05/28/2024

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Kamesh Panjiyar vs. State of Bihar (2005)

The article has been written by Samiksha Singh. This article provides a detailed analysis of the judgement of the Supreme Court in Kamesh Panjiyar v. State of Bihar. In addition to providing a comprehensive analysis of the judgement, the article also elaborates on the relevant provisions of law referred to in the judgement. 

Introduction

While marriage is construed to be sacrosanct, dowry death is a blot on the institution of marriage. In order to control instances of dowry death, Section 304-B was introduced in the Indian Penal Code, 1860 (hereinafter referred to as “IPC, 1860”). Section 304-B of the IPC, 1860, in turn, lays down what would be construed as dowry death. Additionally, it also lays down the punishment for dowry death. Further, since many difficulties were faced in procuring adequate evidence to establish dowry death, Section 113-B was introduced in 1986 in the Indian Evidence Act, 1872 (hereinafter referred to as “IEA, 1872”). Section 113-B of the IEA, 1872, essentially creates a statutory presumption in cases of dowry death. Accordingly, when Section 304-B of the IPC, 1860, is read with Section 113-B of the IEA, 1872, it transpires that once the essentials of dowry death are made out, it shall be presumed by the courts that the accused is responsible for causing dowry death. 

The case of Kamesh Panjiyar v. State of Bihar (2005) is a landmark case of dowry death. In this case, the Supreme Court examined the various essentials of dowry death, the timeline for a dowry demand, and the need for a statutory presumption under Section 113-B of the IEA, 1872. The Supreme Court also distinguished the offence of dowry death provided under Section 304-B of the IPC, 1860, with the offence of cruelty under Section 498-A of the IPC, 1860. In this case, since all the essentials of dowry death were made out, the appellant was found to be guilty, and his conviction and sentence under Section 304-B of the IPC, 1860, were upheld by the Supreme Court. 

Details of the case

Name of the case: Kamesh Panjiyar @ Kamlesh Panjiyar v. State of Bihar

Citation: (2005) 2 SCC 388; 2005 SCC (Cri) 511; 2005 SCC OnLine SC 205

Case Type: Criminal Appeal

Bench: Justice Dr. Arijit Pasayat; Justice S.H. Kapadia

Name of the Appellant: Kamesh Panjiyar

Name of the Respondent: State of Bihar

Date of Judgement: 01.02.2005

Name of the Court: Supreme Court of India

Laws involved: Section 2 of the Dowry Prohibition Act, 1961; Section 304-B of the IPC, 1860; Section 113-B of the IEA, 1872.

Facts of Kamesh Panjiyar vs. State of Bihar (2005)

Kamesh Panjiyar v. State of Bihar (2005) was a Criminal Appeal filed before the Supreme Court of India. In this case, the appellant challenged the decision of the Patna High Court, wherein the conviction of the appellant was upheld under Section 304-B of the IPC, 1860. However, the Patna High Court reduced his sentence from 10 years to 7 years of rigorous imprisonment. This conviction and modified sentence, as awarded by the Patna High Court, were challenged before the Supreme Court. 

The case of the prosecution was that one Jaikali Devi, the appellant’s wife (deceased), and the appellant were married in the year 1988. At the time of their marriage, Rs 40,000 was demanded and paid as dowry. In addition to this, there was a further demand for a she-buffalo by the appellant during the Duragaman ceremony. This demand of the appellant, however, was not fulfilled. Subsequently, the brother of the deceased (also the informant in this case) requested several times for his sister’s bidagari ceremony. Instead of allowing the ceremony to take place, the prior demand of the buffalo was pressed. It is, however, pertinent to mention that the deceased complained that she was ill treated by the appellant and his family members. Later, the informant learned through a rumour that his sister was murdered by the appellant and his family. Further, the informant also heard that the appellant and the family members were deliberating the disposal of the body. Upon a visit by the informant and his family members to the appellant’s house, they discovered the dead body of the deceased on the verandah. At that moment, the state of the deceased was this: blood oozing out from the mouth and marks of violence on the neck. 

During the trial, the appellant submitted that his wife died of rheumatic disease. However, there was no evidence to show this. Upon a perusal of the evidence before it, the trial court drew a presumption in line with Section 113-B of the IEA, 1872, and convicted the appellant under Section 304-B of the IPC, 1860. Consequently, the appellant was sentenced to 10 years of imprisonment. 

Judgement of the Patna High Court

The decision of the trial court was challenged before the Patna High Court. The High Court deemed it fit to uphold the conviction. The appellant’s sentence, however, was reduced to 7 years of rigorous imprisonment. 

Appeal to the Supreme Court

In the present appeal before the Supreme Court, the appellant challenged his conviction and sentence imposed by the Patna High Court, whereby the appellant’s conviction was upheld and his sentence was modified and reduced to 7 years of rigorous imprisonment. 

Laws discussed in Kamesh Panjiyar vs. State of Bihar (2005)

Section 304-B of the Indian Penal Code, 1860

Ingredients

Section 304-B of the IPC, 1860, deals with the provision for dowry death. Accordingly, for an offence of dowry death to be made out, the following essentials must be met:

  • Cause of death: The cause of death of the woman could be any of the following: any “burn”, “bodily injury” or any other circumstance that was not “normal”;
  • Timeline for death: For a case of dowry death to be made out, the death of the wife has to occur within 7 years of her marriage;
  • Subjected to: It has to be established that “soon before” the woman’s death, the woman faced “cruelty” and “harassment” at the hands of either the husband or any of the husband’s relatives;
  • Relates to: This “harassment” or “cruelty” must relate to the “demand for dowry”;
  • When should such behaviour occur: Such “harassment” or “cruelty” should be established to have occurred “soon before” the woman’s death.

It is pertinent to note that Section 304-B of the IPC, 1860, does not categorise the cause of the death. As was observed by the Supreme Court in Maya Devi and Another v. State of Haryana (2015), this section does not classify death into any types, like “homicidal”, “suicidal” or “accidental”. In the opinion of the Supreme Court, once the essentials of dowry death under Section 304-B of the IPC, 1860, are met, any type of death, be it “homicidal”, “suicidal” or “accidental” occurring due to any of the causes mentioned under Section 304-B, be it burn, bodily injury, or any other circumstance (which is not normal), would be construed as “dowry death”. Further, by virtue of statutory fiction, the accused would be deemed to have caused the death.

Presumption in cases of dowry death

In instances of dowry death, the burden of proof is on the accused to show that the essentials for dowry death have not been met. Section 113-B of the IEA, 1872, creates a statutory presumption by virtue of which, once the essentials of dowry death are made, it is presumed that the death in relation to the dowry demand has been caused by the accused (be it the husband or his relative). 

Meaning of dowry

Section 304-B of the IPC, 1860, does not define what constitutes dowry. Instead, it lays down that the term “dowry” under Section 304-B would carry the same meaning as “dowry” under Section 2 of the Dowry Prohibition Act, 1961. Consequently, according to Section 2 of the Dowry Prohibition Act, 1961, it comprises:

  • First, “property” or “valuable security”
  • Second, these items should either already have been given or should have been agreed to be given.
  • Third, such items could be provided either directly or indirectly.
  • Fourth, in a marriage,
    • these items could either be given by one party to the other party or
    • Parent of any of the parties or any other person to the other parent or any other person.
  • Fifth, the time of providing such “property” or “valuable security” could be before, during, or after the marriage.
  • Sixth, these items should be given in relation to the marriage.

However, as clarified, in instances where the Muslim Personal Law is applicable, “dowry” would not include “mehar” or ”dower” within its ambit.

What is not dowry

For any item of “property” or “valuable security” to be construed as “dowry”, it is of paramount importance that such a demand relate to the marriage of the parties. Further, it must fulfil the essentials specified under Section 2 of the Dowry Prohibition Act, 1961. Any demand for money for other purposes would not attract Section 304-B of the IPC, 1860. Thus, the determining factor would be that any sum demanded must ultimately be in connection with the marriage of the parties. If any sum demanded does not relate to the marriage of the parties, then it would not be construed as “dowry.” Consequently, if the death of the wife occurs, then the provisions of “dowry death” would not be attracted. The husband may be liable for homicide, but he would not be liable for dowry death. This is because not every sum of money demanded would be construed as dowry. Such a sum must be demanded in light of the marriage of the parties. The following cases would clarify the position of the law in this regard: 

In the case of Appasaheb and Another v. State of Maharashtra (2007), where the appellant had asked for money in order to meet household domestic expenses, the Supreme Court opined that money asked on the ground of financial emergency would not be construed as dowry.

Further, in the case of Modinsab Kasimsab Kanchagar v. State of Karnataka and Another (2013), the Supreme Court reiterated that any sum demanded must relate to the marriage of the parties for it to be construed as dowry. Herein, the appellant, who had demanded Rs. 10,000 for the payment of the loan, was not held to be liable for dowry death when the woman committed suicide. Even though the husband had harassed his wife for the sum of money because of which the woman ultimately committed suicide, the husband was still found to not be guilty under Section 304-B of the IPC, 1860. 

However, this does imply that every demand for money that is made for financial needs or emergencies would not be construed as “dowry”. It would have to be determined in accordance with the facts and circumstances of each case. Even a demand for money for financial hardship or domestic expenses can come under the purview of dowry if it is made in relation to the marriage between the parties. In the case of Surinder Singh v. State of Haryana (2013), the deceased wife was constantly beaten and insulted owing to the dowry that was given during marriage. When the deceased woman’s brother went to face his sister’s husband, the husband in turn demanded Rs 60,000 for starting a business. Subsequently, the woman committed suicide. In this case, this demand of money for business was considered to be a dowry demand by the Supreme Court since it was made in relation to the marriage. 

Meaning of “soon before”

A lot of confusion arises with regard to the use of the term “soon before” in Section 304-B of the IPC, 1860. According to Section 304-B, one of the important essentials of dowry death is that the deceased should have faced any cruelty or harassment “soon before” her death. This term, however, has not been defined. Yet, it must be understood that the term “soon before” cannot be read to mean “immediately before” the death of the wife. Further, it cannot also be read as “at any time before.” What is required, therefore, is a link between the act of cruelty and the death of the victim. Deriving thereby, the time period of the death must be such that a connection between the effects of the ill-treatment for dowry and the death of the wife can be determined. It must be such that when the death of the wife is caused, one must immediately be led to think that the death in all likelihood was due to the cruelty or harassment the deceased woman was subjected to.

The Supreme Court, thus, in State of Madhya Pradesh v. Jogendra and Another (2022), observed that the prosecution essentially has to establish a “proximate and live link” between the death and the treatment (cruelty or harassment). Thus, while there is no fixed time limit as such, the time gap between the dowry demand, cruelty, and the subsequent death should not be such as to render the cause a “remote” one. 

Cruelty

On a perusal of Section 304-B of the IPC, 1860, it would be clear that this section does not define the term “cruelty.” However, as was observed in the case of Smt. Shanti and Another v. State of Haryana (1990), the term cruelty under Section 304-B of the IPC, 1860 would denote the same meaning as “cruelty” under Section 498-A of the IPC, 1860. Thus, in accordance with the Explanation to Section 498-A, cruelty under Section 304-B would imply either of the following:

  • “Wilful conduct” has the likelihood of leading the woman to either commit “suicide” or cause “grave injury” to her life, limb, or health. For the purposes of this Section, “health” includes both the mental and physical health of the woman.
  • Any harassment caused to the woman. Herein, such harassment must be caused in order to coerce the woman or anyone related to the woman to fulfil any “unlawful demand” of either “property” or “valuable security”. Further, such harassment may also be because the woman or any person related to the woman failed to meet such a demand.

Section 113-B of the Indian Evidence Act, 1872

Section 113-B of the IEA, 1872, lays down the provision for “presumption” in cases of dowry death. 

Ingredients

In instances where the Court is faced with a question regarding dowry death and any person is accused of causing dowry death, then a presumption of dowry death shall arise if it is established:

  • What behaviour: The deceased woman suffered from cruelty or harassment at the hands of the accused;
  • When: Such behaviour was meted out to the woman “soon before” her death;
  • For what: Such behaviour was in relation to a dowry demand.

If the above-mentioned three essentials are proved against any accused, it is the obligation of the court to presume that such accused was the one who committed dowry death. It is important to note that the expression used in Section 113-B of the IEA, 1872, is “shall presume.” Therefore, once the prosecution establishes that the essentials of dowry death have been made out against any accused, the court is obligated to presume that the accused was the perpetrator of dowry death. This presumption, however, is rebuttable, and the burden is on the accused to rebut such a presumption.

Initial burden is on the prosecution 

While Section 113-B of the IEA, 1872, provides for a presumption of dowry death, such a presumption can only arise after the prosecution is able to establish that the essentials of dowry death have been met. If the prosecution is unable to discharge this burden, then Section 113-B of the IEA, 1872, would not be attracted. Thus, initially, it is up to the prosecution to establish that the essential elements of dowry death have been met in the given case. In the case of Baijnath and Others v. State of Madhya Pradesh (2016), a two judge bench of the Supreme Court observed that in order to take benefit of the presumption under Section 113-B of the IEA, 1872, the prosecution has to establish the ingredients of dowry death. In doing so, the prosecution must show that the woman suffered from cruelty or harassment at the hands of the accused. 

Presumption under Section 113-B of the Indian Evidence Act, 1872 is rebuttable

Initially, the burden is on the prosecution to show that the elements of dowry death have been met. However, once the prosecution is able to establish that the essentials of dowry death have been met against an accused, it is presumed that the accused was the one who caused the dowry death of the wife. This presumption, however, is a rebuttable one. The accused is then tasked with proving how the death of the deceased was caused. As was observed by the two judge bench of the Supreme Court in Maya Devi and Another v. State of Haryana (2015), it is the accused who must prove his innocence. Thus, the burden of proof is on the accused to show that the death of the deceased wife was natural. The accused must show that the ingredients of dowry death have not been met.

Issue raised

Only one main issue was raised in this case:

  1. Whether the appellant’s conviction under Section 304-B of the IPC, 1860, and the modified sentence of 7 years rigorous imprisonment awarded by the Patna High Court were correct?

Arguments of the parties

Appellant

It was argued by the appellant’s counsel that the cause of the deceased’s death could not be established. In fact, it was submitted by the appellant that the doctor himself could not ascertain the cause of the death. Further, there was an absence of a live link between the dowry demand and the unnatural death of the deceased. In that light, it was argued by the appellant’s counsel that the conviction of the appellant in the facts of this case was untenable. For these reasons, the appellant submitted that his conviction, as imposed by the Trial Court and upheld by the High Court, was not justified. 

Respondent

It was argued by the state that it was only after a proper perusal of the facts that the appellant was found guilty by the courts below. In that light, the state maintained that the conviction of the appellant was justified and that the courts below were not at fault.

Judgement in Kamesh Panjiyar vs. State of Bihar (2005)

The Supreme Court dismissed the appellant’s appeal without any interference in the judgement of the Patna High Court. Thus, the appellant’s conviction under Section 304-B of the IPC, 1860, and his modified sentence of 7 years of rigorous imprisonment were upheld by the Supreme Court.

Rationale behind this judgement

The provisions relating to dowry death were inserted to curb the menace of dowry death.

The 91st report of the Law Commission titled “Dowry Deaths and Law Reform” examined the need to amend the law to incorporate necessary provisions relating to dowry death. The Supreme Court, in turn, examined the difficulties faced in securing evidence related to dowry deaths. In doing so, it was observed that because it was difficult to secure evidence relating to dowry death, the legislature deemed it fit to create a statutory “presumption of dowry death.” For this reason, Section 113-B of the IEA, 1872, was inserted in 1986. This is to say, once the essentials of dowry death are made out, it is presumed by the courts that it was the accused who caused dowry death. This is because Section 113-B of the IEA, 1872, uses the term “shall presume.”

Thus, when Section 113-B of the IEA, 1872, is read with Section 304-B of the IPC, 1860, it must be shown by the prosecution that the deceased faced cruelty or harassment “soon before” the death. Further, it must be shown that the death of the deceased was unnatural. 

“Soon before” to be determined as per facts of each case. 

Both Section 113-B of the IEA, 1872, and Section 304-B of the IPC, 1860, use the term “soon before.” The prosecution is, thus, tasked with showing that “soon before” the deceased wife’s death, she faced ill treatment (cruelty or harassment) in relation to a dowry demand. This is because the statutory presumption provided under Section 113-B of the IEA, 1872, would apply only when prosecution is able to establish that the deceased was subjected to ill-treatment “soon before” her death. However, as observed by the Supreme Court, there is no formula to determine what would be construed as “soon before.” It has to be determined in accordance with the facts of each case. The only thing that must be kept in mind is that there must be a “proximate and live link” between the dowry demand and the death of the wife.

Dowry death under Section 304-B and cruelty under Section 498-A are distinct offences, and each offence has to be made out separately.

It was observed that while the term cruelty is a common factor in both of these sections, yet these offences cannot be construed as “mutually inclusive.” Thus, the offence under Section 304-B of the IPC, 1860, is different from the offence laid down in Section 498-A. While the meaning of the expression “cruelty or harassment” under Section 304-B of the IPC, 1860, is the same as “cruelty” under Section 498-A, the offences themselves are different from each other since:

  • According to Section 304-B of the IPC, 1860, “dowry death” is a punishable offence. However, under Section 498-A of the IPC, 1860, “cruelty” itself is an offence. 
  • For there to be dowry death, the time period for the death of the wife is “within 7 years” of her marriage. Unlike “dowry death”, there is no such timeline for an offence under Section 498-A of the IPC, 1860. However, Section 113-A of the IEA, 1872, provides discretionary power to the courts to presume “abetment of suicide” when:
    • the woman commits suicide
    • within 7 years of marriage, and 
    • she had suffered from cruelty. 

Cruelty here carries the same understanding as provided under Section 498-A of the IPC, 1860.

Thus, both offences have to be proved separately. If the prosecution is able to successfully establish the ingredients of both of these offences, then the accused can be convicted under both Sections 304-B and 498-A of the IPC, 1860.

Reason for the dismissal of the appeal.

One major argument by the appellant before the Supreme Court was that the doctor (that was PW8) stated that the deceased wife’s cause of death was not ascertainable. The Supreme Court, however, was not convinced by the doctor’s opinion. The reason for this was two-fold. 

  • Firstly, the doctor failed to consider the effect of “black-stained” marks that were found on both sides of the deceased wife’s neck. 
  • Secondly, the doctor also failed to consider the effect of the blood-stained fluid that was trickling out from the side of the deceased wife’s mouth. In fact, the other doctor who conducted the post-mortem of the deceased had noticed that the brain matter of the deceased was congested and blood-stained fluid was trickling out. 

However, PW8 (the doctor upon whom the appellant relies) failed to consider these factors when he opined that the possible cause of the death of the deceased “was not ascertainable.”

Additionally, the other factors were also taken into consideration by the Supreme Court. It was observed that there was no evidence to suggest that the deceased’s death was under “normal circumstances.” Further, the prosecution witnesses’ evidence amply substantiated that there was a dowry demand and there was ill treatment soon before the deceased’s death. For this reason, the Supreme Court found the judgement of the Patna High Court to be justified. 

One more defence was taken up by the appellant. It was submitted that the appellant and his family tried to get the deceased treated for her disease. It was the appellant’s argument that if he indeed had been guilty of committing dowry death, then there was no reason why he would have tried to get the deceased wife treated. In the opinion of the Supreme Court, this argument was in the nature of a “smokescreen.” Accordingly, the Court opined that if the deceased died a natural death, why was there no evidence attested to explain the neck injuries of the deceased? For these reasons, the Supreme Court found the appellant guilty and did not find any infirmity in the judgement of the Patna High Court. Thus, the appeal was dismissed.

Analysis of Kamesh Panjiyar vs. State of Bihar (2005)

In this case, the Supreme Court deemed it fit to uphold the conviction and modified sentence as awarded by the Patna High Court. This was because in this case, the evidence was clear enough to show that there was a dowry demand and that the deceased had to suffer ill-treatment at the hands of the appellant just before her death. In order to oppose his conviction, the appellant had argued that the cause of the death of his wife could not be ascertained. However, as the Supreme Court pointed out, there was no evidence to support that the deceased wife’s death was natural. Hence, the conviction and sentence of the appellant were upheld by the Supreme Court. 

Conclusion

Section 304-B of the IPC, 1860, provides the elements and punishment for dowry death. Further, Section 113-B of the IEA, 1872, creates a statutory presumption whereby, once it is established that there was a dowry demand and the deceased wife suffered ill-treatment at the hands of the accused for such a demand, it is presumed that it was the accused who was the perpetrator of the crime. This provision was incorporated into the IEA in 1872 because the then existing law on evidence failed to adequately address the question of dowry death. Since there existed various difficulties in finding sufficient evidence to show dowry death, Section 113-B of the IEA, 1872, was introduced to create a “presumption” of “dowry death.” Accordingly, once the essentials of dowry death are made out, the court presumes that the accused was the perpetrator of the crime.

The case of Kamesh Panjiyar v. State of Bihar (2005), in this regard, is a landmark judgement of the Supreme Court. Since all the essentials of dowry death were made out, the appellant’s appeal was dismissed, and his conviction and sentence as awarded by the Patna High Court were upheld by the Supreme Court. While doing so, the Supreme Court elaborately examined the essential elements of dowry death. Further, the Supreme Court also distinguished between the offence of cruelty under Section 498-A of the IPC, 1860, and the offence of dowry death under Section 304-B of the IPC, 1860. This distinction made by the Supreme Court in Kamesh Panjiyar v. State of Bihar (2005) was affirmed in a recent decision of the Supreme Court in Gurmeet Singh v. State of Punjab (2021)

Frequently Asked Questions (FAQs)

What is proximate and live link?

There must be a “proximate and live link” between the dowry demand, the effects of the ill treatment, and the subsequent death of the wife. The Supreme Court in Parvati Devi v. State of Bihar (2021) reiterated the test for determining “proximate and live link.” While there is no definite time period, it would imply a time period where a connection between the effects of the ill treatment for dowry and the death of the wife can be ascertained. If the ill treatment that the deceased faced is very “remote” or distant in time so as to not have an impact on the wife’s mental state, then there would be no link.  

In instances of dowry death, can the evidence given by family members be rejected on the ground that the family members are “interested witnesses”?

The Division Bench of the Supreme Court, in a recent order in State of Karnataka by Gandhinagar v. M. N. Basavaraja & Ors (2024), observed that the evidence of the immediate family members of the deceased in a case of dowry death would not be rejected for the sole reason that the family members are “interested witnesses.” According to the observation made by the Supreme Court, a woman facing cruelty for dowry would most likely ‘confide’ in her family members. 

What is meant by the term “relative” under Section 304-B of the IPC, 1860?

It was opined by the Supreme Court in the case of State of Punjab v. Gurmit Singh (2014) that for a case under Section 304-B of the IPC, 1860, to be made out, the accused relative must be related by “blood, marriage, or adoption”.

Can an accused husband be punished merely because the deceased wife died an unnatural death within 7 years of her marriage?

While two of the important essentials of dowry death are that there must be an “unnatural death” and that such death must take place “within seven years of marriage,” these factors alone are not sufficient for the husband to be convicted under Section 304-B of the IPC, 1860. In a recent judgement of the Supreme Court in Charan Singh alias Charanjit Singh v. State of Uttarakhand (2023), it was observed that even if the wife dies unnaturally in her matrimonial home within 7 years of her marriage, this alone would not merit a conviction of the husband. It must also be established that the wife suffered from cruelty or harassment “soon before” her death. 

Can suicidal death fall under the purview of Section 304-B of the IPC, 1860?

Yes, suicidal death, being an unnatural death, can fall under the ambit of Section 304-B of the IPC, 1860. This observation has been made by the Supreme Court in numerous cases, like Smt. Shanti and Another v. State of Haryana (1990), Kans Raj v. State of Punjab and Others (2000), and Satvir Singh and Others v. State of Punjab and Another (2001).

Since cruelty is a common factor in both Section 498-A and Section 304-B of the IPC, 1860, can it be said that a conviction under Section 304-B can take place only when there is also a charge under Section 498-A of the IPC, 1860?

No, for there to be a conviction under Section 304-B of the IPC, 1860, it is not a prerequisite that there has to simultaneously be a charge under Section 498-A of the IPC, 1860. It is true that “cruelty” is a common ingredient in both of these offences. It is also true that the meaning of cruelty under Section 498-A of the IPC, 1860, is the same as that under Section 304-B of the IPC, 1860. However, as affirmed by the Supreme Court in Gurmeet Singh v. State of Punjab (2021), these two offences are distinct and hence must be established separately. However, if the ingredients of both of these Sections are proved separately in any given case, the accused can be convicted under both sections in that case.

References

  • P S A Pillai’s Criminal Law, K I Vibhute (14th edition)
  • Textbook on The Law of Evidence, Chief Justice M Monir (12th edition)

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