DAMODARAM SANJIVAYYA NATIONAL LAW UNIVERSITYVISAKHAPATNAM, A.P., INDIA

PROJECT TITLE: BURDEN OF PROOF

SUBJECT: EVIDENCE

NAME OF THE FACULTY: MRS. NANDINI C.P

Name of the Candidate-AMARENDRA KUMAR

Roll No.2013016 & Semester- IVth

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CERTIFICATE

This is to certify that my Project Work entitled “BURDEN OF PROOF” Submitted by Amarendra

Kumar is the record of work carried out during semester-IV of second Year B.A. LL.B. Course

for the academic year 2013-2018 under my Supervision and guidance in conformity with the

syllabus prescribed by Damodaram Sanjivayya National Law University.

Place: Visakhapatnam.

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ACKNOWLEDGEMENT

Firstly, I would like to thank my Guide and faculty ofcr.pc, Mrs. Nandini C.P for giving an

opportunity to undertake this work and successfully accomplishing the same.

I would also like to thank her for her valuable guidance and for being a solvency of inspiration

and encouragement enabling the work and to complete the work successful.

Last but not the least I would like to thank all the background supports who have spent their

valuable time to support me throughout my project work.

Place: Visakhapatnam

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Research Methodology:

Doctrinal research methodology has been used.

Aims and objectives:

Objective of the paper is to find out how res-judicata binds a pre-litigated matter to be re-

litigated.

Scope and Limitations:

Scope of the present paper is to conceptualise estoppel by res-judicata. While writing the paper

the biggest hurdle that the researcher had to face was of unavailability of views of scholars in the

form of articles.

Research Questions:

I have attempted to answer the following questions in the present paper:

What is the meaning of legal burden of proof ?

How is the principle of burden of proof applied in various legal circumstances?

Style of Writing:

This research work has largely descriptive style of writing.

Sources of Data:

Primary sources in the form of law reports and secondary sources in the form of books have been

used to answer the various research questions and websites.

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Table of Contents

Literature review.......................................................................................................5

Introduction...............................................................................................................7

General Concept of Burden of Proof.........................................................................8

Statutory provisions under Indian Evidence Act, 1872.............................................9Rule 1......................................................................................................................................................9

Burden of Proof and Onus of Proof.......................................................................................................10

Rule 2....................................................................................................................................................10

Rule 3....................................................................................................................................................11

Rule 4:...................................................................................................................................................11

Rules of Presumption –...........................................................................................11Exceptions -...........................................................................................................................................12

Burden of proof in various contexts........................................................................13(1) Plea of alibi:.....................................................................................................................................13

(2) Food Adulteration:...........................................................................................................................14

(3) Election Petition:..............................................................................................................................14

(4) Constitutionality:.............................................................................................................................14

(5) Matrimonial Cases:..........................................................................................................................15

(6) Adoption..........................................................................................................................................15

(7) Blank Signature................................................................................................................................15

(8) Benami Transaction.........................................................................................................................16

(9) Departmental Proceedings...............................................................................................................16

Conclusion...............................................................................................................18

BIBLIOGRAPHY...................................................................................................18

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Literature reviewHARVARD LAW REVIEW.(VOL.IV, MAY 15, 1890,NO. 2) THE BURDEN OF PROOF

The burden of proof is a party’s responsibility to prove a disputed charge, allegation, or defense.

The burden of proof has two components: the burden of production and the burden of persuasion.

The burden of production is the obligation to present evidence to the judge or jury. The burden of

persuasion is the duty to convince the judge or jury to a certain standard, such as beyond a

reasonable doubt, which is defined shortly. This standard is simply a measuring point and is

determined by examining the quantity and quality of the evidence presented. “Meeting the

burden of proof” means that a party has introduced enough compelling evidence to reach the

standard defined in the burden of persuasion.

MERICAN LAW REGISTER(APRI 1870)THE BURDEN OF PROOF IN CASES OF INSANITYWho has the burden of proof with an insanity defense has been a source of controversy. Before, a

majority of states had the burden of proof rest with the state; that is, the prosecutor had to prove

that the defendant was not insane. The vast majority of states required the defense to prove that

the defendant was indeed insane. In states where the burden is on the defense to prove insanity,

the defense is required to show either by clear and convincing evidence or by a preponderance of

the evidence that the defendant is insane. In states where the burden is still on prosecutors to

prove sanity, they are required to prove it beyond a reasonable doubt.

The Burden of Proof Prepared by JACK LAZARUS, Australia, for the meeting of Committee 6 at the Lisbon Conference, May 1981(International Legal Practitioner, 1981, Vol. 6(ii) Printed in Great Britain)

The campaign in Australia against drug related crimes, heroin in particular, has the result that

people charged with trafficking or importing heroin are invariably convicted. The burden of

proof, being so well entrenched in the minds of not only Jurists brought up in the Common Law

traditions, but the people at large, is hard to openly attack. The sanctity of Mens Rea or the

objective standard of morality as an essential element of crime at Common Law,has been

weakened in recent years. Nevertheless it has, for long past, been firmly established as a cardinal

feature of the Criminal Law.

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Burden of Proof by Louis KaplowThis Article examines how strong evidence should have to be in order to assign liability when

the objective is to maximize social welfare. In basic settings, there is a tradeoff between

deterrence benefits and chilling costs, and the optimal proof requirement is determined by factors

that are almost entirely distinct from those underlying the preponderance of the evidence rule and

other traditional standards. As a consequence, these familiar burden of proof rules have some

surprising properties, as do alternative criteria that have been advanced. The Article also

considers how setting the proof burden interacts with other features of legal system design, such

as the determination of enforcement effort and the degree of accuracy of adjudication.

IntroductionA duty placed upon a civil or criminal defendant to prove or disprove a disputed fact1.1 Dr. V. Krishnamachari, Law of Evidence, (7th ed ,S.Gogia &Co., Hyderabad, 2010)

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Burden of proof can define the duty placed upon a party to prove or disprove a disputed fact, or it

can define which party bears this burden. In criminal cases, the burden of proof is placed on the

prosecution, who must demonstrate that the defendant is guilty before a jury may convict him or

her. But in some jurisdiction, the defendant has the burden of establishing the existence of

certain facts that give rise to a defense, such as the insanity plea. In civil cases, the plaintiff is

normally charged with the burden of proof, but the defendant can be required to establish certain

defenses2.

Burden of proof can also define the burden of persuasion, or the quantum of proof by which the

party with the burden of proof must establish or refute a disputed factual issue. In criminal cases,

the prosecution must prove the defendant's guilt Beyond a Reasonable Doubt.

General Concept of Burden of Proof

The responsibility to prove a thing is called burden of proof. When a person is required to prove

the existence or truthfulness of a fact, he is said to have the burden of proving that fact. In a case,

many facts are alleged and they need to be proved before the court can base its judgment on such

facts. The burden of proof is the obligation on a party to establish such facts in issue or relevant

facts in a case to the required degree of certainty in order to prove its case. For example, in a case

of murder, prosecution may allege that all the conditions constituting a murder are fulfilled. All

such conditions are facts in issue and there is an obligation to prove their existence. This

obligation is a burden of proof. In general, every party has to prove a fact that goes in his favor

or against his opponent, this obligation is nothing but burden of proof. Section 101 defines

burden of proof as follows - When a person is bound to prove the existence of any fact, it is said

that the burden of proof lies on that person.

The important question is who is supposed to prove the various facts alleged in a case. In other

words, on whom should the burden of proving a fact lie? The rules for allocation of burden of

2 Scheibe, Benjamin D. 2003. "Claim of Reverse Engineering Doesn't Alter Burden of Proof." The Los Angeles Daily Journal 116 (October 2).

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proof are governed primarily by the provisions in Section 101 to 105. The rules propounded by

these sections can be categorized as General rules and Specific rules.

Statutory provisions under Indian Evidence Act, 1872

Rule 1: As per Section 101, specifies the basic rule about who is supposed to prove a fact. It says

that whoever desires any Court to give judgment as to any legal right or liability dependent on

the existence of facts which he asserts, must prove that those facts exist3. For example, A desires

a Court to give judgment that B shall be punished for a crime which A says B has committed. A

must prove that B has committed the crime. Another example - A desires a Court to give

judgment that he is entitled to certain land in the possession of B, by reason of facts which he

asserts, and which B denies, to be true. A must prove the existence of those facts.

Facts can be put in two categories - those that positively affirm something and those that deny

something. For example, the statement, "A is the owner of this land" is an affirmative statement,

while "B is not the owner of this land" is a denial. The rule given in Section 101 means that the

person who asserts the affirmative of an issue, the burden of proof lies on his to prove it. Thus,

the person who makes the statement that "A is the owner of the land", has the burden to prove it.

This rule is useful for determining the ownership of the initial burden. Whoever wishes the court

to take certain action against the opposite party based on certain facts, he ought to first prove

those facts.

However, it is not very simple to categorize a fact as asserting the affirmative. For example, in

the case of Soward vs Legatt4, 1836, a landlord suing the tenant asserted that the tenant did not

repair the house. Here, he was asserting the negative. But the same statement can also be said

affirmatively as the tenant let the house dilapidate. In this case, Lord ABINGER observed that in

ascertaining which party is asserting the affirmative the court looks to the substance and not the

3 Singh Avtar, Priniciples of the Law of Evidence, (8th ed, Central Law Publications, Allahabad 2007)4 Soward vs Legatt, 1836

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language used. Looking at the substance of this case, the plaintiff had to prove that the premises

were not repaired.

Thus, the court should arrive at the substance of the issue and should require that party to begin

who in substance, though may not be in form, alleges the affirmative of the issue.

Burden of Proof and Onus of Proof

The term Burden of Proof is used in two difference senses - the burden of proof as a matter of

law and pleading, and the burden of proof as a matter of adducing evidence also called as onus.

There is a subtle distinction between burden of proof and onus of proof, which was explained in

the case of Ranchhodbhai vs Babubhai5. The first one is the burden to prove the main contention

of party requesting the action of the court, while the second one is the burden to produce actual

evidence. The first one is constant and is always upon the claimant but the second one shifts to

the other party as and when one party successfully produces evidence supporting its case. For

example, in a case where A is suing B for payment of his services, the burden of proof as a

matter of law is upon A to prove that he provided services for which B has not paid. But if B

claims that the services were not up to the mark, the onus of burden as to adducing evidence

shifts to B to prove the deficiency in service. Further, if upon providing such evidence, A claims

that the services were provided as negotiated in the contract, the onus again shifts to A to prove

that the services meet the quality as specified in the contract..

Rule 2: Determines who has the onus of proof .As per Section 102, the burden of proof in a suit

or proceeding lies on that person who would fail if no evidence at all were given on either side.

The following illustrations explain this point -

Illustration 1:

A sues B for land of which B is in possession, and which, as A asserts, was left to A by the will

of C, B's father. If no evidence were given on either side, B would be entitled to retain his

possession. Therefore the burden of proof is on A.

Illustration 2:

5 AIR 1982 Guj 308

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A sues B for money due on a bond. The execution of the bond is admitted, but B says that it was

obtained by fraud, which A denies. If no evidence were given on either side, A would succeed,

as the bond is not disputed and the fraud is not proved. Therefore the burden of proof is on B.

Rule 3:

As per Section 103, the person who wants the court to believe in an alleged fact is the one who is

supposed to prove that fact unless it is provided by any law that the proof of that fact shall lie on

any particular person. For example, A prosecutes B for theft, and wishes the Court to believe that

B admitted the theft to C. A must prove the admission. Another example - B wishes the Court to

believe that, at the time in question, he was elsewhere. He must prove it. Further, as specified in

Section 104, if a person wants the court to believe in a fact that assumes the existence of another

fact, it is up to the person to prove the other fact also. For example, A wishes to prove a dying

declaration by B. A must prove B's death. A wishes to prove, by secondary evidence, the

contents of a lost document. A must prove that the document has been lost.

Rule 4:

These rules specifically put the burden on proving certain facts on particular persons . As per

Section 106, when any fact is especially within the knowledge of any person, the burden of

proving that fact is upon him. When a person does an act with some intention other than that

which the character and circumstances of the act suggest, the burden of proving that intention is

upon him. For example, A is charged with traveling on a railway without a ticket. The burden of

proving that he had a ticket is on him.6

Rules of Presumption –

Section 107 and 108 say that if a person was known to be alive within 30 years the presumption

is that he is alive and if the person has not been heard of for seven years by those who have

6 http://hanumant.com/LOE-Unit11-BurdenOfProof.html

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naturally heard from him if he had been alive, the presumption is that the person is death. But no

presumption can be draw as to the time of death. Sections 109 establishes the burden in case of

some relations such as landlord and tenant, principle and agent etc. Further sections specify the

rules about burden of proof in case of terrorism, dowry death, and rape.

Exceptions -

1. Presumed Innocence : It is the prosecution who is required to establish the guilt of the

accused without any doubt. At the same time, the accused is not required to prove his innocence

without any doubt but only has to create reasonable doubt that he may not be guilty. Section 105

specifies an exception to this general rule. When an accused claims the benefit of the General

Exception clauses of IPC, the burden of proving that he is entitled to such benefit is upon him.

For example, if an accused claims the benefit of insanity in a murder trial, it is up to the accused

to prove that he was insane at the time of committing the crime.

In the case of K M Nanavati vs State of Maharashtra7, SC explained this point. In this case,

Nanavati was accused of murdering Prem Ahuja, his wife's paramour, while Nanavati claimed

innocence on account of grave and sudden provocation. The defence's claim was that when

Nanavati met Prem at the latter's bedroom, Prem had just come out of the bath dressed only in a

towel; an angry Nanavati swore at Prem and proceeded to ask him if he intends to marry Sylvia

and look after his children. Prem replied, "Will I marry every woman I sleep with?", which

further enraged Nanavati. Seeing Prem go for the gun, enclosed in a brown packet, Nanavati too

went for it and in the ensuing scuffle, Prem's hand caused the gun to go off and instantly kill him.

Here, SC held that there is a presumption of innocence in favor of the accused as a general rule

and it is the duty of the prosecution to prove the guilt of the accused beyond any doubt. But when

an accused relies upon the general exception or proviso contained in any other part of the Penal

Code, Section 105 of the Evidence Act raises a presumption against the accused and also throws

a burden on him to rebut the said presumption. Thus, it was upon the defence to prove that there

existed a grave and sudden provocation. In absence of such proof, Nanavati was convicted of

murder.

7 AIR 1962 SC 605

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2. Admission: A fact which has been admitted by a party and which is against the interest of that

party, is held against the party. If the fact is contested by the party, then the burden of proof rests

upon the party who made the admission. For example, A was recorded as saying that he

committed theft at the said premises. If A wants to deny this admission, the burden of proof rests

on A to prove so.8

3. Presumptions: Court presumes the existence of certain things. For example, as per Section

107/108, court presumes that a person is dead or alive based on how long he has not been heard

of. Section 109, presumes that when two people have been acting as per the relationship of

landlord - tenant, principle - agent, etc, such relationship still exists and anybody who contends

that such relationship has ceased to exist has to provide proof. Section 110 presumes that the

person who has the possession of a property is the owner of that property. As per Section 113A,

When the question is whether the commission of suicide by a woman had been abetted by her

husband or any relative of her husband and it is shown that she had committed suicide within a

period of seven years from the date of her marriage and that her husband or such relative of her

husband had subjected her to cruelty, the court may presume, having regard to all the other

circumstances of the case, that such suicide had been abetted by her husband or by such relative

of her husband9. As per Section 113B, when the question is whether a person has committed the

dowry death of a woman and it is shown that soon before her death such woman had been

subjected by such person to cruelty or harassment for, or in connection with, any demand for

dowry, the court shall presume that such person had caused the dowry death.Thus, when the

presumption of the court is in favor of a party, the burden of disproving it rests on the opposite

party.

Burden of proof in various contexts

8 C.L. Subramaniam v. Collector of Customs, AIR 1972 SC 21789  Anil Kumar v. Presiding Officer & Ors., AIR 1985 SC 1121

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(1) Plea of alibi:

Where the accused raises the plea of alibi(his presence elsewhere) burden lies on him to

substantiate that fact that at least to that extent of a reasonable probability. Even if the evidence

produced is capable of creating a doubt whether the accused was there at the time of the

happening, he becomes entitled to benefit of doubt.10 The court cited the decision of Supreme

Court in Soma Bhai v. State of Gujrat11 where it was taken to be a settled law that a plea of alibi

has got to be proved to the satisfaction of the court. The court also noted that the burden of

substantiating such a plea and making it reasonably probable is on him.

(2) Food Adulteration:

Where a person is charged under Prevention of Food Adulteration Act,1954 for selling sub-

standard Heeng, and it was shown by him that the article was meant for animal consumption, the

pricing factor as well as report of the public analyst showed that it was being marketed for use of

animals, the court said that the burden to show otherwise was upon the food inspector who had

taken the sample from the accused12.

(3) Election Petition:

When an election is challenged on the ground that the result was vitiated by the fact that the

nomination of a candidate wrongly accepted, the Supreme Court held that the burden lay upon

the petitioner that the votes cast on favour of the wrongly accepted candidate would have gone I

his favour to such an extent that he would have been returned and that though this fact is very

difficult to prove the rules relating to burden of proof will remain whether it is difficult or

virtually impossible to prove the fact in question13.

(4) Constitutionality:

In the petition challenging the constitutionality of a statute, the allegations regarding the

violation of the constitutional provisions should be specific, clear and unambiguous and burden

of proof is upon the person challenging its constitutionality. In the case of Gauri Shankar v.

Union of Indai14a, the Supreme Court held that:

10 Jagarnath giri v State of Bihar, 1992 CrLJ 648 Pat.11 AIR 1975 SC 145312 Rajesh Kumar v. State of UP, 2001 CrLJ 2093(All)13 Shiv Charan Singh v. Chandra Bhan Singh, AIR 1988 SC 63714 1994 AIR SCW 4059

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(a) there is always a presumption in the favour of constitutional validity of an enactment and the

burden is upon him who attacks it to show that there has been clear transgression of the

constitutional principles,

(b) it must be presumed that the Legislature understands and correctly appreciates the needs of

its own people, that its laws are directed to problems made manifest by experience and that its

discrimination is based on adequate grounds,

(c) in order to sustain the presumption of constitutionality the court may take into consideration

matters of common knowledge, matters of common report, the history of the times and may

assume every date of facts which can be conceived existing at the time of the legislation.

(5) Matrimonial Cases:

In matrimonial cases principle of burden of proof relating to civil cases are applicable15. Rules of

evidence in divorce cases are the same in other civil matters, namely, decisions go by

preponderance of probability. But even so the initial burden is on the petioner. A party seeking

divorce has to prove the fact that the same was without cause, even if the party going apart is not

liable to justify her conduct. It is the duty of the husband to pay for the medical examination of

the wife and if she did not get costly medical aid for wants of funds, no adverse inference could

be drawn against her16. In the instant case the husband sought divorce on the ground of mental

disorder of the wife.

(6) Adoption

An onus of grave and serious matter lies on the person who alleges adoption because the fact of

adoption changes rights of succession to property17. Where there was no evidence about

consultation between natural and adoptive fathers, no material witness were examined and there

was inconsistency about the ceremonies performed, the adoption was held to be doubtful18.

(7) Blank Signature

Where the defendants said that he had put his signature only on the blank paper, it was held that

the evidence adduced by the plaintiff to the effect that the defendant has executed a document, if

15 A v. B, AIR 1985 Guj 12116 Rekha v. Ravindra Kumar, AIR 1994 NOC 330(MP)17 Bhuvenshwar Prasad v. State of Bihar AIR 1995 OrI 3218 Bijaya Kumar Chaul Singh v. State of Orrisa, AIR 1994 NOC 41(Ori)

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found reliable, would discharge the burden of the plaintiff and put the burden on the defendant to

show that he has not executed any document19.

(8) Benami Transaction

When a person purchases a property in another person’s name and also gets it registered in that

person’s name , if subsequently he wishes to assert his ownership, the burden would be upon him

to prove that fact. In case of this kind, the Supreme Court observed as follows:

“It is well settled that burden of proving that particular sale is benami and the apparent purchaser

is not the real owner, always rests on the person asserting it to be so. The essence of a benami is

the intention of the parties concerned; and not often such intention is shrouded in a thick veil

which cannot be easily pierced through. But such difficulties do not relieve the persons asserting

the transaction to be a benami of the serious onus that rests on him, nor justify the acceptance of

a mere conjecture or surmises, as a substitute for proof.”

(9) Departmental Proceedings

Evaluation of evidence is a judicial process and arbitrariness is surely not allowed. Although the

Indian Evidence Act is not applicable in the departmental proceedings, its provisions have to be

noticed during evaluation of evidence; albeit not with the same rigour as done in courts of law.

The Supreme Court observed in Union of India v. HC Goel20 that “mere suspicion should not be

allowed to take place of proof even in domestic inquiries” and also that “the principle that in

punishing the guilty scrupulous care must be taken to see that the innocent are not punished,

applies as much to regular criminal trials as to disciplinary inquiries.”

In State of Haryana v. Rattan Singh21, the Supreme Court stated that; “The essence of a judicial

process is objectivity, exclusion of extraneous materials or considerations and observance of

rules of natural justice. Of course, fair play is the basis and if perversity or arbitrariness, bias or

surrender of independence of judgement vitiate the conclusions reached, such finding, even

though of a domestic tribunal, can not be held good.” The following established norms and

principles are practiced in departmental inquiries to appreciate and evaluate evidences.

1. Inquiry report must be based on records of the case alone.19 Kuttadan Velayudhan Re, AIR 2001 SC 12320 AIR 1964 SC 36421 AIR 1977 SC 1512

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The deliberations in the report must remain confined to the records of inquiry which consist of

the Charge-sheet, Reply thereto, Original documents relied upon by prosecution as well as

defence, written briefs filed by both parties summing up their respective cases in their own way,

depositions of witnesses produced by both sides, statement of charge-sheeted employee and his

answers to questions put by inquiry officer. Inquiry officer can neither leave out anything from

these records nor can consider anything out of the records. All public servants can claim the

constitutional guarantee provided to civil servants under article 331 that any penalty can be

imposed only on the basis of evidence adduced during the course of inquiry.

2. Material collected behind the back of accused can not be used by Inquiry Officer.

Supreme Court has clearly held in State of Assam v. MK Das22 and Union of India v. Ramzan

khan23 that any information not collected and put to the charged employee during the course of

inquiry can not be used by inquiry officer for drawing his inferences.

3. For drawing his inferences.

Inquiry Officer cannot use his personal knowledge of the case or of persons involved. His

findings must be free from personal bias.

4. Assessment is to be made only of the points at issue.

5. The burden of proof is on the employer.

The Orissa High Court, in Radhakrishna v. State24 observed that “… a tribunal is wrong if it

places the burden of establishing his innocence on the public servant” and charge has to be

proved against delinquent and it is not for the delinquent to absolve himself from the charge’.

But it is necessary to understand that the prosecution is bound to prove those facts which are

necessary to prove the allegations made against employee. The burden of proving essential facts

relating to his version of things lie on employee. For example, in case of a charge of

misappropriation of funds; prosecution is bound to prove that the money in question was

entrusted to the charge-sheeted employee. After that, it is for the employee to prove that he

applied the money for the purpose for which it was entrusted to him. This understanding is 22 AIR 1970 SC 125523 1991 (1) SLR 159 24 1977 SCR (3) 249

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necessary because, in the departmental inquiry, the case of prosecution fails, no doubt, if the

basic facts relating to charge are not proved. But, if basic facts of charge as well as certain facts

related to the version of employee are also proved; the final findings shall be arrived using the

preponderance of probability standard of proof applicable for such inquiries.

6. Guilt is not there if charges not proved. In keeping with The Supreme Court observation in

Union of India v. HC Goel25 that the principle of taking care so that the innocent are not

punished, applies to disciplinary inquiries; the inquiry officer cannot report finding of guilt if the

burden of proof has not been discharged by the prosecution and the articles of charge have not

been proved in accordance with the standard of proof required in such inquiry.

ConclusionThe burden of proof lies on the party who substantially asserts the affirmative of the issue and

not upon the party who denies it. This rule of convenience has been adopted in practice, not

because it is impossible to prove a negative but because the negative does not admit of the direct

and simple proof of which the affirmative is capable. It means sometimes that that a party is

required to prove an allegation before judgment can be given in its favour; it also means that on

contested issue one of the two contending party has to introduce evidence.

BIBLIOGRAPHY

Books Referred:

1) Dr. V. Krishnamachari, Law of Evidence, (Hyderabad: S.Gogia &Co.), 2010

2) Singh Avtar, Priniciples of the Law of Evidence, (Allahabad : Central Law Publications),

2007

3) Dhiraj Lal & Ratanlal, TheLaw of Evidence,(Nagpur : Wadhwa & Company), 2008

25 AIR 1964 SC 364

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WEBSITES:

1) www.manupatra.com

2) www.heinonline.com

3) www.westlawindia.com

4) www.indiankanoon.com

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