This paper provides a detailed analysis of Sections 238 and 61(2) of the Bharatiya Nyaya Sanhita, 2023 (BNS), focusing on the implications of tampering with evidence or providing false information to protect a criminal, especially concerning the responsibilities of police officers. Those who deliberately obliterate, remove, destroy or conceal evidence related to a crime or offer false information to shield an offender face penalty under Section 238 BNS, where the severity varies based on the nature of the offence, potentially resulting in a prison sentence of up to seven years and a fine.

In addition, Section 61(2) BNS in this regard addresses issues related to criminal conspiracy between two or more persons in order to destroy or temper with evidence or furnish false information to shield a criminal from arrest or criminal liability and stipulates punishment commensurate with the seriousness of the offence. It also underscores the importance of investigating police officers' safety and the need to adhere to ethical and investigative standards. The study highlights the crucial role of honesty and transparency within law enforcement to promote accountability and uphold the principles of justice.
 

1. Section 238 of the BNS: Section 238 of the Bharatiya Nyaya Sanhita, 2023 (BNS) specifies that anyone who is aware of or has reason to believe that a crime has occurred and deliberately conceals evidence or provides false information to protect the offender will face the following penalties:
   • If the underlying offence carries a potential death penalty: the individual can be sentenced to a maximum of seven years in prison and fined. This particular crime is classified as either cognizable or non-cognizable, depending on whether the original offence is cognizable. The case will be tried in a Court of Session, is bailable, and cannot be compounded.
   • If the offence is associated with a life sentence or has a maximum penalty of ten years: the offender may be sentenced to a maximum of three years in prison and fined. This offence falls under the jurisdiction of a first-class magistrate, and it is classified as non-cognizable, bailable, and non-compoundable.
   • If the offence carries a prison sentence of less than ten years: the offender could receive a jail term of one-fourth of the maximum penalty, a fine, or both. This offence is also non-cognizable, bailable, and non-compoundable, and is subject to trial by the appropriate court with the necessary jurisdiction.
   Example: If individual X is aware that individual Y has committed murder and assists Y in concealing the body to shield Y from apprehension, then X could face a sentence of up to seven years in prison. Additionally, X may also incur financial penalties.
    
2. Section 61(2) of the BNS – Criminal Conspiracy: Any individual involved in a criminal conspiracy will face the following penalties as outlined in Section 61(2) of the BNS:
   
   1. If the conspiracy aims to commit a crime that carries a death penalty, life imprisonment, or rigorous imprisonment for two years or more, and there are no specific provisions in this Sanhita for punishing such conspiracies, the person will be treated as if they had directly participated in the crime.
   2. For conspiracies related to offences that are not punishable in the aforementioned manner, an individual may receive a sentence of up to six months in prison, a fine, or both.

Agreements between Two or More Individuals Are Essential in Criminal Conspiracy:

The central aspect of the offence in question is the collaboration of two or more individuals in committing crimes. When facing conspiracy charges, the court must assess whether the individuals are independently pursuing a shared criminal goal or if there is evidence of a mutual agreement to achieve that illegal objective. If they are acting independently, they are not considered conspirators; if they are mutually agreed, they are.

A conviction for conspiracy cannot be based only on an agreement, according to Section 61(2) of the Bharatiya Nyaya Sanhita (BNS), 2023, since nonverbal communication is not necessary to support the allegation. It takes more than mere conjecture on illicit activity to prove a link between the parties. Until it is finished, abandoned, or thwarted, conspiracy is regarded as an ongoing offence, and any actions committed by a conspirator during this time may result in prosecution. The seriousness of the intended crime determines the consequences. According to the provision, criminal conspiracy is defined as an agreement between two or more people to carry out a legitimate act using unlawful methods or to do an illegal act.

Can an Investigating Police Officer Be Prosecuted Under Section 238/61(2) of the BNS?

These sections primarily address the crime of concealing evidence or providing false information following the formation of a criminal conspiracy aimed at protecting an offender from legal repercussions. We will conduct a comprehensive examination to assess the potential liability of investigating police officers under these provisions. Our analysis seeks to clarify the circumstances under which law enforcement may face charges for their actions in destroying evidence and supplying false information subsequent to their involvement in a criminal conspiracy. Ultimately, we aim to illuminate the legal implications for police officers in these situations.

Key Components of the Crime:

• Knowledge or Reason to Believe: A person must know or have good reason to suspect that a crime has been committed.
• Making Evidence Disappearance: When someone willfully removes proof of a crime, they are attempting to protect the offender from prosecution.
  • A police officer may be charged if they willfully destroy, hide, or otherwise help make evidence of a crime vanish in order to shield a suspect or criminal. For instance, there are legal repercussions if an officer ignores important evidence linking a suspect to a major crime.
• Giving False Information: A police officer faces prosecution if they give false information to thwart an inquiry or shield an offender.
  • For example, an officer may face charges if they misreport that no evidence was discovered at a crime scene when in fact there was.
• Legal Accountability: Should any investigating police officer engage in destruction, obliteration, or concealment of evidence related to a crime, or provide false information while conspiring with any accused individual or influential figure, they can face charges under Section 61(2) of the BNS, in addition to the implications outlined in Section 238 of the BNS. This ensures accountability for officers who compromise their integrity and the investigation process by colluding with those involved in criminal activities.
• Examples:
  • An officer engaged in a major investigation finds out that a coworker (or a prominent figure) is involved in a crime. To shield them from repercussions, the officer conceals essential evidence, such as murder weapons or pertinent documents. If this concealment comes to light, the officer may face charges for tampering with evidence.
  • While conducting an investigation, an officer deceitfully informs their superiors that a suspect was absent from the crime scene, fully knowing that this statement is false and aims to protect the suspect. This act of providing misleading information could result in legal charges under this statute.

Literature Review:
The integrity of the justice system is undermined by evidence tampering and the spread of false information by law enforcement, often resulting in miscarriages of justice. Research suggests that intentional manipulation of evidence or the provision of misleading data diminishes public trust and obstructs effective law enforcement (Nakhaeizadeh, Dror, & Morgan, 2014). Various studies highlight the serious nature of these actions, which are frequently motivated by factors such as protecting suspects, improving case outcomes, or concealing procedural mistakes (Scheck, Neufeld, & Dwyer, 2000).

High-profile cases serve as crucial examples of the repercussions of evidence tampering in law enforcement. The 1995 O.J. Simpson trial, for example, revealed potential police misconduct, with claims of tampered evidence casting doubt on the prosecution's case and affecting the trial's result (Dershowitz, 1996). Furthermore, the case of Fred Zain, a forensic analyst in West Virginia, saw multiple convictions overturned after it was discovered that Zain had falsified and manipulated forensic evidence across several cases (Thompson, 1997). These instances highlight how official misconduct relating to tampering and dishonesty can lead to wrongful convictions or exonerations and erode public confidence in law enforcement.

Multiple studies investigate the driving forces behind law enforcement's tampering with evidence or dissemination of false information. Often, such behaviour arises from a mentality of "noble-cause corruption," where officers rationalize their unethical actions as means to achieve a perceived greater good, typically aiming to convict those they believe are guilty (Caldero & Crank, 2010). Systemic pressures to resolve cases swiftly or attain high conviction rates also contribute, motivating law enforcement personnel to manipulate evidence (Kassin, Dror, & Kukucka, 2013). These motivations illustrate the complicated ethical dilemmas faced by officers and underscore the necessity for strong procedural safeguards against evidence tampering.

Psychological studies indicate that cognitive biases, such as confirmation bias, can significantly affect how law enforcement officials manage evidence. When officers or forensic specialists hold a firm belief in a suspect's guilt, they may unconsciously alter or ignore conflicting evidence to support their preconceived notions (Dror, 2012). Such biases have been associated with numerous instances of forensic evidence mishandling, resulting in wrongful convictions (Nakhaeizadeh et al., 2014). These challenges emphasize the importance of training aimed at helping law enforcement recognize and counteract these biases.

Tampering with evidence or providing false information is both unethical and illegal, carrying serious consequences for law enforcement officials found guilty of such acts. The Bharatiya Nyaya Sanhita, 2023, illustrates contemporary legislative efforts designed to combat such misconduct by imposing penalties on anyone, including law enforcement officers, who intentionally tamper with evidence to shield offenders (BNS, 2023). Many legal systems now enforce criminal penalties that include imprisonment, fines, and professional disbarment for officers participating in these practices (Jacobs, 2020). Such laws strive to enhance accountability and highlight the necessity of integrity within law enforcement.

The ramifications of evidence tampering are profound, diminishing public confidence in the justice system and risking miscarriages of justice. Research indicates that even perceived tampering or misconduct by law enforcement can lead to widespread public disenchantment and decreased willingness to cooperate with police (Tyler & Huo, 2002). Wrongful convictions, exonerations, and overturned cases due to tampering demonstrate how these actions can damage the judiciary's credibility, incurring substantial reputational and financial repercussions for the state (Gould & Leo, 2010).

In response to evidence tampering, numerous jurisdictions have adopted various measures, including body-worn cameras, evidence-tracking systems, and strict procedural guidelines for managing evidence. Additionally, advancements in technology, such as blockchain-based evidence management, are being considered to increase transparency and deter tampering (Strom & Hickman, 2010). Cultivating an ethical culture within law enforcement, underscoring the consequences of tampering and implementing rigorous checks and balances can further reduce the likelihood of such misconduct. These proactive strategies are essential for fostering accountability and maintaining the integrity of criminal investigations.

The existing literature on evidence tampering by law enforcement highlights its harmful effects on the justice system, emphasizing the importance of ongoing reforms and sustained research. It is crucial to tackle the underlying causes of tampering, including cognitive biases and systemic pressures, while also improving accountability measures to rebuild public trust (Caldero & Crank, 2010). By integrating legislative initiatives, technological advancements, and ethical training, policymakers and law enforcement agencies can strive to reduce occurrences of tampering, thereby reinforcing the principles of justice and fostering a transparent and equitable judicial system.

Strategies for Protection of an Investigating Police Officer against the Charge under Sections 238 of the BNS:
To shield themselves from accusations of evidence tampering or providing false information as outlined in Section 238 of the BNS, police officers can employ a range of proactive and defensive strategies.

Below is an organized overview of how officers can protect their positions against such allegations:

• Thorough Understanding of Sections 238 of the BNS: Officers should thoroughly familiarize themselves with Sections 238 of the BNS, which penalizes individuals for evidence tampering or supplying false information to protect a criminal. A solid grasp of the statute's intent, scope, and potential defenses enables officers to identify and navigate possible legal issues effectively.
   
• Maintaining Transparency in Investigations: Transparency is essential in all investigative processes. The investigating police officer ought to carefully document every aspect of their investigation - including evidence collection, witness interviews, and crime scene management - ideally in real-time. The use of body cameras or other surveillance tools, when permissible, can further enhance the integrity of the investigative process.
   
• Adhering to Established Protocols: Rigid compliance with standard operating procedures (SOPs) for evidence management is vital. SOPs ensure that evidence is collected, preserved, and presented in a systematic and professional manner. By following these protocols, officers create a robust defense against unfounded accusations.
   
• Meticulous Documentation and Record-Keeping: Thorough documentation is a critical line of defense for officers. Each piece of evidence must be carefully logged, detailing its collection, storage, and access history. Maintaining comprehensive records minimizes the potential for accusations by providing a clear, tangible account of all actions taken.
   
• Collaborating with Supervisors and Legal Advisors: Involving supervisors and legal counsel during key moments of an investigation adds an extra layer of protection against allegations. By seeking guidance or approval when handling sensitive cases or contentious evidence, officers ensure collaborative decision-making, which can mitigate personal liability.
   
• Continuous Training in Ethics and Evidence Management: Regular training focused on ethical standards and evidence management is crucial for officers. A deep understanding of these principles enhances the officer's position and diminishes the credibility of any unfounded tampering or misinformation claims.
   
• Utilizing Technology for Evidence Tracking: Implementing evidence-tracking technology, such as barcode systems or digital management software, enhances accountability. Such systems help maintain an unbroken chain of custody, ensuring that evidence is handled and stored correctly, with all actions logged and time-stamped.
   
• Maintaining Professional Boundaries with Subjects: To reduce perceptions of bias, officers should maintain a professional distance from suspects and witnesses. Personal involvement can raise questions about motives, which are often at the heart of tampering allegations. It's crucial to uphold impartiality in all interactions to preserve credibility.
   
• Transparent Response to Allegations: When facing accusations, officers should be forthright, providing thorough documentation, records, and witness statements that affirm their integrity. Fully cooperating with internal investigations demonstrates a commitment to transparency, which can help alleviate suspicions of tampering or misinformation.
   
• Considering Legal Remedies if Required: In cases of baseless claims, officers may need to explore legal avenues to defend their reputations. Pursuing defamation or malicious prosecution claims could be justified if the accusations are unfounded and damaging. Taking legal action underscores the officer's commitment to upholding professional and legal standards in law enforcement.

By implementing these strategies, police officers can effectively safeguard themselves against claims of evidence tampering or issuing false information as defined in Section 238 of the BNS. This proactive approach not only helps to preserve their professional integrity but also ensures compliance with legal standards. By adhering to these practices, officers can work confidently, minimizing the risk of legal repercussions while upholding justice and public trust in their roles within the community.

Protection to Public Servant under Section 218 of the BNSS:
Section 218 of the Bharatiya Nagarik Suraksha Sanhita of 2023 (BNSS) establishes stringent procedures for the prosecution of judges and civil servants accused of misconduct in their official capacities. It stresses the importance of securing government permission prior to initiating legal proceedings, aiming to safeguard public officials from baseless allegations while ensuring their accountability in performing their duties. This framework balances the need for protecting officers with the imperative of upholding their responsibilities effectively.

Challenges in Enforcement of Section 238 BNS:
The enforcement of Section 238 BNS presents several challenges, particularly the requirement to demonstrate the accused's knowledge and intent regarding the criminal activity. This often relies on circumstantial evidence and witness testimonies, which can be hard to obtain and verify. Additionally, the prosecution must establish that the evidence was intentionally tampered with to obstruct the investigation or shield the perpetrator, complicating the distinction between willful evidence destruction and mere loss. Like many other statutory regulations, Section 238 of the BNS is susceptible to misuse; individuals could be wrongfully accused, or the law might be exploited for personal benefit. This underscores the necessity for vigilant oversight by judicial and investigative bodies to ensure just enforcement.

Collection of Evidence Against the Persons or Police Officers Accused Under Section 238/61(2) BNS:
Gathering evidence against individuals, including police officers, who are suspected of either tampering with evidence or providing false information necessitates a methodical strategy. This approach must prioritize meticulous documentation, legal compliance, and the preservation of the integrity of the investigation. A structured framework is essential for systematically addressing these serious allegations.

To address problems related to evidence tampering and misinformation, it is crucial to grasp the applicable laws. In India, the Bharatiya Nyaya Sanhita, 2023 (BNS) contains important provisions, including Section 238, which pertains to the disappearance of evidence. Further, Section 61(2) BNS is attracted if the crime of disappearance of evidence or giving false information to shield a criminal as defined in Section 238 BNS is committed after hatching a criminal conspiracy with other persons. Understanding these legal definitions aids in the investigative process and guarantees that the evidence collected meets necessary legal standards, thereby improving its acceptability in court.

Investigators can identify evidence destruction or falsehoods from a suspect by searching for contradictions between the suspect's statements and physical evidence. They may also analyse digital records or communications indicating efforts to modify or conceal evidence and assess CCTV footage or location data to track movements associated with possible tampering. Forensic methods, like document analysis, can uncover indications of alteration or forgery. Furthermore, statements from witnesses or expert opinions may point out inconsistencies. To ensure a comprehensive analysis of all evidence that could uncover tampering or misleading information, investigators frequently use technological tools to recover deleted data.

Given the complex nature of evidence manipulation by officials, initiating a discreet preliminary enquiry is often essential. This phase involves the collection of indirect evidence that may include detecting inconsistencies in official reports, monitoring any changes to the chain of custody, or reviewing contradictory witness testimonies. A critical tactic during this stage is to scrutinize all records for potential signs of tampering, such as unauthorized document modifications, mobile phone call/videocall/message logs, movement history, of the accused person, missing files, or disruptions in CCTV footage. Maintaining discretion during this period is crucial to avoid alerting suspects who may then attempt to further obstruct the investigation or destroy evidence.

Another pivotal aspect of the evidence-gathering process is obtaining statements from witnesses, which could include junior officers, forensic specialists, or anyone involved in managing the evidence. Such testimonies can reveal suspicious activities or breaches of protocol indicative of evidence manipulation. Additionally, forensic examinations - like handwriting analysis, digital forensics on documents, and recovery of deleted electronic data can uncover attempts to falsify records. It is vital to meticulously document and securely store these testimonies and forensic findings to preserve the investigation's integrity.

When the investigation involves law enforcement officials, judicial oversight becomes an essential element in ensuring credibility and impartiality. Securing a court order to supervise the investigation provides a legal framework that is particularly important in sensitive matters where internal departmental politics might interfere with impartiality. Reporting findings to higher authorities or an independent investigative agency, such as the Central Bureau of Investigation (CBI) or state anti-corruption units, adds an additional layer of protection against internal biases.

In conclusion, assembling a robust case requires presenting well-documented evidence, corroborating witness statements, and comprehensive forensic reports to the judiciary. This thorough approach not only ensures accountability for those involved but also reinforces the principle of the rule of law. By adhering to these steps, the integrity of the investigation is upheld, fostering trust in the justice system.

Defence strategy for a lawyer representing police officers accused of evidence destruction, providing false information, and conspiracy:

1. Analyse Evidence Chain: Initiate the defence by meticulously reviewing the chain of custody for all evidence. Argue that any gaps in this chain can lead to contamination or loss, implying that any alterations to the evidence may have happened without the involvement of the accused officers.
2. Question Witness Credibility: Investigate the reliability of the witnesses accusing the officers of tampering or false reporting. Scrutinize their motivations, biases, and any potential conflicts of interest, while also pointing out inconsistencies in their statements.
3. Propose Alternative Explanations: Present reasonable alternative explanations for the officers' behaviours, indicating that their actions may have been in adherence to standard procedures, which could have been misunderstood as evidence manipulation by those not familiar with police protocols.
4. Highlight Procedural Uncertainties: Focus on any ambiguities within the Standard Operating Procedures (SOPs) the officers were adhering to. This can illustrate that any deviations were likely the result of misunderstandings rather than intentional attempts to alter evidence.
5. Scrutinize Forensic Reports: Analyse forensic findings to determine whether any alleged tampering can be definitively attributed to the officers. If alternative interpretations arise from the timeline, technology, or forensic methods, argue that these possibilities undermine claims of intentional tampering.
6. Establish Absence of Intent: Argue that for charges of tampering or false reporting, the prosecution must establish intent. Suggest that there was no incentive for the officers to engage in evidence tampering, thus raising questions about the allegations of deliberate misconduct.
7. Reveal Investigative Bias: Assert that the officers may be facing undue scrutiny due to internal conflicts within the police department or external pressures that could skew the investigation against them.
8. Invoke "Good Faith" Defence: Argue that the officers acted in good faith based on their training and experience. Mistakes that were made should not automatically lead to assumptions of criminal intent or conspiracy.
9. Dispute Conspiracy Allegations: Contend that there is a lack of concrete evidence supporting a coordinated effort to tamper with evidence or provide false information. Emphasize that the officers operated independently, which reduces the likelihood of a planned conspiracy.
10. Call Upon Expert Testimonies: Bring in retired officers or experts in procedural matters to testify about acceptable police practices, demonstrating that the officers' actions were in line with standard protocols rather than indicative of criminal wrongdoing.
11. Show Absence of Personal Gain: Highlight that the officers gained neither personal nor professional benefits from alleged evidence tampering, thereby weakening the prosecution's claims regarding motive.
12. Emphasize Past Integrity: Showcase the officers' clean records of service, underlining their dedication to duty and countering any implications of unlawful behaviour.
13. Point Out Prosecution Errors: Identify any mistakes made by the prosecution in handling the case or the evidence that could introduce reasonable doubt regarding the officers' alleged misconduct.
14. Provide Proof of Adherence to Protocols: Present any available documentation that indicates the officers complied with official protocols. This supports the argument that their actions were standard and not indicative of conspiracy.
15. Address External Influences: Highlight external factors that were beyond the officers' control, such as unclear protocols, lack of staffing, or inadequate training that might have led to procedural errors.
16. Introduce "Mistake in Fact" Defence: Where appropriate, argue the legal defence of "mistake in fact," asserting that any errors were unintentional, thus negating the mental state necessary for conspiracy or tampering charges.
17. Utilize Surveillance or Documentation: If available, present surveillance footage or official records that substantiate the officers' actions during critical moments, challenging the allegations of tampering or misinformation.
18. Challenge Forensic Reliability: If the forensic analysis presents inconclusive results or has a significant margin of error, emphasize these flaws to generate doubt regarding the tampering accusations reliant on such evidence.
19. Question the Motivations of Reporting Officials: If the claims arise from internal department complaints, suggest that personal grievances or internal politics might be driving these accusations, thereby undermining their credibility.
20. Reinforce Burden of Proof: Ultimately, stress that the prosecution bears the burden of proving guilt beyond a reasonable doubt. Assert that, at best, the evidence only indicates procedural irregularities, failing to conclusively establish intentional tampering, false reporting, or conspiracy.

This systematic approach is designed to methodically dismantle each element of the prosecution's case, questioning credibility, intent, procedural adherence, and evidence handling while affirming the officers' integrity and compliance with established protocols.

Court Judgments:

• In the case of State of Punjab v. Sushil Kumar (2009), the Supreme Court clarified that even if the primary offence is not established beyond a reasonable doubt, Section 201 of the Indian Penal Code (IPC) - now Section 238 of the Bharatiya Nyaya Sanhita (BNS) - can still be applied. The key consideration is whether the accused acted with the intention of concealing evidence of a crime, rather than whether the primary offence was conclusively proven.
   
• The importance of intent was further elucidated in the 2009 ruling of Nirmal Singh Kahilon v. State of Punjab. The Supreme Court emphasized that the prosecution must prove that the actions taken were specifically aimed at protecting the perpetrator from legal consequences; merely destroying evidence is not enough.
   
• In the 1952 case of Palvinder Kaur v. State of Punjab, the Supreme Court stressed the necessity of showing that the accused was aware of the crime. It was determined that specific evidence is required to establish that the accused knew about the offence and acted to destroy or hide evidence in order to shield the offender; mere suspicion or belief does not suffice.
   
• In the notorious Jessica Lal murder case against Manu Sharma, the Supreme Court highlighted the significance of Section 238 BNS. This section serves to penalize individuals who attempt to conceal evidence in order to shield the primary accused from justice.
   
• In the case of Sujit Biswas v. State of Assam, the court underscored that simply being present at the crime scene does not suffice for a conviction under Section 238 BNS. It is crucial to demonstrate the offender's intention to obstruct the investigation for a valid conviction.
   
• The Supreme Court examined claims of evidence tampering in a murder trial in the State of U.P. v. Rajesh Gautam (2003) case, emphasizing the vital significance of evidence integrity. The court emphasized that those who engage in such behaviour must be held accountable, stating that any tampering could lead to a miscarriage of justice. It also emphasized the prosecution's need to maintain and present the evidence in its original form.

Conclusion:
Section 238 BNS plays a crucial role in upholding the integrity of the criminal justice system by addressing behaviours that interfere with justice through the destruction or concealment of evidence. To effectively enforce this provision, one must possess a comprehensive understanding of legal principles, advancements in technology, and the complexities involved in establishing intent and knowledge.

Ongoing legal reforms, capacity-building efforts, and public awareness campaigns can strengthen the enforcement of Section 238 BNS, ensuring that the rule of law is maintained and justice is served. When multiple people are involved in the disappearance of evidence or providing false information over the course of the case investigation, Section 61(2) BNS is activated.

Law enforcement officers involved in investigations are not exempt from this legislation and may face prosecution if they intentionally destroy evidence or supply false information to shield an offender. Key aspects to evaluate include the motivation behind their actions and whether those actions align with the law's stipulations. If an officer's conduct shows a deliberate effort to interfere with or disrupt an investigation, they could encounter repercussions under this law. This highlights the importance of integrity in policing and affirms that all individuals, regardless of their rank, are accountable to legal scrutiny when their behaviour violates established rules. Ultimately, adherence to the law is crucial for maintaining justice and accountability within the police department.

References:

• Caldero, M., & Crank, J. P. (2010). Police ethics: The corruption of noble cause. Routledge.
• Dershowitz, A. M. (1996). Reasonable doubts: The criminal justice system and the O.J. Simpson case. Simon & Schuster.
• Dror, I. E. (2012). Cognitive neuroscience in forensic science: Understanding and utilizing expert bias. Social Issues and Policy Review, 6(1), 191-208.
• Gould, J. B., & Leo, R. A. (2010). One hundred years later: Wrongful convictions after a century of research. Journal of Criminal Law and Criminology, 100(3), 825-868.
• Jacobs, J. B. (2020). The eternal criminal record. Harvard University Press.
• Kassin, S. M., Dror, I. E., & Kukucka, J. (2013). The forensic confirmation bias: Problems, perspectives, and proposed solutions. Journal of Applied Research in Memory and Cognition, 2(1), 42-52.
• Nakhaeizadeh, S., Dror, I. E., & Morgan, R. M. (2014). Cognitive bias in forensic anthropology: Visual assessment of skeletal remains is susceptible to confirmation bias. Science & Justice, 54(3), 208-214.
• Scheck, B., Neufeld, P., & Dwyer, J. (2000). Actual innocence: Five days to execution, and other dispatches from the wrongly convicted. Doubleday.
• Strom, K., & Hickman, M. (2010). Unanalysed evidence in law-enforcement agencies: A national examination of forensic processing in police departments. Criminology & Public Policy, 9(2), 381-404.
• Tyler, T. R., & Huo, Y. J. (2002). Trust in the law: Encouraging public cooperation with the police and courts. Russell Sage Foundation.
• Xperts Legal. (2024). An in-depth analysis of Section 201 of the Indian Penal Code. URL: www.xpertslegal.com/section201-analysis
• Kumari, L. (2024). Section 201 IPC – Causing disappearance of evidence. Ezylegal Blog. URL: www.ezylegal.in/blog/section-201-ipc
• IJFMR. URL: www.ijfmr.com

Written By: Md.Imran Wahab, IPS, IGP, Provisioning, West Bengal
Email: [email protected], Ph no: 9836576565