Introductory Remarks
A witness is an individual who has actually witnessed an event. The event could be a wrongdoing or a mishap or anything. Sections 118 -134 of the Indian Evidence Act, 1872 discussions about who can affirm as a witness, how might one affirm, what statements will be considered as declaration, etc. Section 119 of the Act says that an individual who can't convey verbally can affirm by method of composing or signs. An individual who has taken a vow of quiet and can't talk because of that vow will fall under this classification with the end goal of this Section.

On account of Chander Singh v. State, the High Court of Delhi observed that the vocabulary of a tragically challenged witness might be very restricted and due consideration must be taken when such witness is under questioning. Previously, it was viewed as that not too sharp individuals were imbeciles and bumbling to comprehend and give level-headed answers. Yet, presently, because of logical advancement, it has been proved that these individuals are unmistakably more astute than others and may comprehend the idea of the vow.

The vow can be directed to them and their evidence can be taken with the assistance of a mediator by methods for hard of hearing and unable to speak letters in order/gesture-based communication or outward appearances, hand motions and so forth or if the individual is proficient, he can be given the rundown of inquiries and he can compose the appropriate responses thereto.

However, these evidences would be allowable just when both the witness and the mediator are directed the pledge and communication through signing utilized by the individual unfit to convey verbally and the understanding thereof by the translator are video graphed. Such witnesses will be unable to clarify every little detail and answer every inquiry in detail utilizing the communication via gestures, however this constraint of vocabulary doesn't in any capacity imply that the individual is any less skilled to be a witness. An absence of vocabulary doesn't influence her skill or validity in any capacity.

A detailed insight into the Indian Legislative Position The Indian Legal System has an exceptional personality in the worldwide law for its allpervasive and fusing nature. It has made complex provisions for providing equivalent, nay fair chances to all the individuals irrespective of their physical and emotional wellness and status. It is generally acknowledged and esteemed view that a witness assumes the most vital function in the organization of criminal equity framework.

The version recorded from a witness either encourages a denounced to prove his guiltlessness or helps arraignment to set up its grounds and contentions against the blamed in a more exact way with the norm past the span of any sensible uncertainty. It is often observed that a portion of the witnesses face physical impedance to communicate the occurrences or events witnessed by them.

They will be unable to give their versions in verbal statements. However, this explanation ought to never be a hindrance for depending upon the evidence of such witnesses. Legal provisions and legal professions have set down just as at multiple times repeated the methodology which ought to be followed while looking at and gathering statements from such witnesses.

The dumb witness is one who can't talk because of physical deformation. Section 119 applies just to those situations when the witness is hard of hearing and quiet or an individual who has taken a strict van of quietness. In the event of such witness the evidence might be taken by methods for composed inquiries answers procedures or by recording signs. The evidence given 8 will be considered to be oral evidence.

"The gathering of the evidence of such individual lays on the ground of convenience." Section 119 of the Indian Evidence Act, 1872 speaks, "A witness who can't talk may give his evidence in some other way where he can make it comprehensible, as by composing or by signs; yet such composing must be composed and signs made in open Court, evidence so given will be considered as oral evidence. Provided that if the witness can't convey verbally, the Court will take the help of a mediator or an extraordinary teacher in recording the statement, and such statement will be video diagramed."

From the aforementioned provision, it becomes clear that the lawful conditions have been made conducive to grasp all the witnesses. By all accounts, the content of the law doesn't make any 'capable ist' assumption in tending to the subject of who can give evidence in a court and in what way. In fact, there is an acknowledgment that a few people will be unable to affirm verbally.

The attestation of distinction in this provision however coincides with a call to fair-mindedness in overseeing this provision. Despite the fact that this Section doesn't allude to translators or gesture based communication specialists, all reading material of evidence law underline that the assistance of communication via gestures specialists must be looked for in such cases.1 Additionally, legal choices deciphering this provision have held that while recording tribute evidence with the assistance of mediators, the preliminary court should record both the signs/motions made by the witness and their understandings as conveyed by the mediator so the re-appraising courts have the chance to review the same.

2 This delineates the point made by Young, that 'distinction' consistently represents a danger to 'unprejudiced nature'. Consequently any move to oblige contrast must be joined by satisfactory protections. The pickle made by obliging contrast while demanding fair-mindedness is additionally delineated by the accentuation on 'comprehensibility' in this Section. As Section 119 states, to be considered valid evidence, non verbal declaration must be introduced in 'some other way where he can make it coherent'.

The 'unique' method of correspondence of the incapacitated witness is obliged in the lawful cycle, yet depending on the prerequisite that it is 'understandable' to the ablebodied crowd in the court. Additionally it should be noticed that the duty is on the debilitated witness to 'make it' clear. I allude to this problem as the 'weight of understandability'. However, evidentiary value of 1 Kannabiran, Kalpana (2002). Ravished justice: Rape.

In Kalpana Kannabiran & Vasanth Kannabiran (Eds), De-eroticising assault: Essays on modesty, honour and power (pp. 104�169). Kolkata: Stree. 2 Patrick Devlin, The Judge (OUP 1979) 54. 9 declaration doesn't rely upon its incorporation in the proper guidelines of suitability alone. Notwithstanding these principles which have been examined, there are rules engraved in legal practices and conventions that are conveyed to decide the 'nature' of the evidence created through declaration.

Even if the standards of suitability permit certain accounts to be told in the court and introduced as evidence on the side of one's case, if these accounts are paid attention to relies upon these last guidelines. These casual guidelines draw heavily on the prevalent social characterisations of the individual affirming. At the point when judges demand supporting evidence to certify the declaration of the prosecutrix in assault preliminaries, they often depend on the socially far reaching conviction that ladies are inclined to lying.

Factors, for example, inability to raise alert, inability to report the episode instantly or nonattendance of wounds on the body of the prosecutrix or the denounced are utilized to deduce assent with respect to the prosecutrix. Thusly, these factors or the discoveries of clinical assessment are concurred more noteworthy evidentiary value than the declaration of the prosecutrix herself. In spite of what the Evidence Act says, patterns in legal choices reveal that the very presence of inability drives judges to assume that a witness is unequipped for affirming.

As the decisions examined in the following section of this article show, running under the outside of legal practicality is the assumption that handicap, irrespective of nature or degree, suggests inadequacy to understand and respond to the inquiries presented, and henceforth failure to completely take an interest in the legitimate cycle.

The declaration of the crippled witness is limited in light of the assumed inadequacy of the handicapped to 'freely' observe, recall and portray the experience to which he/she is affirming. Moreover, on account of the impaired witness, both the witness and the structure wherein the declaration is introduced (non-verbal, through signs or signals) are tried contrary to the guidelines surveying the 'nature' of evidence.2 The court while recording the evidence of dumb witness, must record the two signs just as the understandings of the translator and afterward just it gets allowable under the Indian Evidence Act. 2 Mahoney, Martha (1991). Legal images of battered women: Redefining the issue of separation. Michigan Law Review, 90(1), 194. 10 Precedential Mandates and Procedures to be followed in extraction of such evidences.

In M.P. Sharma and Others v. Satish Chandra, District Magistrate, Delhi and Others3 , the Hon'ble Supreme Court was of the view that an individual can be a witness not just by giving oral evidence yet in addition by creating records or making clear signals as on account of a dumb witness or like. The object of enacting the provisions of Section 119 of the Evidence Act reveals that tragically challenged people were before considered in law as blockheads.

However, such a view has in this manner been changed for the explanation that cutting edge science revealed that people influenced with such disasters are commonly discovered more clever, and to be powerless to far higher culture than used to be once supposed.4 At the point when a hard of hearing or quiet individual is created as a witness, the Court, in the activity of due alert would positively discover with regards to whether the individual has the base level of insight to comprehend the significance and nature of the pledge.

At the point when the Judge is fulfilled on the above models, he may allow the witness to make vow and give his evidence by methods for composing. In the event that he can't peruse or compose, he may take the assistance of a mediator and express his version through sign languages. 5 In Public Prosecutor, High Court of Andhra Pradesh, Hyderabad v. Lingisetty Sreenu, the Andhra Pradesh High Court believed that so as to comprehend and welcome the evidence of such witnesses communicating their thoughts with the assistance of signs, it ought to essentially look for the help of a specialist in order to securely depend on such evidence. It is to be noticed that the prerequisite under Section 118 of the Evidence Act must be satisfied or at the end of the day, the witness must be equipped to comprehend the inquiries put to him and ought to have the option to give sane responses to them. On the off chance that he can't comprehend the inquiries or to make his significance clear, he can't be inspected as a witness.6

In State of Rajasthan v. Darshan Singh @ Darshan Lal7 , it was observed that "a tragically challenged individual is a skillful witness. On the off chance that in the assessment of the Court, pledge can be controlled to him/her, it ought to be finished.

Such a witness, if ready to peruse 3 M.P. Sharma and Others v. Satish Chandra, District Magistrate, Delhi and Others, AIR 1954 SC 300. 4 State of Rajasthan v. Darshan Singh @ Darshan Lal, Criminal Appeal No. 870 of 2007. 5 World Health Organisation, International Classification of Functioning, Disability and Health, res 54.21 (2001). 6 Venkattan v. E., 14 IC 655: 13 Cr LJ 271. 7 State of Rajasthan v. Darshan Singh @ Darshan Lal, 2012 AIR SCW (S.C.) 3036. 11 and compose, it is alluring to record his statement giving him inquiries recorded as a hard copy and looking for answers recorded as a hard copy. In the event that the witness can't peruse and compose, his statement can be recorded in gesture based communication with the guide of translator, whenever discovered vital. In the event that the translator is provided, he ought to be an individual of a similar encompassing however ought not have any enthusiasm for the case and he ought to be directed promise." The Court must follow the orders of Sections 4 and 5 of the Oaths Act, 1969, i.e., vow or confirmation to be made by the witnesses, mediators and hearers.

On the off chance that the evidence is recorded with assistance of a mediator, there must be a record/video of signs just as the translation of signs.8 Evidentiary Value of such Evidences To evaluate the evidentiary relevance and tolerability of such versions, we should have a look towards the observations of Hon'ble Supreme Court in various occasions where evidence given by people unfit to talk was taken up for legal thought. In Meesala Ramakrishnan v. State of Andhra Pradesh9 , the Hon'ble Apex Court held that perishing revelation recorded by methods for signs and gestures of an individual who isn't in a situation to represent any explanation adds up to a verbal statement and hence, is relevant and permissible.

The Court emphasized that 'verbal' statement doesn't add up to 'oral statement'. Section 119 of the Evidence Act necessitates that witness may give his/her evidence in any way where he can make it clear, as by composing or by signs and such evidence can be considered to be oral evidence inside the significance of Section 3 of the Evidence Act. Signs and signals made by gestures or head are permissible and have evidentiary value. Subsequently, the evidence given by such people are entirely valid and allowable according to law. Communication and Verbally incapable witnesses: Resolving the Paradox The effectiveness and responsiveness of the public arraignments framework pivots upon vulnerable voices being heard and being paid attention to. The inquiry at that point emerges as 8 Baneshwar Marandi @ Boneshwar Marandi @ Bhuneshwar Marandi v. The State of Jharkhand, Bail Application No. 6591 of 2017. 9 Meesala Ramakrishnan v. State of Andhra Pradesh, (1994) 4 SCC 182. 12 to with regards to how 'the best evidence' of such witnesses can be best encouraged. Evidently, non-verbal victims face a novel test in such manner since they don't communicate verbally.

One potential component that may enable witnesses to interact all the more effectively with the criminal equity framework is Augmentative and Alternative Communication (AAC). AAC alludes to a blossoming territory of instructive and clinical practice which intends to provide a scope of communication techniques to enhance or supplant an individual's normal discourse, which is commonly recognized to have developed as perceived professional specialization in the 1980s.10

Three of the most widely recognized strategies for communication uphold which fall inside the umbrella term AAC incorporate discourse creating devices or SGDs (otherwise called Voice Output Communication Aids or VOCAs) which might be worked by hand or through eye-stare acknowledgment innovation; the utilization of image/picture cards; and the utilization of streamlined manual marking frameworks intended for individuals with learning handicaps, for example, Makaton which draw upon the vocabulary of marked dialects, for example, British Sign Language yet which have essentially less linguistic complexity. 11

However, a rich diversity of different techniques likewise exist including the utilization of composing, drawing, the utilization of artifacts, for example, dolls to re-enact situations; and any methodology which expects to encourage communication by enhancing or supplanting regular discourse with alternative mediums might be said to comprise a type of AAC.

FC is a controversial method which involves a facilitator supporting an individual to illuminate messages on an alphabetic console. This is combined with verbal prompts and good help; often creating surprising results of familiar, profoundly educated communication where communication capacity of this level had not been evidenced previously.

FC has a controversial history in the courtroom, having been embroiled in various examples of sexual maltreatment claims which were accordingly discovered to be false, with initiation suspected to lie with the facilitator.12 FC isn't acknowledged as a genuine AAC intervention by the International Society for Augmentative and Alternative Communication,14 and its alarming courtroom history makes 10 Joyce Plotnikoff and Richard Woolfson, Intermediaries in the Criminal Justice System (Policy Press 2015). 11 R v. Watts, [2010] EWCA Crim 1924. 12 Young, Iris Marion (1990).

The ideal of impartiality and civic public. In I.M. Young (Ed.), Justice and the politics of difference (pp. 96-120). New Jersey: Princeton University Press. 14 Supra Note 11. 13 it deserving of notice for two reasons: initially, to bring issues to light of the likelihood that jury impression of AAC-interceded evidence all the more by and large might be undermined by the historical backdrop of FC specifically; and also to feature the requirement for additional unloading of the various elements of help offered by mediators (social, enthusiastic, hierarchical, communicative, physical) and the ramifications of these for perceived validity and creation. These inquiries are examined further beneath.

The innovations sketched out above have without a doubt engaged voices that have a distant memory unheard in a scope of social settings. While the utilization of these advances is relatively novel inside criminal equity, and there are barely any detailed cases on their utilization in legitimate settings13, there is a developing assortment of evidence that such aids are turning out to be significantly more commonplace.14 The evidence accumulated inside other social settings recommends that, if appropriately utilized, AAC holds the possibility to enable non-verbal victims through decreasing levels of pressure and encouraging them to give best evidence.

A court may arrange that a qualified witness might be inspected through an autonomous mediator so as to impart questions put to the witness, and to any people posing such inquiries, the appropriate responses given by the witness in answer to them, and to clarify such inquiries or answers so far as important to enabled them to be perceived by the witness or individual being referred to. Designed to help witnesses with severe communication challenges, go betweens were first steered in 2004, preceding an eliminated public roll started in 2008.

The plan has since had a huge effect on admittance to equity in cases which could never have previously gone to trial.15 Conventionally, a non-verbal victim ought to be distinguished at a beginning phase in the investigative process, and at this stage the Achieving Best Evidence measure is triggered.

The police and other criminal equity organizations ought to stick to best practice rules set down in regard of interviewing and addressing procedures to guarantee that vulnerable witnesses are engaged to give their best evidence. An enrolled go-between, chose from a scope of professionals with various abilities sets, will at that point be coordinated with the witness by 13 Supra Note 12 14 Nedelsky, Jennifer (1997). Embodied diversity and the challenges to law. McGill Law Journal, 42(1), 91-117. 15 Id. 14 the National Crime Agency to evaluate the witness and make suggestions to various criminal equity staff, (for example, cops, advocates, judges and magistrates, Witness Service and court faculty) regarding how the witness ought to be questioned.16

The underlying appraisal of a non-verbal victim by a delegate should investigate the communicative limits of the individual concerned. This cycle would thus be able to be utilized to distinguish clients of AAC; the kind of AAC innovation depended upon, and the understanding, familiarity and aptitude level of the client.
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This varies extensively from individual to individual. In spite of the fact that ABE interviews by and large spot accentuation on the requirement with the expectation of complimentary narrative, witnesses with learning challenges may often require more organized and shut inquiries the same number of are hesitant to react to open invitations.

These suggestions will at that point be imparted to criminal equity professionals to illuminate dynamic about whether, and if so how, the investigation ought to continue and a preliminary ought to be held. Where a case continues to preliminary, mediators will often go to an acclimation visit with the witness and sit with the witness all through procedures. They are required to screen addressing and miscommunication may or is probably going to have happened (however their essential obligation is to the court).17

Evidently, this speaks to an extreme takeoff from the model adversarial duel and vigorous and enraptured mediators since they were first proposed by the Pigot Committee in quite a while have been communicated that the separating of addressing could bring about the loss of importance, sound and accentuation prompting inquiries with respect to how effective a safeguard the denounced can mount in these circumstances. It additionally speaks to a danger to the longstanding rule of gathering control of evidence,18 and whether they are adequately prepared to distinguish and protest unseemly lines of questioning. 16 Ministry of Justice,

Achieving Best Evidence in Criminal Proceedings (Ministry of Justice 2011). 17 R v. Cox, [2012] 2 Cr App R 6, [28]. 18 Laura Hoyano, Reforming the Adversarial Trial for Vulnerable Witnesses and Defendants (2015) Crim LR 105. 15 Aids to communication under English Law: A source of inspiration for Indian Legislators The utilization of a mediator alone is probably not going to encourage the evidence of nonverbal witnesses. Also, such witnesses are probably going to require the help of some type of AAC to communicate.

The court may coordinate that a witness is allowed to utilize help improve communication based on the individual needs of the witness. Aids to communication may accordingly improve the nature of evidence, yet may likewise decrease feelings of anxiety of the user.

Oddly, no meaning of what may establish such a guide is provided in the enactment itself; anything regarded fitting to the court is reasonable albeit both the Equal Treatment Bench Book and the Criminal Procedure Rules 2015 allude to a variety of apparatuses, for example, pictures, plans, images, dolls, figures, models, body maps and comparative aids.19 On a practical level however, concerns have been communicated that advocates and judges, specifically, are new to the scope of aids available and their capability to enable witnesses who need verbal aptitudes.

There are some positive signs, however, that levels of understanding are improving. Aids in the Criminal Justice System, is one of only a handful scarcely any types of legal direction that make express reference to the utilization of innovative and low-tech types of AAC delineated above. 20 Toolkit 14, notwithstanding providing a clear and educated diagram regarding huge numbers of the types of AAC, underscores the significance of the function of the mediator in evaluating the verbal impediments or eccentric discourse examples of a learning handicapped witness and suggests a blend of instruments and methodologies that may best encourage the evidence of an individual witness.

The YJCEA has made a structure whereby evidence is considerably more liable to be received from non-verbal witnesses providing the competency test is met. However notwithstanding the presentation of exceptional measures and more prominent quantities of witnesses with communication troubles currently being regarded equipped to affirm, utilized every day by 19 Kapur, Ratna, & Cossman, Brenda (1996). Subversive sites: Feminist engagement with law in India.

New Delhi: SAGE. 20 Kirsten Hanna and others, Child Witnesses in the New Zealand Criminal Courts: a Review of Practice and Implications for Policy (NZ Law Foundation 2010). 23 YJCEA 1999, ss. 16(5) and 19(2). 16 safeguard legal advisors in a scope of settings have gotten away from assessment. The onus at that point falls on the preliminary adjudicator to militate against such tactics.23 Analyzing Chander Singh v. State:
 An overlook of the latest Indian Position Discarding an allure where the appealing party was convicted for the offense under Section 9(k) of the Protection of Childen from Sexual Offenses Act, 2012 for aggravated rape of a not too sharp minor, and granted thorough detainment for a very long time with fine of Rs 5000, the Bench of Mukta Gupta, J. held that however accused of a significant offense a blamed can be convicted for a minor offense, however, the vice-versa is impermissible.

In spite of the fact that the litigant was charged under Section 7 of the POCSO Act for rape culpable under Section 8 wherein the base discipline is 3 years stretching out to 5 years with fine, he was convicted under Section 9(k) for aggravated rape. The appealing party had placated that since the prosecutrix, who was tragically challenged, couldn't be interrogated, her declaration can't be perused in evidence and even if the offense is proved against the litigant, the equivalent would fall under Section 7 culpable under Section 8 and not under Section 9(k) culpable under Section 10 of the POCSO Act.

Relying on State of Rajasthan v. Darshan Singh 21, the Court stated that Section 119 of the Evidence Act provides that a witness who can't talk may give his evidence in some other way where he can make it coherent, the Court observed that the prosecutrix had clarified the occurrence through her drawings and through signals to her mom with the end goal of interrogation. The Court observed that the motivation behind interrogation is to learn reality corresponding to the allegation leveled against an acused and circumspection vests in the court to control the questioning. A gathering interrogating an almost totally senseless witness like some other witness is needed to act inside the limits of law and can't be allowed to interview the witness one and all on irrelevant inquiries. It is the obligation of a Judge to control the interrogation to prevent any maltreatment and to shield a witness from being unjustifiably managed. Sections 149 to 152 of the Evidence Act denied inquiries without sensible grounds 21 State of Rajasthan v. Darshan Singh, (2012) 5 SCC 789. 17 and Section 138 provides that questioning need not be restricted to the facts to which the witness affirmed in his assessment in-boss.

The Court observed that "When an almost totally senseless witness is under questioning, the Court is needed to take due consideration of the fact that vocabulary of such an individual is restricted as the person communicates in through gesture based communication and it may not be workable for that witness to reply, or in detail clarify every answer by gesture based communication. This incapacity of a restricted vocabulary of communication via gestures doesn't influence either the skill or the believability of such witness. The Court is needed to practice power over the interrogation keeping in view the capacity of the witness to address the inquiries." Concerning the idea of the offense, the Court observed that in the facts of the case it isn't needed to go into if aggravated rape is made out from the evidence on record, for the explanation there was no charge for aggravated rape outlined against the litigant. It is prosaic law that however accused of a significant offense a charged can be convicted for a minor offense, however the vice-versa is impermissible, which has been finished by the preliminary court.

Observing that the direct of the appealing party in explicitly attacking a not too sharp young lady who was not in a situation to secure herself completely justified most extreme discipline, the conviction was adjusted to one for the offense under Section 7 and culpable under Section 8 and the request on sentence was altered to thorough detainment for a very long time with fine of Rs 10,000.

Conclusion:
The vague assumption that the people having physical obstacles are mentally frail is obsolete. The Indian equity delivery set-up has provided a comprehensive environment where every single witness who has a base level of knowledge is given an opportunity to be affirmed. Moreover, the procedural protections are carefully executed to check any prohibited or indiscernible evidence. However, legal mandates are sufficiently prepared to overcome all the procedural bottlenecks.

On the off chance that conviction of the blamed is the objective for moving the legitimate cycle for a situation of assault, at that point the purpose of intervention of law change endeavors ought to be some place other than where it is in current women's activist law change 18 proposition. It is imperative to recollect that even if the weight of proof is put on the blamed, the lawful relevance of the declaration of the prosecutrix isn't decreased.

On the off chance that due consideration isn't taken in recording and evaluating the declaration of the prosecutrix, the arraignment case is probably going to come up short, regardless of on which party the weight of proof falsehoods.

The principal point ought to be to unstick the aggregating thought of inability as a fixed state of inadequacy. In solid terms, this would involve underscoring that the debilitated witness is to be paid attention to and that his/her declaration is to be viewed as relevant and recorded with due consideration according to the Indian Evidence Act.

Simultaneously, we have to inquire as to whether the natural women's activist sayings of 'exclusion', 'hushing' or 'subjection' are adequate to represent the underestimation of the non verbal by the legitimate cycle. We additionally need to ask whether women's activist hypothesis could discuss the underestimation of the non-verbal without subsuming it inside its central distraction with sex/sexual orientation.

Second, we have to give more prominent consideration to how the method of enunciation or language utilized by the prosecutrix to describe her experience of sexual violence is connected to the 'exclusion' (Smart, 1989) of her version by the legitimate cycle.

On account of debilitated ladies, we have to especially inquiry the pretended by the communication via gestures master or the mediator in intervening between the handicapped prosecutrix and the lawful cycle. So, we need a more profound commitment with issues caused by the 'body' and 'contrast' in lawful talk, while being aware of the agitating ramifications of such commitment for conventional ideas of unbiasedness, declaration, comprehensibility or weight of proof.

As Jennifer Nedelsky has composed, 'It is fundamental to see with equivalent lucidity and conviction both the inconceivability of continuing with conventional understandings of these ideas and the trouble of creating new ideas'. 19

Bibliography:
Statutes:

• Indian:
  1. The Indian Evidence Act, 187
• Foreign:
  1. Youth Justice and Criminal Evidence Act, 1999

Cases:

• Indian:
  1. State of Rajasthan v. Darshan Singh @ Darshan Lal, Criminal Appeal No. 870 of 2007
  2. M.P. Sharma & Others v. Satish Chandra, District Magistrate, Delhi & Others, AIR 1954 SC 300
  3. Public Prosecutor, High Court of Andhra Pradesh, Hyderabad v. Lingisetty Sreenu, 1997 Cr LJ 4003 (AP).
  4. Baneshwar Marandi @ Boneshwar Marandi @ Bhuneshwar Marandi v. The State of Jharkhand, Bail Application No. 6591 of 2017.
  5. Meesala Ramakrishnan v. State of Andhra Pradesh, (1994) 4 SCC 182.
• Foreign:
  1. R v. Watts, [2010] EWCA Crim 1924
  2. R v. Sharp, [1993] 3 All ER 225, 231
  3. R v. Barker, [2010] EWCA Crim 4.
  4. R v. Christian, [2015] EWCA Crim 1582.

Books and Articles 20

1. Addlakha, Renu, & Mandal, Saptarshi (2009). Disability law in India: Paradigm shift or evolving discourse? Economic and Political Weekly, 44(41), 62-68.
2. Baxi, Pratiksha (2005). The medicalisation of consent and falsity: The figure of the habitu in Indian rape law. In Kalpana Kannabiran (Ed.), The violence of normal times: Essays on women's lived realities (pp. 266-311). New Delhi: Women Unlimited.
3. Coombs, Mary (1993). Telling the victim's story. Texas Journal of Women & Law, 2(2), 227-315.
4. Fineman, Martha (2008). The vulnerable subject: Anchoring equality in human condition. Yale Journal of Law & Feminism, 20(1), 1-23.
5. Young, Iris Marion (1990). The ideal of impartiality and civic public. In I.M. Young (Ed.), Justice and the politics of difference (pp. 96-120). New Jersey: Princeton University Press.