INTRODUCTION
The criminal justice system has historically been structured around the determination of guilt and the imposition of punishment, with the State assuming a central role in prosecuting offenders. Within this framework, victims were often relegated to a passive and peripheral position, functioning primarily as informants or witnesses whose role was limited to aiding the prosecution. The harm suffered by victims—whether physical, emotional, or economic—was seldom addressed in a comprehensive manner. Justice, in its traditional sense, was equated with the punishment of the offender rather than the restoration of the victim’s dignity and well-being.
This offender-centric orientation can be traced to classical theories of criminal law, particularly retributive and deterrent models, which emphasized societal order and state authority over individual victim experiences. As a result, victims frequently encountered neglect, procedural insensitivity, and even hostility within the justice process. The absence of institutional mechanisms to address victim needs often led to what is now recognized as “secondary victimization,” where victims suffer further trauma due to their interaction with justice administering authorities.1
The emergence of victimology as a distinct field of study in the mid-twentieth century marked a significant turning point in this regard. Scholars and practitioners began to critically examine the experiences of victims and the systemic deficiencies that marginalized them. This shift led to the development of a more inclusive understanding of justice—one that acknowledges victims as key stakeholders with independent rights and legitimate interests. The global recognition of victim rights, particularly through the United Nations Declaration of Basic Principles of Justice for Victims of Crime and Abuse of Power 1985, further reinforced the need for a justice system that is responsive, compassionate, and equitable.
In contemporary discourse, the concept of victim-centric justice has gained prominence, emphasizing principles such as participation, protection, compensation, and restoration. This approach seeks to balance the scales of justice by ensuring that victims are not merely passive observers but active participants in the legal process. It also underscores the responsibility of justice administering authorities—namely the police, prosecution, judiciary, and correctional institutions—to uphold the rights and dignity of victims at every stage of the criminal process.
In India, this shift towards a victim-oriented framework has been reflected in both legislative reforms and judicial activism. Amendments to the Code of Criminal Procedure 1973, particularly the introduction of provisions such as Section 357A (victim compensation) and the proviso to Section 372 (victim’s right to appeal), signify a growing recognition of victim rights within statutory law. Additionally, special legislations such as the Protection of Women from Domestic Violence Act 2005 and the Protection of Children from Sexual Offences Act 2012 have introduced victim-sensitive procedures aimed at safeguarding vulnerable groups.2
In this context, it becomes imperative to critically examine the approaches adopted by justice administering authorities towards crime victims. Such an analysis not only highlights the gaps between law and practice but also underscores the need for a more integrated, empathetic, and rights-based approach to justice administration. The present study seeks to explore these dimensions, with a view to contributing to the ongoing discourse on victim justice and the reform of criminal justice institutions in India.
CONCEPTUAL FRAMEWORK: VICTIMS AND VICTIMOLOGY
Victimology, as a specialized branch of criminology, focuses on the study of victims, their relationship with offenders, and their interaction with the criminal justice system. It seeks to analyze not only the causes and consequences of victimization but also the systemic responses that shape victims’ experiences. Traditionally, criminology concentrated primarily on offenders and criminal behavior; however, the emergence of victimology marked a significant shift by placing victims at the center of academic inquiry and policy formulation.
The concept of a “victim” encompasses individuals who suffer harm as a result of criminal acts. Such harm may be physical, emotional, psychological, or economic in nature. Importantly, victimology recognizes that victimization extends beyond immediate physical injury to include long-term trauma, social stigma, and financial hardship. This broader understanding has led to the recognition that justice must address not only the offense but also its impact on victims.
A comprehensive and widely accepted definition of victims is provided in the United Nations Declaration of Basic Principles of Justice for Victims of Crime and Abuse of Power 1985, which defines victims as persons who have suffered harm, including physical or mental injury, emotional suffering, economic loss, or substantial impairment of their fundamental rights through acts or omissions that violate criminal laws. This international framework emphasizes the need for access to justice, fair treatment, restitution, compensation, and assistance for victims, thereby laying the foundation for victim-oriented legal reforms across jurisdictions.
For analytical clarity, victims are commonly classified into distinct categories based on the nature and extent of harm suffered:
• Primary victims are those who directly experience the criminal act and suffer immediate harm. For instance, a person injured in an assault or a survivor of theft falls within this category.
• Secondary victims include individuals who are indirectly affected by the crime, such as family members, dependents, or close associates of the primary victim. They may suffer emotional distress, financial loss, or social consequences as a result of the victimization.
• Vulnerable victims refer to individuals who, due to their age, gender, physical or mental condition, or social status, are at a heightened risk of victimization or face greater difficulty in accessing justice. This category typically includes women, children, the elderly, persons with disabilities, and marginalized communities.
This classification is significant for justice administering authorities as it enables a more nuanced and responsive approach to victim needs. Different categories of victims require distinct forms of protection, support, and redress. For example, child victims may require specialized procedures such as in-camera trials and psychological counseling, while victims of domestic violence may need shelter, legal aid, and protection orders.3
Furthermore, victimology also examines concepts such as victim precipitation, victim vulnerability, and repeat victimization, which help in understanding patterns of crime and developing preventive strategies. It highlights the importance of minimizing secondary victimization by ensuring that victims are treated with dignity, respect, and sensitivity throughout the justice process.
In the Indian context, the growing influence of victimology is evident in legislative and judicial developments that seek to incorporate victim rights into the criminal justice framework. By providing a conceptual foundation, victimology not only informs policy but also guides the functioning of justice administering authorities towards a more humane, inclusive, and victim-centric system of justice.4
APPROACHES TO JUSTICE: RETRIBUTIVE, REFORMATIVE, AND RESTORATIVE PERSPECTIVES
The administration of criminal justice has evolved through different philosophical approaches, each reflecting distinct objectives and priorities. Among these, the retributive, reformative, and restorative approaches represent three significant models that shape how justice administering authorities respond to crime and, importantly, how they engage with victims.
The retributive justice approach is one of the oldest and most traditional models of criminal justice. It is founded on the principle that offenders must be punished in proportion to the harm they have caused. The primary focus of this approach is on the अपराध (wrongdoing) and the offender, with the State assuming responsibility for prosecution and punishment. While retributive justice serves important purposes such as deterrence and societal condemnation of crime, it offers limited scope for victim participation. Victims often remain passive observers in the process, and their emotional, psychological, and financial needs are not adequately addressed. Consequently, although punishment may provide a sense of closure, it does not necessarily lead to victim satisfaction or restoration.
In contrast, the reformative (or rehabilitative) approach shifts the focus from punishment to the reformation of the offender. It is based on the belief that criminal behavior can be corrected through education, counselling, and social reintegration. Justice administering authorities, particularly correctional institutions, play a key role in implementing this approach by providing opportunities for rehabilitation. While this model is progressive in reducing recidivism and promoting social harmony, it has been criticized for insufficiently addressing the plight of victims. The emphasis on offender welfare may inadvertently overshadow the needs of victims, who may not receive adequate recognition, compensation, or participation in the justice process.
The restorative justice approach represents a more recent and transformative model that seeks to bridge the gap between offender accountability and victim needs. Unlike the retributive and reformative approaches, restorative justice emphasizes healing, reconciliation, and the repair of harm caused by crime. It actively involves victims, offenders, and the community in the justice process through mechanisms such as victim-offender mediation, family group conferencing, and restitution. This approach recognizes victims as central stakeholders and provides them with an opportunity to express their experiences, seek answers, and obtain emotional closure. At the same time, it encourages offenders to take responsibility for their actions and make amends.
From a victim-centric perspective, restorative justice offers several advantages, including empowerment, validation, and psychological healing. However, its application is not without limitations. Concerns such as power imbalances between victim and offender, the risk of coercion, and its suitability in serious offences must be carefully addressed by justice administering authorities.5
In essence, these three approaches reflect the gradual evolution of criminal justice from a purely punitive system to a more balanced and humane framework. While retributive justice ensures accountability and reformative justice promotes offender rehabilitation, restorative justice provides a more inclusive model that integrates victim needs into the justice process. An effective criminal justice system must therefore adopt a hybrid approach that harmonizes these models, ensuring that justice is not only done but is also meaningful and responsive to the experiences of victims.
VICTIM-CENTRIC JUSTICE IN INDIA AND INSTITUTIONAL MECHANISMS
The Indian criminal justice system has gradually evolved towards a victim-centric approach, recognizing that justice must extend beyond the punishment of offenders to include the protection, participation, and rehabilitation of victims. This shift reflects a broader understanding that victims are not merely witnesses but rights-bearing individuals entitled to dignity, support, and redress throughout the criminal process. Justice administering authorities—including police, judiciary, and prosecution—are increasingly expected to adopt practices that are sensitive to the needs and vulnerabilities of victims.
This transformation is evident in key legislative developments. The Code of Criminal Procedure 1973 was amended to incorporate provisions that strengthen victim rights, most notably Section 357A6, which mandates the establishment of victim compensation schemes by State governments. Additionally, the proviso to Section 372 recognizes the victim’s right to appeal against acquittal, conviction for a lesser offence, or inadequate compensation. These provisions signify an important departure from the traditional state-centric model by formally acknowledging the victim’s role in the justice process.
Special legislations have further reinforced this approach by introducing victim-sensitive procedures. The Protection of Women from Domestic Violence Act 2005 provides civil remedies such as protection orders, residence rights, and monetary relief to victims of domestic abuse. Similarly, the Protection of Children from Sexual Offences Act 2012 establishes child-friendly procedures, including in-camera trials and the appointment of support persons, to safeguard the interests of child victims. These laws demonstrate a conscious effort to address the specific needs of vulnerable categories of victims.
Complementing these legal provisions are various institutional mechanisms designed to operationalize victim-centric justice. Victim compensation schemes, implemented under Section 357A of the CrPC, aim to provide financial assistance to victims for medical expenses, rehabilitation, and loss of livelihood. Judicial pronouncements, such as Ankush Shivaji Gaikwad v State of Maharashtra7, have emphasized that courts must actively consider compensation in every case, thereby strengthening the practical application of this mechanism.
Another crucial component is the Witness Protection Scheme 2018, recognized and enforced by the Supreme Court in Mahender Chawla v Union of India8. This scheme seeks to ensure the safety and security of victims and witnesses through measures such as identity protection, relocation, and police protection. It addresses the fear and intimidation that often discourage victims from participating in the justice process.
Further, the Legal Services Authorities Act 1987 plays a vital role in ensuring access to justice by providing free legal aid and support services to victims, particularly those from economically weaker and marginalized sections. Legal aid services, along with counseling and rehabilitation support, contribute to reducing the barriers that victims face in seeking justice.
Despite these advancements, the effective implementation of victim-centric measures remains a challenge. Issues such as delays in compensation, lack of awareness among victims, inadequate infrastructure, and limited coordination among authorities continue to hinder the realization of these rights in practice. Therefore, while India has established a strong legal and institutional framework for victim justice, sustained efforts are required to ensure that these mechanisms function efficiently and reach those in need.
In essence, the integration of victim-centric principles with institutional mechanisms reflects a progressive shift in the Indian criminal justice system. However, the true success of this approach depends on its consistent and empathetic implementation by justice administering authorities, ensuring that victims are not only recognized in law but also meaningfully supported in practice.
LEGAL AID AND ROLE OF POLICE IN VICTIM JUSTICE
Access to justice for crime victims depends significantly on two foundational pillars of the criminal justice system: effective legal aid and a responsive police mechanism. Both play a crucial role in ensuring that victims are able to navigate the legal process, assert their rights, and receive timely protection and redress. When functioning in coordination, these institutions can substantially reduce barriers faced by victims, particularly those from marginalized and vulnerable backgrounds.
Legal aid serves as an essential tool for democratizing access to justice by providing free legal services to individuals who lack the financial means to engage legal representation. In India, this mandate is institutionalized under the Legal Services Authorities Act 1987, which establishes a framework for delivering legal assistance to eligible persons, including victims of crime. Legal aid encompasses not only representation in courts but also legal counseling, assistance in filing complaints, and support in accessing compensation schemes. For victims, especially women, children, and economically disadvantaged individuals, legal aid ensures that justice is not denied due to financial constraints or lack of awareness.
Parallelly, the police constitute the first point of contact for victims within the criminal justice system and thus play a decisive role in shaping their initial experience. Their responsibilities include the prompt registration of complaints, conducting impartial investigations, ensuring victim safety, and facilitating access to medical and legal assistance. The significance of police responsiveness has been underscored by the Supreme Court in Lalita Kumari v Government of Uttar Pradesh9, where it was held that the registration of a First Information Report (FIR) is mandatory in cases disclosing a cognizable offence. This judgment marked a critical step in strengthening victim access to justice by preventing arbitrary refusal to register complaints.
The intersection of legal aid and police functions is particularly important in ensuring that victims are adequately informed of their rights and available remedies. Police officers are often responsible for guiding victims towards legal aid services, victim compensation schemes, and support mechanisms. In this regard, a coordinated approach between law enforcement agencies and legal services authorities is essential to provide a seamless support system for victims.
However, several challenges persist in the effective functioning of these mechanisms. Victims frequently encounter issues such as lack of awareness about legal aid services, delays in accessing legal assistance, and inadequate communication from police authorities. Additionally, instances of insensitive behavior, reluctance to register FIRs, and procedural complexities can contribute to secondary victimization, further discouraging victims from pursuing justice.
To address these concerns, there is a pressing need for capacity building and sensitization of police personnel, along with strengthening the outreach and efficiency of legal aid services. Integrating victim support services within police stations, enhancing training programs, and leveraging technology for better coordination can significantly improve the overall experience of victims.
In conclusion, legal aid and the role of police are intrinsically linked in advancing victim justice. Their effective functioning not only facilitates access to justice but also reinforces the principles of fairness, dignity, and equality within the criminal justice system.
ROLE OF JUDICIARY IN VICTIM JUSTICE
The judiciary occupies a central position in the administration of criminal justice and plays a transformative role in advancing victim-centric jurisprudence. As the ultimate interpreter of law and guardian of fundamental rights, the judiciary ensures that victims are treated with dignity, fairness, and sensitivity throughout the legal process. Over time, Indian courts—particularly the Supreme Court and High Courts—have expanded the scope of victim rights through progressive interpretations of constitutional and statutory provisions.
One of the most significant contributions of the judiciary has been the recognition of victims’ rights as an integral part of the right to life and personal liberty under Article 21 of the Constitution. In Bodhisattwa Gautam v Subhra Chakraborty10, the Supreme Court held that victims of rape are entitled to compensation, recognizing sexual violence as a violation of fundamental rights. This marked a shift towards acknowledging the need for immediate and meaningful relief for victims beyond the traditional criminal process.
The judiciary has also played a proactive role in institutionalizing victim support mechanisms. In Delhi Domestic Working Women’s Forum v Union of India, the Court laid down comprehensive guidelines for assisting victims of sexual offences, including the provision of legal aid, protection of identity, and access to compensation. These directions significantly contributed to the development of victim-friendly procedures within the justice system.
Further strengthening victim protection, the Supreme Court in Nipun Saxena v Union of India emphasized the importance of maintaining the confidentiality and dignity of victims, particularly in cases of sexual offences. The Court issued directions to prevent the disclosure of the identity of rape victims, thereby safeguarding them from social stigma and further trauma.
The judiciary has also reinforced procedural safeguards that enhance victim participation and access to justice. For instance, judicial interpretation of provisions under the Code of Criminal Procedure 1973 has ensured that victims have the right to appeal, seek compensation, and be heard at various stages of the trial. Courts have increasingly recognized that justice must not only be done but must also be seen to be done from the perspective of victims.
Despite these progressive interventions, challenges remain in the effective realization of victim justice. Judicial delays, case backlogs, and procedural complexities often hinder timely relief for victims. Moreover, limited interaction between the judiciary and victims during trial proceedings can reduce the sense of participation and satisfaction.
To address these issues, courts have begun adopting victim-friendly practices such as in-camera proceedings, video conferencing for vulnerable witnesses, and fast-track courts for specific categories of offences. These measures aim to reduce trauma and ensure a more accessible and humane justice process.
In conclusion, the judiciary has been instrumental in transforming the Indian criminal justice system into a more victim-sensitive framework. Through judicial activism and innovative interpretations, it has expanded the scope of victim rights and strengthened institutional mechanisms. However, continued efforts are necessary to ensure that these principles are effectively implemented, thereby guaranteeing that victims receive not only legal recognition but also substantive justice.
ROLE OF PROSECUTION AND SECONDARY VICTIMIZATION
The prosecution occupies a crucial intermediary position within the criminal justice system, acting as the representative of the State while simultaneously bearing a responsibility towards the victim. Traditionally, prosecutors have been viewed as agents of the State whose primary objective is to secure conviction. However, in a victim-centric framework, their role extends beyond mere adversarial advocacy to ensuring fairness, sensitivity, and effective representation of victim interests.
Prosecutors are responsible for presenting the case before the court, examining witnesses, and ensuring that the evidence is fairly and effectively placed on record. In this process, they serve as a vital link between victims and the judicial system. A victim-oriented prosecutorial approach requires maintaining communication with victims, informing them about the progress of the case, preparing them for court proceedings, and safeguarding their dignity during trial. The growing recognition of victims’ participatory rights under the Code of Criminal Procedure 1973, including the right to appeal under Section 372, reflects the evolving role of prosecution in accommodating victim interests.
Despite this, the prosecutorial system in India continues to face several limitations. Heavy caseloads, inadequate resources, and a continued emphasis on conviction rates often result in insufficient engagement with victims. In many instances, victims remain unaware of the status of their cases or their legal rights, which undermines their confidence in the justice system. This gap highlights the need for a more victim-sensitive prosecutorial culture that prioritizes both justice and victim satisfaction.
Closely linked to the role of prosecution is the issue of secondary victimization, which refers to the additional trauma experienced by victims due to insensitive or inappropriate treatment by criminal justice authorities. Secondary victimization may occur at various stages of the legal process, including police investigation, prosecutorial handling, and court proceedings. Victims may face hostile cross-examination, repeated questioning, delays, public exposure, or a lack of empathy, all of which can exacerbate their suffering.
The judiciary has acknowledged this concern in cases such as Bodhisattwa Gautam v Subhra Chakraborty11, where the Supreme Court recognized the need to protect victims from further harm during legal proceedings and emphasized the importance of compensation and dignity. Similarly, courts have increasingly stressed the need for in-camera trials and confidentiality in sensitive cases to prevent re-traumatization.
Secondary victimization not only affects the psychological well-being of victims but also discourages them from participating in the justice process, thereby weakening the overall effectiveness of the system. It undermines the principles of fairness and justice, making it imperative for justice administering authorities to adopt victim-friendly practices.
To mitigate secondary victimization, several measures are necessary, including specialized training for prosecutors, adoption of sensitive interviewing techniques, minimizing unnecessary delays, and ensuring privacy and protection for victims. Strengthening coordination between prosecution, police, and support services can also contribute to a more humane and responsive system.
In conclusion, the role of prosecution is central to achieving victim justice, but it must be exercised with a conscious commitment to empathy and fairness. Addressing the issue of secondary victimization is equally critical in ensuring that victims are not subjected to further harm within the justice system. Together, these elements underscore the need for a more compassionate and victim-oriented approach to criminal justice administration.
COMPARATIVE PERSPECTIVE, CHALLENGES, AND RECOMMENDATIONS
A comparative analysis of victim justice frameworks across jurisdictions reveals that many countries have moved significantly towards institutionalizing victim rights and support systems. In jurisdictions such as the United Kingdom and the United States, victims are recognized as active participants in the criminal justice process rather than passive observers. Mechanisms such as victim impact statements, dedicated victim advocacy services, compensation funds, and specialized courts for sexual offences have strengthened the role and protection of victims. These systems emphasize timely information sharing, psychological support, and procedural safeguards to minimize trauma.
Internationally, the influence of the United Nations Declaration of Basic Principles of Justice for Victims of Crime and Abuse of Power 1985 has been instrumental in shaping national policies by advocating access to justice, restitution, compensation, and assistance for victims. Many countries have incorporated these principles into domestic legislation, creating structured victim support services and ensuring greater accountability of justice administering authorities.12
In comparison, India has made notable progress through legislative reforms, judicial activism, and the introduction of institutional mechanisms such as victim compensation schemes and witness protection programs. However, the implementation of these measures often falls short of global best practices. While the legal framework is increasingly victim-centric, gaps persist in execution, coordination, and accessibility.
Several challenges continue to hinder the realization of effective victim justice in India. One of the most significant issues is the lack of awareness among victims regarding their rights and available remedies. Many victims remain unaware of compensation schemes, legal aid services, and procedural safeguards, limiting their ability to seek justice. Additionally, delays in investigation and trial processes contribute to prolonged uncertainty and distress, undermining confidence in the system.
Institutional limitations further exacerbate these challenges. Inadequate infrastructure, shortage of trained personnel, and lack of coordination among police, prosecution, and support services create barriers to efficient service delivery. Victims also face social and cultural obstacles, including stigma, fear of retaliation, and societal pressure, particularly in cases involving gender-based violence. These factors often discourage victims from reporting crimes or participating fully in legal proceedings.
Another critical concern is the persistence of secondary victimization, where victims experience further trauma due to insensitive treatment by authorities or procedural complexities. Despite judicial guidelines, the absence of uniform implementation of victim-friendly practices continues to affect victim experiences negatively.
To address these challenges, a series of recommendations can be proposed. First, there is a need to strengthen the legal framework by clearly codifying victim rights and ensuring their enforceability. While existing provisions provide a foundation, a comprehensive victim rights charter could enhance clarity and accountability. Second, institutional capacity must be improved through better infrastructure, increased funding, and the establishment of dedicated victim support units within the criminal justice system.
Third, training and sensitization programs for police officers, prosecutors, and judicial officers are essential to foster a victim-centric approach in practice. Such training should focus on communication skills, psychological awareness, and handling vulnerable victims with empathy and respect. Fourth, awareness campaigns should be conducted to educate the public and victims about their rights and available support mechanisms.
Fifth, the integration of technology can significantly improve access to justice. Digital platforms for filing complaints, tracking case progress, and accessing legal aid services can enhance transparency and efficiency. Additionally, strengthening witness protection mechanisms and ensuring timely disbursement of compensation are crucial for building victim confidence in the system.
Finally, greater involvement of civil society organizations and community-based initiatives can complement state efforts by providing counselling, rehabilitation, and advocacy services. A collaborative approach involving all stakeholders is essential for creating a holistic and responsive victim justice framework.
In conclusion, while India has taken important steps towards aligning with international standards of victim justice, substantial work remains to bridge the gap between law and practice. A comparative perspective highlights both the progress made and the areas requiring reform. By addressing existing challenges through targeted recommendations, the criminal justice system can move closer to achieving a truly victim-centric model that upholds dignity, fairness, and justice for all victims.
CONCLUSION
The transformation of justice administering authorities towards a victim-centric model represents a significant and necessary evolution in criminal jurisprudence. Moving beyond a traditionally offender-focused system, contemporary legal frameworks increasingly acknowledge that justice must address the rights, dignity, and needs of victims alongside the adjudication of guilt. In India, this shift is evident through progressive legislative measures, judicial activism, and the development of institutional mechanisms aimed at enhancing victim protection and participation. Instruments such as the Code of Criminal Procedure 1973, along with judicial pronouncements in cases like Ankush Shivaji Gaikwad v State of Maharashtra and Lalita Kumari v Government of Uttar Pradesh, demonstrate a growing commitment to integrating victim rights into the criminal justice process.
Despite these advancements, the practical realization of victim-centric justice remains constrained by systemic inefficiencies. Delays in investigation and trial, inadequate implementation of victim compensation schemes, lack of awareness among victims, and insufficient coordination among justice administering authorities continue to undermine the effectiveness of existing frameworks. Moreover, issues such as secondary victimization and social stigma further complicate the victim’s journey through the justice system, often discouraging meaningful participation.
In this context, a holistic and multi-dimensional approach is imperative. Legal reforms must be complemented by robust institutional capacity building, including improved infrastructure, specialized training for police and judicial officers, and strengthened prosecutorial practices. Equally important is the promotion of societal awareness, which can empower victims to assert their rights and reduce the stigma associated with victimization. The integration of technology, expansion of victim support services, and active involvement of civil society organizations can further enhance accessibility and responsiveness.
Ultimately, a truly effective criminal justice system is one that not only punishes offenders but also restores the dignity, security, and confidence of victims. Recognizing victims as central stakeholders is not merely a legal necessity but a moral imperative. The continued commitment of justice administering authorities towards empathy, fairness, and accountability will be crucial in achieving a balanced and humane system of justice that serves both societal interests and individual rights.
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Footnotes
1. R I Mawby and S Walklate, Critical Victimology (Sage Publications 1994)
2. Criminology and Penology by N.V. Paranjape.
3. Ratanlal & Dhirajlal’s The Code of Criminal Procedure (LexisNexis).
4. United Nations Declaration of Basic Principles of Justice for Victims of Crime and Abuse of Power 1985.
5. Andrew Ashworth, Sentencing and Criminal Justice (Cambridge University Press 2015)
6. Code of Criminal Procedure 1973
7. (2013) 6 SCC 770 (India)
8. (2019) 14 SCC 615 (India)
9. (2014) 2 SCC 1 (India)
10. (1996) 1 SCC 490 (India
11. Ibid
12. United Nations Declaration of Basic Principles of Justice for Victims of Crime and Abuse of Power 1985