Powers of police under Code of Criminal Procedure

Powers of Police are very wide and are based on two main functions of Police. These functions are Maintaining of Law and Order and Investigation of illegal activities. The Police Act defines Police as an instrument for prevention and detection of Crime.[i] The Police define most of its powers from the Code of Criminal Procedure, 1973 and the Police Act, 1861. Following are some of the Powers of Police;

Powers of Police to Investigate

The Investigation of Police starts when;

• When someone lodges an FIR(First Information Report).[ii]
• When a Police officer suspects commission of a cognizable offense.[iii]
• Whenever a competent magistrate orders the Police.[iv]

The Police have the power to investigate Cognizable as well as Non-Cognizable offenses.[v] Police officers can investigate Cognizable offenses without the magistrate’s orders. If a Police officer suspects the commission of a cognizable offense, he has the power to investigate under s 157 without the filing of FIR.[vi] Police also have the power to require the presence of witnesses in order to pursue an investigation. Males under 15 years and over 60 years of age, females, or mentally/physically disabled persons shall not be required to attend as a witness except for their residences.[vii] Police can examine these witnesses as well.[viii] Police also has the power to conduct a medical examination of rape victims.[ix]

Powers of Police to Arrest

Police have the power to arrest the persons as well. The Police can make the arrests for both Cognizable as well as Non-cognizable offenses. For non-cognizable offenses, a Police officer has no authority to arrest a person without warrant. However, a Police officer can arrest a person without a warrant for Cognizable offenses.[x] In case of adequate grounds, the magistrate may extend the period of detention to 15 days. Also, the Police have the power to release the accused in case of lack of evidence.[xi]

Power of Preventive Arrest

The preventive arrest is the detaining of a person who is likely to commit an offense. It is a highly debated topic all over the world. In India, s 107 and s 151 of CrPC give the powers of Police for preventive detention mainly. In case an Executive Magistrate recieves information that a person is likely to commit a breach of peace, he may order him to show cause. The magistrate may also order him to execute a bond to keep peace in such period.[xii] It is the duty of the Police to prevent Cognizable offenses.[xiii] Also, the Police have the power to arrest a person without a warrant or an order from the magistrate in cases they have knowledge that such person is planning to commit a cognizable offense.[xiv]

Though, the Police can only make the arrest if it is the only way to prevent such offense. The idea behind these provisions is to avert the commission of an offense. The constitutional validity of these Sections has always been in controversy. Many persons have filed petitions questioning the validity of the provisions of the preventive arrest.[xv] In a case, certain landowners of MP were protesting after being affected by the Sardar Sarovar Project. Even though they posed no threat to commit cognizable offenses but were still beaten up and arrested. The Court held that this was in violation of Article 21 of the Constitution.[xvi] However, s 151 already mentions the grounds of the arrests. Also, preventive arrest laws are given legal recognition under the Constitution of India.[xvii] So, these provisions cannot be said to be in violation of Articles 21 and 22.[xviii]

Read Also: Everything You Need to Know About Criminal Law In India

Abuse of Powers of Police under Preventive Arrest

There have been many instances when these powers have been misused by the Police as well. This was because of the arbitrary and unjust use of these powers. In a case, the persons arrested under s 107 and 151 were not given a chance to be heard for 6 days. The case was tried without any scrutiny under issue. And, no order was issued under s 111 of the CrPC. The Karnataka HC held that this process was arbitrary and unjust as the Police didn’t follow proper procedure.[xix]

In the case of Ahmed Noormohmed Bhatti v State of Gujarat[xx], it was suggested that the guidelines given for the detainees must be followed in cases of Preventive arrests as well. The Court gave these guidelines in the case of D K Basu v State of West Bengal. The Court also held that a provision is not unreasonable or unconstitutional because of arbitrary exercise of it by the authorities. Proper scrutiny of each case is to be done to determine whether the arrest is unconstitutional or not.

Conclusion

Police is an important part of a healthy society. We always remember Police first when we are in trouble or under a threat. The powers of the Police are invested in them to have a smooth and healthy society. But, they ultimately have a duty to protects the rights and interests of the individuals. Due to this, they must use their powers with the utmost care and caution. The author notes that there are many instances where the Police have misused these provisions and there should be a proper check on these practices.

[i] The Police Act 1861, preamble.

[ii] Code of Criminal Procedure 1973, s 154.

[iii] ibid, s 157(1), 156(1).

[iv] Code of Criminal Procedure 1973, s 156(3).

[v] ibid, s 155, 156.

[vi] State of Maharashtra v Sarangdharsingh Shivdassingh Chavan (2011) 1 SCC 577.

[vii] Code of Criminal Procedure 1973, s 160.

[viii] ibid, s 161.

[ix] Code of Criminal Procedure 1973, s 164A.

[x] ibid, s 2(c), 2(l).

[xi] Code of Criminal Procedure 1973, s 169.

[xii] ibid, s 107.

[xiii] Code of Criminal Procedure 1973, s 149.

[xiv] ibid, s 151.

[xv] ‘Role of Police and its power to Investigate’ (Lawnn, 14 February 2017) <https://lawnn.com/role-police-power-investigate/> accessed 12 December 2018.

[xvi] Medha Patkar v State (2011) 8 SCC 55.

[xvii] Constitution of India 1950, a 22.

[xviii] Ahmed Noormohmed Bhatti v State of Gujarat (1999) SCC (Cri) 1014.

[xix] Sathi Sundaresh v The State PSI of Moodigere 2007 (4) CrLJ 649.

[xx] Supra Note xviii.

Public Prosecutor Meaning and Functions

INTRODUCTION

Public prosecutors are appointed in almost all the common law countries as an agent of the Attorney General to represent the interest of general people in the criminal justice system. They serve as a foundation of the Rule of Law’s principle that everyone should have an opportunity of being heard (audi alteram partem). The prosecutors are duty-bound to act in a way that strikes the right balance between the competing interests of conviction of guilty, protection of citizen’s rights and freedoms and protection of the public from crimes.

DEFINITION OF PUBLIC PROSECUTOR

Public Prosecutor has been defined in the Code of Criminal Procedure under Section 2 (u) as under:-

“Public prosecutor meaning is a person appointed under Section 24; it further includes any person acting under the directions of a Public Prosecutor.”

In India, the Prosecutors act on the directions of the Judge. Being an officer of the court, the Prosecutor is required to act in public interest and not seeking conviction by hook or crook. In Babu v. State of Kerala[1], it was stated that Public Prosecutors are the ministers of justice whose job is to assist the state to administer justice.

When Section 2(u) is read with Section 24, the following hierarchy can be traced:-

Public Prosecutor appointed by the Central Government->Public Prosecutor appointed by the State Government->Additional Public Prosecutor appointed by the State->Special Public Prosecutor appointed by the Central Government->Special Public Prosecutor appointed by the State Government.

Here, it is pertinent to note that according to the pattern prescribed by Criminal Procedure Code, the Public Prosecutors (including Additional Public Prosecutors) are required to conduct criminal proceedings in the Sessions and the High Court, while the Assistant Public Prosecutors are required to conduct proceedings on the behalf of the Magistrate’s court.

RATIONALE BEHIND THE ESTABLISHMENT OF THE OFFICE OF PUBLIC PROSECUTOR

The rationale behind the appointment of Public Prosecution is that crimes committed by an individual or a group are deemed to have been committed against society. Hence it is the duty of the state to bring justice to the people or group affected by the crime. In India, the Criminal Justice system is required to function within the boundaries of the Indian Constitution, which means the Public Prosecutor needs to follow the following principles:-

1. Presumption of innocence, until proven guilty beyond a reasonable doubt,
2. Right to life and personal liberty, until deprived by a procedure established by law[2],
3. Equality before the law[3],
4. Protection against double jeopardy[4],
5. Protection against ex-post-facto law[5],
6. Protection against self- incrimination[6],

What is The Role of Public Prosecutor

The Directorate of Prosecution is established with the objective of exercising supervision and scrutiny over all the prosecuting agencies. It is headed by a Director who is assisted by various subordinate rank officers and ministerial staff. The role of Public Prosecutor is the following in the investigation process:-

1. Appearing in the Court and obtaining an arrest warrant,
2. Obtaining search warrants to search specified premises,
3. Obtaining Police custody remand for custodial interrogation of the accused[7],
4. Initiating proceeding for declaring a non-traceable accused a proclaimed offender[8],
5. Recording his advice in the Police file regarding the advisability of the prosecution.

PUBLIC PROSECUTOR Functions ACCORDING TO POST

Assistant Public Prosecutor: They scrutinize the charge sheets prepared by the investigating agencies and submit the discharge/ acquittal. They are further in charge of evaluating the evidence and filing revision petitions as well as conducting cases in the Court of Metropolitan Magistrates.

Additional Prosecutor: They conduct cases in the Sessions Court.

Chief Prosecutor: They supervise the work of Assistant Public Prosecutor in the Metropolitan Magistrate’s Court.

Public Prosecutor: They supervise the work of Additional Public Prosecutor in the Sessions Court.

ROLE OF THE PUBLIC PROSECUTOR DURING TRIALS

1. Speedy trial: The Public Prosecutor being an officer of the Court can play the role of ensuring a speedy trial, which forms an essential part of the Right to Life enshrined under Article 21. The Prosecutors are responsible for ensuring that all the essential witnesses are called and none of the witnesses are left non-examined, further making sure that all the required documents are produced before the court in time while ensuring that no uncalled for the delay is caused to the proceeding.
2. Sentencing: After the accused is proven guilty, the defense counsel and the Public Prosecutor are called upon to decide the quantum of the punishment. At this stage, the Public Prosecutor is required to exercise his discretion of arguing for an adequate punishment while keeping in view the gravity of the offence, the facts and the circumstances of the case. It is very important at this stage that the Prosecutor help the Court arrive at a judicious decision.

PRESENT STATE OF PUBLIC PROSECUTORS IN INDIA

The office of the Public Prosecutors in India suffers from various incompetencies due to rigid and various unnecessary formalities. Most of the offices have inadequate staff and infrastructure

SUGGESTIONS TO IMPROVE THE POSITION OF PROSECUTORS

1. The foremost problem is lack of quality law education in most of the Law Colleges in India.
2. Further, the earnings are very low as compared to the ones that can be earned in open markets. The only way to remedy this situation is by improving the salary structure.
3. A national-level institute needs to be set up to impart proper training upon the aspiring candidates.

CONCLUSION

In the final analysis, a Public Prosecutor is an officer of the Court assisting in just and equitable impartation of justice. He is required to be fair to the opposite party while trying to act for the good of society. The guiding principle of any Prosecutor should be justice, equity, and a good conscience and not just the letter of law.

[1] (1984 KLT) 165

[2] Article 21 of the Indian Constitution.

[3] Article 14 of the Indian Constitution.

[4] Article 20 (2) of the Indian Constitution.

[5] Article 20 (1) of the Indian Constitution.

[6] Article 20 (3) of the Indian Constitution.

[7] Section 167 of Cr. P.C.

[8] Section 82 of Cr.P.C.

Section 415 of the Indian Penal Code

Cheating is that offense which is understood even by a layman. Often people use the term ‘cheating’ whereby they mean something to be deceitful or fraudulent. Cheating is considered as a wrong act when done, even in some of the trivial issues. Section 415 of IPC (India Penal Code), 1860 defines ‘Cheating’ and this article would be discussing the legal definition and legal aspect of the offense of cheating.

Section 415 – Cheating

Cheating is defined under Chapter XVII which deals with ‘Offences against Property‘ under Section 415 as follows-

Cheating.—Whoever, by deceiving any person, fraudulently or dishonestly induces the person so deceived to deliver any proper­ty to any person, or to consent that any person shall retain any property, or intentionally induces the person so deceived to do or omit to do anything which he would not do or omit if he were not so deceived, and which act or omission causes or is likely to cause damage or harm to that person in body, mind, reputation or property, is said to “cheat”.

Explanation.—A dishonest concealment of facts is a deception within the meaning of this section.[1]

From the above-mentioned definition, some of the basic elements of cheating are as follows-

Fraudulently  

The act should either be fraudulent or dishonest to be termed as under the offense of cheating. The term ‘fraudulently’ is defined under Section 25 of the IPC.

“A person is said to do a thing fraudulently if he does that thing with intent to defraud but not otherwise.”[2]

Acting dishonestly

The intention of the wrongdoer in every criminal offense is of great importance. Therefore, in cheating, also the person who commits the offense should act dishonestly. The term ‘dishonesty’ is defined under Section 24 of the IPC.

“Whoever does anything with the intention of causing wrongful gain to one person or wrongful loss to another person, is said to do that thing “dishonestly”.[3]

Property

Section 415 comes under Chapter XVII, which makes the offense of Cheating that is committed against property.

Deceive

The accused must deceive the person in such a way that he is induced to deliver any property or gives consent to the accused to retain a property that he posses. Also, it is very important to note down here that the deception should be with a dishonest or fraudulent intention.[4]

All the elements of cheating specified under Section 415 should be connected to each other in order to make an offense of cheating.

As per the Supreme Court very clearly held that the crux of the offense of cheating is the intention of the person who induces the victim of his representation. The nature of the transaction is irrelevant, which would become decisive in discerning whether there was the commission of an offense or not.[5]

The Supreme Court in a case held that in order to convict a person under the offense of cheating there should be the pre-existing fraudulent or dishonest intention of the accused from the beginning whereas in case of breach of contract the dishonest intention is generally not present at the beginning of the agreement. [6]

Punishment of Cheating

Cheating is punishable under section 417, and the punishment for cheating is imprisonment up to 1 year or fine or both. [7]Imprisonment depends upon the cheating and quantum of the act. If the act is grave, imprisonment and fine, both can be awarded. Whereas, when the act committed is not grave imprisonment is generally not imposed.

Difference between Cheating and Fraud

The offense of cheating and fraud are almost similar, and therefore, sometimes there is confusion between the two. It is very important to know the differences between the two.

1. The offense of Cheating is mentioned under section 415-420 of the Indian Penal Code, 1860, whereas, fraud is mentioned under 421-424 of the Indian Penal Code, 1860.
2. Usually, cheating is committed to obtaining some advantage from a person. Fraud is committed to gain an advantage by another’s loss.
3. Fraud basically is confined to contract cases, but cheating has a wide ambit.

Conclusion

The offense of Cheating, which is very common, includes two main elements, that is deception and inducement. Sometimes cheating is confused with fraud or other civil or criminal offense, but it differs from all of them in one way or the other. Therefore, the conceptual understanding of the offense of cheating becomes very important. Apart from section 415, another section related to cheating are also important.

[1] Indian Penal Code, 1860, s. 415.

[2] Indian Penal Code,1860, s. 25.

[3] Indian Penal Code, 1860, s. 24.

[4] A. Pareed Pillai v State (1973) SC 326.

[5] Rajesh Bajaj v. NCT of Delhi and Ors. (1999) SC 1216.

[6] S.W. Palanitkar V. State of Bihar 2001(10) TMI 1150.

[7] Indian Penal Code, s. 417.

Section 34 of the Indian Penal Code, 1860

Introduction

Section 34 of the Indian Penal Code talks about the joint liability of persons involved in a criminal act. It says that if more than one person is involved in a criminal act done to satisfy a common intention, then each of such persons will be liable in the same way as if it was done by him alone.

The ingredients of Section 34 are as follows

• There should be a criminal act;
• Several persons should do the act;
• The criminal act must be done to satisfy a common intention of all;
• There must be actual participation of all the persons in some way or the other in furthering the common intention.

Common Intention

When the Indian Penal Code was enacted in 1860, Section 34 at that time did not include the provision of common intention, and later an amendment was made in the year 1870 to include it. Intention occupies a very crucial place in criminal law. The term ‘intention’ is not defined anywhere in the Indian Penal Code, but Section 34 of it deals with common intention. It implies a pre-decided plan and acting in accordance to execute that plan. It comes into the picture before the commission of the act.

Section 34 is limited to a situation, where an offense requires a particular criminal intention or knowledge and is committed by more than one person who shares that intention. Each person who participates in the act with such knowledge or intention will be liable in the same way as if it were done by him exclusively with that intention or knowledge. The liability of all the individuals involved in this circumstance is called ‘Joint Liability.’

Joint Liability

Joint liability occurs in the case when there is the existence of common intention in the criminal act done. If it can be shown that it was done by one of the accused persons in furtherance of the common intention of all, then the liability for the act may be imposed on any one of the persons in the same manner as if the act were done by him in his capacity. Court decisions have emphasized on the point that meeting of minds need not be something always very much before the incident, but could be something that may develop on the spot, at the very moment when the crime is being committed.

Proving that every one of the persons was involved in the actual act is irrelevant. The case of Barendra Kumar Ghosh v. King Emperor is one of the most important and earliest cases where the court convicted another person for the act of another done in fulfillment of common intention. A group of armed persons had entered the police station and demanded money from the postmaster, where he was counting it. They fired from the pistol at him, due to which he died on the spot. All of the accused were able to escape without taking money. The Police were able to catch Barendra Kumar Ghosh who was standing outside the post office keeping a check. Barendra on being arrested contended that he was only standing as a guard, but the Calcutta high court convicted him for the murder of the postmaster. His appeal to the Privy Council was also rejected.

There is also a general rule in the criminal jurisprudence that the courts cannot distinguish between the people involved in an activity and it is impossible to see what part is played by whom in the commission of the act, so each person is held jointly liable for the acts of another.

Common intention versus Similar Intention

A common intention can only be said to be formed when the intention of one is known to all others and shared by them. It does not mean the similar intention of several persons formed at the moment. The mere presence of the accused together is not sufficient to form a common intention to commit the offense. It is necessary that the intention of each one of ‘several persons’ be known to each other for constituting common intention; otherwise, it will be a similar intention. Similar intention can happen for several persons at the same time.

The distinction between a common intention and similar intention is a real one and if overlooked by courts, may lead to a miscarriage of justice. Section 34 can be invoked only when the accused shares a common intention and not one a similar intention. Unless the common intention is proved, individuals will be liable for their actions only. If there occurs any doubt, the benefit of the doubt is given to the accused.

Conclusion 

Section 34 does not lay down a separate offense but defines the liabilities. Therefore, it is always read with other sections for framing of charges or while deciding the punishment. The maximum sentence for an offense would depend upon the main offense along with which Section 34 is applied. To bring this section into effect a prior meeting of minds need not necessarily be proved, but it may well develop on the spot as between several persons and could be decided based on the facts and circumstances of each case. There must be an ultimate objective, the fulfillment of which should be the goal of each person involved.

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You Will Never Thought That Knowing 5 Top White Collar Crime Cases In India You Never Know Could Be So Beneficial!

What is White Collar Crime?

White–collar crime or a corporate crime refers to financially motivated, nonviolent crime committed by government and businesses professionals. Below are some of the top 5 white collar crime cases in India.

1. Harshad Mehta Securities Fraud (1988-1995)  

Protagonist – Harshad Mehta 

Harshad Mehta was a stockbroker, and he established his security firm in 1990, “ Grow More Research & Asset Management Limited”. He was a reputed name in the stock market, and is considered the ‘Sultan of Dalal Street’, investors blindly followed Mehta’s footsteps.[1] He took a loan of huge amount from the bank and purchased the scrips at high prices, thereby creating a false market. He misused his status and manipulated the stock prices of certain scrips for his gain.[2] This resulted in unnatural pumping of money in the stock markets causing an abnormal rise in the price of these shares. This act of Harshad Mehta though being immoral was not illegal. The problem arose when Mehta obtained capital to invest in the stock market by misappropriating bank’s money. This misappropriation of money falls in the purview of money laundering. He earned approximately ₹ 5000 crores.[3] The then renowned journalist Sucheta Dalal exposed this scam. This unabated selling caused the market to loose ₹ 0.1 million in a day. This was the biggest ever crash which the Indian stock market had ever experienced. To curtail such transaction various changes were brought in SEBI rules and regulations.

2. Satyam Scandal: biggest ever corporate accounting fraud

Protagonist – B. Ramalingam Raju

This scam came into light on 7^th January, 20009 by way of confession letter written by B. Ramalingam Raju (Founder and chairman of Satyam Computers Services Limited) published in Times of India. The letter confessed about manipulating his books of account by overstating the assets and understating liabilities.[4]

The books of accounts are the reflection of the company’s financial standing. They act as an important tool on which investors can rely on before investing their money. Accounts books were manipulated to cheat investors and shareholders.

The whole scam cost approximately ₹14,000 crore and is considered to be an important factor which contributed to the recession of 2009.[5]

In this scandal, SEBI hit back strongly, holding Ramalinga Raju and nine major associates and guilty of insider trading, indulging in fraudulent and unfair trade practices. SEBI directed accused to pay approximately ₹3000 crore within 45 days and also debarred them from accessing the security markets in any way for 14 years.[6] SEBI managed to lash back strongly to ensure such a scam never happened again.

3. Ketan Parekh Security Scam

Protagonist – Ketan Parekh  

Parekh was involved in circular trading and stock manipulation through 1999-2001. He borrowed from banks like Global trust Bank and Madhavpura Mercantile Co-operative bank and manipulated a host of stocks known as K-10 stocks.[7] The scandal amount was approximately ₹ 1,250 Crore. He has spent only one year in jail, but he has been debarred from trading in the Indian Stock market till 2017.

Although his name continues to haunt the street as he has been accused of playing from backstage. An Intelligence Bureau Report alleged Parekh and his associates to be engaged in circular and insider trading through front entities.

4. Saradha chit fund case

Protagonist- Sudipta Sen  

Saradha Group financial Scandal was a major financial scam and alleged political scandal caused by the collapse of Ponzi scheme run by Saradha Group, a consortium of 200 private companies that were believed to be running collective investment schemes popularly and wrongly referred to as Chit Fund.[8] This group collected around ₹200 to ₹300 billion from over 1.7 million depositors, promising a multiplied hefty sum in return in the form of cash or real estate and other assets.[9]

At least 10 Saradha group entities were alleged for committing fraud through public money-pooling activities. Amidst continuing public protest against the group’s alleged fraudulent activities, SEBI barred Saradha Realty India and its managing director Sudipta Sen from the securities market till it winds up all the Collective Investment Schemes (CIS) and makes the refund, as the same amounts to CIS Violation.[10]

The central government through income tax department and Enforcement Directorate launched a multi-agency probe to investigate the Saradha Scam and similar Ponzi scheme. Later, in May 2014 Supreme Court of India, alleging possible international money laundering, severe regulatory failures an alleged political nexus, referred this case to CBI, India’s federal investigation agency.[11] Many prominent personalities were arrested for their involvement in the scam including two Members of Parliament- Kunal Ghosh, Srinjoy Bose, former West Bengal director general of police- Rajat Majumdar, a top football club official Debabrata Sarkar, Sports and Transport minister in the Trinamool Congress government Madan Mitra.

This scam is often compared to the Sanchayita investment scam, a multi-crore rupees scam that occurred in West Bengal in the 1970s, complaints related to the same have to lead to the formation of Prize Chits and Money Circulation Schemes (Banning) Act, 1968.[12]

5. Punjab National Bank Fraud

Protagonist- Nirav Modi  

Nirav Modi is a diamantaire, elite jewelry designer and India’s 85^th richest person.

Bank said that Modi and the companies linked to him colluded with its officials to get guarantees or Letter of Undertaking to help fund buyer’s credit from other overseas banks.[13]

PNB’s preliminary investigation showed that two officials of the bank had fraudulently issued Lou’s to the said firms without following the due procedure. These Los were then transmitted across the SWIFT messaging system, based on which the credit was offered to the said firms.[14]

PNB alleged that the funds ostensibly so raised for the purchase and sale of diamonds were not used for the purpose.

PNB issued to the stock exchange, about the detection of the fraudulent and unauthorized transaction. PNB has incurred $1.8 billion fraud, one of the largest to be detected in Indian Banking Sector.[15]

Read Also: Taxpayers Don’t Fall For These Types of Tax Scams in India

[1] “THE GROWTH OF SEBI – FROM HARSHAD MEHTA TO SUBRATA ROY” (PDF) <https://lawsdocbox.com/Legal_Issues/73899378-The-growth-of-sebi-from-harshad-mehta-to-subrata-roy.html> accessed May 13, 2019.

[2] Ibid.

[3] Ibid.

[4] Datta D and Datta D, “Ramalinga Raju And The Incredible Story Of India’s Greatest White Collar Crime” (HuffPost India July 15, 2016) <https://www.huffingtonpost.in/devangshu-datta/ramalinga-raju-and-the-in_b_7032688.html> accessed May 13, 2019.

[5] Ibid.

[6] Ibid.

[7] Nimmi (KETAN PAREKH SCAM) <https://www.indianmirror.com/indian-industries/indian-scams/ketanparekhscam.html> accessed May 13, 2019.

[8] “Here’s Why Saradha Was Not a Chit Fund but a Ponzi Scheme” (first post-December 20, 2014) <https://www.firstpost.com/business/heres-why-saradha-was-not-a-chit-fund-but-a-ponzi-scheme-739597.html> accessed May 13, 2019.

[9] Ibid

[10] “Saradha Chit Fund Scam: Mercedes of Sudipta Sen’s Son Seized” (The Economic TimesMay 7, 2013) <https://economictimes.indiatimes.com/news/politics-and-nation/saradha-chit-fund-scam-mercedes-of-sudipta-sens-son-seized/articleshow/19937529.cms?from=mdr> accessed May 13, 2019.

[11] Reporters BS, “SC Jolt for Mamata: CBI to Probe Saradha Scam” (Business StandardMay 9, 2014) <https://www.business-standard.com/article/current-affairs/sc-jolt-for-mamata-cbi-to-probe-saradha-scam-114050900345_1.html> accessed May 13, 2019.

[12] Mukherji UP, Bandyopadhyay K, and TNN, “Sanchayita Haunts Saradha Victims | Kolkata News-Times of India” (The Times of IndiaMay 13, 2019) <https://timesofindia.indiatimes.com/city/kolkata/Sanchayita-haunts-Saradha-victims/articleshow/19656723.cms> accessed May 13, 2019.

[13] “Nirav Modi Case: How PNB Has Defrauded of Rs 11,400 Crore” (Business TodayMarch 15, 2018) <https://www.businesstoday.in/sectors/banks/nirav-modi-case-pnb-fraud-11400-crore-scam-ed-cbi-raid/story/270708.html> accessed May 11, 2019.

[14] Desk BQ, “The Nirav Modi-PNB Fraud Case: Everything We Know So Far” (BloombergQuintFebruary 17, 2018) <https://www.bloombergquint.com/law-and-policy/the-nirav-modi-pnb-fraud-case-everything-we-know-so-far> accessed May 11, 2019.

[15] Nair V, “The Nirav Modi Case: How The $1.8 Billion Fraud Detected At PNB Unfolded” (BloombergQuintFebruary 19, 2018) <https://www.bloombergquint.com/pnb-fraud/the-nirav-modi-case-how-the-18-billion-fraud-detected-at-pnb-unfolded> accessed May 11, 2019.

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