RIGHT TO PRIVATE DEFENCE UNDER CRIMINAL LAW: PROVISIONS, PRINCIPLES AND CASES

Author-M. Yesaswini Sai Nikitha, Dr.B.R.Ambedkar College of Law, Andhra University

INTRODUCTION-

In India, the Indian Penal Code, 1860 governs crimes, defences and punishments. The general defences and exceptions are explained by Sec.76 to 106 of Chapter –IV, IPC. The concept of right of private defence is also described with relevant provisions from Sec.96 to 106 extensively below the aforesaid chapter. The types, principles and limitations to right of private defence of the person and property were provided in this part of IPC.

These sections permit the individuals to use required force against an assailant  or wrongdoer to safeguard their own body and property, as well as that of others, when rapid support from the public authorities can’t be taken. In such instances, the persons cannot be made liable for the acts done in self-defence. Self-Help is treated as the foremost principle in law governing crimes. The right of private defence is crucial for any citizen to secure his/her life, liberty or property which is diligently regulated by the law.

Keywords : Right of Private Defence, Indian Penal Code,1860, concept of self-defence, In defence of person, In defence of property, limitations, defensive right, Sec.96 to 106 of IPC.

Meaning of the right of private defence :

Private Defence refers to using unlawful acts to protect oneself, another person, or property or to prevent criminal activity. The right of private defence is considered as inherent right of man. “The term “Body” refers to one’s own physical body or other person body, whereas the “property” indicates both movable and immovable possessions of oneself or of others.”[1]

Sec.96 of the IPC elucidates the provision of things done in private defence. The acts done by the individual in the exercise of their right of private defence against the attackers are not considered as offences, only if they fall under the specified criteria. The aforesaid right can be exercised only when there is a forthcoming danger and when aid from the statutory authorities is unavailable.

In simple terms, private defence refers to the exercise of actions which are prohibited but performed to protect oneself, another human being or property or to prevent any criminal activity. In this purview, the right of private defence is granted to Indian citizens to endure threats or dangers without delay and secure their bodies. Article-21 of the Constitution of India,1950 guarantees the right to life and personal liberty to all persons, in accordance of this fundamental right, a person can utilise the right of private defence under IPC,1860.

Nature of the right of private defence :

According to Eminent jurist, Bentham, “A man owes a duty to society to protect person and property of others. It concerns the public safety that every honest man should consider himself as the natural protector of every other.[2] It is rightly said that the self- help is treated as the best help that a person could do for himself.

The ultimate aim of a state is the welfare and protection of the people, but it cannot deploy police officers everywhere to safeguard its citizens from harm or injury. So the state empowers the people to save themselves through the right of private defence.  A fundamental duty is imposed on the state to secure public property and renounce public violence by Art.51(a)(i)[3] of the Constitution of India ,1950.

 The protection of the body and property should often considered as his primary responsibility. In the exercise of his foremost duty, if the person commits any unlawful act it doesn’t generate a reciprocal right of private defence, if that illegal action taken by the defender is in genuine self-defence. In democratic countries, the citizens should be provided with the aforesaid privilege to protect themselves from unavoidable danger when state assistance is unavailable or no reasonable time to take recourse to police authorities.

Essential components of the right of private defence :

The elements of the right of private defence can be compiled under the following heads:

  • Apprehension of danger: The aforesaid right can be exercised where a reasonable fear of harm or danger arises to a person or other person or property, but the harm must be impending and not merely uncertain and hypothetical.
  • Unlawful act: The right of private defence can be invoked only in defence of an unlawful act by another person that includes assault, criminal trespass, housebreaking, mischief or robbery.
  • Proportionate force: The reasonable force used by a person to defend himself, should be in accordance with the threat faced and the person while defending himself should try to decrease the harm done to the assailant.
  • No alternative remedy: This privilege can be used in a situation when there is no time to take recourse from legal authorities or to seek protection from public authorities.
  • Continuity of the threat: This right can be invoked until the threat or harm continues to exist, but once the harm is ceased, its exercise beyond the threat is not justified.
  • Absence of aggression: While exercising this privilege, to protect oneself from impending danger or harm, the person should not do such acts in aggression and later plead for the right of private defence.
  • No excessive force: The reasonable force used by the defender should not exceed the required force to prevent imminent harm.

Interpretation of the Legal Provisions involved :

Sec.96 of IPC, 1860Things done in private defenceNothing is an offence which is done in the exercise of the right of private defence.”[4]

Under Sec.96 of IPC, it is explained that all citizens have the right of private defence. However, it is not absolute but qualified by Sec.99 which states that this right will not apply to the case in which more harm is caused than it is actually required to defend himself. The burden of proving that a particular act is done in self defence is on the person who pleads it. The accused can be absolved on the plea of aforesaid right even if not pleaded by the him.

The right of private defence, as the name signifies, is an act of defence but not an act of offence. In a free quarrel, when the mutual parties fight, this right cannot be pleaded by any of the parties as both parties are responsible for their actions. Even if the act is result of the aggression of the accused then under the aforesaid privilege, the accused cannot be safeguarded.

To know whether the act was committed under self-defence or aggression, the court has to look into the facts and incidents keenly, and should not rely on any unreasonable presumptions. The court may apply any limitations to the case if necessary. A person by merely assuming the probability of threat and without reasonable cause, cannot exercise the defensive right. The distance between the attacker and the accused can also be a deciding factor to determine whether the act is done under aggression or self-defence. There is no certain measuring stick to determine that distance, whether it is done based on the facts and circumstances of the case or not.

  • 97 of IPC,1860– “Right of private defence of the body and of property.—Every person has a right, subject to the restrictions contained in section 99, to defend—

(First)— His own body, and the body of any other person, against any offence affecting the human body;

(Secondly)— The property, whether movable or immovable, of himself or of any other person, against any act which is an offence falling under the definition of theft, robbery, mischief or criminal trespass, or which is an attempt to commit theft, rob­bery, mischief or criminal trespass.”[5]

Sec.97 of IPC, 1860 authorises all the citizens to protect themselves and others from any immediate danger. Further, this provision expressly states that a person can protect his body, property as well as others property, regardless of whether it is movable or immovable, by exercising this right. An individual can protect himself from offences including theft, mischief or criminal trespass, robbery or an attempt to commit the above said offences by exercising this right.

Under this section, even a stranger can utilise this privilege to safeguard the body and property of others with whom he is not having any relationship before.

  • 98 of IPC,1860- “Right of private defence against the act of a person of unsound mind, etc.— When an act, which would otherwise be a certain offence, is not that offence, by reason of the youth, the want of maturity of understanding, the unsoundness of mind or the intoxication of the person doing that act, or by reason of any misconception on the part of that person, every person has the same right of private defence against that act which he would have if the act were that offence.”[6]

Sec.98 of IPC, explains the factors, depending on which the defensive act is not considered as an offence, which would be considered as an offence under normal circumstances. “The determining factors are:

  • Youth
  • Lack of maturity of understanding
  • Unsoundness of mind
  • Intoxication
  • Any misconception existing on the part of the attacker.”[7]

So if the act is performed by an individual under the above factors, in such instances this right can be invoked. This section further states that in the exercise of this right, the physical or mental capacity of the person, against whom the right is exercised, is not considered as a bar to its exercise. Therefore, one can utilise this privilege against the attackers regardless of their motive, legal status or any other exception, only when there is an actual fear of threat or harm.

  • 99 of IPC,1860Acts against which there is no right of private defence.—

There is no right of private defence against an act which does not reasonably cause the apprehension of death or of grievous hurt, if done, or attempted to be done, by a public servant acting in good faith under colour of his office, though that act, may not be strictly justifiable by law. There is no right of private defence against an act which does not reasonably cause the apprehension of death or of grievous hurt, if done, or attempted to be done, by the direction of a public servant acting in good faith under colour of his office, though that direction may not be strictly justifiable by law. There is no right of private defence in cases in which there is time to have recourse to the protection of the public authorities.

 Extent to which the right may be exercised.—The right of private defence in no case extends to the inflicting of more harm than it is necessary to inflict for the purpose of defence.”[8]

Limitations to exercise of the right of private defence: Sec.99 of IPC provides the extent to which the right can be exercised and the restrictions on exercise of this privilege. The limitations can be explained as:

(1)“The right of private defence cannot be exercised if the act doesn’t result in real apprehension of death or grievous hurt.

(2) This right can’t be invoked in the case where the act is done or attempted to be done by a public servant acting in good faith during his official duty.

(3)The right of private defence cannot be exercised when the act is performed under the direction of public authority in good faith while discharging his lawful duty.

(4)This right can’t be invoked when there is a reasonable time to take recourse to public authorities.”[9]

In this section, good faith, defined under Sec.52[10] of IPC,1860, is treated as the deciding factor to consider whether the act done or attempted to be done by the statutory authority or under the direction of public authority falls under Sec.99 or not.

The extent to which the right may be invoked is discussed in this section.

  • This privilege can be exercised only in a situation where the act by the attacker is treated as a specified offence under IPC,1860 or otherwise as stated under any other circumstances.
  • The right can be invoked in the case when the assailant’s act results in actual fear, threat or danger and that danger should be real, impending or resulting in criminal activity.
  • The privilege is itself defensive but not for the sake of imposing punishment or retribution.
  • This right cannot be exercised to shield an act of aggression of the accused.
  • This privilege cannot be invoked in a situation where there is reasonable means and time to seek protection from public authorities.

Sec.100 of IPC,1860When the right of private defence of the body extends to causing death.

The right of private defence of the body extends, under the restrictions mentioned in the last preceding section, to the voluntary causing of death or of any other harm to the assailant, if the offence which occasions the exercise of the right be of any of the descriptions hereinafter enumerated, namely:—

(First)— Such an assault as may reasonably cause the apprehension that death will otherwise be the consequence of such assault;

(Secondly)— Such an assault as may reasonably cause the apprehen­sion that grievous hurt will otherwise be the consequence of such assault;

(Thirdly)— An assault with the intention of committing rape;

(Fourthly)— An assault with the intention of gratifying unnatural lust;

(Fifthly)— An assault with the intention of kidnapping or abduct­ing;

(Sixthly)— An assault with the intention of wrongfully confining a person, under circumstances which may reasonably cause him to apprehend that he will be unable to have recourse to the public authorities for his release.

(Seventhly)— An act of throwing or administering acid or an attempt to throw or administer acid which may reasonably cause the apprehension that grievous hurt will otherwise be the consequence of such act.”[11]

Under Sec.100 of IPC, this privilege safeguards the accused whose defensive act resulted in death or grievous hurt to the assailant. “But this Sec.100 shall be applicable if it falls under the following circumstances:

  • Assault that reasonably causes the real apprehension of death.
  • Assault that reasonably causes the real apprehension of grievous hurt.
  • Assault to commit rape.
  • Assault to gratifying lust.
  • Assault with the intention of kidnapping or abducting.
  • An assault with the intention of wrongfully confining a person in the circumstances making the person not to take recourse to any public authority.
  • An act of throwing acid or attempt to administer the acid causing reasonable apprehension of grievous hurt.”[12]

Essentials of Sec.100 of IPC, 1860: To utilise this right under Sec.100, the essential factors are

  • The defender must not be at any fault like aggression while taking the self-defence.
  • There must be apprehension of imminent, actual and real harm or danger.
  • No other means and time to take recourse to statutory authorities.
  • There is no other option rather than defending the attacker.

Sec.101 of IPC, 1860 “When such right extends to causing any harm other than death.

If the offence be not of any of the descriptions enu­merated in the last preceding section, the right of private defence of the body does not extend to the voluntary causing of death to the assailant, but does extend, under the restric­tions mentioned in section 99, to the voluntary causing to the assailant of any harm other than death”[13].

This section explains that if the prohibited act cannot be brought under the factors stated in the earlier provision, the right of private defence can’t be extended to an act causing death or grievous hurt, but extends to the acts other than causing death specified under Sec.99.

Sec.102 of IPC,1860Commencement and continuance of the right of private defence of the body.—

The right of private defence of the body commences as soon as a reasonable apprehension of danger to the body arises from an attempt or threat to commit the offence though the of­fence may not have been committed; and it continues as long as such apprehension of danger to the body continues.”[14]

This section explains that the aforesaid privilege can be utilised as soon as the reasonable fear for the harm or injury of the act starts to exist, even if the act resulting harm was not yet committed. The self-defence can be exercised until the act inflicting harm ceases. But it is crucial that the actual attack must take place and the harm arising out of it must be immediate.

Sec.103 of IPC, 1860 –“When the right of private defence of property extends to causing death.

The right of private defence of property extends, under the restrictions mentioned in section 99, to the voluntary causing of death or of any other harm to the wrong-doer, if the offence, the committing of which, or the attempting to commit which, occasions the exercise of the right, be an offence of any of the descriptions hereinafter enumerated, namely:—(First)— Robbery;

(Secondly)— House-breaking by night;

(Thirdly)— Mischief by fire committed on any building, tent or vessel, which building, tent or vessel is used as a human dwell­ing, or as a place for the custody of property;

(Fourthly)— Theft, mischief, or house-trespass, under such circum­stances as may reasonably cause apprehension that death or griev­ous hurt will be the consequence, if such right of private de­fence is not exercised.”[15]

Sec.103 of IPC, 1860 provides the right of private defence of property extending to cause death. The act done in self-defence of property within the limitations specified in Sec.99 causing death of the attacker is allowed under this provision if the act can be brought under some conditions. These circumstances include robbery, house-breaking by night, mischief by fire committed on any building, tent or vessel that is considered as a human dwelling place, mischief, theft, or house-trespass that raises a rational fear of causing death or grievous hurt. Sec. 100 of IPC explains that the aforesaid right can be used by a person to secure his or some others body, whereas Sec.103 of IPC describes about right of an individual to defend his or others property.This right cannot be exercised against the person who has the title or possession over that property.

Sec.104 of IPC,1860-“When such right extends to causing any harm other than death.

If the offence, the committing of which, or the attempt­ing to commit which, occasions the exercise of the right of private defence, be theft, mischief, or criminal trespass, not of any of the descriptions enumerated in the last preceding section, that right does not extend to the voluntary causing of death, but does extend, subject to the restrictions mentioned in section 99, to the voluntary causing to the wrong-doer of any harm other than death.”[16]

According to this section, the above said right upon property cannot be extended to cause death or grievous hurt, but applied in case of theft, criminal trespass and not under any conditions mentioned in the previous provision. However, it is subjected to the limitations prescribed under Sec.99. As per Sec.104, if the defender while utilising this privilege causes death or grievous hurt of the attacker then he is liable under Sec.304 of IPC.

Sec.105 of IPC,1860Commencement and continuance of the right of private defence of property.

The right of private defence of property commences when a reasonable apprehension of danger to the property com­mences. The right of private defence of property against theft continues till the offender has effected his retreat with the property or either the assistance of the public authorities is obtained, or the property has been recovered. The right of private defence of property against robbery contin­ues as long as the offender causes or attempts to cause to any person death or hurt or wrongful restraint or as long as the fear of instant death or of instant hurt or of instant personal re­straint continues. The right of private defence of property against criminal tres­pass or mischief continues as long as the offender continues in the commission of criminal trespass or mischief. The right of private defence of property against house-breaking by night continues as long as the house-trespass which has been begun by such house-breaking continues.”[17]

This section provides about that the commencement and continuance of right depends on the nature of the act. The time period for the privilege to be utilised and the specified acts for exercising the right are summarised as follows:

  • “In the case of criminal trespass or mischief, the right of private defence continues as long as the offender is engaged in the commission of trespass or mischief.
  • In the case of robbery, the right of private defence continues as long as the offender is causing or attempting to cause death, hurt, or wrongful restraint to any person.
  • In the case of theft, the right of private defence continues until the offender has retreated with the property, until assistance from public authorities is obtained, or until the property has been recovered.
  • In the case of house-breaking by night, the right of private defence continues as long as the house trespass, which began with the act of house-breaking, continues.”[18]

The right of private defence can be exercised only if there is no reasonable time to seek protection from statutory authorities, and once a trespasser gets the lawful possession of that property, the right of private defence can’t be exercised by the person who has the possession till then.

Sec.106 of IPC,1860 Right of private defence against deadly assault when there is risk of harm to innocent person.

If in the exercise of the right of private defence against an assault which reasonably causes the apprehension of death, the defender be so situated that he cannot effectually exercise that right without risk of harm to an innocent person, his right of private defence extends to the running of that risk.”[19]

This provision empowers a citizen to protect himself by using this right against a group of attackers or a mob. This privilege can also be exercised by an individual even though the group consists of fault less people involving reasonable possibility of harm or injury to the defender. So causing harm to innocent people who are not involved in the attack is not a bar to the defender to save his life by exercising this right.

Relevant Case Laws :

  • 96 of IPC –

In Thangavel case[20], it is highlighted that the common proverb or principle that “necessity knows no law” cannot be applied to modern jurisprudence. It is also stated that even though the right of self defence is inherent it should not be utilised in such a way disturbing others rights. It prevents the persons from expressing their aggression against innocent people in the name of self-defence.

In the case of Laxman Vs. State of Orissa[21], it was held that the aforesaid right is available only to one who is suddenly encountered with the prompt necessity of averting an imminent danger but not of his own creation.

In the case of Gordhan Vs. State of Rajasthan[22] , the court ruled that the plea for the right of private defence should not be readily assumed merely because the accused had suffered meagre injuries.

  • 97 of IPC –

Right of private defence to be pleaded– In the case of Munshi Ram Vs. Delhi Administration[23], it is explained that generally, the accused must plead for the above said right, but even if he does not plead for self-defence, it is open to the court to consider the plea of private defence if it arises from materials on record.

In defence of person – In the case of Sonelal Vs. State[24], the Apex Court held that the right of private defence begins when there is reasonable apprehension about the injury to the human body.

In the case of Kishan Vs. State of M.P.[25], the court decided that Mere intimidation will not constitute a valid ground for the exercise of the right of private defence and to use this privilege he should not be an aggressor.

In defence of property-The Supreme Court in the case of State of U.P. Vs. Niyami[26], ruled that the aforesaid right is used not only to protect oneself but also for securing the body or property of others.

  • 99 of IPC –

In the case of Emperor Vs. Mammun[27], a group of five individuals armed with weapons, who were accused in the present case, attacked a person who was cutting rice from their field, consequently, he got severely injured and died. The accused pleaded for the right of private defence, but the court dismissed it on the ground that there is a reasonable time to seek protection from police authorities under Sec.99.

  • 100 of IPC –

In the case of State of Orissa Vs. Nirupama panda[28], there was a quarrel took place between the accused and the deceased as he entered her house to rape her, consequently, she stabbed him and he died. The accused pleaded for the right of private defence and the court held she was not guilty of the offence.

  • 102 of IPC-

In the case of Sitaram Vs. Emperor[29], the court decided that the person could exercise this defensive right until he finds himself secured from danger.

  • 103 of IPC-

In the case of Jagan Ram Vs. State[30], the court ruled that the defender need not be the owner of the property in order to use this privilege, however the same can’t be pleaded when the act is done under aggression.

New Legislation in the recent period :

Recently the Bharatiya Nyaya Sanhita bill was passed by the Parliament in December, 2023 and it also received the President’s assent and was enacted in December, 2023. This Act will come into force from 1st July, 2024. This new Criminal Act replaces the Indian Penal Code which was enacted in 1860. After coming into force, this new act governs the offences, punishments, and exceptions in India.

Chapter-3 of Bharatiya Nyaya Sanhita, deals with the General Exceptions. Under this part of General Exceptions, the right of private of defence is covered from Sec.34 to 44.

CONCLUSION-

In my opinion, this right of private defence can be considered like armour granted to the citizens by Indian Penal Code, 1860. But in this exercise of this right, the citizens must also be aware of its limitations so that the misuse of the privilege can be mitigated. The concept of “self-help is the best help” that a person can do to himself is strongly reflected in the concept  defensive right. There are some determining factors like reasonable apprehension of real harm or imminent danger by an attacker, no reasonable time to take recourse to the statutory authorities, and act should not be performed under aggression to use the aforesaid right.

So, this right should be effectively utilised by the Indian citizens for defending themselves or their property or that of others. However, there are some difficulties in determining the case under this right, the proportionate force should be used while protecting and whether the act was performed in good faith or not. In spite of all this, the right of private defence is a good right granted to the people for their self-defence.

REFERENCES-

  1. Books / Commentaries / Journals Referred :
    1. N.V.Paranjape, Indian Penal Code ,p.no.143(Central Law Publications, 4th edition, Prayagraj, 2019).
  • S.N.Misra, Indian Penal Code, p.no.214 and 219 (Central Law Publications,12th edition, Allahabad,2004).
  1. Online Articles / Sources Referred :
    1. https://lawbhoomi.com/private-defence-in-ipc/
    2. https://www.legalserviceindia.com/article/l470-Private-Defence.html
    3. https://blog.ipleaders.in/to-what-extent-can-you-exercise-your-right-of-private-defence/
    4. https://indiankanoon.org/doc/1569253/
  2. Cases Referred :
    1. Thangavel Case.
    2. Laxman Vs. State of Orissa, AIR 1988 SC 83.
    3. Gordhan Vs. State of Rajasthan, 1987 Cri.L.J.541(Raj.)
    4. Munshi Ram Vs. Delhi Administration, AIR 1968 SC 702
    5. Sonelal Vs. State, AIR 1981 SC 1379
    6. Kishan Vs. State of M.P. , AIR 1975 SC 244
    7. State of U.P. Vs. Niyami , AIR 1987 SC 1652
    8. Emperor Vs. Mammun Case.
    9. State of Orissa Vs. Nirupama Panda , 1989 CRILJ 621.
    10. Sitaram Vs. Emperor, 1973 SC 473
    11. Jagan Ram Vs. State, 2014 CrLJ NOC 483.
  3. Statutes Referred :
    1. Indian Penal Code,1860

[1] Private Defence in IPC. (2023, June 24). LawBhoomi. Retrieved March 4, 2024, from https://lawbhoomi.com/private-defence-in-ipc/

[2] Principles of the Penal Code, p.269

[3] Art.51(1)(a). (n.d.). Indiankannon. Retrieved March 4, 2024, from https://indiankanoon.org/doc/854952/

[4] Indian Penal Code,1860. (n.d.). Indiankannon. Retrieved March 4, 2024, from https://indiankanoon.org/doc/777353/

[5] Indian Penal Code,1860. (n.d.). Indiankannon. Retrieved March 4, 2024, from https://indiankanoon.org/doc/1499794/

[6] Indian Penal Code,1860. (n.d.). Indiankannon. Retrieved March 4, 2024, from https://indiankanoon.org/doc/1159920/

[7] Private Defences in IPC,1860. (2023, June 24). LawBhoomi. Retrieved March 13, 2024, from https://lawbhoomi.com/private-defence-in-ipc/

[8] Indian Penal Code,1860. (n.d.). Indiankannon. Retrieved March 4, 2024, from https://indiankanoon.org/doc/650803/

[9] Indian Penal Code ,1860. (2023, June 24). LawBhoomi. Retrieved March 4, 2024, from https://lawbhoomi.com/private-defence-in-ipc/

[10] Indian Penal Code,1860. (n.d.). Indiankannon. Retrieved March 4, 2024, from https://indiankanoon.org/doc/1180351/

[11] Indian Penal Code,1860. (n.d.). Indiankannon. Retrieved March 4, 2024, from https://indiankanoon.org/doc/714464/

[12] Private Defences in IPC,1860. (2023, June 24). LawBhoomi. Retrieved March 13, 2024, from https://lawbhoomi.com/private-defence-in-ipc/

[13] Indian Penal Code,1860. (n.d.). Indiankannon. Retrieved March 4, 2024, from https://indiankanoon.org/doc/399205/

[14] Indian Penal Code,1860. (n.d.). Indiankannon. Retrieved March 4, 2024, from https://indiankanoon.org/doc/1985227/

[15] Indian Penal Code,1860. (n.d.). Indiankannon. Retrieved March 4, 2024, from https://indiankanoon.org/doc/860501/

[16] Indian Penal Code,1860. (n.d.). Indiankannon. Retrieved March 4, 2024, from https://indiankanoon.org/doc/1409246/

[17] Indian Penal Code,1860. (n.d.). Indiankannon. Retrieved March 4, 2024, from https://indiankanoon.org/doc/1944062/

[18] Indian Penal Code,1860. (2023, June 24). LawBhoomi. Retrieved March 4, 2024, from https://lawbhoomi.com/private-defence-in-ipc/

[19] Indian Penal Code ,1860. (n.d.). Indiankannon. Retrieved March 4, 2024, from https://indiankanoon.org/doc/1606852/

[20] Thangavel Case. (2023, June 24). LawBhoomi. Retrieved March 5, 2024, from https://lawbhoomi.com/private-defence-in-ipc/

[21] AIR 1988 SC 83

[22] 1987 Cri. L.J. 541 (Raj.)

[23] AIR 1968 SC 702

[24] AIR 1981 SC 1379

[25] AIR 1975 SC 244

[26] AIR 1987 SC 1652

[27] Emperor vs. Mammun  Case. (2023, June 24). LawBhoomi. Retrieved March 5, 2024, from https://lawbhoomi.com/private-defence-in-ipc/

[28] 1989 CRILJ 621

[29] 1973 SC 473

[30] 2014 CriLJ NOC 483

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