It
establishes a hierarchical channel for
conveying investigative findings, enhancing
coordination and accountability.
Sections 178 and 179 - Powers of Section 178 empowers Magistrates to direct
Magistrates and Police Officers to Initiate investigations or conduct preliminary
Investigations inquiries upon receiving reports. Section
179 delineates the powers of police officers
to summon witnesses for interrogation
during investigations, with provisions to
protect vulnerable individuals.
Sections 180 and 181 - Examination and Section 180 empowers police officers to
Admissibility of Statements orally examine individuals during
investigations, with provisions for recording
statements. Section 181 addresses the
admissibility of statements made to police
officers, specifying circumstances under
which they can be used as evidence.
Sections 182 and 183 - Voluntary Section 182 prohibits coercion during
Statements and Recording of Confessions investigations but allows for the voluntary

7
 provision of information. Section 183
outlines procedures for recording
confessions and statements by Magistrates,
ensuring adherence to legal standards and
safeguards for vulnerable individuals.
Sections Related to Specific Investigative Actions
Sections 184 and 185 - Medical Section 184 mandates the medical
Examination and Search Powers examination of rape victims by registered
medical practitioners, ensuring proper
documentation. Section 185 grants police
officers authority to conduct searches in
specified circumstances, with procedures for
judicial oversight.
Sections 186 and 187 - Inter-Agency Section 186 facilitates cooperation between
Cooperation and Transmission of Records police stations in investigations, allowing
for searches by officers in charge of other
stations. Section 187 mandates the
transmission of investigation records to the
nearest Magistrate when investigations
cannot be completed within the specified
timeframe.
Sections 188 and 189 - Reporting of Sections 188 and 189 outline procedures for
Investigation Results and Release of reporting investigation results to the officer
Accused in charge of the police station and releasing
accused persons when investigations do not
yield sufficient evidence. These provisions
ensure accountability, transparency, and
adherence to legal procedures in
investigations and handling of suspects.
Sections Related to Judicial Processes and Handling of Cases
Section 190 - Cases to be Sent to Magistrate This section outlines procedures for
forwarding accused individuals to a
Magistrate when there is sufficient evidence
or reasonable grounds. It specifies

8
 conditions for releasing accused persons on
bail bond and requires the submission of
relevant articles or weapons to the
Magistrate.
Section 191 - Complainant and Witnesses Section 191 ensures that complainants and
not to be Required to Accompany Police witnesses are not unnecessarily
Officer inconvenienced while attending court
proceedings. It allows for their detention if
they refuse to comply with attendance
requirements.
Section 192 - Diary of Proceedings in This section mandates the maintenance of a
Investigation daily diary by police officers conducting
investigations. It requires the documentation
of investigation activities and witness
statements to aid in trial proceedings.
Section 193 - Report of Police Officer on Section 193 requires prompt completion of
Completion of Investigation investigations, especially for specified
offences. It mandates the submission of
investigation reports to a Magistrate, along
with progress updates to the informant or
victim.
Section 194 - Police to Enquire and Report Section 194 mandates police investigations
on Suicide, etc. into deaths due to various circumstances,
including suicide, homicide, accidents, or
suspicious causes. It requires the preparation
and submission of reports describing the
apparent cause of death.
Section 195 - Powers of Police Officer in This section empowers police officers to
Investigation summon individuals for questioning during
investigations. It outlines attendance
requirements and exemptions based on age,
gender, disability, or illness, ensuring
compliance with legal procedures.

9
RECENT JUDGEMENTS ON FIR

Following are the judgements which discuss the registration of FIR and issues
associated with it:

1. In the case of Amish Devgan v. Union of India,9 the Supreme Court clarified that the
validity of a First Information Report (FIR) depends on whether it provides reason to
suspect a cognizable offense. The Court emphasized that FIRs serve as triggers for
investigations and need not contain exhaustive details or eyewitness accounts.
Additionally, it highlighted the discretionary powers of police officers in initiating,
foreclosing, or concluding investigations based on grounds and evidence sufficiency,
ensuring a balanced approach to criminal investigations while upholding individual rights
within the legal framework.
2. In the Lalita Kumari v. State of Uttar Pradesh 10 (2014) case, the Supreme Court
mandated the registration of FIRs for all cognizable offenses and emphasized providing
the informant with a complimentary copy of the FIR.
3. In Jayantibhai Lalubhai Patel v. State of Gujarat 11 (1992), it was ruled that police
officers must forward copies of FIRs to magistrates under Section 157 of the CrPC, after
which they become public documents. Failure to provide accused individuals with copies
of FIRs upon request was considered prejudicial, violating principles of natural justice
and fair trial under Article 21.
4. Mohammed Khalid Shaikh v. State of Maharashtra 12 (2010) further clarified that the
denial of FIR copies to accused individuals violates their rights under Article 21,
emphasizing that arrest entails a deprivation of personal liberty that must adhere to fair
and reasonable procedures. The judgment highlighted that the accused must receive a
copy of the FIR prior to arrest, as it forms a crucial part of their defense and ensures a fair
trial, including bail proceedings. This ensures transparency and fairness at every stage of
the criminal trial, aligning with the principles of Article 21.
5. In the landmark case of State of Haryana v. Bhajan Lal13, the Supreme Court cautioned
that the power to quash criminal proceedings should be exercised sparingly and only in
the rarest of rare cases. The Court established parameters for quashing by High Courts,

9
Amish Devgan v. Union of India, (2021) 3 SCC 306
10
Lalita Kumari v. Govt. of U.P., (2014) 2 SCC 1
11
Jayantibhai Lalubhai Patel v. State of Gujarat 1992 SCC OnLine Guj 26
12
Mohammed Khalid Shaikh v. State of Maharashtra, 2016 SCC OnLine Bom 14815
13
State of Haryana v. Bhajan Lal, AIR 1992 SC 604

10
 emphasizing that they should not embark on an inquiry into the reliability of the
allegations in the FIR.
6. Subsequent judgments, such as Arnab Manoranjan Goswami v. State of Maharashtra,14
reiterated the need for a prima facie evaluation of the alleged offense's ingredients during
quashing petitions.
7. Similarly, in Dhruvaram Murlidhar Sonar v. State of Maharashtra15, the Court stressed
the sparing and cautious exercise of this provision, considering it an obligation to provide
a remedy as a matter of right.
8. Additionally, in Central Bureau of Investigation v. Aryan Singh 16, the Court emphasized
that the discharge or quashing stage is not a mini-trial, and the burden of proof lies with
the prosecution during the trial.
9. Recent observations by the Supreme Court highlighted the need to closely examine facts
and circumstances when considering quashing on grounds of personal vengeance, as seen
in the case of Salib @ Shalu @ Salim vs State of UP 2023 LiveLaw (SC) 618.
10. In Mahmood Ali vs State of UP 2023 Latest Caselaw 616 SC, the Supreme Court
dismissed an appeal seeking FIR quashing, noting the absence of crucial ingredients to
constitute the alleged offenses and the significant delay in lodging the FIR.

POLICY SUGGESTIONS

1. Clarification on Transfer of Zero FIRs: Government should issue clear guidelines for
police stations' responsibilities in transferring Zero FIRs, including standardized
procedures for inter-district or inter-state transfers.
2. Capacity Building for Electronic FIR Submission: Government should invest in
enhancing IT infrastructure and providing training for law enforcement on electronic
complaint handling. Public awareness campaigns should educate citizens on e-FIR
filing and timely signature authentication.17
3. Alignment with Lalita Kumari Judgment: BNSS's provisions for preliminary inquiries
should align with the Lalita Kumari judgment, ensuring mandatory FIR registration

14
Arnab Manoranjan Goswami v. State of Maharashtra, (2021) 1 SCC 802
15
Dhruvaram Murlidhar Sonar v. State of Maharashtra, AIR 2019 SC 327
16
Central Bureau of Investigation v. Aryan Singh, 2023 292 SC
17
Diaz, S. M. Journal of the Indian Law Institute, vol. 32, no. 2, 1990, pp. 281–82. JSTOR,
http://www.jstor.org/stable/43953190. Accessed 14 Mar. 2024.

11
 for cognizable offenses while allowing judicious discretion in conducting preliminary
inquiries.18
4. Enhanced Safeguards for Victim and Witness Rights: Comprehensive state-level
witness protection schemes should be established, incorporating relocation, financial
support, and monitoring mechanisms to prevent witness intimidation.
5. Review of Police Custody Provisions: Conduct a comprehensive review of
intermittent police custody provisions within the BNSS to ensure adherence to
individual rights and constitutional safeguards, with provisions for judicial oversight.
6. Promotion of Digital Case Management: Incentivize adoption of digital case
management systems by courts and law enforcement, including funding support,
standardization, and capacity-building initiatives for digital literacy.
7. Strengthening Oversight Mechanisms: Establish robust oversight bodies to monitor
BNSS implementation, review complaints, conduct audits, and issue
recommendations for policy reforms to ensure accountability and transparency.

CONCLUSION

The Bharatiya Nagarik Suraksha Sanhita (BNSS) brings forth significant reforms aimed at
streamlining the process of registering First Information Reports (FIRs) and subsequent
criminal procedures. Notable among these reforms is the introduction of the "Zero FIR"
concept, allowing individuals to file complaints at any police station irrespective of
jurisdiction for cognizable offences. This addresses the previous challenge where victims of
serious offences were hindered from lodging complaints without visiting the jurisdictional
police station, thus ensuring swift initiation of investigations.

Moreover, the BNSS embraces electronic communication for reporting offences, with
stringent conditions mandating the signing of such information within three days by the
informant. This move towards digitalization aims to enhance accessibility and efficiency in
the registration process. Additionally, the BNSS introduces the statutory provision for
preliminary inquiries, particularly for offences punishable with imprisonment of three to
seven years. This empowers police officers to conduct a preliminary investigation within 14
days to establish a prima facie case before proceeding with a full-fledged investigation,
thereby ensuring a more judicious allocation of investigative resources.
18
Kanwel, Sidra, and Nazia Ayub. "FIR Denial by Police: A Legal and Ethical Dilemma." PAKISTAN
ISLAMICUS (An International Journal of Islamic & Social Sciences) 3.2 (2023): 335-343.

12
Furthermore, the BNSS expands the powers of Magistrates for the attachment and forfeiture
of properties identified as proceeds of crime, aiming to curb criminal activities and disrupt
illicit financial flows. However, concerns arise regarding the lack of safeguards and the
potential for abuse in the exercise of such powers. The BNSS also emphasizes transparency
through the mandatory audio-video recording of search and seizure procedures, aiming to
prevent illegal searches and tampering with evidence.

In terms of victim and witness rights, the BNSS introduces measures to enhance
accountability and provide compensation to victims, while also establishing state-governed
witness protection schemes to prevent witness intimidation and ensure their cooperation in
criminal proceedings. However, challenges remain concerning the BNSS's approach to police
custody, which grants intermittent police custody within the initial detention period,
potentially leading to uncertainty and harassment for accused persons.

Lastly, the BNSS adopts a technology-friendly approach by permitting electronic service of

summons, warrants, and reports, as well as electronic conduct of inquiries and trials. This
move towards digitalization is expected to expedite case management and improve access to
justice. Despite these advancements, the BNSS raises concerns regarding due process
safeguards, particularly in property attachment and police custody provisions. Overall, the
BNSS represents a comprehensive overhaul of the criminal justice system, aiming to balance
efficiency with the protection of rights and procedural fairness.

BIBLIOGRAPHY

Books

 Ratanlal & Dhirajlal, The Code of Criminal Procedure (CrPC), (32nd Ed., 2022).
 Kelkar, Criminal Procedure (Code of Criminal Procedure Act), (6th Ed., 2020).
 Kelkar, R.V., Criminal Procedure, (7th Ed., 2021).

13
  Aktar, S., Code of Criminal Procedure, (2021).
 Takwani, C.K., Code of Criminal Procedure (Set of 2 Volumes), (2020).

Articles

 Citation: Baruah, Priyanka. "Procedural Justice under the Code of Criminal

Procedure, 1973." Indian Journal of Law and Justice, vol. 11, no. 2, 2020, pp. 115-
127.
 Citation: Srivastava, Ankit. "A Critical Analysis of the Relevance of the Code of
Criminal Procedure, 1973 in Contemporary India." Journal of Indian Law and
Society, vol. 5, no. 1, 2019, pp. 72-89.
 Citation: Singh, M.K. "Role of the Magistrate under the Code of Criminal Procedure,
1973: A Study." Indian Journal of Criminology and Criminalistics, vol. 8, no. 2, 2018,
pp. 145-159.
 Citation: Rai, Meena. "Victim Protection under the Code of Criminal Procedure,
1973: An Analytical Study." Journal of Legal Studies, vol. 3, no. 3, 2021, pp. 215-
228.
 Citation: Kumar, Arun. "Constitutional Validity of Section 377 of the Code of
Criminal Procedure, 1973: A Critical Analysis." Supreme Court Journal, vol. 25, no.
4, 2017, pp. 320-335.

Websites

 https://indiacode.nic.in/
 http://nalsa.gov.in/
 https://main.sci.gov.in/

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