1

GUJARAT NATIONAL LAW UNIVERSITY

ATTORNEY-CLIENT PRIVILEGE UNDER INDIAN EVIDENCE ACT,1872.

SUBMITTED TO: Dr. Jagadeesh Chandra T. G.

(Asst. Professor of Law, GNLU)
SUBJECT: Law of Evidence
SEMESTER: V

SUBMITTED BY:
Lodhi Vishal (19B093) & Kashvi Vachhani (19B172)
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ACKNOWLEDGMENT

We would like to extend our special gratitude to Dr. Jagdeesh Chandra T.G., Assistant Professor
of Law, who gave us the golden opportunity to do this intellectually enriching report on Attorney-
Client Privilege under the Indian Evidence Act which also helped us in doing a lot of research and
enabled learning various new concepts.

During the drafting and research for this project, we had the opportunity to learn about the
admissibility of evidence and the ramifications of it in the broader scheme.
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CONTENT

SR. NO. PARTICULARS PAGE

NO.
1 INTRODUCTION 3

2 PRIVILEGED COMMUNICATIONS UNDER INDIAN STATUTES 3

(DEFINITIONS)
3 A CRITICAL EXAMINATION OF ATTORNEY-CLIENT 5
PRIVILEGE UNDER INDIAN EVIDENCE ACT, 1872

4 BAR COUNCIL OF INDIA RULES 7

5 7
POSITION OF IN-HOUSE COUNSEL

6 LANDMARK CASE DISCUSSING ATTORNEY-CLIENT 8

PRIVILEGE UNDER LITIGATION

7 EXCEPTIONS TO THE RULES OF ATTORNEY-CLIENT 10

PRIVILEGE

8 DEMERIT OF ATTORNEY-CLIENT PRIVILEGE UNDER INDIAN 11

LEGAL SYSTEM

9 CONCLUSION 12

10 REFERENCES
 4

INTRODUCTION

The attorney-client privilege protects a client's right to decline any disclosure of sensitive
information and prevents the attorney from releasing it to a third party. In other words, it's an
agreement between the attorney and the client that any information revealed by the client with the
attorney will not be shared with anyone else. This relates to the client's rights to safeguard their
own interests. It is simply a privilege that exists only for the client's advantage. It allows clients
and lawyers to communicate freely and openly without fear of being exposed or indicted. This
privilege is essential to the legal system. The law is a complicated web of relationships, interests,
and regulations. The premise that people must be able to speak openly with their lawyers for their
interests to be adequately represented is at the heart of this privilege. Every developed legal system
ensures that communications between lawyers and their clients are protected.1

Further, a "privileged professional communication" is a type of communication between a lawyer

and a client that is protected. The Indian Evidence Act, 1872 ("the Act"), protects professional
communications as well as confidential interactions with legal counsel. If the privilege did not
exist, everyone would be forced to rely only on his or her own legal resources. Without any
professional support, a man would not contact an expert or would simply tell his counsel part of
his story.

A strong system of justice administration mainly includes three components: a well-planned body
of law based on the concept of social justice, a judicial hierarchy grounded in law and guided by
high standards of professional conduct, and a generation capable of ensuring fair trials2. The
protection granted between the legal advisor and the client is referred to as privileged professional
communication. The rights available to the client for the preservation of their interests are referred
to as legal privilege or attorney-client privilege. It ensures that the information discussed between
the client and the attorney is protected from incrimination and disclosure. The fundamental goal

1
Legal India and legal India, 'Lawyers In India - Advocates,Law Firms,Attorney Directory,Lawyer,Vakil'
(Legalserviceindia.com, 2021) <https://www.legalserviceindia.com/legal/article-1403-attorney-client-privilege-
under-section-126-of-indian-evidence-act-1872.html https://www.legalserviceindia.com/articles/pc.htm> accessed
21 November 2021.
2
Gauri Kulkarni, ‘Privileged Legal Communication’ (Legal Service India, 10 October 2019)
<ttp://www.legalserviceindia.com/articles/pc.htm> accessed 20th November, 2021.
 5

of this notion is for the client to be able to tell their lawyers anything so that their interests are fully
represented.

Privileged Communications under Indian Statutes (Definitions)

Under the Indian laws, Sections 126 to 129 of the Indian Evidence Act, 1872 deal with privileged
communication that is attached to professional communication between a legal adviser and the
client.

Accordingly, the scope of privilege linked to professional communications in an attorney-client

setting is defined in Section 126 of the Act. It prohibits attorneys from disclosing any interactions
with clients or stating the contents or circumstances of documents in the legal advisor's possession
during and for the duration of the latter's employment with the client.

Section 127 of the Act extends the privilege provided under section 126 to the interpreters, clerks,
and servants of the legal adviser.

While Section 128 of the Act continues to bind the legal adviser from disclosing any information
covered under sec 126 unless the client calls the legal adviser as a witness and questions him on
the same.

Lastly, Section 129 of the Act lays down that no one shall be compelled to disclose to the court
any confidential communication which has taken place between him and his legal professional
advisor unless he offers himself as a witness.

The provision also stipulates that such privilege will be granted if it is in furtherance of any
criminal purpose or if facts come to the attorney's attention that reveals that either a crime or fraud
has been committed since the beginning of the attorney's work on the subject. It makes no
difference whether such barrister, [pleader], attorney or vakil's notice was drawn to such truth by
or on behalf of his client.

In the case of, Memon Hajee Haroon Mohammed v. Abdul Karim3 it was held that a
communication made by the party to their attorney must be secret in nature to claim privilege under

3
Kalikumar Pal v. RajkumarPal 1931 (58) Cal 1379, Para 5.
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Section 126 of the Indian Evidence Act, 1872. Furthermore, prior to the formation of an attorney-
client relationship, no privilege will be granted to such communication. The Bar Council of India
Rules Part VI, Chapter II, Section II, Rule 17 states that an advocate shall not directly or indirectly
commit a breach of an obligation imposed under Section 126 of the Indian Evidence Act, 1872,
thus protecting the spirit of the attorney-client relationship and that any violation of the same would
result in a violation of the Bar Council Rules of India.

It is primarily essential to treat an attorney's perspective apart from that of the client when
determining the scope of the attorney-client privilege under Section 126 of the act. Whether
information or documents are sought from an advocate or his client, the level of protection that
should be offered to the communication varies. Any conversation between an advocate and the
client is protected under Section 126. Yet, there are a few exceptions to this rule, such as when
communication is made for the intention of committing a crime or where a fact noticed in the
course of work indicates that a crime or fraud was committed prior to the start of employment4.
All conversations with an advocate must be kept confidential in order to maintain the attorney-
client relationship.

The privilege provided by Section 126 of the Act continues long after the attorney or advocate's
engagement has ended, but it does not protect communication or advice received after the
employment has ended. This regulation also applies to attorneys' interpreters or agents, who are
subject to the same ban and are entitled to the same immunity as the advocate involved in the
case5. However, any confidential communication or documents can only be released by the
advocate with the client's express authorization. When a client voluntarily gives testimony as a
witness in court, the client can disclose such documents or material if the Court believes it is
essential to explain evidence that the client has already disclosed to an attorney but for no other
purpose. According to Section 23 of the Indian Evidence Act, 1872, no such admission is regarded
relevant in a civil case if it is made on the express condition that no evidence of it be given or when
the court can infer that the parties agreed together that no evidence of it be given.

Nothing in Section 26 of the Act will be construed as exempting any attorney, advocate, or vakil
from giving testimony in any case in which he may be required to give evidence under Section

4
Section 127, the Indian Evidence Act, 1872.
5
PR Ramakrishnan vs. Subbaramma Sastrigal, [(1988) CrLJ 124].
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126 of the Indian Evidence Act, 1872. In India, the attorney-client relationship is limited to the
sharing of information, communication, documents, or advice between the client and advocates
and their agents, with provisions for communication or documents to third parties by the parties
or their attorneys in the case of pending or anticipated litigation. Neither the attorney nor the client
is obligated to explain it to a third party6.

A Critical examination of attorney-client privilege under Indian Evidence Act, 1872

The application of the attorney-client is not absolute, but the relationship has been developed as a
legal notion that preserves the secret communication between the client and their advocate. Section
126 of the Evidence Act contains various ambiguities. Section 126 solely applies to barristers or
attorneys; it does not grant privileges to in-house lawyers. In-house lawyers are not permitted to
practice as advocates or attorneys during their employment, and thus plainly fall outside the scope
of the Act's Section 126.

In Satish Kumar Sharma v. Bar Council of Himachal7, the Supreme Court held that if a full-time
employee is not pleading on behalf of his employer, or if the term of his employment allows him
to perform other functions or is not required to plead, he is merely a government or body corporate
employee. The judgment also cited the Bar Council of India Rules, Part VI, Chapter II, Section
VII, Rule 49, which said that an advocate cannot be a full-time salaried employee of any person,
government, corporation, or corporate entity while practicing8.

In the case of, Municipal Corporation of Greater Bombay v. Vijay Metal Works, the court held
that salaried employees who provide legal advice to their employers are entitled to the same
protection as lawyers or advocates under Sections 126 and 129 of the Indian Evidence Act,
provided that the communication is not made for any illegal purpose. However, The ECJ appears
to have taken the opposite position in the Azko Nobel case. Section 129 of the Act stipulates that
a legal professional advisor may not include a patent agent, therefore limiting the privilege to

6
Sonia Chan, ‘An in-house lawyers right to legal privilege Asia Law’ (lw. Com, May 2008)
<https://www.lw.com/upload/pubcontent/_pdf/pub2251_1.pdf> accessed 20 November, 2021.
7
D.H. Law Associate ‘Attorney Client Privilege in India’ (Newslex, September 2012)
<https://www.irglobal.com/article/dh-law-associates-newsletter-2317/> accessed 20 November, 2021.
8
Municipal Corporation of Greater Bombay vs Vijay Metal Works [(AIR) 1982 Bom 6].
 8

clients exclusively. Another key limitation of Section 126 of the Act is that it protects
communication or information between third parties or clients, as well as between lawyers and
third parties such as technical experts or expert witnesses. A distinction should be made between
the legal advice privilege and the litigation privilege.

Under the Evidence Act of India, communications made for the purpose of getting legal advice are
not protected, while only communications made after the decision to begin suit are protected. An
attorney or advocate cannot withhold personal information, communication, or document from the
public under the RTI Act, and such communication is not entitled to be released. In the case of
Karamjit Singh vs. State9, the court ruled that any information or communication provided by the
client is not subject to access.

Under the Indian Evidence Act, the norm governing the attorney-client relationship is insufficient.
This clause may be used to protect criminals or offenders in the future. It is said that "once a
privilege, always a privilege," which means that communication or information provided by a
client to his attorney during the course of his job is always protected, even after the engagement
ends. However, in specific circumstances like as rape, murder, and crimes relating to the POCSO
Act, Section 126 plays a significant role. For example, if a person has committed rape and it is his
responsibility to provide all necessary information, communication, or documents to his advocate
or attorney regarding such crime during the trial period, his advocate shall not disclose his client's
entire secret or personal information to anyone or to the Court.

It would be against an attorney's professional ethics if he did not keep the correspondence private
or disclose it to the court or police. As a result, Section 126 grants privilege to offenders who may
be prosecuted under the Indian Penal Code but are shielded by the Evidence Act's attorney-client
privilege. Only the client has privilege under Section 126, not legal advisors or attorneys, and only
the client can waive it. It is indeed true that if professional communication is not accorded
privilege, no one will come to the lawyers. However, we can see that this regulation has a
significant gap, in that it protects the customers' secrets on the one hand while also protecting
criminals on the other.

9
Gauri Kulkarni, ‘Privileged Legal Communication’ (Legal Service India, 12th October, 2019)
<http://www.legalserviceindia.com/articles/pc.htm> accessed 20 November 2021.
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Bar Council of India Rules

The Bar Council of India Rules establishes specific norms of professional conduct and etiquette
for all advocates (legal advisers). Part VI, Chapter II, Section II, Rule 17 of the Rules states, "An
advocate shall not, directly or indirectly, commit a breach of the obligations imposed by Section
126 of the Indian Evidence Act," reiterating the spirit of attorney-client privilege, whose violation
will also result in a violation of the Bar Council Rules. Further, Rule 7 and 15 of the Rules on An
Advocate’s Duty towards the Client states:

(1) Not disclose the communications between the client and himself.

(2) An advocate should not misuse or take advantage of the confidence reposed in him by his
client.

An advocate could face disciplinary action if he or she violated the aforementioned Rules. It's vital
to remember that confidential communication between an attorney and a client isn't admissible in
court as evidence.

Position of In-House Counsel

There are several legal issues that are exclusive to various sorts of businesses. These companies
hire an in-house lawyer to handle any legal issues that arise. In-house counsel might work as a
lawyer or an advocate for the company. Because Section 126 of the Indian Evidence Act only
applies to advocates, barristers, pleaders, and vakils, if the in-house counsel is appointed as a
lawyer, he is not bound by the attorney-client privileges. As a result, any communication between
the in-house counsel and the company's board will not be protected as confidential.

However, an in-house counsel's employment contract usually includes a confidentiality clause that
ensures that any information is kept private. However, it's important to remember that a
"confidentiality clause" and "privileged communication" are two different things, and a client can
sue in-house counsel for damages if the confidentiality provision is breached, subject to specific
contractual exceptions.
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In the case of, Satish Kumar Sharma v. Bar Council of Himachal Pradesh10 (AIR 2001 SC 509)
the Supreme Court laid down that, "If a full-time employee is not pleading on behalf of his
employer, or if his employment contract stipulates that he is not required to act or plead but is
required to perform other duties, he no longer qualifies as an advocate. The latter is subsequently
reduced to a government or business employee".

The judgment also cites Part VI, Chapter II, Section VII, Rule 49 of the Bar Council of India Rules,
which states that "an advocate shall not be a full-time salaried employee of any person,
government, firm, corporation or concern, so long as he continues to practice" and that "an
advocate shall not be a full-time salaried employee of any person, government, firm, corporation
or concern, so long as he continues to practice and shall, on taking up any such employment,
intimate the A full-time salaried employee cannot be an advocate. Only if the person is a Law
Officer of the Central Government of a State or of any public corporation authorized to be enrolled
in the Bar is there an exception”.

Subsequently, in the case of Municipal Corporation of Greater Bombay v. Vijay Metal Works11,
the court held that, "a salaried employee who advises his employer on all legal questions and also
other legal matters would get the same protection as others, viz., barrister, attorney, pleader, or
vakil, under Ss.126 and 129, and, therefore, any communication made in confidence to him by his
employer seeking legal advice or by him to his employer giving legal advice should get the same
protection as mentioned in the Act”.

As a result, in India, interactions between clients and in-house lawyers would have to be
scrutinized to see if the in-house counsel is a full-time salaried employee as defined by Bar Council
of India Rules Part VI, Chapter II, Section VII, Rule 49.

10
Satish Kumar Sharma v. Bar Council of Himachal Pradesh [AIR (2001) SC 509].
11
Municipal Corporation of Greater Bombay vs Vijay Metal Works [(AIR) 1982 Bom 6].
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Landmark case discussing attorney-client privilege under Litigation

A significant judgment on legal advice privilege was recently determined by the Court of Appeal
in England. The judgment in "Three Rivers District Council and others v. Governor & Company
of the Bank of England" is likely to have a significant impact on how much privilege is handled,
and companies may need to rethink their internal structures as a result.

Factual Matrix: The issue of legal advice privilege arose during the continuing litigation between
the BCCI's liquidators and the Bank of England. Following the collapse of the BCCI in 1991, the
government established the Bingham Inquiry to look into the Bank of England's supervision of the
company and to see if the actions taken by UK authorities were appropriate and timely. The
Bingham Inquiry Unit (BIU), a three-person internal organization within the Bank of England, was
established to handle all communications between the Bank of England and the Bingham Inquiry.
During the investigation, the Bank of England's counsel advised the bank.

Following the fall of the BCCI, the liquidators filed a lawsuit against the Bank of England for
misfeasance in public office relating to circumstances surrounding the collapse of the BCCI. The
liquidators sought disclosure of certain papers created by Bank employees and ex-workers that had
become available at the time of the Bingham Inquiry, which the Court of Appeal categorized as
follows:

(i) documents prepared by Bank employees and sent to the bank's solicitors;

(ii) documents prepared by Bank employees with the dominant purpose of the Bank obtaining legal
advice but not sent to the bank's solicitors;

(iii) documents prepared by Bank employees without the dominant purpose of the Bank obtaining
legal advice but sent to the bank's solicitors;

(iv) documents prepared by the bank's employees without the dominant purpose of the Bank
obtaining legal advice but sent to the bank's solicitors.

The Bank declined to release these records, claiming that the legal advice privilege applied to
them. At the first instance, the claim of privilege was upheld. The Court of Appeal, on the other
hand, overturned the judgment, ruling that the records were not protected by the privilege. The
 12

Court of Appeal's decision upheld the fundamental legal concept that papers passed directly
between a lawyer acting in his professional capacity and a client are protected by the legal advice
privilege if the primary objective of the communication is to get legal advice. The Court of Appeal
has addressed various key aspects of the legal advice privilege, including:

1) Who is the client?

2) What constitutes legal advice privilege?
3) Whether evidential material obtained from the employees prior to the communication is
excluded from privilege?

1. Who is the client?

The Court took a restrictive view of who qualifies as a client as opposed to a client’s
employee. While the Court acknowledged that a company can only act through its workers,
it decided that this was insufficient to safeguard all employee communications with the
employer's counsel. However, the Court provided no guidance as to when an employee is
considered a customer and when they are not.

2. What constitutes legal advice privilege?

This question was left unanswered, but the Court suggested that obtaining information for
employees and ex-employees in the context of an investigation might be for the primary
purpose of enabling evidence to be presented to the investigation rather than to obtain legal
advice, and thus fall outside the privilege once again. As a result, legal counsel has to be
separated from other types of aid that a lawyer could offer.

3. Whether evidential material obtained from the employees prior to the communication is
excluded from privilege?
Preparatory documentation appeared to be treated by the Court as little more than raw
material from which the client may seek legal guidance later. As a result of the Court's
ruling, all following communications may not be covered by the legal advice privilege:
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i. If the client is not recognized to be the client, communication and documents

generated by the client's workers with the primary goal of getting legal counsel but
not forwarded to the client's lawyers.

ii. If the client is not recognized to be the client, communication and documents
generated by the client's workers with the primary goal of getting legal advice,
which are intended to be delivered to and are actually sent to the client's lawyers.

iii. Communication and documents made by the client's workers with the primary
purpose of obtaining legal advice, which are meant to be provided to and are sent
to the client's lawyers if the client is not recognized as the client.

iv. Communication and documents generated by independent third parties (including

those mentioned in the third item) with the primary goal of getting legal advice for
a client and forwarded to the client's legal counsel by the third party.

In order to put these standards into practice, it must be determined whether the investigation or
regulatory proceedings are adversarial or non-adversarial. If the dispute is adversarial, the full
scope of litigation privilege would apply. Only legal advice privilege would be used if the case
was non-adversarial. The Court of Appeal did, however, point out that the legal advice's scope is
not as obvious as one might assume.

Exceptions to the rules of attorney-client privilege

Some of the common exceptions to attorney-client privilege are as follows:

• Death of a Client: When a testator-client dies, the privilege may be violated if there is
litigation between the decedent's heirs, legatees, or any parties claiming under the deceased
client.
• Crime or Fraud Exception: The communication is not privileged if a client seeks legal
counsel to aid in the commission of a crime or fraud, or the post-commission concealment
of the crime or fraud. If a client has committed a criminal or committed fraud and then
 14

seeks legal advice, such discussions are private unless the client is considering concealing
the crime or fraud.
• Common Interest Exception: If two parties are represented by the same attorney in a single
legal proceeding, neither client may use the attorney-client privilege against the other in
later litigation if the current litigation relates to the previous joint representation's subject
matter.

Further, Section 126 does not protect every communication made by a person to his legal counsel
from disclosure; rather, only those communications made in confidence with the intent of
obtaining professional advice are privileged. It's also worth noting that the privilege only applies
after the pleader-client relationship is established, not before. Also, communication with the
lawyer must be done in the position of a professional advisor, not a friend.

Sections 126, 27 and 128 of the Act have a different scope than Section 129. The former Sections
make it illegal for a legal adviser to reveal professional communication. Section 129 applies when
a customer is questioned, whether or not he is a party to a lawsuit. Section 129 provides that no
one can be forced to reveal any communication between himself and his legal counsel in court
unless he presents himself as a witness. As a result, Section 129 protects a person from being
subjected to coercive proceedings. Third parties, such as consultants hired to assist in the
preparation of the case for trial, may be granted immunity. However, once the information has
gotten out, it should not be kept out of Court due to its sensitivity, any more than any other
confidential subject. Also, if a party voluntarily becomes a witness, he may be forced to divulge
everything necessary for the true comprehension of his testimony if the Court so orders.

Demerit of attorney-client privilege under Indian Legal System

One of the most significant disadvantages of attorney-client privilege is that it is completely reliant
on loyalty. There are two sides to every coin. Because loyalty has a positive connotation, it can
also be abused. An attorney who is devoted to his client can be disloyal to the state, resulting in
unfair trials and injustice; yet, an attorney who is disloyal to his own client can result in the loss
 15

of his client's reputation, which can lead to defamation. In any situation, an attorney owes it to his
client not to reveal any secret information about the proceedings.

As seen in the case of M. Yovas & others v. Immanuel Joseph & others, the opposing party's
advocate was called as a witness to testify whether one of the plaintiffs had sent a letter after the
commencement of the proceedings between the same parties, and secondly, whether the advocate
had offered the plaintiff any compromise proposal. In this case, the Kerala High Court decided
that refusing to be a witness in a court of law was proper.

In addition, Sec 126 limits privilege to the client alone. Furthermore, the provision excludes patent
agents, although in Sec 129, the term "legal professional advisor" does not include a patent agent.
Communication between a lawyer and a client is privileged under Section 126 of the Evidence
Act, but contact between a client and a third person, such as a technical expert or a witness, is not
privileged unless the communication is made to get legal advice.

Conclusion

The need for attorney-client privilege is undisputed in this day and age, but the law in itself needs
several amendments to function with efficiency and serve to the best of the citizens. It is self-
evident that the relationship of the attorney and his client is seen as a privileged document that is
critical to the successful resolution of the dispute. A lawyer or attorney has a moral as well as a
legal obligation to maintain the trust placed in him by his clients by not disclosing their personal
information, communications, or documents to anyone in the course or purpose of their job. If such
communication is not protected, no one will consult an advocate or attorney for defense or
enforcement of his rights, and no one will come to court to seek redress or defend himself.

The Indian rule governing the attorney-client relationship is nearly a century old, but it is still
woefully inadequate to give the level of protection that one would expect in a modern relationship
with an attorney. The wordings linked to in-house lawyers should be made clear and they should
be covered under the purview of this regulation, among other limitations and downsides of this
rule. Furthermore, any communication sent to a third party is completely unprotected. This rule is
believed to be highly strict in nature, and it may function to the exclusion of the truth on occasion.
 16

Yet, due to the rigidity of the Act, it may afford protection to criminals who have committed a
crime and sought restitution in court. In such cases, Section 126 of the Evidence Act protects the
client, and an advocate's moral and professional ethics should prohibit him from disclosing any
communication made by his client during the course of his work. As a result, it is concluded that
as time passes, the complexity of legal procedures increases at a rapid rate, necessitating the
adjustment or modification of specific wordings in this clause in order to bring it under the purview
of the attorney-client relationship.

Notably, A lawyer has a moral obligation to uphold the trust placed in him by not disclosing
communications made to him in professional confidence, i.e. during and for the purpose of his
employment, by or on behalf of his client, or to state the contents or conditions of documents with
which he has become acquainted during his professional employment without his client's consent.
If such communications were not protected, no one would dare to see a professional adviser in
order to defend himself or enforce his rights, and no one could safely enter a courtroom to seek
redress or defend himself.
 17

REFERENCES

E-Sources

1. Gauri Kulkarni, ‘Privileged Legal Communication’ (Legal Service India, 10 October 2019)
<ttp://www.legalserviceindia.com/articles/pc.htm> accessed 20th November, 2021.

2. Sonia Chan, ‘An in-house lawyers right to legal privilege Asia Law’ (lw. Com, May 2008)
<https://www.lw.com/upload/pubcontent/_pdf/pub2251_1.pdf> accessed 20 November, 2021.
1
3. D.H. Law Associate ‘Attorney Client Privilege in India’ (Newslex, September 2012)
<https://www.irglobal.com/article/dh-law-associates-newsletter-2317/> accessed 20
November, 2021.

4. India l, and India l, 'Lawyers In India - Advocates,Law Firms,Attorney

Directory,Lawyer,Vakil' (Legalserviceindia.com, 2021)
<https://www.legalserviceindia.com/legal/article-1403-attorney-client-privilege-under-
section-126-of-indian-evidence-act-1872.html
https://www.legalserviceindia.com/articles/pc.htm> accessed 21 November 2021.

Cases

1. Kalikumar Pal v. RajkumarPal 1931 (58) Cal 1379,

2. PR Ramakrishnan vs. Subbaramma Sastrigal, [(1988) CrLJ 124].
3. Municipal Corporation of Greater Bombay vs Vijay Metal Works [(AIR) 1982 Bom 6].

4. Satish Kumar Sharma v. Bar Council of Himachal Pradesh [AIR (2001) SC 509].