TITLE: Critical Analysis of Section 154 of Criminal Procedure Code, 1973

IN THE COURSE OF
CODE OF CRIMINAL PROCEDURE, 1973

SUBMITTED TO:
AMITY UNIVERSITY RAJASTHAN
AMITY LAW CHOOL
SEMESTER IV

UNDER THE GUIDANCE OF

Mr. ASHUTOSH SRIVASTAV

SUBMITTED BY:
NAME: PRERNA GUPTA
B.B.A LL.B(H)

ACKNOWLEDGEMENT

I take this opportunity to express my gratitude and personal regards to Mr. ASHUTOSH
SRIVASTAV for inspiring and guiding me during the course of this project work.
I also owe my sincere thanks to the Library staff, Amity University for the cooperation and
facilities extended from time to time during the progress of my project work.
I owe all inconsistencies and mistakes, if any, in this research study and sincerely apologize again
for the same.

PRERNA GUPTA

TABLE OF CONTENTS
2

Abbreviations....................................................................................................................4
Table of Cases...................................................................................................................5
Introduction.......................................................................................................................6
Research Methodology......................................................................................................6
Chapter I............................................................................................................................7
Distinction between cognizable and non-cognizable cases...............................................7
Investigation......................................................................................................................8
The First Information Report.............................................................................................8
Object of recording the FIR..............................................................................................10
Chapter II..........................................................................................................................11
Evidentiary Value of a usual FIR......................................................................................11
The Anonymous FIR.........................................................................................................12
Implications of an Anonymous FIR..................................................................................14
Conclusion.........................................................................................................................16
Bibliography......................................................................................................................17

ABBREVIATIONS
3

1. Cr.P.C - Criminal Procedure Code, 1973

2. F.I.R

- First Information Report

3. S.

- Section

4. IEA

- Indian Evidence Act, 1872

TABLE OF CASES

Bijoy Singh v. State of Bihar, (2002) 9 SCC 147.

Binay Kumar Singh v. State of Bihar, (1997) 1 SCC 283.
Dharma Rama Bhagare v. The State of Maharashtra, (1973) 1 SCC 537.
H.N. Rishibud v. State of Delhi, AIR 1955 SC 196.
Harkirat Singh v. State of Punjab, 1997 SCC (Cri) 1068.
Mani v. State of Kerala, 1987 Cri LJ 1965 (Ker).
Meharaj Singh v. State of U.P., (1994) 5 SCC 188.
Ram Chander v. State of Haryana, (1981) 3 SCC 191.
Ramsinh Bavaji Jadeja v. State of Gujarat, 1994 SCC (Cri) 609.
Saroop Singh v. The State, AIR 1964 Punj 508.
Satvinder Kaur v. State (Govt. of N.C.T. of Delhi), 1999 SCC (Cri) 1503.
Soma Bhai v. State of Gujarat, 1975 SCC (Cri) 515.
Tapinder Singh v. State of Punjab, 1970 SCC (Cri) 328.

TABLE OF STATUES

The Code of Criminal Procedure, 1973.

The Indian Evidence Act, 1872.

INTRODUCTION

The Criminal Procedure Code of 1973 provides detailed procedure when it comes to dealing
with criminal matters in our country. The criminal process in our country is divided into
many phases. One such phase is the pre-trial stage. This is the stage where the role of the
police is important. They investigate into any crime and collect evidence that is crucial to
prosecute the accused. Without proper evidence, the court will not convict the accused. In a
criminal trial, the facts lie scattered all over the record and are not readily available in one
single document. They have to be therefore collected from a multitude of papers. The earliest
version of the prosecution case is available in the First Information Report which is the
trigger point of action1.
This project focuses on the aspect of investigation. There is usually a lot of controversy in
determining when the actual investigation started as the Code of Criminal Procedure affords a
certain protection to the accused.
Through this project, the examination of a few concepts related with the report under S.154,
which in popular parlance is called the First Information Report. S.154(1) of the new Code is
an exact reproduction of the old code with the exception that two new provisions, namely,
S.154(2) and 154(3) have been added2.

Research Methodology
Aims and Objectives
The aim of this project is to find out what the First Information Report exactly is. The
researcher has examined S.154 and a few allied provisions. An important question as to
whether an anonymous piece of information can constitute a FIR has been focused in this
project.
Chapterization
This project is divided into two chapters with sub-divisions therein to simplify the project.
Chapter I deals with the basics of an FIR.
Chapter II deals with what the evidentiary value of the FIR is and whether it can be
anonymous.

1 ] Dhirendra Pal Varshini, How to Frame a Charge under the Penal Code and Other Criminal Acts, 2nd Edn., Eastern Book
Co., Lucknow, 1994, p.2.

2 N.D. Basu, The Code of Criminal Procedure, S.K. Bose Ed., Vol.1, 9th Edn., Ashoka Law House, New Delhi, 2001, p.742.
6

Research Questions

What is an FIR?
Is an FIR required in all types of cases?
If no, then why has there such a distinction been made?
What is the object of recording the FIR?
What is the evidentiary value of the FIR?
Can an FIR be anonymous?
What are the PROS and CONS of an anonymous FIR?
What is the situation in real life as regards whole concept of an anonymous FIR?

CHAPTER I:
Cognizable Cases, Investigation, and the Role of the Police:

Distinction between cognizable and non-cognizable cases:

A non-cognizable case is one under which a police officer can arrest a person only with a
warrant3. Cases falling under this category are usually petty offences or those of a less serious
character.
A cognizable case is one under which a police officer can arrest a person without a warrant 4.
These types of cases are usually those of a serious nature. Hence, the police are vested with
powers to arrest a person accused of such an offence without a warrant, and in doing so, a
procedural safeguard that is given to a person is done away with. The possible rationale
behind the removal of such a safeguard could be the fact that the police are expected to act
quickly in such cases and put the accused behind bars immediately.
A very important distinction between cognizable and non-cognizable cases is the procedure
for the commencement of investigation. In the former an FIR is essential whereas for the
latter, the permission of a Magistrate is a must5.
The First Schedule of the Cr.P.C specifies what offences are cognizable and those which are
non-cognizable.
3 Section 2(l) of the CrPC for the meaning of the term non-cognizable cases or non-cognizable offences.
4 Section 2(c) of the CrPC for the meaning of the term cognizable cases or cognizable offences.
5 Section 155 of the CrPC to know about how an investigation commences in a non-cognizable case.
7

Investigation:
This term has been defined in S. 2(h) of the Cr.P.C and includes all the activities carried out
by a police officer or any other officer authorised by a magistrate that are associated with the
collection of evidence.
The Supreme Court had the opportunity to consider what all are the activities that constitute
an investigation6. The Court said that an investigation consists of:

Proceeding to the spot;

Ascertainment of the facts and circumstances of the case;
Discovery and arrest of the suspected offender;
Collection of evidence relating to the commission of the offence (this includes
examination of witnesses and search and seizure);

Formation of an opinion as to whether material collected is enough to place accused

on trial; and

Submission of Charge-Sheet under section 173 of the Cr.P.C.

Therefore, it can be said that the process of investigation begins with the recording of the FIR
and culminates with the filing of the charge-sheet.
The First Information Report:
As has been discussed above, there is a distinction between how an investigation commences
in a cognizable case and a non-cognizable case. In simple terms, FIR is the basis on which an
investigation begins in a cognizable case. The object of lodging the FIR is to obtain the
earliest information regarding the circumstance in which the crime was committed, including
the names of the actual culprits and the parts played by them, the weapons, if any, used, as
also the name of the eye-witnesses7.
Chapter 12 of the Cr.P.C deals with the power of the police to carry out investigation. The
first provision appearing under this chapter is S.154. S.154 deals with information given to
the police in cognizable cases and is divided into three distinct parts. It is on the basis of
this initial information given to the police that investigation commences. This initial
information is more commonly known as the FIR. It is very important to note that S.154 itself
does not make use of the term First Information Report. However, one should not
immediately come to the conclusion that this term has not been mentioned anywhere in the
code. A couple of authors have stated that the term First Information Report has not been

6 H.N. Rishibud v. State of Delhi, AIR 1955 SC 196.

7 Meharaj Singh v. State of U.P., (1994) 5 SCC 188.
8

used in the Cr.P.C8. The researcher differs from the view shared by these authors. Though
S.154 does not make use of this term, one should read S. 207(2) of the Cr.P.C. The conclusion
that can be drawn by reading this section is that the report recorded under S.154 is the First
Information Report. The FIR is a very important document and marks the beginning of the
investigation. The object of the FIR is to set the criminal law machinery into motion.
The three distinct parts of S.154:
The first part which corresponds to sub-section (1) of S.154 deals with the procedure
involved in recording of an FIR. An important component of this provision is that the
information should be given to an officer in charge of a police station. S.2 (o) of the Cr.P.C
defines who an officer in charge of a police station is. The officer in charge should reduce the
information so given into writing. The informant should also sign the FIR. If he does not then
he can be punished under S.180 of the Indian Penal Code which provides for punishment if a
person refuses to sign a document.
The second part which corresponds to sub-section (2) of S.154 mentions that a copy of the
FIR should be given to the informant.
The third part corresponds to sub-section(3) of S.154 which contains the procedure to be
followed in case the officer in charge of a police station refuses to record the FIR.
Once, the FIR is recorded Sections 156 and 157 of the Cr.P.C come into play. S.157 lays
down the procedure for investigation. The police officer has to send a report to the
appropriate Magistrate and take necessary steps for carrying out investigation. The Proviso to
S.157(1) lays down a few exceptions from the procedure prescribed under S.157(1) but the
officer in charge of the police station should record reasons for doing so as is laid down under
S.157(2). If the officer in charge of the police station is desirous of going ahead with the
investigation he can do so. S.156 gives the power to investigate cognizable cases without
order of the Magistrate. S. 156(2) is crucial as it empowers the police to carry out
investigation in any area without the investigation being called into question. As has been
authoritatively laid down by the Supreme Court, the Station House Officer has statutory
authority under S.156 of the Cr.P.C to investigate any cognizable offence for which an FIR is
lodged9. The commission of a cognizable offence can be reported at any police station,
irrespective of whether it has jurisdiction over the place where the alleged offence was
committed10. Once the investigation is over, the officer may forward the report to the
appropriate magistrate. The logic being that at the time of investigation it might not be known
8 P. Ramanatha Aiyar, Code of Criminal Procedure, Justice J.K. Mathur Ed., Vol.2, 7th Edn., Modern Publishers (India),
Lucknow, 2000, p.1350, and, Ratanlal and Dhirajlals The Code of Criminal Procedure, Justice Y.V. Chandrachud Ed., 15th
Edn., Wadhwa and Co., Nagpur, 1997, p.209.

9 Satvinder Kaur v. State (Govt. of N.C.T. of Delhi), 1999 SCC (Cri) 1503
10 R. Nagaratnam, Criminal Procedure: Principles and Precedents, Tata McGraw-Hill, New Delhi, 1990, p.22
9

where the offence has been committed. The researcher completely agrees with this line of
reasoning.
The FIR must clearly show the commission of a cognizable offence. This is one of the
prerequisites for a FIR. The researcher would like to elucidate this with the help of two
illustrations.

Illustration 1:
X is the officer in charge of the police station. A comes to the police station and tells X that
there is a lot of commotion in a certain market place. The officer enters this information into
the Station House Diary. Based on this information given by A, the officer goes to the market
place and finds out that a person has been killed. He questions an eye-witness and records his
statement under S.154 of the Cr.P.C. A question arises as to whether the information given by
A should be treated as the FIR as it was the first in point of time. The question one should
consider is whether the information so given discloses the commission of a cognizable
offence. If the answer is yes, then the information does constitute the FIR or else it is not. In
the instant fact situation, the information does not show the commission of any cognizable
offence at all. All that was said was that there was a commotion in the market place and
nothing else. A mere commotion in the market place is not a cognizable offence.
Illustration 2:
X is the officer in charge of the police station. A comes to the police station and tells X that
B, a friend of A, was stabbed to death by M at the residence of B. The police records this
information in the Station House Diary. The SHO goes to the residence of B and verifies the
information given by A. X finds the information to be substantially correct. In such a
situation, the information given by A to X would constitute the FIR as it clearly shows the
commission of a cognizable offence.
Illustration 1 is quite similar to the facts of the case in Tapinder Singh v. State of Punjab11. In
that case however, there was a telephone call made to the police station stating that firing had
taken place in a taxi stand. The Supreme Court held that this would not constitute the FIR as
it was cryptic and anonymous and did not show the commission of a cognizable offence. The
information must unmistakably relate to the commission of a cognizable offence. A cryptic
piece of information received which does not disclose any authentic knowledge about the
commission of a cognizable offence would not be sufficient to register an FIR12.
Object of recording the FIR:

11 1970 SCC (Cri) 328

12 Binay Kumar Singh v. State of Bihar, (1997) 1 SCC 283
10

One may be compelled to ask at this stage why there is so much emphasis or attention given
to the FIR, so long as the police act upon it. Determining when the FIR was actually
recorded, according to the researcher, is of significant importance. Firstly, it signifies the
beginning of the investigation stage and secondly, and more importantly, S.162 of the Cr.P.C
comes into play. S.162 is a protection afforded to the accused. No information obtained by
the police during investigation, if reduced to writing, can be used as evidence in any trial.
This is a protective mechanism that has been incorporated to benefit the accused.
The accused in a trial always tries to show that the information first received by the police is
the FIR. Since the FIR marks the beginning of the investigation, the accused resorts to S.162
to prevent the admissibility of any statement recorded by the police subsequently. Invariably,
this is the most common ground raised by the accused when the accused challenges the
contents of the FIR. This causes the police to act with caution when they receive any
information as to the possible commission of a cognizable offence. They go the scene of
crime, ascertain more facts, find a suitable eye-witness and record his statement as the FIR.
This approach of the police is not accused friendly, but indeed one may put forth convincing
arguments for and against the adoption of such a method adopted by the police. Thus,
determining as to what piece of information constitutes the FIR is in itself an extremely
important task and has a significant bearing on the very trial itself.
Illustration:
X, the SHO, on the information received through a telephone call, goes to the scene of the
crime and gathers certain information. He records the statement of B, an eyewitness, as the
FIR. At the trial, M, the accused might raise the plea that the telephone call will constitute the
FIR (provided it had clearly shown the commission of a cognizable offence) and the
statement of B is therefore barred under S.162 as it was made to a police officer during the
course of investigation.

CHAPTER II:
The Anonymous FIR and its Evidentiary Value
The FIR is usually lodged by a person who is identifiable; i.e.- the FIR bears the name and
signature of the informant. The issue the researcher seeks to examine in this chapter is
whether an FIR can be anonymous and would be its evidentiary value. The researcher was
not able to come across a single Supreme Court ruling that allows for the recording of an
anonymous FIR.
Evidentiary Value of a usual FIR:
One may ask as to what other purpose does the FIR serve other than marking the beginning
of the investigation stage. Can an FIR be used to convict the accused? Logically speaking it
should not form the sole basis of the conviction of the accused because the FIR only allows
11

for the police to begin investigating. The evidentiary value of the FIR is far greater than that
of any other statement recorded by the police during the course of investigation13.
An FIR is admissible as evidence in a trial. But how does the prosecution benefit by
producing the FIR as evidence? Or does it actually benefit the accused by allowing him an
opportunity to cross-examine the maker of the FIR. The prosecution has to always show that
the FIR was properly recorded so as to show the credibility of their case and to prevent the
Court from drawing an adverse inference. The accused on the other hand tries to crossexamine the maker of the FIR and tries to show some contradiction in the version of the
maker in the FIR and that before Court. He tries to cast a doubt on the correctness of the FIR.
The evidentiary value of the FIR has been discussed by the Supreme Court in many a times.
In 1973, a three-judge bench of the Supreme Court had discussed the evidentiary value of an
FIR14. In this case, the contents of the FIR were at variance with the testimony of other
witnesses in Court. The submission of the appellant before the Supreme Court was that
because of this the prosecution evidence must be considered unreliable and hence, cannot
form a safe basis for holding the appellant guilty. The Court said that:
The FIR is never treated as a substantive piece of evidence. It can only be used to contradict
or corroborate its maker when he appears in Court as a witness15.
The Court further held that an FIR cannot be used for contradicting or discrediting other
witnesses who do not have any desire to spare the real culprit. An important conclusion can
be arrived at if one reads the judgment of the Court in this case which is that even if the
maker of the FIR contradicts himself, the prosecution case still stands and the testimony of
other witnesses can be relied upon to convict the accused.
In another case that arose before the Supreme Court, the counsel for the respondents urged
that the contents of the FIR could be used to corroborate the testimony of other eyewitnesses16. They intended to do so by invoking S.11 of the Indian Evidence Act, 1872 (IEA).
However, the Court rejected their argument and said that the contents of the FIR can be used
only to contradict or corroborate the maker of the FIR and of nobody else.
As recent as 2002, a division bench of the Supreme Court has held that the FIR is not a
substantive piece of evidence and can only be used to corroborate the statement of the maker
under S.161 of the IEA or to contradict him under S.145 of that Act. It cannot be used as

13 R.V. Kelkars Criminal Procedure, K.N. Chandrasekharan Pillai Ed., 4th Edn., Eastern Book Co., Lucknow, 2001, p.119
14 Dharma Rama Bhagare v. The State of Maharashtra, (1973) 1 SCC 537
15 Ibid., at Para.7
16 Ram Chander v. State of Haryana, (1981) 3 SCC 191
12

against the maker at the trial if he himself becomes an accused nor to corroborate or
contradict other witnesses17.
To summarise the preceding paragraphs, it can be said that the FIR can only be used to
corroborate or contradict the maker of the FIR. If the maker of the FIR happens to be the
accused himself, then his conduct of lodging the FIR becomes relevant under S.8 of the IEA.
However the contents of the FIR cannot be used against him.
The Anonymous FIR:
An anonymous FIR necessarily implies that the FIR is made by some person whom the SHO
does not know and cannot see. An anonymous FIR can be made over the telephone, via
telegram, via SMS or via the Internet. However, all these cases invariably deal with telephone
calls.
An interesting case came up before the Punjab High Court in 1964 18. In the instant case, the
police had received an anonymous telephone call, which conveyed that the deceased had been
injured by two persons and had run away. Based on this the police went to the scene of crime
and recorded the statement of an eye-witness as the FIR. The accused/appellant sought to
show that the telephone call constituted the FIR and hence, the statement of the eye-witness
was barred by S.162 of the Cr.P.C. The High Court cited many High Court decisions and said
that a telephonic message cannot constitute an FIR. It further said that the identity of the
assailants was not disclosed and was therefore cryptic. The Court said that the statement of
the eye-witness would be the FIR.
The researcher would like to differ from the view expressed by the court in the above
mentioned case. She feels that an FIR need not necessarily name the assailants as that are the
very purpose for which the investigation takes place. If the informant is expected to mention
everything in his information then what is the whole purpose of investigation. Secondly, if the
telephone call does show the commission of a cognizable offence, as in the above fact
situation, then why should it not be treated as the FIR? The researcher feels that it should be
treated as the FIR because but for the telephone call, the police would not have proceeded to
the scene of crime.
The above mentioned case was cited with approval by the Supreme Court in the Tapinder
Singh Case19. It is not necessary to go into the facts of this case as they have already been
discussed in the previous chapter. What is relevant for the present discussion is that the court
17 Bijoy Singh v. State of Bihar, (2002) 9 SCC 147
18 Saroop Singh v. The State, AIR 1964 Punj 508
19 Supra, note 11
13

said that telephone call to the police station was cryptic and anonymous. It was cryptic
because it did not show the commission of a cognizable offence. Would that mean then that if
a telephone call were anonymous but not cryptic, it would then constitute an FIR. The Court
somehow overlooked this point or did not find it necessary to comment on this aspect.
Once again in 1975, when one of the questions before the Supreme Court in a case was
whether the telephone call of the Police Sub-Inspector would constitute the FIR or not, the
Court just said that since it was too cryptic, it would not constitute the FIR 20. However, in that
case the telephone call was not anonymous and therefore the Court might have been justified
in expressing its view on that point.
However, the Supreme Court did answer this point in 1994 21.It said that if a telephone call is
cryptic it would not constitute the FIR. Because the purpose of such a telephone call is to ask
the police to proceed to the crime scene and ascertain a few more facts before recording the
FIR. But interestingly, the Court went a step ahead and said that if the telephone call shows
the commission of a cognizable and based on that information the police officer proceeds to
the crime scene, any statement made by a witness subsequently to him would be struck by
S.162 of the Cr.P.C. Therefore, by implication, the Court has held that the telephone call
constitutes an FIR.
However, the researcher feels that a particular judgment of the Kerala High Court in 1987,
even if given a narrow interpretation, would allow anonymous telephone calls to be
considered as an FIR, provided it shows the commission of a cognizable offence 22. The Court
said:
A First Information Report which sets the process of law in motion can come from any
quarters, even anonymous sources23.
Consequently, the researcher opinions that an anonymous telegram, telephone call or e-mail
would constitute an FIR if it clearly shows the commission of a cognizable offence. The
researcher would now like to move on to the implications that might arise out of an
anonymous telephone call.
Implications of an Anonymous FIR:

20 Soma Bhai v. State of Gujarat, 1975 SCC (Cri) 515

21 Ramsinh Bavaji Jadeja v. State of Gujarat, 1994 SCC (Cri) 609
22 Mani v. State of Kerala, 1987 Cri LJ 1965 (Ker)
23 Ibid., at Para.4

14

Let us assume an anonymous telephone call has been recorded as the FIR by the police. This
has its own implications on the police as well as the accused. The police might be put at a
disadvantageous position. The telephone call might have disclosed the commission of a
cognizable offence but the police can never be sure that the event has happened. Once they go
to the crime scene, they find a few further facts from eye-witnesses but they cannot produce
the statements of such witnesses before the Court as their statement will be barred by S.162
of the Cr.P.C. This will prove beneficial to the accused. Another disadvantage is that the
contents of the telephone call when written down by the police cannot be read over back
again to the informant. The police would not be able to verify the contents of the FIR that it
has recorded. This would happen in cases where the informant makes a call to the police but
disconnects before the information recorded is read over to him. But to overcome this, the
police can have a recording device that tapes the whole telephone call.
But allowing anonymous phone calls to constitute an FIR will also prove beneficial to the
police. Sometimes, people do not wish to lodge a complaint with the police. In such cases, the
FIR is lodged by the police. Usually, the Court does not much importance to an FIR recorded
by the police themselves. Therefore, by recognizing an anonymous FIR, people who are
afraid of criminals can still give information to the police without any fear whatsoever as
their identity is not revealed.
An anonymous FIR might also be a disadvantage to the accused in a trial. When an FIR is
anonymous, it is implied that the maker will not testify in Court. Consequently, the accused
loses his very valuable right of cross-examination against the maker of the FIR. However,
after Dharma Rama Bhagares case, even if the maker contradicts himself, the prosecution
might still succeed if they have other reliable evidence. So, it may be said that the accused is
not put to a big hardship except for the fact that he loses his very valuable right to crossexamine the maker of the FIR. He can still cross-examine the other witnesses.
In another case before the Supreme Court, where the informant had died after lodging the
FIR, the Court said that since such a person cannot come to court to testify, he cannot be
contradicted or corroborated. Therefore reliance cannot be placed on the FIR. However, if
there is other reliable evidence or there are other witnesses, the court might still convict the
accused24.

24 Harkirat Singh v. State of Punjab, 1997 SCC (Cri) 1068

15

CONCLUSION
The FIR is an important document as it allows the police to commence investigation in a
cognizable case and also establishes the period from which the provisions of S.162 of the
Cr.P.C come into play.
The Court usually tries to see whether there exists an FIR based on which the police began
investigation. Any irregularity in the trial does not vitiate the trail by itself, but the Court does
draw an adverse inference from it.
Coming to the issue of allowing anonymous FIRs, the researcher feels that a couple of the
decisions of the High Court and the Supreme Court settle this matter conclusively. An
anonymous FIR can definitely be allowed. If the call shows the commission of a cognizable
offence and the police begin investigation, then the telephone call will definitely be the FIR.
However, in reality, the police do not like to record an anonymous call due to reasons
mentioned above. Moreover, the police themselves are aware of S.162 of the Cr.P.C and
thereby like to record a statement, complete in facts, as the FIR.
The only thing that the researcher would like to add is that if the police were to begin
recording information from an anonymous source as the FIR, then the accused would
definitely be at an advantage as that would mean the operation of S.162 of the Cr.P.C would

16

come into play much earlier. This is in spite of the fact that he loses the right to crossexamine the maker of the FIR.

BIBLIOGRAPHY
Books:

Dhirendra Pal Varshini, How to Frame a Charge under the Penal Code and Other
Criminal Acts, 2nd Edn., Eastern Book Co., Lucknow, 1994.
N.D. Basu, The Code of Criminal Procedure, S.K. Bose Ed., Vol.1, 9th Edn., Ashoka
Law House, New Delhi, 2001.
P. Ramanatha Aiyar, Code of Criminal Procedure, Justice J.K. Mathur Ed., Vol.2,
7th Edn., Modern Publishers (India), Lucknow, 2000.
R. Nagaratnam, Criminal Procedure: Principles and Precedents, Tata McGraw-Hill,
New Delhi, 1990.
R.V. Kelkars Criminal Procedure, K.N. Chandrasekharan Pillai Ed., 4th Edn., Eastern
Book Co., Lucknow, 2001.
Ratanlal and Dhirajlals The Code of Criminal Procedure, Justice Y.V. Chandrachud
Ed., 15th Edn., Wadhwa and Co., Nagpur, 1997

17