DR.

RAM MANOHAR LOHIYA NATIONAL LAW

UNIVERSITY, LUCKNOW

2020 – 2021

CODE OF CRIMINAL PROCEDURE

PROJECT

TITLE – RIGHTS OF AN ARRESTED PERSON

SUBMITTED TO: SUBMITTED BY:

Dr. Prem Kumar Gautam Kushagra Tripathi

Assistant Professor (Law) Enrollment No. - 180101074
Dr. Ram Manohar Lohiya National Law University, B.A. LL.B. (Hons.)
Lucknow 3rd Year (Semester - V)

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 ACLNOWLEDGMENT

I would like to take this opportunity to extend a word of gratitude to my esteemed “Code of
Criminal Procedure” faculty Dr. Prem Kumar Gautam, who had been a constant source of
inspiration for me in the pursuance of this project. Sir has been gracious enough to guide me on
the right path which has enabled me to strengthen my efforts.

I may also take this opportunity to wish the reader of my project a knowledgeable experience.
The project has been made with utmost care and with utmost finesse to see that the information
mentioned is to the best of accuracy and correctness. Sir’s constant guidance and suggestions
regarding the format and subject matter regarding the project has been very helpful.

I also take this opportunity to express my sincere gratitude to our Honourable Vice Chancellor
Prof. Subir K. Bhatnagar Sir for his guidance and supervision. I would like to thank the
University staff for providing extensive database resources in the Library and through Internet.
Lastly I thank my dear parents, family and friends for their constant encouragement and
without them this work would not have been possible.

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 RESEARCH OBJECTIVE

The aim and objective of the project is to present an overview of various aspects and legal
principles of ‘Rights of an arrested person’ through case laws, judicial pronouncements,
established legal principles, constitutional provisions, journals and articles.

HYPOTHESIS

The research of the project focusses on the hypothesis that the person who is arrested by police
has certain constitutional and statutory rights available with him in order to ensure that state does
not act arbitrarily and ambiguously.

RSEARCH METHODOLOGY

The research methodology used in the making of this project will be doctrinal research methodology.
This project work is descriptive analytical in approach and has been done taking the help of secondary
data i.e. websites, articles, journals, books, etc. To construct this project, the help of dictionaries,
websites as well as foreign journals and books has been taken. The points as discussed in this project
include the study of different sources on the topic as well as the points guided by the faculty. Footnotes
have also been provided for acknowledging the sources as and where needed.

RESEARCH QUESTIONS

• What does the term ‘Arrest’ in criminal law means and signifies?
• What are the rights and legal remedies available with an arrested person?
• What are the Constitutional rights of an arrested person?
• What are the rights guaranteed to an arrested person by The Code of Criminal Procedure?
• What are the relevant judicial pronouncements and case laws enlightening the rights of an
arrested person?

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 CONTENT

1. LIST OF CASES REFERRED...……………………..…………………………….….…….5

2. LITERATURE SURVEY & PREFACE………………………………..…….………..........6
3. RIGHTS UNDER THE INDIAN CONSTITUTION……………………………..…….…...8
4. RIGHTS UNDER THE CODE OF CRIMINAL PROCEDURE…………………....…......11
5. CONCLUSION…………………………………………………………………….............17
6. BIBLIOGRAPHY………………………………………………………………………….18

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 LIST OF CASES REFERRED

• Maneka Gandhi v. Union of India, AIR 1978 SC 597

• Thiruvananthapuram v. State of Kerela, 1993 CrLJ 3242
• Kishore Singh Ravinder Dev v. State of Rajasthan, AIR 1981 SC 625
• Nandini Sathpathy vs P.L.Dani, AIR 1978 SC 1025
• Avinash Madhukar Mukhedkar v. State of Maharashtra,1983 CrLJ 1833
• Emperor v. Vimlabai Deshpande, AIR 1946 SC 123.
• In Re Madhu Limaye, AIR 1971 SC 2486
• Joginder Singh v. State of UP, AIR 1994 SC 1349
• D.K. Basu v. State of West Bengal, AIR 1997 SC 610
• Thaneil Victor v. State, 1991 CrLJ 2416 (Mad)
• Dakhi Singh v. The State, AIR 1995 All 379
• Govind Prasad v. State of West Bengal, 1975 CrLJ 1249 (Cal)
• Khatri v. State of Bihar, AIR 1983 SC 378
• Poovan v. Sub- Inspector of Police, 1993 CrLJ 2183
• Suk Das v. Union Territory of Arunachal Pradesh, AIR 1986 SC 991
• Gurbaksha Singh Sibbia v. State of Punjab, AIR 1980 SC 1632

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 LITERATURE SURVEY & PREFACE

Literature survey or literature review is the documentation of a comprehensive survey or review

of the published and unpublished work from secondary sources of data in the areas of specific
interest to the researcher. Thus the following literatures have been reviewed:

• R.V.Kelkar’s Criminal Procedure, Eastern Book Company

• Ratanlal and Dhirajlal, Code of Criminal Procedure, Lexis Nexis
• Rights of Arrested Person- Case Analysis, Mubashshir Sarshar, National Law University,
Delhi
• Rights of Arrested Person by Smarika Azad, Lex Articles

On the basis of the above mentioned literatures, following review and preface has been framed-

One of the basic tenets of our legal system is the benefit of the presumption of innocence of the
accused till he is found guilty at the end of a trial on legal evidence. In a democratic society even
the rights of the accused are sacrosanct, though accused of an offence, he does not become a
non-person. Rights of the accused include the rights of the accused at the time of arrest, at the
time of search and seizure, during the process of trial and the like.
The accused in India are afforded certain rights, the most basic of which are found in the Indian
Constitution. The general theory behind these rights is that the government has enormous
resources available to it for the prosecution of individuals, and individuals therefore are entitled
to some protection from misuse of those powers by the government. An accused has certain
rights during the course of any investigation; enquiry or trial of an offence with which he is
charged and he should be protected against arbitrary or illegal arrest. Police have a wide powers
conferred on them to arrest any person under Cognizable offence without going to magistrate, so
Court should be vigilant to see that theses powers are not abused for lightly used for personal
benefits. No arrest can be made on mere suspicion or information. Even private person cannot
follow and arrest a person on the statement of another person, however impeachable it is.
Though the police has been given various powers for facilitating the making of arrests, the
powers are subject to certain restraints. These restraints are primarily provided for the protection

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of the interests of the person to be arrested, and also of the society at large. The imposition of the
restraints can be considered, to an extent, as the recognition of the rights of the arrested person.
There are, however, some other provisions which have rather more expressly and directly created
important rights in favour of the arrested person.

State and for that matter the police as its principal law enforcing agency have the undoubted duty
to bring offenders to book. Even so, the law and procedure adopted by the State for achieving
this laudable social objective have to conform to civilized standards. The procedure adopted by
the State must, therefore, be just, fair and reasonable.1

“Arrest” means:

“A seizure or forcible restraint; an exercise of the power to deprive a person of his or her liberty;
the taking or keeping of a person in custody by legal authority, especially, in response to a criminal
charge.”2

The purpose of an arrest is to bring the arrestee before a court or otherwise secure the
administration of the law. An arrest serves the function of notifying the community that an
individual has been accused of a crime and also may admonish and deter the arrested individual
from committing other crimes. Arrests can be made on both criminal charges and civil charges,
although civil arrest is a drastic measure that is not looked upon with favor by the courts. The
federal Constitution imposes limits on both civil and criminal arrests.

In the leading case of Kishore Singh Ravinder Dev v. State of Rajasthan3, it was said that the
laws of India i.e. Constitutional, Evidentiary and procedural have made elaborate provisions for
safeguarding the rights of accused with the view to protect his (accused) dignity as a human being
and giving him benefits of a just, fair and impartial trail

1
Maneka Gandhi v. Union of India, AIR 1978 SC 597.
2
Legal Dictionary by Farlex.
3
AIR 1981 SC 625.

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 RIGHTS UNDER THE INDIAN CONSTITUTION

The Indian Constitution guarantees certain rights to the person who is arrested by investigation
agencies particularly police. There are two particular provisions that distinctively provides rights
to the arrested person in order to protect his/her individual liberty as also mentioned in the
preamble of our constitution.

Articles 20(3) and Article 22 of the Indian Constitution confer some rights on the arrested
person which are discussed below elaborately -

ARTICLE 20(3): Right against Self-Incrimination

Article 20(3) is a protective umbrella against testimonial compulsion for people who are accused
of an offence and are compelled to be a witness against themselves.4

The ‘right to silence’ is a principle of common law and it means that normally courts or tribunals
of fact should not be invited or encouraged to conclude, by parties or prosecutors, that a suspect
or an accused is guilty merely because he has refused to respond to questions put to him by the
police or by the Court. The Justice Malimath Committee writes about the origin of the right to
silence that “it was essentially the right to refuse to answer and incriminate oneself in the absence
of a proper charge. Not initially, the right to refuse to reply to a proper charge.” The Justice
Malimath Committee’s assumption is that the right to silence is only needed in tyrannical societies,
where anyone can be arbitrarily charged. It assumes that whenever a charge is “proper”, there is
no need for protection of the accused. In this backdrop it becomes necessary to examine the right
to silence and its companion right against self-incrimination. These are the two aspects of fair trial
and therefore cannot be made a subject matter of legislation. Right to fair trial is the basic premise
of all procedural laws. The very prescription of procedure and the evolution of procedural law
have to be understood in the historical context of the anxiety to substitute rule of men by rule of
law. In law any statement or confession made to a police officer is not admissible. Right to silence
is mainly concerned about confession. Breaking of silence by the accused can be before a
magistrate but should be voluntary and without any duress or inducement. To ensure the
truthfulness and reliability of the facts he stated the magistrate is required to take several

4
http://www.lawctopus.com/academike/immunity-self-incrimination/.

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precautions. Right to silence and the right against self-incrimination have been watered down quite
considerably by interpretation than by legislation. The defendant if he so desires can be a witness
in his trial. His confession outside the court either to the police officer or to the magistrate is
admissible. He is encouraged to betray his colleagues in crime on promise of pardon. He is
expected to explain every adverse circumstance to the court at the conclusion of evidence with the
court having jurisdiction to draw adverse inference while appreciating the evidence against him.

The constitution of India guarantees every person right against self incrimination under Article 20
(3) “No person accused of any offense shall be compelled to be a witness against himself”. It is
well established that the Right to Silence has been granted to the accused by virtue of the
pronouncement in the case of Nandini Sathpathy vs P.L.Dani 5 , no one can forcibly extract
statements from the accused, who has the right to keep silent during the course of interrogation
(investigation). By the administration of these tests, forcible intrusion into one’s mind is being
restored to, thereby nullifying the validity and legitimacy of the Right to Silence. In 2010 The
Supreme court made narco-analysis, brain mapping and lie detector test as a violation
of Article 20(3).6

ARTICLE 22: Protection against arrest and detention in certain cases

(1) No person who is arrested shall be detained in custody without being informed, as
soon as may be, of the grounds for such arrest nor shall he be denied the right to consult,
and to be defended by, a legal practitioner of his choice.

(2) Every person who is arrested and detained in custody shall be produced before the
nearest magistrate within a period of twenty-four hours of such arrest excluding the time
necessary for the journey from the place of arrest to the court of the magistrate and no such
person shall be detained in custody beyond the said period without the authority of a
magistrate.

Article 22 (1) and (2) confers four following fundamental rights upon a person who has been
arrested:

5
AIR 1978 SC 1025.
6
http://www.legalservicesindia.com/article/article/rights-of-arrested-person-1635-1.html.

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 i) Right to be informed, as soon as may be, of the grounds for such arrest.

ii) Right to consult and to be defended by a legal practitioner of his choice.

iii) Right to be produced before the nearest magistrate within twenty-four hours of his
arrest excluding the time necessary for the journey from the place of arrest to the
Court of Magistrate.

iv) Right not to be detained in custody beyond the period of twenty four hours without
the authority of the Magistrate.

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 RIGHTS UNDER THE CODE OF CRIMINAL PROCEDURE

Though the police have been given various powers for facilitating the making of the arrest, the
powers are subject to certain restraints. These restraints are primarily provided for the protection
of the interest of the person to be arrested, and also the society at large. The imposition of the
restraints can be considered, to an event, as the recognition of the rights of the arrested person.
There are, however some other provisions which have rather more expressly and directly created
important rights to favor of the arrested person. Some of the following are discussed below-

(a) When police may arrest without warrant: Under sections 41 very wide powers are conferred
on the police in order for them to swiftly act for the prevention or detect ion of cognizable offences
without the formality and delay of having to go to a Magistrate for the order of arrest. Therefore,
the arrest and detention of persons without warrant of caprice but are governed by rules which are
clearly laid down by law.7 There can be no legal arrest if there is no information or reasonable
suspicion that the person has been involved in a cognizable offence however the burden is on the
police officer to satisfy the court before which the arrest is challenged that he has reasonable
ground of suspicion8.

(b) Right to know the grounds of arrest: According to section 50(1), “every police officer or
other person arresting any person without a warrant shall forthwith communicate to him full
particulars of the offence for which he is arrested or other grounds for such arrest.” Apart from the
provisions of the code recognizing the right to know the ground of arrest, our constitution has also
conferred on this right the status of a fundamental right. Article 22(1) provides, “No person who
is arrested shall be detained in custody without being informed as soon as may be, of the ground
of such arrest nor shall he be denied the right to consult, and to be defended by a legal practitioner
of this choice.”

In case of arrest to be made under a warrant, Section 75 Cr.P.C. provides that “the police officer
or other person executing a warrant of arrest shall notify the substance thereof to the person to be

7
Avinash Madhukar Mukhedkar v. State of Maharashtra,1983 CrLJ 1833.
8
Emperor v. Vimlabai Deshpande, AIR 1946 SC 123.

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arrested, and if so required, shall show him the warrant.” If the substance of the warrant is not
notified, the arrest would be unlawful.
In Re, Madhu Limaye9 the facts were: Madhu Limaye, Member of the Lok Sabha and several
other persons were arrested. Madhu Limaye addressed a petition in the form of a letter to the
Supreme Court under Article 32 mentioning that he along with his companions had been arrested
but had not been communicated the reasons or the grounds for arrest. One of the contentions raised
by Madhu Limaye was that there was a violation of the mandatory provisions of Article 22 (1) of
the Constitution. The Supreme Court observed that Article 22 (1) embodies a rule which has
always been regarded as vital and fundamental for safeguarding personal liberty in all legal
systems where the Rule of Law prevails. The court further observed that the two requirements of
Clause (1) of Article 22 are meant to afford the earliest opportunity to the arrested person to
remove any mistake, misapprehension or misunderstanding in the minds of the arresting authority
and, also to know exactly what the accusation against him is so that he can exercise the second
right, namely of consulting a legal practitioner of his choice and to be defended by him.
Whenever that is not done, the petitioner would be entitled to a writ of Habeas Corpus directing
his release. Hence, the Court held that Madhu Limaye and others were entitled to be released on
this ground alone.

The rules emerging from decisions such as Joginder Singh v. State of UP10 and D.K Basu v.
State of West Bengal11, referred to, have been enacted in Section 50A12 making in obligatory to
on the part of the police officer not only to inform the friend or relative of the arrested person about
his arrest, etc. but also to make an entry in the register maintained by the police. The magistrate is
also under an obligation to satisfy himself about the compliance of the police in this regard.

(c) Arrest- how to be made: Section 46 envisages three modes of arrest, i.e. submission to
custody, touching the body physically, or confining the body. Arrest is restraint on personal liberty.
Unless there is submission to custody, by words or by conduct, arrest must be made by actual
contact.13 In case force is required, it should be no more than which is justly required and this

9
AIR 1971 SC 2486.
10
(1994) 4 SCC 260.
11
(1997) 1 SCC 416.
12
Section 50A enacted by Act 25 of 2005.
13
Thaneil Victor v. State, 1991, CrLJ 2416 (Mad).

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section does not give a right to cause death of a person, who is not accused of an offence punishable
with the death or with imprisonment for life14. Accordingly, a police officer in an attempt to re-
arrest an escaped person has no right to shoot.15

(d) No unnecessary restraint: According to section 49, there should be no more restraint than is
justly necessary to prevent escape, i.e. reasonable force may be used for the purpose, if necessary;
but before keeping a person under any form of restraint there must be an arrest. Restraint or
detention without arrest is illegal.

(e) Person arrested to be informed of the right to bail: Section 50(2) provides that any person
arrested without warrant and in a bailable case the person shall immediately of his right to be
released on bail. Arrest without compliance of this provision will be illegal and will made the
officer or person making such illegal arrest liable to all such remedies as are available in case of
an illegal arrest.
Section 50 is mandatory and if its provisions are not complied with, the non-consideration of such
non-conformance by the court when considering the question of bail operates to the prejudice of
the arrested person and the order is liable to be set aside on this ground. This provision carries out
the mandate of Article 22(1) of the Constitution of India16.

(f) Search of arrested person: Section 51 is the only provision which allows a police officer to
make a personal search of arrested persons, but it comes into operation after the arrest and not
before. Search should be made in the presence of a respectable and independent witness, but this
provision under section 51 does not permit medical examination of the accused without his
consent. With regard to the provisions of this section the reference may be made to article 20(3)
of the Constitution which is a guarantee to the accused against testimonial compulsion. The
principle appears to be that though an accused cannot be compelled to produce any evidence
against him, it can be seized under process of law from the custody or person of the accused by
the issue of a search warrant.

14
Sec 46(3).
15
Dakhi Singh v. The State, AIR 1995 All 379.
16
Govind Prasad v. State of West Bengal, 1975 CrLJ 1249 (Cal).

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(g) Person arrested not to be detained more than 24 hours: The constitutional and legal
requirements to produce an arrested person before a Judicial Magistrate within 24 hours of the
arrest must be scrupulously observed.17 Section 57 is concerned solely with the question of the
period of detention. The intention is that the accused should be brought before a magistrate
competent to try or commit, with the least delay. The right to be taken out of police custody by
being brought before a Magistrate is given, firstly, to prevent arrest and detention with a view to
extract confession, or as a means of compelling people to give information, secondly, to prevent
police stations being used as though they were prisons, and thirdly, to afford an early recourse to
a judicial officer independent of the police on all questions of bail or discharge.

This right has been further strengthened by its incorporation in the Constitution as a fundamental
right. Article 22(2) of the Constitution proves that “Every person who is arrested and detained in
custody shall be produced before the nearest magistrate within a period of twenty-four hours of
such arrest excluding the time necessary for the journey from the place of arrest to the court of the
magistrate and no such person shall be detained in custody beyond the said period without the
authority of a magistrate.” In case of arrest under a warrant the proviso to Section 76 provides a
similar rule in substance.

In a case of Khatri v. State of Bihar18, the Supreme Court has stated that this healthy provision
enables the magistrate to keep check over the police investigation and it is necessary that the
magistrates should try to enforce this requirement and where it is found disobeyed, come heavily
upon the police. If police officer fails to produce an arrested person before a magistrate within 24
hours of the arrest, he shall be held guilty of wrongful detention.

In a case of Poovan v. Sub- Inspector of Police19 it was said that whenever a complaint is received
by a magistrate that a person is arrested within his jurisdiction but has not been produced before
him within 24 hours or a complaint has made to him that a person is being detained within his
jurisdiction beyond 24 hours of his arrest, he can and should call upon the police officer concerned;
to state whether the allegations are true and if so; on what and under whose custody; he is being

17
Khatri v. State of Bihar, AIR 1983 SC 378.
18
AIR 1983 SC 378.
19
1993 CrLJ 2183.

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so helped. If officer denies the arrest, the magistrate can make an inquiry into the issue and pass
appropriate orders.

(h) Right to consult and to be defended by a counsel of his choice: Apart from ensuring a fair
prosecution, a society under the Rule of law has also a duty to arrange for the defense of the
accused, if he is too poor to do so. Article 22(1) of the Constitution provides that no person who
is arrested shall be denied the right to consult a legal practitioner of his choice. Further, as has been
held by the Supreme Court that state is under a constitutional mandate (implicit in article 21) to
provide free legal aid to an indigent accused person, and the constitutional obligation to provide
free legal aid does not arise only when the trial commences but also attaches when the accused is
for the first time produced before the magistrate, as also when remanded from time to time. It has
been held by the Supreme Court that non- compliance with this requirement and failure to inform
the accused of this right would vitiate the trial. Section 50(3) also provides that any person against
whom proceedings are instituted under the code may of right be defended by a pleader of his
choice. The right of an arrested person to consult his lawyer begins from the moment of his arrest.
The consultation with the lawyer may be in the presence of police officer but not within his
hearing.

(i) Rights Of Free Legal Aid: In Khatri v. State of Bihar20, the Supreme Court has held that the
state is under a constitutional mandate (implicit in Article 21) to provide free legal aid to an
indigent accused person, an and the constitutional obligation to provide free legal aid does not
arise only when the trial commences but also attaches when the accused is for the first time
produced before the magistrate, as also when remanded from time to time. However this
constitutional right of an indigent accused to get free legal aid may prove to be illusory unless he
is promptly and duly informed about it by the court when he is produced before it. The Supreme
Court has therefore cast a duty on all magistrates and courts to inform the indigent accused about
his right to get free legal aid. The apex court has gone a step further in Suk Das v. Union Territory
of Arunachal Pradesh21, wherein it has been categorically laid down that this constitutional right
cannot be denied if the accused failed to apply for it. It is clear that unless refused, failure to provide

20
AIR 1983 SC 378.
21
AIR 1986 SC 991.

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free legal aid to an indigent accused would vitiate the trial entailing setting aside of the conviction
and sentence.

(j) Rights to Anticipatory Bail: Section 438 deals with this right of the arrested. Special powers
have been conferred only on the High Court and the Court of Session for directing a person on bail
previous to his arrest, which is commonly called anticipatory bail, imposing such conditions as the
court thinks fit. The order of anticipatory bail shall take effect at the time of arrest.22

(k) Right to be examined by a medical practitioner: Section 54(1) provides for the examination
of arrested person by medical practitioner at the request of the arrested person.
When a person who is arrested, whether on a charge or otherwise, alleges, at the time when he is
produced before a Magistrate or at any time during the period of his detention in custody that the
examination of his body will afford evidence which will disprove the commission by him of any
offence or which will establish the commission by any other person of any offence against his
body, the Magistrate shall, if requested by the arrested person so to do direct the examination of
the body of such person by a registered medical practitioner unless the Magistrate considers that
the request is made for the purpose of vexation or delay or for defeating the ends of justice.

22
Gurbaksha Singh Sibbia v. State of Punjab, AIR 1980 SC 1632.

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 CONCLUSION

To sum up, the power of arrest involves restriction of liberty of a person arrested and therefore,
infringes the basic human rights of liberty. Nevertheless the Constitution of India as well as
International human rights law recognizes the power of the State to arrest any person as a part of
its primary role of maintaining law and order. The Constitution requires a just, fair and reasonable
procedure established by law under which alone such deprivation of liberty is permissible.

Although Article 22 (1) of the Constitution provides that every person placed under arrest shall be
informed as soon as may be the ground of arrest and shall not be denied the right to consult and be
defended by a lawyer of his choice and S.50 of the Code of Criminal Procedure, 1973 Cr. PC
requires a police officer arresting any person to "forthwith communicate to him full particulars of
the offence for which he is arrested or other grounds for such arrest". In actual practice these
requirements are observed more in the breach.

Likewise, the requirement of production of the arrested person before the court promptly which is
mandated both under the Constitution Article22 (2) and the Cr. PC Section 57 is also not adhered
to strictly. A large number of complaints pertaining to Human Rights violations are in the area of
abuse of police powers, particularly those of arrest and detention. Even after the prescribing of
guidelines by the National Human Rights Commission to narrow the gap between law and practice,
curtailing the powers of the police to effectively maintain and enforce law and order and proper
investigation, it has been ineffective to a very large extent.
Hence, there is a dire need for a more stringent step to be taken and enforced to curtail the powers
of arrest by police personnel in actual practice. One of the steps suggested is the formation of the
office of police ombudsmen, as prevalent in the countries of Ireland and Brazil, which have to a
very large extent been successful in controlling the exercise of arbitrary powers of the police and
have helped in upholding the rights of arrested person to a wide extent.

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 BIBLIOGRAPHY

LITERATURE REFERRED

• R.V.Kelkar’s Criminal Procedure, Eastern Book Company

• Ratanlal and Dhirajlal, Code of Criminal Procedure, Lexis Nexis
• Rights of Arrested Person- Case Analysis, Mubashshir Sarshar, National Law University,
Delhi
• Rights of Arrested Person by Smarika Azad, Lex Articles

WEBSITES REFERRED

• http://www.legalservicesindia.com/article/1635/Rights-of-Arrested-
Person.html#:~:text=Article%2022(2)%20of%20the,legal%20practitioner%20of%20his
%20choice.%E2%80%9D
• https://blog.ipleaders.in/rights-arrested-person/
• http://www.legalserviceindia.com/legal/article-1747-arrest-and-rights-of-arrested-
person.html
• http://lawtimesjournal.in/arrested-persons-rights-under-crpc/
• https://shodhganga.inflibnet.ac.in/
• http://ignited.in/a/58203
• https://www.vakilno1.com/legal-news/rights-arrested-person.html
• https://kanwarn.wordpress.com/
• https://tripakshalitigation.com/rights-of-an-arrested-person-in-india/

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