Journal of Acharaya Narendra Dev Research Institute l ISSN : 0976-3287 l Vol-27 (Jan 2019-Jun 2019)

Independence of Judiciary: A Study in Indian Perspective

*Sudhansu Ranjan Mohapatra, **Tanmaya Pattnayak

Abstract

Just like Human body needs its entire organ system to perform properly, every institution of the government
also needs a diligentfunctioning to run smoothly. The legislative, executive and judiciary known to be the
inseparable wings of the government, are required to do their duties properly. While governance is contingent
on the functional consortium of the threewings, it is the judiciary which interprets and applies the law. It also
adjudicates upon controversies between one citizen and another, and between a citizen and the state. It is also
vested with the duty to safeguarding the supremacy of the constitution by interpreting and applying its
provisions but within the constitutional framework.In this regard, the independence of judiciary from the
executive and legislature as well as independence of each and every judge within the judiciary is considered
necessary for a free society and a constitutional democracy. It ensures the rule of law and realisation of human
rights and also the prosperity and stability of a society. The independence and impartiality of the judiciary is one
of the hallmarks of the democratic system of the government. Only an impartial and independent judiciary can
protect the rights of the individual and can provide equal justice without fear and favour. There are many factors
which has direct and indirect impact on judicial independence. Such as powers of judicial review, modes of
appointment, remuneration and immunity to judges, etc. It is essential to let the judiciary act freely and
independently to unleash its full potential. Judicial review is sine qua non for the constitutional governance by
the organs of the State and its instrumentalities. Additionally, the appointment of judges has direct nexus with
independence of judiciary because the by-product is always dependent on the original source. If the
appointments are made by the executive or political masters, it is quite obvious that such appointed judges will
have allegiance towards their appointees. It is the need of the day to make the judiciary more accountable, as
derogation of values in judiciary is more poisonous than in any other organs of the government. It is an
absolutely undeniable fact that judicial independence is vital for the survival of any democracy but at the same
time we cannot ignore the requirement of judicial accountability.

Keywords: Judicialindependence, separation of power, judicial review, judicial activism and accountability

Introduction
Laws are a dead letter without court to expound
and define their true meaning and operation.
-- Alexander Hamilton
A concordance among the units of a system is salient to the system's functioning. This is invariably
true for every deliverable. In this regard, even the human body can be considered analogous to the governance
of a state. The organs perform their functions individually but not completely independently, since the
individual functionalities together result in overall health. Similarly, in the model of governance adopted in
India (the parliamentary system), the powers of a state are separated into individual units: the legislative, the
judiciary and the executive, which might function independently but for the same cause, welfare of the state.
While different countries might exercise their governance with several metonymic counterparts of these
bodies, the system of state is essentially represented by the collective functioning of those. Hence, the
executive, Legislature and judiciary are the most essential organs of any government.They have different
functions but they collectively work to make the country move forward. The legislature makes law, the
executive implements the law and the judiciary interprets and applies the law and adjudicates upon
controversies between citizen and another and between a citizen and the state. It is also vested with duty to
safeguarding the supremacy of the constitution by interpreting and applying its provisions but within the

*Prof. Head of the P.G. Department Law Sambalpur University, Burla, Odisha, India
**Associate Researcher Xavier Institute of Labour Relation, Jamshedpur, India

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 Independence of Judiciary: A Study in Indian Perspective

constitutional framework. When in a federation dispute arises regarding allocation power between centre and
state, judiciary act as an arbiter. It is the Duty of the Judiciary to see whether all the other organs of the
governments are discharging their duties under the provided constitutional framework or not. Judiciary also
has the significant function of protecting and enforcing fundamental rights guaranteed to them by the
constitution. Justice Untwalia has compared the judiciary to “A watching tower above all the big structures of
the limbs of the state” from which it keeps a watch like a sentinel on the function of the other limbs of the state as
to whether they are working in accordance with the law and the constitution, the constitution being supreme.
Liberty, democracy and the rule of law are most important indices of a free and civilized society. They
can well be described to be the three faces of Holy Trinity which presides over the destiny of all free
societies.The rule of law requires every government officials and citizens to bound by and act consistent with
the law so that harmony can be established. It is again the duty of the judiciary to protect the rule of law. It can
therefore, be aptly appraised that the judiciary of any country must be “sacrosanct” to perform all multi-
dimensional functions. By saying sacrosanct it must be independent, impartial and proactive in exercising all of
its functions. The supreme court of India in Subhassharma v. Union of India observed that “An independent
non-political judiciary is crucial to the sustenance of any chosen political system. The vitality of the democratic
process, the ideals of social and economic egalitarianism, the imperatives of a socio-economic transformation
envisioned by the constitution as well as the Rule of law and great values of liberty and equality are all
dependent on the tone of the judiciary”.Further, if the judiciary were to be controlled by the legislature and / or
the executive, the rule of law would become chimerical for absence of an external audit machinery of the
constitutional validity of any legislative or executive action. Hence, the judiciary needs to be fully independent
so that it can test the acts of the legislature or executive on theanvil of the constitution.
It is not only an ordinary expectation but the basic and fundamental rights of every citizen of a country
to have an independent judiciary. It is very well said that “the weaker may prevail over the strong” which
provide balance in the society. Such a balance is possible only when the judiciary remains independent and
exercises its powers without any influence. So the independence judiciary is not only vital for the rights of the
citizen but also for sustenance of a nation. Justice KrishnaIyer in Sankalchand Case was of the view that, “ In a
dynamic democracy, with goals of transformation setby the Constitution, the Judge, committedto uphold the
founding faiths and fighting creeds of the nation so set forth, has to act heedless of executive hubris, socio-
economic pressure, and die-hard obscurantism. This occupational, heroism, professionally essential, demands
the inviolable independence woven around the judiciary by our Constitution.”

Necessity of Independence of judiciary

The independence of judiciary from the executive and legislature as well as independence of each and
every judge within the judiciary is considered as necessary conditions for a free society and a constitutional
democracy. It ensures the rule of law and realisation of human rights and also the prosperity and stability of a
society. Therefore, the Indian constitution provides for the independence not only of the Supreme Court but
also of the high Courts and subordinate courts. The Indian Supreme Court has also held more than once that the
independence of judiciary is basic feature of the constitution and any attempt to curtail it directly or indirectly
even by an amendment of the constitution is invalid.
The independence and impartiality of the judiciary is one of the hallmarks of the democratic system of
the government. Only an impartial and independent judiciary can protect the rights of the individual and can
provide equal justice without fear and favour. The equality to prevail in a society full of diversity, the judiciary
needs to be impartial and independent. The Constitution of India provides many privileges to maintain the
independence of judiciary. Our Constitution is essentially a social document unlikethe American
Constitutionwhich is essentially a political document. It is well known that underlying the constitution is the
egalitarian philosophy, the concept of socio-economic justice, the theory of welfare state, secularism, dignity
of the individual, unity in diversity and the spirit of 'SalusPopuliSuprema Lex'. Therefore, an independent
judiciary cannot remain immune to the environment surrounding it in the discharge of its role as an institution
established by the Constitution armed with the supreme power of judicial review of not only executive action
but also legislative action. The judiciary is most ideally placed and no other institution is perhaps in my opinion
is placed in a more advantageous position than the judiciary in feeling the authentic feel of the nation's pulse as
day in and day out, problems of multitudes in all hues and colours stemming from a side cross-section of society

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Journal of Acharaya Narendra Dev Research Institute l ISSN : 0976-3287 l Vol-27 (Jan 2019-Jun 2019)

keep pouring into the court clamouring for justice and for the enforcement of the rule of law as against of rule
arbitrariness. Therefore, independence of judiciary depends on some certain conditions like mode of
appointment of the judges, security of their tenure in the office and adequate remuneration and privileges,
jurisdiction of courts over all issues of judicial nature, principles of non-interference by other branches of
government in judicial functions, entitlement of judges to certain fundamental freedoms, posting, promotion,
transfer, immunities, disqualification, discipline and removal and court administration. Satisfactory
implementation of these conditions enables the judiciary to perform its due role in the society thus inviting
public confidence in it. Supreme Court of India in S.P. Gupta v. Union of India, the court held that "the concept
of independence of the judiciary is a notable concept which inspires the constitutional scheme and constitutes
the foundation on which the edifice of our democratic polity rests. If there is one principle which runs through
the entire fabric of Constitution, it is the principle of the rule of law under the Constitution; it is the judiciary
which is entrusted with the task of keeping every organ of the state within the limits of the law thereby making
the rule of law meaningful and effective".As Cardozo once said, “the great tides and currents which engulf the
rest of men do not turn aside in their course and pass the judges by.”

Factors effecting Independence of Judiciary

There are many factors which has direct and indirect impact on judicial independence. Such as powers
of judicial review, modes of appointment, remuneration and immunity to judges post-retirement benefits etc.
Looking forward to this the constituent assembly has debated over a long period of time to write down the
appropriate provisions to establish an independent and impartial judiciary.

Powers of judicial Review

Judiciary is and intended to be an integral partof the state, complimentary to both the Legislature and
the Executive. It is essential to let the judiciary act freely and independently to unleash its full potentials.There
can be no absolute or total independence.Dr.Ambedkar declared in the Constituent Assembly that Article 32 is
the "soul" and "Conscience" of the Constitution implying thereby that the rights given to the citizens remains
nebulous without judicial remedy which Article 32 does give remedy. Judicial review is sine qua non for the
constitutional governance by the organs of the State and its instrumentalities. By using the power of judicial
review the judiciary can declare any law or administrative action, which is inconsistent with the provisions of
the constitution as void or invalid. Thus putting a constraint on the power of the executive, it restricts the
executive from over using its powers. It is the duty of the judiciary to keep the organs of the government under
the framework of law and to make rule of law stronger. Article 13 of the constitution of India clearly states that
any law which is inconsistent with the fundamental rights can be declared void by the Judiciary. There is
plethora of cases where the judiciary has protected the fundamental rights of the citizens from arbitrary laws
made by the legislature.Referring to the doctrine of separation of power it provides checks to the arbitrary use
of power by the legislature. The Indian constitution gives power to grant pardon and to commute sentence in
certain cases.
The Supreme Court in Maru Ram v. Union of India expressly stated that, the power of pardon,
commutation and release under Article 72 (Also under Article 161) can run riot and must keep sensibly to a
steady course and that public power “shall never be exercisable arbitrarily and mala fide and, ordinarily,
guidelines for fair and equal execution are guarantors of the valid play of power. Again in Kehrarsingh v. Union
of India, the court reiterated: “It appears to us clearly that the question as to the area of the president's power
under Article 72 falls squarely under the judicial domain and can be examined by the court by way of judicial
review. In Swaransingh v. State of U.P. the court held: If such power was exercised arbitrarily, malafide and
absolute disregard of the finer canons of the constitutionalism, the by-product order cannot get the approval of
law and in such cases, the judicial hand must be stretched to it.”By all these judgments,it was made clear that
even the executive action of the highest position can even brought into question by using the power of judicial
review. Summing it of in one word now the executive is under the scanner of the judiciary and accountable to
every action it makes because anything which is outside the framework of law can be declared invalid by the
judiciary. So it is vital for any country to have an independent judiciary to make entire of its organ to perform
flawlessly.

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Modes of appointment
In the matter of choosing judges, the Constituent Assembly sought hard to ensure that the executive
does not exercise unfettered discretion andcompletecontrol overthe appointments process.The Assembly's
concern was to create a judiciary that was independent and efficient.The Constitution provides for appointment
of Supreme CourtJudges by Article 124(2), which only requires appointment by the President by a warrant
under his hand and seal 'after consultation with such of the judges of the Supreme Court and of the High Courts
in the States as the President may deem for the purpose'. Article 217 provides that every judge of the High Court
shall be appointed by the President by a warrant under his hand and seal 'after consultation with the Chief
Justice of India, the Governor of the State, and, in the case of the appointment of a judge other than the Chief
Justice, the Chief Justice of the High Court. The interpretation of these provisions has been the primary issue on
which the debate over judicial independence has played in India. Appointment of judges has direct nexus with
independence of judiciary because the by-product is always dependent on the original source. If the
appointments are made by the executive or political masters, it is quite obvious that such appointed judges will
have allegiance towards their appointer.Besides, yieldingto someone's pressure or acting on account of ill will
or affection or corrupt motives, often the judge may act from benign motives but because of deep seated
prejudices.During the days of discussion on committed judiciary, while advocating an active role for a judge
and 'value packing' a learned judge of the Supreme Court delivered how political bias is destructive of the
independence of judiciary, it was observed, “It is not unlikely that the total insulation may breed ivory tower
attitude, a bishop delivering sermon from the pulpit and therefore no claim to be imperium in imperio can be
extended to the judiciary or for that matter to any other instrumentality under the constitution. It is not as if
judicial independence is an absolute thing like a brooding omnipresence, nor should the judges be independent
of the broad accountability to the nation and it's indigent and injustice ridden millions. Therefore, consequently
one need not too much idolise this independence of judiciary so as to become counter-productive...The
judiciary cannot stand aloof and apart from the mainstream of society”.It would therefore only be an illusion to
expect justice from such judges as in plethora of petitions the executive and the legislature are a party to it.
TheIndian scenario is quite a lot reflects the same values discussed below in the three judges case.

The story of three judge's case

The Supreme Court of India's collegiums system, which appoints judges to the nation's constitutional
courts, has its genesis in, and continued basis resting on, three of its own judgments which are collectively
known as the Three Judges Cases.
The collegium system, which appoints the constitutional courts in India, has its genesis in, three
supreme court's Judgements which collectively known as the three judges case. Those are;
? S. P. Gupta v. Union of India
? Supreme Court Advocates-on Record Association vs. Union of India
? In re Special Reference
Over the course of these three cases, the court made it clear that there should not be any executive or
legislative interference in appointment of judiciary, showing the significance of independence of judiciary.
Since the decision of second judge's case the court created the collegium system. The constitution is silent on
such a system in its original text and successive amendments. In the third judges case an opinion was delivered
by the Supreme Courtresponding to the question of law relating to the collegium system. In this case the
responsibility to make recommendation for appointment as Supreme Court judges has been taken away from
the central executive and has now been placed on a collegium consisting of the chief justice of India and four
senior most puisne judges.
In 2014 the central government framed a National Judicial Appointment Commission vide 99th
constitutional amendments and the National Judicial Accountability Act that put in place a framework that
gives the executive considerable powerover the appointments process. Article 124A of the Constitution
established a six-member National Judicial Appointments Commission (NJAC) of which only half the
members were to be judges. Three members were to consist of the Union Minister of Law and Justice and the
two 'eminent persons' nominated by the Prime Minister, Chief Justice of India and the Leader of Opposition in
the Loksabha, the lower house of the Indian Parliament.TheSupreme Court quashed the NJAC Act along with
the amendment and held thatprimacy of judiciary extends to not only rejection of unworthy candidates, but also

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Journal of Acharaya Narendra Dev Research Institute l ISSN : 0976-3287 l Vol-27 (Jan 2019-Jun 2019)

to ensure appointment of worthy candidates thus NJAC Act which provides veto to two members or law
minister or an “eminent person” is struck down as being violative of basic structure of the constitution.The
Supreme Court very aptly noted in L.Chandra Kumar, “While the Constitution confers the power to strike
down laws upon the High Courts and the Supreme Courts, it also contains elaborate provisions dealing with the
tenure, salaries, allowances, retirement age of judges as well as the mechanism for selecting judges to the
superior courts.The inclusion of such elaborate provisions appear to have been occasioned by the belief that,
armed with such provisions, the superior courts would be insulated from any executive or legislative attempts
to interfere with the making of their decisions.”

Immunity to Judges
The constitution insulates the Court from political criticism, and,thus ensures its independence from
political pressures and influence, by laying down that neither in Parliament nor in a State Legislature the
conduct of a 'supreme court judge in the discharge of his duties can be discussed. The provision amounts to an
absolute constitutional prohibition against any discussion in a House with respect to a Supreme Court Judge.
There should be no fear, no burden in the mind of the adjudicator which causes derailment of justice system.
Judges must be protected against any attack on their conducts in court. Any pronouncement of judgment can't
be brought under the scope of law of defamation everything said in the course of adjudication is absolutely
privileged. It gives the judge the privilege to act and opine freely to secure justice. The judiciary is not required
to give cause for their verdict nor are they punished for not giving a verdict. As only an independent and
unburdened mind can distinguish between right and wrong.

Post Retirement Benefit

A very pertinent and significant question is raised sometimes in the knowledgeable quarter as to
whether the retired Supreme Court and High Court judges take any quasi-judicial jobs, or any post-retirement
benefits or contest election for the legislaturewhich hampers independence of the judiciary. Many a time, they
areappointed to pure and simple executive posts.There is no specific bar inthe Constitution against this but
actions like this arehighlycondemnable because it makes the judges obligated to the executive. K. Narayana
Kurup J. has expressed a firm opinion against this practice. To maintain the dignity and independence of the
judiciary as well aspublic confidence in the institution, it is necessary that a judge should now allow his judicial
position to be compromised at any cost. He remarked that, “The general public reposing absolute faith in
thejudiciary, see in it, justifiably an institution, that can rein in, if not eliminate, the rapacity, nepotism and
corruption, especially at high places which have come to be associated with governance. The judiciary should
continue to merit the exalted position it occupies in the minds and hearts of the people as the 'saviour of
democracy'. It cannot be gainsaid that the one necessary condition for this is its independence. Independence in
the sense free from the executive, meaning the bureaucracy and politician's interference and influence of every
type. And fundamental to freedom from such influence and pressures on the judiciary is to eschew active
politics and acceptance of positions by judges after retirement.”On the other hand, if the executive desires to
exploit the talent of a retired judge for public benefit by appointment to a commission or a tribunal, there can in
principle be no conceivable objection to it, if it is done honestly and transparently. What is objectionable would
be any attempt to offer an allurement to a sitting judge or attempts to negotiate terms with a sitting judge with
regard to post-retirement benefits.

Independence and Accountability

The goal of judicial independence must be considered alongside the goal of judicial accountability.Power
implies responsibility, independence is tyranny without accountability. Our judges must realize their
immensepowers and sensitive obligation to keep abreast of advances of events, information, knowledge and
wisdom.Further, independence ofjudiciary cannot be viewed in an abstract sense. Ithas to be gauged in terms of
the quality of justice which ultimately dispensed to the one who is craving for it, the beneficiary may be the
ordinary citizen, or an institution or the State or a system. The means adopted may be conventional or
unconventional, through social activism or juristic activism, through judicialism orthrough pragmatic
instrumentalism. The challenge in any modern constitutional democracy is to design a system that
institutionally secures the independence of the judiciary as well as produces a degree of

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accountability.Therefore, SwamyVivekanana is very apt in his saying, “The tree is judged by the fruit it
bears.”The goals of judicial independenceand judicial accountability are necessarily at odds. In a system where
judges have a greater degree of autonomy will itself produce a greater degreeof accountability. This idea of
accountability will be based on self-regulation. Judicial accountability and answerability of the judges is not a
new concept. Several countries in their constitutions have already provided for ensuring accountability of
judiciary. Thus, there is no difficulty in accepting the principle that in a society based on the rule of law and
democratic principles of governance, every power holder is, in the final analysis, accountable to the people.
There is no reason why the judiciary should not be accountable to the community for due performance of the
functions vested in it. Power is given on trust and judicial power is no exception. But at the same time it must be
developed consistent with the principles of judicial independence.The independence of judiciary is assured
when we are internally free subject to the accountability to our judicial conscience.
The two Judge Bench of the Supreme Court examined this question in detail. Justice D.M.
Dharmadhikari speaking for the Bench held that a teacher is not an employee within the meaning of the
expression "employee" as defined under Section 2(e) of the Payment of Gratuity Act, 1972 and hence he/she is
not entitled to claim any gratuity amount from his employer under the Act. In other words, it was held that since
a teacher is not an employee under Section 2(e) of the Act, he has no right to invoke the provisions of the Act for
claiming gratuity under the Act from his/her employer. The Court has relied on Ahmadabad Pvt. Primary
Teachers Association v. Administrative Officer and Others.
On 9th January 2019, the Supreme Court realised that Section 2(e) and Section 13A which were
amended in 2009 has not been considered hence the decision of the Court falls squarely as per incuriam and the
Court declared suomoto that the decision pronounced by the Court will not be enforced. Thanks to the social
media which at least prevented the judges from taking a wrong decision. So where is the accountability? As
Lord Denning said there must be restraint over the power of judiciary. It is the need of the day to make judiciary
more accountable, as derogation of values in judiciary is more poisonous than in any other organs of the
government.

Conclusion

The Supreme Court of India holds a unique status for several reasons. It is the apex court of the largest
common- law court system in the world. The Indian Constitution grants it far reaching authority to initiate
actions and direct appellate authority over all other courts in the country. The basic structure doctrine gives the
apex judiciary the power to review constitutional amendments. These features distinguish it from other
powerful supreme courts, such as the Supreme Court of United States of America. And the Supreme Court of
India remains a highly respected institution by the people of India and beyond giving it legitimacy when it
exercises its broad powers.
Therefore, from the above discussion an inference can be drawn that judicial branch is sacrosanct, an
institution to upheld the “Rule of law”, a messiah to secure toall citizens of the country, their fundamental and
human rights, a dispute settler for people and state etc. the sanctity of the same would remain unblemishedif it
remains Independent from any interference. As to fulfil their unbridled expectations, the political leaders and
executives have not left a single organisation functioning within the bounds of law. Corrupt practices are the
only food to be served in every meal of the day. The nation wants a society free of these heinous practices;
otherwise a welfare state is just a Utopian concept beneath our soul, struggling to see the light of the day. Taking
a note of this the judiciary has to maintain its sanctity and purity unaffected by any means of interference of
other institutions. Moreover, it is not only the function of the judiciary to secure justice but it's an imperative
duty of the same to be accountable for every decision it makes as the society at large depends upon its
functioning.Therefore, to uphold the legitimacy of judicial review the judiciary must strive to maintainthe
respect it commands against this masses for its independence and integrity.' Justice must not only be done it
must also seem to be done' is more a truism than a legal adage. In a democracy, especially in one where the
judiciary adopts an activist approach, the citizens have the right to examine the integrity of judicial process, I
would like to stress that whatever may be thenorms, welay down for ensuring independence of judiciary
whatever may be the safeguards we may provide therefore,, and whatever may be the hazards to which
individual judges may be exposed because of their independence, the devotions and adherence to the principle

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of independence and impartiality in the final analysis would depend upon the personality of individual judges.
In judicial process, the role of judges is more important than the written words of a statute. Krishna Iyer, J., has
rightly observed,” A socially sensitized judge is better statutory armour against gender outrage than long
clauses of a complex section with all protection writs into it.” It is an absolutely undeniable fact that judicial
independence is vital for the survival of any democracy but at the same time we cannot ignore the requirements
of judicial accountability.

References

1. Jain, MP. 2018.Indian Constitutional Law. s.l. : Lexis Nexis, 2018.p-194

2. 1991 AIR 631, 1990 SCR Supl. (2) 433
3. Union of India v. SankalchandHimmatlalSheth(1977) 4 SCC 193(65)
4. Singh, M.P. 2008.Constitution of India. Lucknow : Eastern Book Publisher, 2008.
5. 1982(2) se c 831
6. Benjamin N Cardozo, heNature of Judicial Process (Yale University Press 1923), 168
7. AIR 1980 SC 2147
8. AIR 1989 SC 653
9. AIR 1998 SC 2026
10. Singh, M.P. 2008.Constitution of India. Lucknow : Eastern Book Publisher, 2008. p-388
11. See Austin Granvile, The Indian Constitution: Cornerstone of a Nation(Oxford University Press
1966) 218-29
12. The Oxford Hand Book of the Indian Constitution, ed.Sujit Choudhury, Madhaqb Khosla and
PratapBhanu Mehta, OUP,P.350
13. S.P.Gupta v. Union of India(1981) Supp SCC 67(710-11)
14. 1981 SuppSCC 87
15. 1993 4 SCC441
16. AIR 1999 SC 1
17. (2016) 5 SCC 1
18. L.Chandra Kumar v Union of India(1995) 1 SCC 400
19. The dangers in accepting public office like that of a State Governor are very tellingly revealed by an
episode. FatimeBeevi, a retired Supreme Court Judge, was appointed the Governor of Tamil Nadu.
Sheappointed Jayalalitha as the Chief Minister of Tamil Nadu.Jayalalitha was at the time
disqualified to be a member of the State Legislature. Annoyed by the action of the Governor, the
Central Executive recalled from her Office.
20. AIR 1998 Ker 385
21. Balakrishnan H.G, J. ,NewDimensions of Law and Justice,p.6
22. Ibid, p.6
23. http://www.legalservicesindia.com/article/1951/Judicial-Accountability-Bill.html Last seen
15.04.2019
24. (2004) 1 SCC 755
25. Padhi, P.K. 2019.Labour and Industrial Law. New Delhi : PHI, 2019
26. Krishna lal v. State of Haryana, A.I.R, 1980. S.C.1252

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