Illegal Arrest

ILLEGAL ARREST & DETENTION

A REPORT BY UNITED HUMAN RIGHTS FEDERATION

United Human Rights Federation United Human Rights Federation (UHRF) is the organisation of international ramifications and working in different fields all over the world for protecting the human race with its dignity. UHRF with the help of experts, volunteers and in association with several agencies, are closely observing the affairs and activities of various countries in the field of politics, economy, foreign trade, business, safety and security measures ensured by the respective governments to its citizen. Making efforts to provide solution to the problems by appraising the cause and extending help to the people and societies of the native country through our organisation and effective administration of those countries.

Vision: The Vision of UHRF is to form fearless and non-succumbing society on the basis of truthfulness & nonviolence.

This society will allow peaceful existence of all types of physically challenged persons, schedule castes, schedule tribes, people below poverty line, old-aged, widow & deserted women and down trodden people irrespective of their caste, creed, sex and religion. This society in its majority will be constituted by the believers in human rights and the activists consequently reducing the pool of wrongdoers. UHRF visualizes a society of human rights followers.

Objectives: To be one of the prime organizations of the world ensuring basic human rights and encouraging human rights activities.

To organise and proces UHRF working by opening up different cells viz. Human Rights Helpline, Family Discipline, Advisory Centres, Public Justice Legal Aid Centres, Crime Prevention Team, Information Gain Centres, National and International Committees, Accident Relief Centres, Scheduled Castes and Scheduled Tribes Help Centers, Women and Labour Welfare Centres, Medical Legal Relief Centres for helpless, Consumer Forum Centres, Inquiry Committees, Centre for Government's Project etc.

To Create awareness among the people so they can voice their complaints/grievances to UHRF against injustice. These complaints will be verified by UHRF for their validity and human right violations issues and carried forward for justice.

To bring under the banner of human rights, all the like minded people of the world. The organisation appeals to the people of the world to join UHRF and contribute some of your time for the cause of human rights.

To continue to form and maintain a society concious of its human rights. This will be done by activities viz. Legal literacy awarness, medical reliefs, Lok Adalats, Janta Darbar and with the support of National Legal Service Authority, Administration and with the support of many National and International committees, councils, UNO, NALSA, NGOs, social workers, Central and State governments, NRI etc.

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Philosophy: "Vasudhaiva Kutumbakam (The whole world is one family)” All human beings are equal and born free. The only permissible discrimination amongst the people of the world is for geographical identification only. Human Rights are yardsticks against which people measures their Governments’ and Public Officials’ conduct and through which the global community as a whole ought to measure its progress.

No nation can move along the true democratic way of life without the real democracy.

Without true democracy, political democracy cannot lasts unless there lies on the base of it, a social democracy.

UHRF helps those who helps themselves. In this period of globalisation, intellectual people have a duty to help and save those below poverty line. Slum dwellers, illiterates and poors helpless people have been cut-off from the main stream of their national and international bodies.

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Human Rights - An Overview Human rights are rights, which inherits in every human being – man, woman or child from birth and which he or she is entitled to enjoy in every society. These rights recognize the essential worth of a human being and acknowledge the basic equality and dignity inherent in all human beings irrespective of race, color, sex, religion or economic levels of living. These have existed in some form in all cultures and have been enjoyed by the people everywhere with varying degrees of emphasis. While this is a historical fact, it is also a part of our experience that powerful forces within the human race, at both the national and the international levels, have been conspiring to condemn millions of men, women and children in all regions of the world to a state of misery, deprivation and continuing exploitation, thereby violating their Human Rights.

Human rights are similar to fundamental rights or moral principles that provide certain standards of human behavior defended by national and international Human rights law. The law of human rights has been highly influential within international human rights agency (the part of UNO), global and regional institutions. Under the human rights violation against individual, everyone is protected by the law.

Government initiatives, including police reform and improved access to health care and education, languish due to poor implementation. Many women, children, Dalits, tribal communities, religious minorities, people with disabilities, and sexual and gender minorities remain marginalized and continue to suffer discrimination because of government failure to train public officials in stopping discriminatory behavior.

Human rights are based on the law of respect for every citizen. Their fundamental theory is that each individual is a moral and rational being who deserves to be treated with self-respect. They are called human rights because they are universal. Whereas nations or specialized groups enjoy specific rights that apply only to them, human rights are the rights to which everyone is entitled—no matter who they are or where they live—simply because they are alive.

But there is nothing to same; a large number of men, women and children are facing the violation against humanity across the globe. These violations include bonded labour, child abuses, sexual harassment, slavery, fake encounter, human trafficking and many more.

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ILLEGAL ARREST, DETENTION AND TRIAL

Each person has the right to resist an unlawful arrest.

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In this context, it is very essential to go through the following case-law to know the consequences of illegal arrest.

It is solemn duty of the court to protect and uphold the basic human rights of the weaker section of the society. In order to bring arrestee before a Court of Law or otherwise secure of the administration of the law, an arrest will usually be made.

Ÿ Boya Nallabothula Venkateswarlu and Ors Vs. The Circle Inspector of Police, Nandikotkur PS and Ors (2010 (3) U.P.L.J 19 (HC)) Ÿ Boya Nallabothula Venkateswarlu and Ors’case (Cited supra), 2010 (3) U.P.L.J 19 (HC) Ÿ Nilabati Bahera’s case

FALSE ARREST

Ÿ Byrne Vs Ireland (1972) IR 241, Walsh J opines at p264:

‘’A tort (a civil wrong) that consists of an unlawful restraint of an individual’s personal liberty or freedom of movement by another purporting to act according to the law.’’ An action can be instituted for the damages ensuing from false arrest, such as loss of salary while imprisoned, or injury to reputation that results in a pecuniary loss to the victim. Ill will and malice are not elements of the tort, but if these factors are proven, Punitive Damages can be awarded in addition to Compensatory Damages or nominal damages. In view of this, it is clearly known that if illegal arrest is made, punitive damages in addition to compensatory or nominal damages can be awarded.

Ÿ Joginder Kumar Vs State of U.P And Others Ÿ Bhim Singh, MLA Vs State of J&K And others Ÿ Lucknow Development Authority Vs M.K.Gupta Ÿ Sanganagouda A. Veeranagouda and others vs State of Karnataka. Ÿ Hindustan Transmission Products Ltd Vs. State of Kerala

In this context, it is very essential to go

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MISUSE OF POWER OF ARREST Notwithstanding the safeguards contained in the Code of Criminal Procedure and the Constitution referred to above, the fact remains that the power of arrest is wrongly and illegally exercised in a large number of cases all over the country. Very often this power is utilized to extort monies and other valuable property or at the instance of an enemy of the person arrested.

Even in case of civil disputes, this power is being resorted to on the basis of a false allegation against a party to a civil dispute at the instance of his opponent.

CONSTITUTIONAL PROTECTION Clause (1) of Article 22 of the Constitution which is one of the fundamental rights in Part III, declares that “no person who is arrested shall be detained in custody without having informed, as soon as maybe, on 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.” Clause (2) of Article 22 says that every person arrested and detained in custody shall be produced before the nearest magistrate within a period of 24 hours of such arrest excluding of course the time necessary for the journey from the place of arrest to the court of magistrate.

The clause further declares that no such person shall be detained in custody beyond the said period without the authority of a magistrate. Clause (3) of Article 22 however provides that clauses (1) and (2) shall not apply to an enemy-alien or to a person who has been arrested under any law providing for preventive detention.

The vast discretion given by the CrPC to arrest a person even in the case of a bailable offence (not only where the bailable offence is cognizable but also where it is non-cognizable) and the further power to make preventive arrests (e.g. under section 151 of the CrPC and the several city police enactments), clothe the police with extraordinary power which can easily be abused. Neither there is any in-house mechanism in the police department to check such misuse or abuse nor does the complaint of such misuse or abuse to higher police officers bear fruit except in some exceptional cases.

We must repeat that we are not dealing with the vast discretionary powers of a mere civil service simpliciter, we are dealing with the vast discretionary powers of the members of a service which is provided with firearms, which are becoming more and more sophisticated with each passing day (which is technically called a civil service for the purposes of Service Jurisprudence) and whose acts touch upon the liberty and freedom of the citizens of this country and not merely their entitlements and properties. This is a civil service which is being increasingly militarized, no doubt, to meet the emerging exigencies.

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ILLEGAL ARREST A BLOW TO INDIVIDUAL DIGNITY, SAYS SUPREME COURT

QUASHES CRIMINAL CASE

The 27-page judgment details how the mother-daughter duo, accused of fraud and offences under the now extinct Section 66A of the IT Act, declared unconstitutional by the Supreme Court, were cruelly ill-treated by the police team and later allegedly enticed to pay a bribe of Rs. 5 lakh to a senior police officer to buy back their freedom.

PROCEDURE NOT FOLLOWED

Quashing the criminal case against the women, Justice Misra, who authored the judgment for the Bench, ordered Madhya Pradesh to pay Rs. 5 lakh each as compensation to the mother, an advocate Illegal use of state power to rob a person of 36 years standing, and her daughter. The of her liberty is an assault on the citizen’s judgment observed identity and constitutional right to dignity, the Supreme Court held in a judgment Dr. Rini “We are inclined to think that the dignity of the petitioners, a doctor and a practising Johar vs. State of MP. advocate has been seriously jeopardised.

The Hon’ble Court details the conduct of a Dignity is the quintessential quality of a Madhya Pradesh police team which went personality for, it is a highly cherished value. from Bhopal to Pune to arrest a woman It is also clear that liberty of the petitioner lawyer in her seventies and her doctor was curtailed in violation of law,”. daughter.

“The two ladies have been arrested without following the procedure and put in the compartment of a train without being produced before the local magistrate from Pune to Bhopal. One need not be Arguseyed to perceive the same. Its visibility is as clear as the cloudless noon day. It would not be erroneous to say that the enthusiastic investigating agency had totally forgotten the golden words of Benjamin Disraeli that all power is a trust,” Justice Misra observed.

A Bench of Justices Dipak Misra and S.K. Singh narrated the women’s story, in which they were denied food and water, medical help for the mother, who was made to sleep on the “cold floor” of an unreserved train compartment during their transit from Pune to Bhopal.

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memo of arrest at the time of arrest and such memo shall be attested by at least one witness, who may be either a member of the family of the arrestee or a respectable person of locality from where the arrest is made. It shall also be countersigned by the arrestee and shall contain the time & date of arrest.

GUIDELINES LAID DOWN BY THE HON’BLE SUPREME COURT OF INDIA Ÿ To know about guidelines to be followed before arrest, it is essential to refer the ruling Joginder Kumar vs State of Utter Pradesh.

3. A person who has been arrested or detained and is being held in custody in a police station or interrogation center or other lock-up, shall be entitled to have one friend or relative or other person known to him or having interest in his welfare being informed, as soon as practicable, that he has been arrested and is being detained at the particular place unless the attesting witness of the memo of arrest is himself such a friend or a relative of the arrestee.

Ÿ To know more as to guidelines during arrest, it is necessary to refer the decision D.K.Basu vs State of West Bengal. Ÿ Further, to know about guidelines after arrest, it is essential to refer the ruling Sunil Batra vs Delhi Administration, Prem Shankar Shukla vs Delhi Administration and D.K.Basu’s case. Ÿ D.K. Basu Vs State of West Bengal (AIR1997 SC610).

4. The time, place of arrest and venue of custody of an arrestee must be notified by the police where the next friend or relative of the arrestee lives outside the district or town through the Legal Aid Organisation in the District and the police station of the area concerned telegraphically within a period of 8 to 12 hours after the arrest.

The requirements to be followed in all cases of arrest or detention as per ruling. It would be sufficient if we quote paras 36 to 40 which contain the final directions issued in the said decision. They read as follows: “We, therefore, consider it appropriate to issue the following requirements to be followed in all cases of arrest or detention, till legal provisions are made in that behalf, as preventive measures:

5. The person arrested must be made aware of this right to have someone informed of his arrest or detention as soon as he is put under arrest or is detained.

1. The police personnel carrying out the arrest and handling the interrogation of the arrestee should bear accurate, visible and clear identification and name tags with their designations. The particulars of all such police personnel who handle interrogation of the arrestee must be recorded in a register.

6. An entry must be made in the diary at the place of detention regarding the arrest of the person which shall also disclose the name of the next friend of the person who has been informed of the arrest and the names and particulars of the police officials in whose custody the arrestee is.

2. That the police officer carrying out the arrest of the arrestee shall prepare a

7. The arrestee should, where he so

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requests, be also examined at the time of his arrest and major and minor injuries, if any, present on his/her body, must be recorded at that time. The “Inspection Memo” must be signed both by the arrestee and the police officer effecting the arrest and its copy provided to the arrestee.

at all district and State headquarters, where information regarding the arrest and the place of custody of the arrestee shall be communicated by the officer causing the arrest, within 12 hours of effecting the arrest and at the police control room it should be displayed on a conspicuous police board.

8. The arrestee should be subjected to medical examination by a trained doctor every 48 hours during his detention in custody by a doctor on the panel of approved doctors appointed

by Director, Health Services of the concerned State or Union Territory, Director, Health Services should prepare such a panel for all Tehsils and Districts as well.

Failure to comply with the requirements hereinabove mentioned shall apart from rendering the concerned official liable for departmental action, also render him liable to be punished for contempt of Court and the proceedings for contempt of Court may be instituted in any High Court of the country, having territorial jurisdiction over the matter.

The requirements, referred to above flow from Articles 21 and 22(1) of the 9. Copies of all the documents including Constitution and need to be strictly the memo of arrest, referred to above, followed. These requirements are in should be sent to the Ilaqa Magistrate addition to the constitutional and statutory safeguards and do not detract from for his record. various other directions given by the 10. The arrestee may be permitted to meet Courts from time to time in connection his lawyer during interrogation, though with the safeguarding of the rights and not throughout the interrogation. dignity of the arrestee.

11. A police control room should be provided

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It is true that after pronouncement of judgment by the Hon’ble Supreme Court in the case of D.K. Basu ( supra), certain amendments have been made in Chapter V of the Code of which Section 41B is the result which reads as follows : Section 41B : Procedure of arrest and duties of officer making arrest.

“Every police officer while making an arrest shall a. bear an accurate, visible and clear identification of his name which will facilitate easy identification; b. prepare a memorandum of arrest which shall be iii. attested by at least one witness, who Rights of Arrested Person is a member of the family of the person 1. Right to silence arrested or a respectable member of the locality where the arrest is made; 2. Right to know the grounds of arrest iv. countersigned by the person arrested;

3. Information regarding the right to be released on bail

v. inform the person arrested, unless the memorandum is attested by a member of his family, that he has a right to have a relative or a friend named by him to be informed of his arrest.”

4. Right to be taken before a magistrate without delay 5. Right of not being detained for more than 24 hours without judicial scrutiny 6. Rights at fair trial

Need For Providing Statutory Safeguards To Prevent Abuse of Power of Arrest

7. Right to consult a legal practitioner 8. Rights of free legal aid

It is necessary to make appropriate legal provisions not only incorporating the guidelines/directions issued by the Hon’ble Court time to time but also making such changes in law as may be necessary to prevent abuse/ misuse of the said power while at the same time ensuring that interest of the society in maintenance of peace and law and order is not jeopardized.

9. Right to be examined by a medical practitioner 10. Right of the accused to produce an evidence

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Arrests and Detention without Reasonable Cause: A Persistent Problem All human beings have the right to enjoy respect for their liberty and security. It is axiomatic that, without an eďŹƒcient guarantee of the liberty and security of the human person, the protection of other individual rights becomes increasingly vulnerable and often illusory. Yet, as is evidenced by the work of the international monitoring organs, arrests and detentions without reasonable cause, and without there being any eective legal remedies available to the victims concerned, are common place. In the course of such arbitrary and unlawful deprivations of liberty, the detainees are frequently also deprived of access both to lawyers and to their own families, and also subjected to torture and other forms of ill-treatment.

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RIGHTS OF PERSON WHEN ARRESTED INVESTIGATION Investigation by any police officer of any male below 15 years or any woman can be made only at the place of residence (Sec.160 Cr. P.C)

ARREST Ÿ Persons

arrested must be informed of the full particulars of the offence committed and the grounds for arrest. (Sec.50 Cr. P.C. & Art 22 (1) Constitution of India)

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All persons arrested / detained must be served a custody memo as per Supreme Court directions in D.K. Basu Vs State of West Bengal.

be examined by a registered medical practitioner (Sec.54) to disprove, the commission of Offence or to prove the ill-treatment of the police or any other suitable reason. (S.54 Cr. P.C).

Persons arrested cannot be detained for more than 24 hours in Police Custody (Sec.56/57 Cr.P.C. & Art 22 (2) Constitution of India.

An Accused person is entitled to a copy, free of cost, of the Police Final Report, First Information Report (FIR), statements of all persons whom prosecution proposes to examine as its witnesses (Sec 207, Sec. 154, Sec. 161 [3]) confessions and statements if any recorded and any other documents, relevant extracts forwarded to the magistrate.

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The arrested person has a right to consult and be defended by a legal practitioner of his choice (Article 22 (1) of the Constitution of India).

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If the arrested person is poor, he can get free Legal Assistance from the Legal Services Authority (Art 39 A Constitution of India).

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The person arrested, has a right to

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In the case of a woman the medical examination has to be made only by a female registered medical practitioner.

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Police are empowered by Sec.41, 42, 151 and 432 (3) of Cr.P.C. to arrest without a warrant.

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Arrest should not be made on mere suspicion (145 Cr. P.C).

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The arrested person is entitled for compensation for groundless arrest / illegal detention.

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The registering of the FIR is not a condition precedent to grant anticipatory bail.

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Warrant of arrest should be in writing and signed by the Presiding officer of the court with seal. Substance of the warrant should be shown or intimated to the person to be arrested.

IN POLICE CUSTODY Ÿ

Custody includes surrender of accused before the court and submissions to directions.

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A Magistrate may order for the remand of the arrested person to police custody u/s 167 (3) of the Cr.P.C. The Magistrate should be fully satisfied that there is good ground to remand the accused to police custody.

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there should always be an entry in the Daily Diary (i.e. General Diary) when accused is taken out of police lock-up or readmitted;

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if the accused falls ill in police lockup, he must be given medical aid or treatment admitted for in a hospital.

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if an accused dies in police custody, officer - in - charge shall immediately inform the nearest Executive Magistrate empowered to hold inquests, for investigation u/s 176 Cr.P.C. and intimated to the National Human Rights Commission within 24 hours.

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If a person is released on bail he cannot be remanded to police custody.

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When remand to police custody is granted (subject to Supreme Court orders in D.K. Basu).

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detention of accused for longer than 24 hours when not produced for remand and beyond period of remand without orders of Magistrate is illegal and Police Officer is liable u/s 342 IPC and u/s 29 of the Police Act.

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Accused may engage a counsel during proceedings of remand and accused may raise an objection that the police is not entitled to custody.

xi. the accused in police custody can be kept in police lock - up. xii. can be taken to any place for purposes of investigation within this period. xiii. can be kept at any place for purposes of investigation within this period.

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FURNISHING COPIES OF DOCUMENTS TO ACCUSED IS SOLEMN DUTY OF THE COURT An omission to comply with section 207 Cr. P.C. read with section 238 Cr. P.C. is bound to cause a serious prejudice to the accused. It is obligatory for the Trial Magistrate to ensure supply of copies of the relevant documents upon which the prosecution intends to rely upon during trial. The Hon’ble Apex Court held that it was incumbent upon the trial court to supply the copies of these documents to the accused as that entitlement was a facet of just, fair and transparent investigation/trial and constituted an inalienable attribute of the process of a fair trial which Article 21 of the Constitution guarantees to every accused.

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Accused could not be refused to supply of documents even at the stage of trial

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It is the duty of the magistrate himself to supply copies of relevant documents to accused

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The accused is entitled to copies of the documents which were seized under seizure list.

The Hon’ble Apex Court held that it was incumbent upon the trial court to supply the copies of these documents to the accused as that entitlement was a facet of just, fair and transparent investigation/trial and constituted an inalienable attribute of the process of a fair trial which Article 21 of the Constitution guarantees to every accused.

Object of Section 238 of Cr.PC. Section 238 of Cr.P.C unequivocally provides that a solemn duty is cast on the Magistrate to satisfy himself that he has strictly complied with the provisions of 207 Cr. P.C viz. furnishing the accused, free of cost, copies of documents as prayed for

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by him and referred to in that section itself Bench of Kolkata HIgh Court reported in without delay and such satisfaction has to be 1975 CRI. L. J. 832 (The Superintendent and Remembrancer of Legal Affairs, invariably judicial satisfaction. west Bengal, Petitioner v. Anthony Alten An omission to comply with the Fletcher and Anr., Opposite Parties). mandatory provision of law as enshrined in section 207 Cr. P.C. read with Section 238 Cr. P.C. is bound to cause a serious prejudice to the accused and such a situation may Analysis – even vitiate the criminal trial. The supply If we go carefully go through the ratio laid of documents and statements prepared at down in V.K. Sasikala v. State Represented the investigating stage as mandated under by Superintendent of Police (2012) 9 section 207 Cr. P.C. cannot be treated as SCC 771 and in the ratio laid down in case mere superfluity or empty formality. of Manjeet Singh Khera Versus State of The underlying purpose in prescribing this procedure is to ensure speedy disposal of warrant cases instituted on police reports without in any way prejudicing the accused.

Both the section 207 Cr. P.C and 238 Cr. P.C. taken together leaves no room for doubt that it is obligatory for the Trial Magistrate to ensure supply of copies of the relevant documents upon which the prosecution intends to rely upon during trial and it is highly improper and irregular on his part to shirk his responsibility in this regard and put the accused at the mercy of the prosecution by merely observing inter alia that it is the duty of the prosecution ‘to follow the rules of natural justice.’

Maharashtra (supra) and the ratio in the case of Shivjee Singh vs nagendra Tiwary & Ors, we get clear idea about the solemn duty of the Court to supply copies of documents to accused. In short, it is apt to say that Section 207 casts a duty on the Magistrate to supply to the accused, copies of the police report, the first information report recorded under Section 154, the statements recorded under Section 161(3), the confessions and statements, if any, recorded under Section 164 and any other document or relevant extract thereof, which is forwarded to the Magistrate along with police report.

Section 208 provides for supply of copies of statement and documents to accused in the cases triable by the Court Compliance with section 207 – of Sessions. It lays down that if the case, When in any warrant-case instituted on instituted otherwise than on a police report, is a police report, the accused appears triable exclusively by the Court of Sessions, or is brought before a Magistrate at the the Magistrate shall furnish to the accused, commencement of the trial, the Magistrate free of cost, copies of the statements recorded shall satisfy himself that he has complied under Section 200 or Section 202, statements and confessions recorded under Section 161 with the provisions of section 207. or Section 164 and any other document on The rulings of the Hon’ble Supreme which prosecution proposes to rely. court of India reported in AIR 1957 S.C. 623 (Gurbachan Singh, Appellant v. State of Punjab, Respondent) and 2008 CRI. L. J. 3540 (Bharat Parikh v. CBI & Anr.) and also another ruling of the Division

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BAIL Ÿ Person

accused of a bailable offence has right to be released on bail. It is the duty of the police officer incharge to intimate this. Bail not Jail is the Rule of Law.

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An accused person surrendering before the Magistrate has a right to bail or demand judicial custody.

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The provision of bail to women, sick and old age persons is given priority subject to the nature of the offence.

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Once the accused is granted bail by invoking Sec. 205 Cr.P.C. he need not attend the court (unless it is a condition

of bail) before charegesheet is filed and process issued .

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If no charge -sheet is filed before the expiry of 60/90 days as the case may be, the accused in custody has a right to be released on bail.

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If the arrested person is remanded to judicial custody by the Magistrate on Sundays or holidays, the bail application should be considered on the Sunday or the holiday itself.

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In non-bailable offences, the Magistrate has the power to release on bail without notice to the other side if charge sheet is not filed within a period of sixty days.

Balancing of societal Interests and protection of rights of the accused We must also take note of the fact that very often it is the poor who suffer most at the hands of Police. Their poverty itself makes them suspects. Nowadays, even middle classes and other well-to-do people, who do not have access to political power-wielders, also are becoming targets of Police excesses. We recognize that ensuring a balance between societal interest in peace and protection of the rights of the accused is a difficult one but it has to be done. We also recognize the fundamental significance of the Human Rights, which are implicit in Part III of our Constitution and of the necessity to preserve, protect and promote the Rule of Law which constitutes the bedrock of our constitutional system.

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