This Article is in light of the recent repatriation and human rights violation faced by Indian citizens imprisoned in foreign prisons. The word Repatriation[2] means the process of returning an asset, an item of symbolic value or a person – voluntarily or forcibly – to its owner or their place of origin or citizenship in the present context Repatriation is the act to provide for the remittance of certain prisoners from India to country or place outside India and reception in India of certain prisoners from country or place outside India[3]. The process of repatriation is governed by the Repatriation of Prisoners Act, 2003 (Herein Referred to as RPA) in India. The right to return to one’s home country is assured under Article 12(4) of the International Covenant on Civil and Political Rights[4].

“Free and Civilized societies do not hold prisoners incommunicado” - Tom McClintock[1]

A sentence served in a foreign land, far away from family, familiar food and language, has been globally perceived to be more onerous than one served at home. Therefore, the Vienna Convention on Consular Relations, 1963[5], provides for information to consulate, consular protection and consultation upon arrest, detention and during the trial in a foreign country including entitlement to travel documents. Transfer of Foreign Prisoners and Recommendations on the Treatment of Foreign Prisoners 1985[6], emphasizes the social rehabilitation of foreign prisoners through early repatriation to their home countries to serve their remaining sentence.

The legacy of transfer of sentenced prisoners lies in the post-war humanitarian exchange of prisoners of war and two UN Conventions of 2004[7] (against transnational organized crime and corruption) which have emphasized the issue of inter-country transfer of prisoners. Both anticipate, under Articles 17 and 45 of the above-mentioned conventions, respectively, that state parties may consider entering into bilateral or multilateral agreements for transfer to their territory of persons sentenced to imprisonment or other forms of deprivation of liberty for completion of their sentences[8]. The RPA provides for governance of the same.

Statement of Purpose (SOP)
The act's purpose as it reaffirms is:
An Act to provide for the transfer of certain prisoners from India to country or place outside India and reception in India of certain prisoners from country or place outside India.[9]

The Repatriation of Prisoners (Amendment) Bill, 2010

Amendments are essential in making changes to the statute. The Repatriation of Prisoners (Amendment) Bill, 2010 was introduced in the Lok Sabha on August 16, 2010, by the Former Minister of Home Affairs, Shri P. Chidambaram. The Bill seeks to amend the Repatriation of Prisoners Act, 2003 which allows the transfer of prisoners from India to another country and vice versa. The Act allows a prisoner to apply for transfer. The application shall be considered by the central government[10]. If the central government is duly satisfied that the prisoner meets certain conditions, including the provision that the prisoner has not been convicted of martial law. This benefit is, however, not available to prisoners awarded a death sentence[11]. The Bills amends the word “martial law” to “military law” since it is not relevant to India and was an oversight when the Act was passed. The bill was passed on Mar 23, 2011, in the Rajya Sabha[12].

Difference Between Repatriation and Extradition

There is a substantial difference between them both. Extradition is a formal process by which a criminal suspect held by one government is handed over to another government for trial or, if the suspect has already been tried and found guilty, to serve his or her sentence[13], while Repatriation is to provide for the transfer of certain prisoners from an India to country or place outside India and reception in India of certain prisoners from country or place outside India. Under Repatriation, the Indian Citizen who is in foreign prison may be remitted back in India to serve the same prison sentence and conditions as set by the foreign court, but to serve the sentence in an Indian prison[14].

The Need for Repatriation of Prisoners

The need for Repatriation can be observed from the case of Mr Ismail Samma[15] a resident of Gujarat, India who was imprisoned in Karachi, Pakistan after 9 years in prison he was given up after his death and his family is unaware about his conditions and whereabouts for almost a decade. In the second case of a sick 21-year-old named Mr Jetendaera Arjanwara[16] a resident of Madhya Pradesh, India highlights the tribulations of being imprisoned in a foreign prison. Jetendaera’s case became known in May after five years of detention. They were detained well past their terms as a result of delayed consular attention and nationality verification. At many times Prisoner’s in foreign prisons are subjected to harsh imprisonment and torcher which is against Human Rights and Humanity[17]. Other factors such as Rehabilitation, Humanitarian Concerns, Cultural differences, International Cooperation, Administrative Issues, etc. are a factor.

It has been contended that convicts who serve their sentences in their native countries can be rehabilitated and reintegrated into the community better than elsewhere and distance from family may aggravate the impact of the imposed sentenced[18]. Humanitarian concerns also arise out of certain conditions of individual prisoners. For example, a prisoner may be pregnant. The transfer of prisoners highlights cooperation between two countries in the field of judicial and penal matters. Prisoner transfer agreements[19] are an important tool in fostering international relations. Transfers of prisoners reduce the cost of providing consular services to nationals imprisoned overseas. Further, it also reduces the cost of housing foreigners in national prison systems[20].

International Conventions

There are several International Conventions which govern the Repatriation of prisoners[21]:
i. International Covenant on Civil and Political Rights
Article 10 mentions that essential aim of a penitentiary system is the reformation and social rehabilitation of prisoners. Article 12 mentions the right of a prisoner to return to the home country.

ii. Vienna Convention on Consular Relations, 1963
It provides for information to consulate, consular protection and consultation upon arrest, detention and during trial in a foreign country including entitlement to travel documents.

iii. UN Model Agreement on the Transfer of Foreign Prisoners, 1985
The Agreement calls for quick promotion of social resettlement of offenders by facilitating the return of persons convicted of crime abroad to their home country to serve their sentence.

Recommendations on the Treatment of Foreign Prisoners, 1985

It made the following recommendations[22]:

• a) Equal access as national prisoners to education, work and vocational training.
• b) Eligible for alternative measures to imprisonment according to the same principles as nationals
• c) The religious precepts and customs to be respected.
• d) Informed about prison regime and regulations, in a language they understand
• e) Informed about the right to contact consular authorities
• f) Facilitate contact between foreign prisoners and their families and with humanitarian international organizations.

Application of Act
Section 3 of the RPA deals with the Applicability. The Central Government of India publishes notifications as per they inclusions or exclusions of the country. The notification has to relate to a country or place outside India with which a treaty has been entered into by India for the transfer of prisoners between that country and India. The said notification has to contain the full transcript of the said treaty and shall remain operational and effective till the end of such treaty.

Salient Features of the Act

1. The Act is significant for India which sees considerable outflow and inflow annually by blue- and white-collar workers, fishermen, students, stateless persons and other groups.
2. The act enables the transfer of foreign prisoners to the country of their origin to serve the remaining part of their sentence.
3. It also enables the transfer of prisoners of Indian origin convicted by a foreign court to serve their sentence in India.
4. Transfers take place with contracting states. The Contracting States have been enumerated in the act as the Government of any country/ place outside India with whom an arrangement to transfer prisoners from India to that country/place and vice versa through a treaty or otherwise[23]
5. India has such prisoner transfer arrangements with 43 countries.
6. The treaties are negotiated or guided by the Indian Standard Draft Agreement which is a model treaty prepared by the Ministry of Home Affairs in consultation with the Ministry of External Affairs and Ministry of Law.

Relevant terms

1. Contracting State - The term contracting state has been defined under section 2 (a) of the RPA. The term “contacting state” means the Government of any country or place outside India in respect of which arrangement has been made by the Central Government with the Government of such country or place through a treaty or otherwise for transfer of prisoners from India to such country or place and vice versa and includes any other Government of such country or place specified by the Central Government, by notification in the Official Gazette, under sub-section (1) of section 3; (b) of the RPA.
2. Prisoner- The term "prisoner" is defined as 2 (c) of the RPA. The said terms mean a person undergoing a sentence of imprisonment under an order passed by a criminal court including the courts established under the law for the time being in force in contracting States.
3. There is an additional provision under section 2 (e) of the RPA which enumerates that the words and expressions mentioned in the act if so not defined under the RPA, reliance shall be placed on the meaning of the words as defined under the Code of Criminal Procedure, 1973.

Comments of the Contracting State.
After submitting the application of the prisoner to the concerned ministry the same shall be forwarded by the Central Government through prescribed means to the Government of the contracting State as defined under section 2 (a) of the RPA to deal with such application of the prisoner along with the following information as required by section 6 of the RPA.

The application should contain the following information, namely

• (a) a copy of the judgment and a copy of the relevant provisions of the law under which the sentence has been passed against the prisoner;
• (b) nature, duration and date of commencement of the sentence of the prisoner;
• (c) medical report or any other report regarding the antecedents and character of the prisoner, where it is relevant for the disposal of his application or for deciding the nature of his confinement; and
• (d) any other information which the Central Government may consider necessary.

One such application is duly accepted by the contracting State, the Central Government may seek from such contracting State, all or any of the following information or documents before deciding to transfer the prisoner to the contracting State, namely:

• (a) a statement or document indicating that the prisoner is a citizen of the contracting State;
• (b) a copy of the relevant law of the contracting State constituting the act or omission as the offence, on account of which the sentence has been passed in India as if such act or omission was an offence under the law of that State;
• (c) a statement of the fact or any law or regulation relating to the duration and enforcement of the sentence of the prisoner in the contracting State upon his transfer;
• (d) the willingness of the contracting State to accept the transfer of the prisoner and an undertaking to administer the remaining part of the sentence of the prisoner;
• (e) an undertaking to comply with the conditions, if any, specified by the Central Government; and
• (f) any other information or document which the Central Government may consider necessary.

Such documentation is of utmost necessity for the transfer of the prisoner. However, procurement of such documents is time-consuming and adds considerable delay for the said transfer of the prisoner. Compliance and procurement of such documents is crucial for issuance of warrant of transfer.

Warrant for Transfer

Under the section 8 of the said Act the Central Government authorizes an officer not below the rank of a Joint Secretary to a State Government, within the limits of whose jurisdiction the place of imprisonment of the prisoner is situated, to issue a warrant on behalf of the Central Government under sub-section (1) of section 7 directing the officer in charge of the prison therein to deliver the custody of the prisoner to the person authorised by the contracting State to which the prisoner is to be transferred, presenting such person a copy of the warrant together with all the records relating to the prisoner and the personal effects taken from the prisoner at the time of his admission in the prison.

Under subsection (2) of the proviso once such presentation of a warrant referred to in sub-section (1), the officer in charge of the prison shall forthwith comply with the warrant and obtain thereon the signature of the person to whom delivery of the prisoner, records and the personal effects relating to the prisoner to be removed from the prison is given.

The section under subsection (3) further goes to enumerate the procedure that after delivery of the prisoner to the person authorised by the contracting State, the officer in charge of the prison transferring the prisoner shall forward a copy of the warrant to the court which committed the prisoner to the prison, along with a statement that the prisoner has been delivered to the person authorised by the contracting State.

Operation of a warrant and retaking prisoner

As per section 9 of the RPA it is lawful for the person authorised by the contracting State to whom the custody of a prisoner is delivered under the provisions of sub-section (2) of section 8 to receive and hold in custody such prisoner and to convey him out of India and if the prisoner escapes from such custody within India, the prisoner may be arrested without warrant by any person who shall without undue delay deliver such prisoner to the officer in charge of the nearest police station.

Such prisoner so arrested shall be made liable for committing an offence under section 224 of the Indian Penal Code (45 of 1860) and shall also be liable for such sentence of imprisonment in India which he would have to undergo if the delivery of custody of such prisoner had not been made under section 8.

Determination of prison and issue of a warrant for receiving the transfer in India

As per section 10 of the RPA, the central government has description to determine the prison situated within the jurisdiction of such State Government where the prisoner with respect to whom a warrant has been issued under sub-section (2) of section 12, shall be lodged and the officer who shall receive and hold him in custody.

Under subsection (2), the Central Government authorizes any officer not below the rank of a Joint Secretary to that Government to issue a warrant under subsection (2) of section 12 and to direct the officer referred to in sub-section (1) to receive and hold the prisoner, with respect to whom the warrant is issued, in custody.

Under subsection (3) of the said act, It shall be lawful for the officer referred to in sub-section (1) to receive and hold in custody any prisoner delivered to him under the direction made in the warrant issued under sub-section (2) of section12 and to convey such prisoner to any prison determined under sub-section (1) for being dealt with in accordance with the said warrant and if the prisoner escapes from such custody, the prisoner may be arrested without warrant by any person who shall without undue delay deliver such prisoner to the 5 officer-in-charge of the nearest police station and the prisoner so arrested shall be liable for committing an offence under section 224 of the Indian Penal Code (45 of 1860) and shall also be liable to be dealt with in accordance with the said warrant.

Further under subsection (4) of the act a warrant under subsection (2) of section 12 shall provide for- (a) the bringing of the prisoner into India from a contracting State or a place outside India;
(b) the taking of such prisoner in any part of India is a place at which effect may be given to the provisions contained in the warrant;
(c) the nature and duration of imprisonment of the prisoner in accordance with the terms and conditions referred to in sub-section (1) of section 12 and the imprisonment of such prisoner in India in such manner as may be contained in the warrant; and
(d) any other matter which may be prescribed.

One of the important provisions under the act being the non-obstante clause enumerates that if the sentence of imprisonment passed against the prisoner in the contracting State is incompatible with the Indian law as to its nature, duration or both, the Central Government may, by order, adapt the sentence of such punishment as to the nature, duration or both, as the case may be, as is compatible to the sentence of imprisonment provided for a similar offence had that offence been committed in India.

At times a prisoner may be convicted of a particular offence in a contracting state but such an act may not be an offence in India. Thus the sentence has to be adapted. However in order that such adaptation is not seen as a means to reduce sentence or modify sentence into a less effective or aggravated form the section has inserted a safeguard that that the sentence so adapted shall, as far as possible, correspond with the sentence imposed by the judgment of the contracting State to the prisoner and such adapted sentence shall not aggravate the punishment, by its nature, duration or both in relating to the sentence imposed in the contracting State.

Transfer of record & Proceedings
One of the important provisions governing transfers is handing over record and proceedings of the prisoners. The same is enumerated under section 10 of RPA, where a prisoner is or is to be transferred to a contracting State under the provisions of this Act, the Central Government may requisition the records of any proceeding, including judicial proceedings relating to that prisoner from any court or office, and may direct that such records shall be sent to the Government of the contracting State.

Consideration of a request by Central Government
As per section 5 of the RPA on receipt of the application under section 4, the Central Government shall direct the officer in charge of the prison, where the prisoner is confined, to furnish such information which in the opinion of that Government is relevant for the transfer.

The central government will have to be satisfied with the following conditions not limited to:

• (a) No inquiry, trial or any other proceeding is pending against the prisoner;
• (b) The death penalty has not been awarded to the prisoner;
• (c) The prisoner has not been convicted for an offence under the 1 [military law]; and
• (d) Transfer of custody of the prisoner to the contracting State shall not be prejudicial to the sovereignty, security or any other interest of India, it shall pass an order for forwarding the application of the prisoner to the contracting State.

Further consideration of cases of transfer of prisoners involves verification steps like nationality verification, security clearance, views of Narcotic Control Bureau, if drug trafficking is involved, identification of prison by the State/Union Territory Government, completion of documents process by the India/foreign Mission concerned and consent of the transferring/receiving Governments. Time taken to process an application for transfer depends on the completion of necessary formalities and documents by the concerned agencies and State/ Union Territory Governments.

Process of Prisoner of Indian nationality convicted by Foreign Court

The procedure followed for the process of Repatriation differs with the country.

1. Firstly, Under the Act, the request for transfer is to be made by the convicted prisoner on grounds of age or physical or mental condition and such request is to be granted only when the receiving and transferring State agree. The remitting country has to verify the identity, Nationality and the offence committed and if the same is punishable in the host country. This process is undertaken by the state and centre jointly in cooperation with the Investigation authorities.
   
2. Secondly, the sentence adaptability as per Indian laws has to be decided. This is undertaken by the central government under the RPA and MHA[24] guidelines. In some cases, the particular action may be offences in foreign countries but may not be offences in India, at such there cannot be repatriation. There could also be differences in sentencing which may cause hindrances. The courts intervene in cases of adaptability of sentences and other petitions[25].
   
3. Thirdly, the central government has to coordinate with the foreign country and other authorities within India and outside the country.
   
4. Lastly, monitoring and other procedure as prescribed by the treaty and other central government notifications.

Repatriation, however, cannot be made if the transferring State opines that the request would prejudice its sovereignty, security, national interest, and if the convict is convicted under the military law of the transferring State and the death penalty has been awarded to the convicted person in the transferring State[26].

Obstruction in Repatriation

As identified by the Roundtable Discussion on Repatriation of Indian Nationals in Foreign Prisons held on 13th July 2017[27] the act faces from certain disabilities which hinder the execution of the act. These disabilities are necessarily not negative as in certain situations are beneficial for the effective administration of justice.

1. Eligibility Criteria
   Habitual offenders and repeat offenders are restricted from repatriation through Act specify that all Indian nationals are eligible. The Act does not enumerate specifically on the eligibility of those whose sentence is not adaptable.
   
2. Applications
   Frequently Applications incompletely reach the government and long-time is taken for them to reach valid application status as the specification documents are not uniform and correspondence time between government and Indian Missions or foreign country gets protracted. The government will look at an application only when it is complete. Therefore, it is important to shorten the pre-application time.
   
3. Early release and remission
   The government’s commitment to parole-remission and life-sentence laws are not articulated. This leads to an environment of queries and prolonged correspondence as seen in case details. This information can incentivize quick decision/consent from the prisoner and reduce lengthy paper chain.
   
4. Verification
   The government usually takes more time (almost a month) than specified in the Guidelines (10 days) for cases where nationality cannot be verified through the Passport Portal and has to be conducted through the Nationality Verification Portal, Regional Passport Office and the physical verification by state/district police. Nationality verification would have to be completed and national identity confirmed before the Ministry of Home Affairs considers it. It is observed that the Guidelines issued by the Ministry of Home Affairs are misleading in pointing out that after the application is received by the Ministry of Home Affairs nationality verification begins.
   
5. Sentence adaptation
   No scope for appeal against adapted sentence as a result of which prisoners have gone to court in cases of aggravation of sentence; and no procedures or SOP to guide stakeholders in sentence adaptation.
   
6. Constraints of Indian High Commissions
   The Precedents reveal that Indian High Commission in Sri Lanka was most aware of the funds and facilities they could make available to prisoners and made weekly visits, had awareness literature to reach out to prisoners, followed by Mauritius. Indian High Commission in the UK was least aware. IHCs of UK and Canada were obstructed by the privacy laws of the respective countries where they functioned. The problem of privacy laws has been cited in court and Parliament since 2010 as a barrier before the Indian Missions but no strategy has been evolved by the government to ensure the ease of access and information to prisoners.
   
7. Monitoring Committee
   The committee as understated in the Guidelines of Ministry has not been meeting as there are no records available. This affects overall supervision. It has recently been revived by the Joint Secretary with the assurance that minutes of meetings will be maintained so that in future it is available for the public.
   
8. Real Pendency
   It is a false divide to think that people do not want to come from prisons of advanced countries and those who are interested in transfer to India are in worse prisons. The reality of case details from these countries reveals that applications supported by numerous affidavits get delayed by our process here. In some cases, it has taken more than 4 years to get to the stage of the no Objection Certificate from the state. Though we may not be able to discern where exactly the delay was caused, it is clear that there has been a delay.
   
9. Unavailability of Data
   Since repatriation data is not a priority data set that is being gathered by the National Crime Records Bureau, this is not available or easily accessible from the states and can take months to gather as compared to state-level data on custodial deaths where jail wise and type of death wise disaggregated data can be made available in a matter of hours.
   
10. Transfer Costs
    The Ministry has some earmarked funds for transfer so this may not be a barrier to transfers. This is going under-utilized. More importantly, there are funds at the disposal of Indian Missions through the ICWF and this too is going under-utilized. With a more targeted approach of the Indian Missions to reach Indian prisoners and inform them, funds could be better utilized.

Conclusion
The RPA has indeed been a solution to an existing issue. Although lingering problems in execution are yet to be addressed by the Government. Notably, India has taken concrete steps for reciprocal transfers under the RPA by developing a Standard Draft Agreement or SDA, signing 30 bilateral transfer agreements and entering into transfer arrangements with signatories of the Inter-American Convention on Serving Criminal Sentences Abroad and the Council of Europe’s Convention on the Transfer of Sentenced Persons. This brings at least 50 more countries into a co-operative administration of justice framework.

However, despite the efforts of the Indian Government, there were only nine foreign prisoners repatriated from India in 2015, six from the United Kingdom and one each from France, Germany and the UAE. Between 2003 and 2018, only 63 of 171 prisoner applicants abroad have been transferred to India[28].

In many cases due to strong privacy laws prevailing in many countries, the local authorities do not share information on prisoners unless the person concerned consents to the disclosure of such information. Even countries which share information, do not generally provide detailed information about the Indians who have been imprisoned.

Effecting successful transfers under the RPA is beneficial to India and foreign Countries as it need not spend unduly on the housing of foreign national prisoners. It can also save the cost of providing frequent consular services abroad by bringing back Indian prisoners. Thus, the RPA has miles to go in terms of execution for its successful implementation.

End-Notes
[1] United States of America, Former Representative.
[2]Merriam-Webster, (Sept. 14, 2019, 09:00 AM), https://www.merriam-webster.com/dictionary/repatriation.
[3]Black's Law Dictionary: 2nd Edition, (Sept. 14, 2019, 09:00 AM), https://openjurist.org/law-dictionary/repatriation.
[4]UN. General Assembly, Res. 2200A (XXI),(16/12/1966), (Sept. 14, 2019, 09:00 AM), https://www.ohchr.org/en/professionalinterest/pages/ccpr.aspx.
[5]The Vienna Convention on Consular Relations, 1963, Article 36.
[6]UN. A/CONF.121/10, Model Agreement on the Transfer of Foreign Prisoners and Recommendations for the Treatment of Foreign Prisoners, (25/4/1985), (Sept. 14, 2019, 09:00 AM), https://digitallibrary.un.org/record/97152.
[7]UN. General Assembly, Res. A/RES/55/25, (15/11/2000), (Sept. 14, 2019, 09:00 AM) https://www.un.org/en/development/desa/population/migration/generalassembly/docs/globalcompact/A_RES_55_25.pdf).
[8]Rrevised Manuals on the Model Treaty on Extradition and on the Model Treaty on Mutual Assistance in Criminal Matters, (The Manuals on the Model Treaties on Extradition and Mutual Assistance in Criminal Matters were reviewed in an Intergovernmental Expert Group Meeting, organized by the United Nations Office on Drugs and Crime (UNODC), in cooperation with the International Association of Penal Law (AIDP), the International Institute of Higher Studies in Criminal Sciences (ISISC) and the Monitoring Centre on Organized Crime (OPCO), and hosted by ISISC in Siracusa, Italy, from 6 to 8 December 2002. The new versions were further updated to include more comprehensive references to the United Nations Convention against Transnational Organized Crime and the United Nations Convention against Corruption).
[9]The Repatriation of Prisoners Act, 2003.
[10]Ministry of External Affairs Government of India, (Sept. 14, 2019, 09:00 AM), https://www.mea.gov.in/Images/pdf1/TSP.pdf.
[11]Ministry of External Affairs Government of India, (Sept. 14, 2019, 09:00 AM , https://www.mea.gov.in/indians-imprisoned-abroad.htm.
[12]PRS Legislative Research, https://www.prsindia.org/billtrack/the-repatriation-of-prisoners-amendment-bill-2010-1240.
[13] Centre for Immigration studies, (Sept. 14, 2019, 09:00 AM), https://cis.org/Cadman/Interesting-Case-Illuminates-Difference-Between-Extradition-and-Deportation-and-Complexity.
[14] Mr Prem Kishore Raj vs The Department Of Home, Cr/WP/2428.
[15] India Today, (Sept. 14, 2019, 09:00 AM), Https://Www.Indiatoday.In/Pti-Feed/Story/Nationality-Not-Verified-By-Mha-Guj-Man-Still-In-Pak-Jail-1129855-2018-01-08.
[16] The Hindu, (Sept. 14, 2019, 09:00 AM ), Https://Www.Thehindu.Com/Opinion/Op-Ed/Coming-Home-To-Jail/Article24414332.Ece.
[17] A Pocketbook of International Human Rights Standards for Prison Officials, United Nations.
New York and Geneva, 2005,(Sept. 14, 2019, 09:00 AM), https://www.ohchr.org/documents/publications/training11add3en.pdf.
[18] Joe Russo, George B. Drake, John S. Shaffer, Brian A. Jackson, Envisioning an Alternative Future for the Corrections Sector Within the U.S. Criminal Justice System, November 2017.
[19]Ministry for External Affairs Government of India, Bilateral Agreements, (Sept. 14, 2019, 09:00 AM), http://mea.gov.in/Images/pdf1/TSP_Final_List.pdf.
[20] British Embassy at Rome Report; British Consulate-General, Milan, May 2019.
[21] Repatriation of prisoners Act, 2003: An Analysis, ForumIAS, (Sept. 14, 2019, 09:00 AM )https://blog.forumias.com/article/repatriation-of-prisoners-act-2003-an-analysis.
[22] Model agreement on the transfer of foreign prisoners and recommendations for the treatment of foreign prisoners, Model Agreement on the Transfer of Foreign Prisoners (1985), Vienna, April 25, UN Document A/CONF/121/10, (Sept. 14, 2019, 09:00 AM ), https://digitallibrary.un.org/record/97152.
[23]Ministry of External Affairs Government of India, (Sept. 14, 2019, 09:00 AM ), Https://Www.Mea.Gov.In/Indians-Imprisoned-Abroad.Htm.
[24] Ministry of Home Affairs of India.
[25]Shodganga,(Sept.14, 2019, 09:00 AM), http://shodhganga.inflibnet.ac.in/jspui/bitstream/10603/20871/13/13_chapter-08-foreighners.pdf.
[26] Supra 15.
[27] Roundtable Discussion on Repatriation of Indian Nationals in Foreign Prisons, Commonwealth human rights initiative (CHRI) & institute of correctional Administration (ICA), 13th July 2017 , Chandigarh, (Sept. 14, 2019, 09:00 am) http://www.humanrightsinitiative.org/download/1503481373Repatriation%20of%20Indian%20Nationals%20in%20Foreign%20Prisons-Minutes%20and%20Actionable%20Points.pdf .
[28] Coming home to jail: on the Repatriation of Prisoners Act, 2003, The Hindu, (Sept. 14, 2019, 09:00 AM), https://www.thehindu.com/opinion/op-ed/coming-home-to-jail/article24414332.ece.