Hurdles in Investigation of Crimes

A final draft submitted in partial fulfilment of the course

of Criminal Law-I during the academic session 2018-19,
Semester IV

Submitted by: Aanchal

Roll no: 181602

B.B.A. LL.B.(Hons.)

Submitted to: Dr. Fr. Peter Ladis

Criminal law II

March, 2019

Chanakya National Law University, Mithapur, Patna,

800001
 DECLARATION

I, AANCHAL, declare that the project entitled “Hurdles in Investigation of Crime” submitted
by me for the award of course certificate in “Criminal Law-II” is my own work. This project
has not been submitted for any other degree/ certificate/ course in any institution/ university.

AANCHAL
 ACKNOWLEDGEMENT

I would like to thank my faculty, Dr. Fr. Peter Ladis , whose assignment of such a relevant
topic made me work towards knowing the subject with a greater interest and enthusiasm.

I owe the present accomplishment of my project to my friends, who helped me immensely

with the sources of research materials throughout the project and without whom I couldn’t
have completed it in the present manner.

I would also like to express my gratitude to my parents and all those unseen hands who
helped me out at every stage of my project.
TABLE OFCONTENTS
1. Investigation: An analysis
2. Problems faced by investigators:
a) Cyber Crime and its evolution
b) Budgetary Constraint
c) Lack of public cooperation
d) Forensic Science
e) Political interference
f) Transfer of police officer
g) Role of media
h) Hostile witness
3. Criminal Profiling and data
4. CONCLUSION AND SUGGESTIONS.
INTRODUCTION

Criminal investigation is an applied science that involves the study of facts, used to identify,
locate and prove the guilt of an accused criminal. A complete criminal investigation can
include searching, interviews, interrogations, evidence collection and preservation and
various methods of investigation.1 Modern-day criminal investigations commonly employ
many modern scientific techniques known collectively as forensic science.

Criminal investigation is an ancient science that may have roots as far back as c. 1700 BCE in
the writings of the Code of Hammurabi. In the code it is suggested that both the accuser and
the accused had the right to present evidence they collected.2 In the modern era criminal
investigations are most often done by government police forces. Private investigators are also
commonly hired to complete or assist in criminal investigations.

An early recorded professional criminal investigator was the English constable. Around 1250
CE it was recorded that the constable was to " record matters of fact, not matters of judgment
and law."3

The incidence of crime in India is increasing alarmingly with a disastrous spatial distribution
of population due to mismanagement and an overwhelmingly ubiquitous new technology.
The profile of the criminal has undergone a sea change from the earlier stereotypes, requiring
a new paradigm to comprehend and manage the emerging scenario. Today’s criminal could
well be your suave, smooth talking colleague or neighbour, someone who is relatively well
off and well educated. The criminal mind is no more matching the orthodox definition of an
economically deprived background but one that seeks to compete, outsmart and short-change
the society that he or she lives in.

Recently, an internal survey conducted by a leading retail chain found that the largest section
of loss due to theft was of women’s clothing and women’s innerwear. This by natural
extension points to women as the emerging segment for pilferage in the organized retail
sector.

There is a fair chance that most of the women stealing come from reasonably well-to-do
families but their craving for excitement from pilferage is what drives many to the crime.

1
Fundamentals of Criminal Investigation (Sixth Edition). Charles E. O'Hara and Gregory L. O'Hara; 1994;
2
Victimology:Theories and Applications, Ann Wolbert Burgess, Albert R. Roberts, Cheryl Regehr,Jones &
Bartlett Learning, 2009, p. 103
3
Henry of Bratton (1968). Bracton On the Laws and Customs of England; volume 4 pg 136. Cambridge, MS:
Belknap Press
Several Hollywood celebrities are known to be compulsive kleptomaniacs. But this is a
relatively mild crime when compared to the number of child rape and molestation that is
being reported from all parts of India and include urban, semi-urban and rural areas. Violent
crime is on the increase.

Emerging trends in cyber crimes include hacking, phishing and cyber stalking with social
media as the new playground for the criminal mind to let itself loose.

With these emerging trends in crime, it is time for India to revamp and reform how crime is
reported, investigated and followed through with scientific evidence, which can ensure
successful prosecution of the criminal.

The Indian system of policing and criminal investigation is still stuck in the old ways of
information gathering and beating out a confession from the suspects. The police force is
completely untrained on modern methods of criminal investigation and is not primed to
gather scientific evidence to present a watertight case in the court. This is why the gap
continues between reporting of crime, arresting a criminal and finally ensuring successful
prosecution of the accused.

A. OBJECTIVE OF THE STUDY:

i) This research work is a modest step in quest of suggesting
improvement of the investigating system in direction of overhauling
the system in direction of those suggestions.
ii) This research work is focused on understanding the kind of hurdles the
key role players in the field of investigation are experiencing in the
field and to find out the ways and means to gear up the system
towards a new direction with new goals and objects of better
administration of criminal justice machinery.
B. HYPOTHESIS:

This paper would focus on the hurdles faced by the investigators in investigating various
types of crimes including searching, interviews, interrogations, evidence collection and
preservation and various methods of investigation.
C. RESEARCH METHODOLOGY
1. Doctrinal method :- Books, internet, journals, judgements etc.
2. Researcher will mainly rely on library based study.
3. The researcher would like to follow doctrinal research methodology.
D. SOURCES OF DATA COLLECTION:-
1. Primary sources- Judgements of apex court, provisions of Indian penal

code, statute, precedent & other official document.

2. Secondary sources- statement of judges, websites, articles, news paper,

books, journals etc.

E. LIMITATION & SCOPE OF THE STUDY.
Due to lack of time, finance and lack of resources my research work is
wholly based on doctrinal method of research, my research work doesn’t
rely on non-doctrinal research or empirical research.
 1. INVESTIGATION: AN ANAYSIS

Section 2 (h) of the CRPC reads as under:

2.(h) “investigation” includes all the proceedings under this Code for the collection of
evidence conducted by a police officer or by any person (other than a Magistrate) who is
authorised by a Magistrate in this behalf;
Section 2(h) CrPC defines “investigation” and it includes all the proceedings under the Code
for the collection of evidence conducted by a police officer or by any person (other than a
Magistrate) who is authorised by a Magistrate in this behalf. It ends with the formation of the
opinion as to whether on the material collected, there is a case to place the accused before a
Magistrate for trial and if so, taking the necessary steps for the same by filing of a charge-
sheet under Section 173.4

A three Judge Bench in H.N. Rishbud v. State of Delhi , while dealing with investigation, has
stated that under the Code, investigation consists generally of the following steps:
(a) Proceeding to the spot,
(b) Ascertainment of the facts and circumstances of the case,
(c) Discovery and arrest of the suspected offender,
(d) Collection of evidence relating to the commission of the offence which may consist of:
(i) The examination of various persons (including the accused) and the reduction of their
statements into writing, if the officer thinks fit,
(ii) The search of places or seizure of things considered necessary for the investigation and to
be produced at the trial, and
(e) Formation of the opinion as to whether on the material collected there is a case to place
the accused before a Magistrate for trial and if so taking the necessary steps for the same by
the filing of a chargesheet under Section 173.
In Adri Dharan Das v. State of W.B. , it has been opined that:
“arrest is a part of the process of investigation intended to secure several purposes. The
accused may have to be questioned in detail regarding various facets of motive, preparation,
commission and aftermath of the crime and connection of other persons, if any, in the crime.”
In Niranjan Singh v. State of U.P. It has been laid down that investigation is not an inquiry or
trial before the Court and that is why the Legislature did not contemplate any irregularity in
investigation as of sufficient importance to vitiate or otherwise form any infirmity in the

4
Union of India v. Prakash P. Hinduja .
inquiry or trial. In S.N.Sharma v. Bipen Kumar Tiwari , it has been observed that the power
of police to investigate is independent of any control by the Magistrate. In State of Bihar v.
J.A.C. Saldanha , it has been observed that there is a clear cut and well demarcated sphere of
activity in the field of crime detection and crime punishment and further investigation of an
offence is the field exclusively reserved for the executive in the Police Department.5

The mere undertaking of a further investigation either by the investigating officer on his own
or upon the directions of the superior police officer or pursuant to a direction by the
Magistrate concerned to whom the report is forwarded does not mean that the report
submitted under Section 173 (2) is abandoned or rejected. It is only that either the
investigating agency or the court concerned is not completely satisfied with the material
collected by the investigating agency and is of the opinion that possibly some more material
is required to be collected in order to sustain the allegations of the commission of the offence
indicated in the report.6

5
Manubhai Ratilal Patel v. State of Gujarat and Others,(2013) 1 SCC 314.
6
Vipul Shital Prasad Agarwal v. State of Gujarat and another, (2013) 1 SCC 197.
2. Problems faced by Investigators

a) Cyber Crime and its evolution

“We live in a society exquisitely dependent on science and technology in which hardly
anyone knows anything about science and technology”.7 It has been said that there are three
factors necessary for the commission of crime: a supply of motivated offenders, the
availability of suitable opportunities and the absence of capable guardians. On all three
counts the digital environment provides fertile rounds for offending. The growing popularity
of digital network however, comes out at a cost. As the business and societies in general
increasingly rely on computers and internet based networking, cybercrime and digital
incidents have increased around the world. These attacks generally classified as any crime
that downloading pornographic images from internet, virus attacks, E-mail stalking and
creating websites that promotes racial hatred.

Technology has both facilitated and impeded the investigation of crime, particularly crimes
involving computing of crime and communication technologies or what is described as
cybercrime. On the one hand, computers have enabled vast amounts of data to be searched
and analyzed quickly and permitted documents and files to be scanned and transmitted across
the globe in seconds. On the other hand, the sheer quantity of information creates
considerable problems for investigators and who sometimes have to examine gigabytes of
data and break encryption codes before the material they are interested in can be discovered.
Adding fuel to the fire the trans-border nature of cybercrime has created jurisdictional
problems for law enforcement agencies and adjudicator. Over past few years, the global
cybercrime landscape has changed dramatically, with criminal employing more sophisticated
technology and greater knowledge of cyber security. Until attacks were mostly the work of
computer geniuses showcasing their talent. These attacks which were rarely malicious, have
gradually evolved into cybercrime syndicates siphoning off money through illegal cyber
channels.

7
Dr.Carl Sagan, cited in “In the matter of Application of United States of America for an Order Authorizing the
Illustration and Use of Pen Register and a Trap and Trace Device on E-mail Accounts”, 416, F Supp 2d 13,14
(DDC)
The challenges posed by Cybercrime:-

i) Failures to report Cybercrime:- Consumer trust is vital for private sector

corporations, so data breaches can be catastrophic for businesses. As a result,
when criminals takes their money from victims bank account or make
fundamental charges on victim’s credit card companies often reimburse the victim
for losses, rather than suffer bad publicity about their customer being victimized.
While this approach makes situation easier for victim and it may make sense for
businesses there are significant disadvantages. If the victim’s first phone call is to
bank and banks quickly reimburse the victim, the victim may never even think to
report the crime to police. If the crimes are never reported, they are not
investigated by law enforcement agencies or counted in crime statics. And the
perpetrators remain free to commit more crime.
ii) Encryption:- Encryption technology is the science of converting readable data
into unintelligible form or turning plain text into cipher text that cannot be read or
understood by unauthorized person, to protect confidentiality, privacy and to
prove integrity. It has become pervasive in private sector and between individual
users, because encryption program are freely available online and easy to
download and install from several websites of personal use.
In 2002, the Wall Street Journal was for example able to successfully decrypt-files
found on Al-Qaeda computer were encrypted with 40-bit encryption. Using a 56
bit encryption, a single computer would take 2285 years to break the encryption.
If the offenders use a 128-bit encryption, a billion computer systems operating
solely on the encryption could take thousands of billions of years to break it. The
latest version of the popular encryption software PGP permits 1024 bit encryption.
For investigative authorities it is difficult to distinguish the harmless exchange of
holiday pictures and exchange of pictures with encrypted hidden messages. The
availability and use of encryption technologies by criminals is a challenge for law
enforcement agencies. Various legal approaches to address the problem are
currently under discussion, including potential obligations for software developers
to install a back door for law enforcement agencies: limitation on key strength:
and obligation to disclose keys, in case of criminal investigations.
iii) Anonymity:- Anonymity is important for online discussion involving sexual
abuse, minority issues, harassment, sex lives and many other things. Anonymity is
 also useful for people who want to ask technical questions that they don’t want to
admit they don’t know the answer, to report illegal activities without fear of
retribution and many other things. Without anonymity these actions can result to
social ridicule or censure, physical injury, loss of employment or status, and in
some cases, even legal action, protection from harm resulting from this type of
social intolerance is a definite example of an important and legitimate use of
anonymity on interest. National policy concerning anonymity and accountability
on the internet thus need to be developed in a way that takes account of privacy,
authentication and public safety concern.

b) Budgetary Constraint

The constraint of budget is one of the factors that can affect many areas of the police
organizations, leading upto situations that inevitably harm police effectiveness, such as lack
of skill, caused by insufficient training; lack of appropriate or insufficiency of equipment and
lack of logistic support which detoriates their operational capacity and affects the police
officer’s motivation; as well as low pay, which in the same way leads to lack of motivation of
personnel, and as a reflection makes the police service less attractive for recruitment of
personnel.8

Due to insufficient funds, the police officers have to bear the cost of investigation from their
own pocket and they recover the same from the public in form of ‘ Bhatta’, this is one of the
reasons of corruption in police system.

c) Lack of public cooperation

It is because the lack of confidence on police system. Many times eye witnesses reluctant
to give the statement to the police officers.

d) Forensic science
The fingure prints, foot prints etc. at the scene of crime may be contaminated or
destroyed if delay is there to conduct inspection of the scene of crime. Police dogs may
be found useless as the smell of the suspects is not likely to last long on physical clues.

8
http://www.unafei.or.jp/eng/pdf/RS No60/ No60_20RC_Group1.pdf.
 The degree of change depends upon the time the upkeep and the use or the misuse of the
particular object. In course of time, the object may lose all practical identity vis a vis a
particular time.87
While collecting & packing the material for examination to the expert, proper care
should be taken because, an expert analyses what is sent to him. If the object on which
the figure prints are essentials damaged, then the investigation fails. It can be avoided by
taking the close-up photographs.
Forensic science, the sibling of science has transformed the criminal adjudication
especially the criminal trial process. Nowadays, it has become a greater helping hand of
the crime investigation agencies and the criminal justice system in properly identifying
the guilty and safeguarding the innocent. In a recent case, Dharam Deo Yadav v. State
of U.P. 9, the Supreme Court of India has explained the importance of forensic scientific
evidence, particularly in more brutal and well organized crimes. The potentiality of
scientific evidence in criminal investigation and trial is undisputed but the role of the
legal stakeholders and their capability in screening the evidence is always a controversial
topic not only in India but also throughout the globe. In India, it is also doubtful whether
the criminal investigation team is fully equipped to grab the culprit without using third
degree methods. Moreover, the most alarming thing is the reporting of some erroneous
convictions as a result of faulty forensic evidence.10 To date around 318 convicts who
were convicted with faulty forensic evidences were released from jail on the basis of
DNA test. The purpose of the paper is to highlight some of the major shortcomings in our
system concerning forensic scientific evidence and to bring out some suggestions for
improvement.
In India, though forensic science is considered as a reliable discipline, there are various
pertinent factors, apart from those discussed earlier, which affects the reliability of case
specific application of the technique. The list includes

(1) lack of scientific certainty

9
(2014) SCc_509 hypothetical protein [ Serratia symbiotica str. 'Cinara cedri' ], Gene ID: 11576315:
http://www.ncbi.nlm.nih.gov/gene?term=scc%20509[gene]%20AND%20alive[prop]%20NOT%20newentry[ge
ne]%20 & sort=weight

10
Jane Campbell Moriarty (2007) “Misconvictions,” science, and the ministers of justice. Neb. L. Rev. 86: 1.
 (2) lack of research
(3) forensic science as neglected discipline
(4) absence of well defined code of ethics
(5) lack of certification to the technical personnel’s
(6) lack of national database for identification evidence
(7) lack of error rate statistics for all techniques, and so on.
The lack of scientific certainty in forensic science is not only the problem in India but
also it is a common problem throughout the world. Different from other scientific
disciplines, in forensic science there is no absolute scientific proof or certainty. The
major reason is because of its close association with law since in legal truth finding
different from scientific, law is not expecting any certainty but the proof based on
probabilities. As Craig rightly stated, “public crime laboratories are not sanctuaries of
science”. The public cannot give that much of reliance on those labs similar to other
research laboratories because in crime labs the scientists are researching with old,
degraded, partial, distorted, blurred and contaminated samples. Similarly, all forensic
identification tests based on matching of samples are based on the subjective evaluation
of the examiner which is subject to the final interpretation by an independent person.
Because of the human intervention, there is possibility of error in fixing the match of
different characteristics in two samples.
The other major problem affecting the reliability is the lack of research and the shortage
of peer-reviewed papers and validation studies. Moreover, the applications of the
majority of forensic techniques are based on long standing application in the court of law
and not as a result of proper scientific research. The best example is fingerprint technique
which has no valid scientific basis, though considered as reliable by the judiciary due to
its long standing track record.11
The National Research Council of the National Academies, United States, in its
publication “Strengthening Forensic Science in the United States: A Path Forward” has
made certain valuable recommendations for improving the accuracy, reliability and
validity in the forensic science disciplines. The recommendations are:
“The National Institute of Forensic Science should competitively fund peer-reviewed

11
1. P.C. Giannelli (2001) Scientific evidence in civil and criminal cases. Ariz. St. L. J.103: 112.
 research in the following areas:
a. Studies establishing the scientific bases demonstrating the validity of forensic
methods.
b. The development and establishment of quantifiable measures of the reliability and
accuracy of forensic techniques should reflect actual practice on realistic case scenarios,
averaged across a representative sample of forensic sciences and laboratories. Studies
also should establish the limits of reliability and accuracy that analytic methods can be
expected to achieve as the conditions of forensic evidence vary. The research by which
measures of reliability and accuracy are determined should be peer reviewed and
published in respected scientific journal.
c. The development of quantifiable measures of uncertainty in the conclusions of forensic
analyses.
d. Automated techniques capable of enhancing forensic technologies”.12

Apart from the aforesaid problems, in comparison with other scientific disciplines,
forensic science is always treated as a neglected discipline. From very early days most of
the nations have sidelined it as a part of law enforcement and justice delivery system.
This was the reason for the shortage of funding from the government for research.
The bias, bribe and partisanship of experts are escalating due to the absence of well
defined code of ethics and its proper implementation. Restrictions should be imposed by
the state against experts in offering the services to the defense. For all forensic
techniques stringent protocol should be implemented to overcome bias. In India also we
have to formulate a code of ethics and proper mechanism for enforcing it. In the U.S.,
The National Institute of Forensic Science (NIFS) has recommended that there should be
a national code of ethics for all forensic science disciplines and encourages individual
societies to incorporate this national code as part of their professional code of ethics.13 It
also emphasizes that a proper mechanism should be established to enforce the code for
those who commit serious ethical violations.
The other well-known challenge is the quality assurance in forensic service. The quality

12
National Academy of Sciences (2009) Strengthening forensic science in the United States: a path
forward. The National Academies Press; Washington, D.C, 190.

13
Supra 12
 of the evidence depends on several factors like validation of a technique, instrumental
quality check, capacity of the persons employed, standard protocol, and accreditation of
the crime labs and certification of the scientists. If there is compromise in any of these
factors, it will directly affect the quality and there by the reliability of test results. Apart
from this, the overall quality can be tested using proficiency tests. The proficiency tests
are useful for testing both scientific personnel and crime lab. The test can be conducted
by a national body like NIFS in U.S. or National Accreditation Board for Testing and
Calibration Laboratories (NABL) in India,14

e) Political interference
Investigation in the cases where the high profile people, VIP’s as well political parties
are involved cannot succeed. In Prakash Singh & Ors. v. U.O.I. & Ors88, the S.C. given
direction to State Governments that, “Constitute a State Security Commission (SSC) to:
(i) Ensure that the State government does not exercise unwarranted influence or pressure
on the police
(ii) Lay down broad policy guideline and
(iii) Evaluate the performance of the State police.”
But all this directions remained on paper still there is direct or indirect interference of
political parties in the police investigation.

f) Transfer of police officer during investigation

It causes delay in the investigation as the new officer has to understand the case & to
start the investigation.

g) Role of the media during investigation

No doubt it is the duty of the media to keep update to the public but the media should
take the precautions that what to disclose to the public & when? It has been cleared form
the 26/11 Mumbai terrorist attack incident that media was showing the entire incident
live on television. It made the task of the terrorist very easy so that they could guide how
to attack?

14
Supra 12
During the investigation, media should take precaution that not to reveal the police
investigation progress.

h) Duty of the police officers is overburdened with maintaining order &

investigation
‘Maintaining the order’ by ‘preventing the crime’ and ‘investigation’ are two different
responsibilities of the police officers. In the latter responsibility more work of intellectual
is required. The investigating police shall be separated from the law and order police to
ensure speedier investigation, better expertise and improved rapport with the people.89

i) Witness turns hostile

It is said: ‘Even God does not know how human mind works. With the passage of time,
several witnesses may turn hostile to police. They may be influenced, coerced, unduly
remunerated by culprit or his party. The same is the case with the victim too. The victim
may feel sympathy or even may attempt to reach a compromise with the culprit.’
 3. Criminal profiling and data

Every person who is brought into the police station as a suspect must be full body scanned
and facial data recorded. This will include bone structure, facial and dental profile, iris scan
along with finger print and DNA profile collected and recorded for posterity.

The data can be kept under suspect, accused and prosecuted groupings. Sub groupings may
also be created, as per need. While, this may evoke strong debate on the need for profiling, it
is necessary to understand the importance of collecting this data as the primary requirement
in surveillance, tracking and subsequent arrest of a potential criminal.

Today, software is available to capture real time data through surveillance cameras located at
public places like airports, railway and bus stations. The data captured is matched on the
basis of bone structure and facial recognition software. So if there is a potential terrorist or
criminal passing through any public area, there is a fair chance that the software will pick him
out of the crowd in real time. This would be possible only if his profile has been collected,
recorded and made available to all law enforcement agencies, seamlessly.

The National Security Agency (NSA) of the United States is using this widely and the same
data has helped agencies like FBI, CIA, State Police, Homeland Security etc solve several
cases, in addition to monitoring and tracking suspects to prevent crime. There is no point in
data being collected by one agency and not being available to other agencies, seamlessly.
This was one of the biggest lessons the United States learnt post the 9/11 incident.

India has no choice but to learn and implement similar strategies if it were to seriously
attempt crime prevention and crime control. Data collection, availability and access is the
first tool in this battle.
Suggestions
1. Government responsibility to provide sufficient funds
It is the duty of the government to provide financial support taking into consideration the
needs of the police for investigation, equipments, travel & others essential requirements.

2. Exclusive cadre for investigation

There should be separate cadre needs to be established in police system which exclusively
look into the investigation matters apart from the public order.

3. Trust building
It is necessary to create trust in the witnesses & victims so that they will not turn hostile. It
can be done by proper counseling & showing the progress in the investigation. Transparency
of police system is important in order to win the confidence of the citizens.

4. Removal of political interference

It is necessary to follow the Japanese police system which is based on political neutrality and
democratic control, as it is built in such a way as to ensure absence of arbitrary and political
interference. The National Police Safety Commission & the National Police Agency is under
the jurisdiction of the Cabinet Office, the Prime Minister is not empowered to exercise direct
command or control. This guarantees the Commission’s independence and ensures its
political neutrality.

5. Police & Media

There should be friendly relations between police & media. Police should take help of the
media in investigating the crime. Media should cooperate by not disclosing the confidential
information to the public.

6. Collection of evidence
It is necessary to collect the finger prints at the incident of the crime first because once the
object on which the figure prints are visible damaged then it becomes difficult for the expert
to give the analysis report.
In many times police officers does not use the Investigation officer’s evidence collection kit.
It is the duty of the investigating officer to invariably examine whether or not all the
following items are available in the kit.
i) Photographic kit-camera
ii) Finger print kit- powder, brushes, fimger print card, transfer paper etc.
iii) Measuring kit- steel tape measures, pedometer to measure long distances etc.
iv) Other articles- magnifying glass, flash light, storage materials (boxes, bottles of
various sizes), tissue paper, tools (knife, screwdrivers, dividers), electronic torch
etc.
BIBLIOGRAPHY.

Books:
1. Criminal law- PSA Pillai, 12th edition, lexis- nexis
2. Indian Penal Code - Ratanlal & Dheerajlal, 34th edition
3. Bhattacharya, Prof. T, Indian Penal Code, 5th Edition, Central Law Agency,
Allahabhad, 2007.
4. Tandon, Mahesh Prasad, Indian Penal Code, Allahabad Law Agency, Faridabad,
2006.

Article:

1. ‘The Hindu : Is euthanasia ethical?’

2. ‘Euthanasia in India’ by A.K. Tharien
3. ‘Amardeep Singh: The Right to Die in India (and everywhere)’

Websites:
 http://indianlawcases.com/Act-Indian.Penal.Code,1860-1526
 https://indialawyers.wordpress.com
 https://Manupatra.com
 https://lexisnexis.com