INSTITUTE OF LAW, NIRMA UNIVERSITY

NIRMA UNIVERSITY

INSTITUTE OF LAW

CONSTITUTIONAL LAW PROJECT

TITLE- Free Legal Aid under Indian Constitution : An analytical study

Submitted to: Submitted by:

Mr. Yogesh Dharangutti Ravi Raj Singh Choudhary

12BLL010

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Table of Contents

CHAPTERISATION ............................................................................................................................ 13
I. HISTORICAL DEVELOPMENT OF LEGAL AID ................................................................ 13
II. HISTORICAL DEVELOPMENT OF LEGAL AID IN INDIA ............................................... 15
III. RIGHT TO FAIR TRIAL AND FREE LEGAL AID AS A FUNDAMENTAL ................. 17
CONCOMITANT ............................................................................................................................. 17
IV. CONSTITUTIONAL PROVISION OF LEGAL AID ......................................................... 18
V. JOURNEY OF LEGAL AID THROUGH SUPREME COURT PRONOUNCEMENT ......... 19

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Introduction

The concept of free legal aid in the form of Article 39-A was incorporated in the Indian
Constitution by the forty second amendment act, 1976. Free legal aid strives at ensuring the
fulfilment of the constitutional pledge in its letter and spirit and making equal justice
available to the downtrodden and weaker section of the society.1

The concept of free legal aid derives the validity from the Indian Constitution itself i.e.
Article 21 and also under Article 14. Although free legal aid is a provision under Directive
Principle of State Policy but Supreme Court in deciding various cases has stated and treated
free legal aid as a part of right created under Article 21 and also under Article 14.

Thus, the research aims at the concept and the need behind the enactment of free legal aid in
India and its real implementation under Article 21 and 39-A of the constitution of India. For
this purpose the researcher has gone through various books, cases, acts, reports and articles to
get to the depth of the topic.

1
Varun Pathak; A Brief History Of Legal Aid; India Legal Services

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STATEMENT OF PROBLEM

The researcher aims at finding out the enactment of the concept of free legal aid in India and
its efficiency in providing the poor and indigent with free legal aid under 39A of the
constitution of India.

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RESEARCH METHODOLOGY

This is a doctrinal research based on the cases, articles and reports related to the given topic.
In order to provide a much better picture of the topic the researcher has also quoted and
elaborated on certain case studies which are related to the topic in some way or the other. The
researcher has done secondary data collection for the given research paper. The researcher
has referred to several articles, case laws and reports for the same.

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OBJECTVES

To study the Free Legal Aid in India provided in both Part III and Part IV of
the Indian constitution.
To analyze the enforcement of the concept of free legal Aid in India according
to the provisions of article 21 as a fundamental right.
To analyse the evolvement of the concept of free legal aid after the early
nineties.

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HYPOTHESIS
The maturity of the legal aid concept has accelerated over the passage of time
after early nineties.

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LITERATURE REVIEW

The researcher has gone through several articles, reports, acts, case laws and newspaper
articles
In order to develop a basic and essential understanding of the topic-

The 14th law commission stated the fact that if laws do not provide for an equality of
opportunity to seek justice to all segments of society they have no protective value and unless
some arrangement is made for providing poor man the means to pay court fees, advocates
fees and other incidental costs of litigation, he is denied an opportunity to seek justice.

In the report of the committee on legal aid titled, processionals justice to poor, presided
over by Justice V.R Krishna Iyer in 1973, the committee emphasized on the need for active
and widespread legal aid system that enabled law to reach the people, rather requiring people
to reach law. Justice Krishna Iyer regarded Legal Aid program as a catalyst which would
enable the aggrieved masses to re-assert state responsibility under Part IV of the Constitution.

In the final report on legal aid program in 1977, the report emphasized on the need for a new
legal service program cautioned that it must be framed in the light of socio-economic
conditions prevailing in the country. In addition it stated that the traditional legal service
program which is essentially court or litigation oriented, cannot meet the specific needs and
the peculiar problems of the poor in the country.

After understanding the historical ante cedes of the given problem, it was necessary to
understand that what has been the supreme courts view.

In this view the first case was Hussainara khatoon v. Home Secretary, State of Bihar in which
it was held that equality under Article 21 is impaired where procedural law does not provide
speedy trial of accused ; does not provide for his pre-trial reliefs on bail on his personal bond
, when he is impoverished and there is no substantial risk of his absconding ; if an under-trial
prisoner is kept in jail for a period longer than the maximum term of imprisonment which
could have been awarded on his conviction and if he is not offered free legal aid , where he is
too poor to engage a lawyer , provided the lawyer engaged by the state is not objected to by
the accused

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In case of M.H Hoskot v.s State of Maharashtra the court declared if a prisoner sentenced
to imprisonment is virtually unable to exercise his constitutional and statutory right of appeal
inclusive of special leave to appeal for want of legal assistance, there is implicit in the curt
under article 142 read with article 21 &39 (a) of the constitution , power to assign council for
such imprisoned individual for doing complete justice.

In the case of Khatri & ors. V. state of Bihar & ors. Right to free legal aid, just, fair, and
reasonable procedures is a fundamental right it is elementary that the jeopardy to his
personal liberty arises as soon as the person is arrested and is produced before a magistrate or
it is at this stage that he gets the first opportunity to apply for bail and obtain his release is
also to resist to remain to police or jail custody. This is the stage at which an accused person
needs competent legal advice and representation. No procedure can be said to be just, fair and
reasonable which denies legal advice to the accused at this stage. Thus, state is under a
constitutional obligation to provide free legal aid to the accused.

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CONCLUSION

The need for free legal aid arises as a constitutional obligation of the state and derives its
validity from the Constitution itself i.e. from Art. 21 & Art 14 Part III of the Constitution.
Judiciary time and again has interpreted Art. 21 along with Art. 39-A which assures that the
state provides the poor and downtrodden with free legal aid. The language of Art. 39-A is
also couched in mandatory terms as it is clear by the use of word Shall twice therein.

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INTRODUCTION

The researcher has gone through several articles, reports, acts, case laws and books in order
to develop a basic and essential understanding of the topic-

The 14th law commission stated the fact that if laws do not provide for an equality of
opportunity to seek justice to all segments of society they have no protective value and unless
some arrangement is made for providing poor man the means to pay court fees, advocates
fees and other incidental costs of litigation, he is denied an opportunity to seek justice.

In the report of the committee on legal aid titled, processionals justice to poor, presided
over by Justice V.R Krishna Iyer in 1973, the committee emphasized on the need for active
and widespread legal aid system that enabled law to reach the people, rather requiring people
to reach law. Justice Krishna Iyer regarded Legal Aid program as a catalyst which would
enable the aggrieved masses to re-assert state responsibility under Part IV of the Constitution.

In the final report on legal aid program in 1977, the report emphasized on the need for a new
legal service program cautioned that it must be framed in the light of socio-economic
conditions prevailing in the country. In addition it stated that the traditional legal service
program which is essentially court or litigation oriented, cannot meet the specific needs and
the peculiar problems of the poor in the country.

After understanding the historical ante cedes of the given problem, it was necessary to
understand that what has been the supreme courts view.

In this view the first case was Hussainara khatoon v. Home Secretary, State of Bihar in which
it was held that equality under Article 21 is impaired where procedural law does not provide
speedy trial of accused ; does not provide for his pre trial reliefs on bail on his personal bond ,
when he is impoverished and there is no substantial risk of his absconding ; if an under trial
prisoner is kept in jail for a period longer than the maximum term of imprisonment which
could have been awarded on his conviction and if he is not offered free legal aid , where he is
too poor to engage a lawyer , provided the lawyer engaged by the state is not objected to by
the accused

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In case of M.H. Hoskot v. State of Maharashtra the court declared if a prisoner sentenced to
imprisonment is virtually unable to exercise his constitutional and statutory right of appeal
inclusive of special leave to appeal for want of legal assistance, there is implicit in the curt
under article 142 read with article 21 &39 (a) of the constitution , power to assign council for
such imprisoned individual for doing complete justice.

In the case of Khatri & ors. V. state of Bihar & ors. Right to free legal aid, just, fair, and
reasonable procedures is a fundamental right it is elementary that the jeopardy to his personal
liberty arises as soon as the person is arrested and is produced before a magistrate or it is at
this stage that he gets the first opportunity to apply for bail and obtain his release is also to
resist to remain to police or jail custody. This is the stage at which an accused person needs
competent legal advice and representation. No procedure can be said to just, fair and
reasonable which denies legal advice to the accused at this stage. Thus, state is under a
constitutional obligation to provide free legal aid to the accused.

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CHAPTERISATION

I. HISTORICAL DEVELOPMENT OF LEGAL AID

The earliest legal aid movement took place in the year 1851 when some enactment was
introduced in France for providing legal assistance to the poor and indigent. From the
beginning, the basis behind legal aid is the supposition that in every society there are
individuals who are unable to participate in the legal system. In United States it began in
1876 with the establishment of an organisation for providing legal assistance for some
immigrants in New York2. In the beginning, legal service was not provided on humanitarian
grounds as a grant of legal services from advocates to poor rather, it was a social service
under the third party subsidy of an independent organisation.

Although legal aid had a direction to head on but was a diffused movement till 1919, when
Reginald Heber Smith published his work Justice and the Poor. Reginald Heber in his work
promoted the concept of free legal assistance for the poor. Smith challenged the legal
profession to consider it an obligation to see that justice was accessible to all, without regard
to ability to pay. Without equal access to the law, he wrote, the system not only robs the
poor of their only protection, but it places in the hands of their oppressors the most powerful
and ruthless weapon ever invented.3

In the later years the legal aid movement went on in a good steady pace but the real budding
of policy oriented legal aid became evident in the early 1930s. A model in public interest
supported entirely through small donations came in picture with a major concern for the
Negroes4. The model was developed in order to function in an organised manner and perform
the work of providing legal aid efficiently. The principles used in this model are still being
used by all Public Interest Law endeavours in the United States in one or the other way.

In the year 1974, the legislation created an independent Public Corporation to manage the
legal services was passed. Although in govt. financing of legal aid programmes includes the
inherent risk of govt. domination and control the Legal Services Programme is, today, firmly

2
Justice T. Mathivanan; Legal aid issues, challenges and solutions-an empirical study
3
Supra n. 1
4
Dr. Mamta Rao; Public interest litigation legal aid and lok adalats; 2nd edition; eastern book company;2002

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based and institutionalised and functions independently with governments financial aid but
free from government control over policies.5

The legal fraternity in England was initially, during the 19th century, reluctant to change the
settled rules. However, the judiciary played a vital role in the evolution of legal aid in
England. These starts lead to the evolvement of legal aid and in developing a criminal legal
aid system under statute. This was eventually completed in 1933, but was most restrictively
operated by the judges. But legal aid movement in England entered a new era with the 'Legal
Aid and Advice Act, 1949'. The Legal Aid Act, 1949, dealt with legal aid in civil cases and it
extended to criminal cases in 1967. This act laid down the principle that legal aid was not
charity but national responsibility funded by the state. The other major principle laid was that
the new legal aid system was to embody constitutional protections to ensure both the
professional independence of the lawyers in their service of their assisted clients and of the
body administering the system.6

5
Supra n. 3
6
Supra n. 1

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II. HISTORICAL DEVELOPMENT OF LEGAL AID IN INDIA

In a country like ours where the proportion of the poor and indigent is high, the need to
advance justice on the basis of equality is essentially required. The philosophy of legal aid as
an absolute element of justice is evident from Mr. Justice Brennan's (Legal Aid and Legal
Education) well known words:

"Nothing rankless more in the human heart than a brooding sense of injustice. Illness we can
put up with. But injustice makes us want to pull things down. When only the rich can enjoy
the law, as a doubtful luxury, and the poor, who need it most, cannot have it because its
expense puts it beyond their reach, the threat to the continued existence of free democracy is
not imaginary but very real, because democracy's very life depends upon making the
machinery of justice so effective that every citizen shall believe in and benefit by its
impartiality and fairness.7

Thus after framing a Constitution of our own with a precious Preamble, which promises to
promote justice, the need to deliver the opportunity for equal justice arose. So in 1952,
schemes for providing legal aid to those who could not afford the litigation costs were
formulated by various state governments like State of Uttar Pradesh, State of West Bengal
and State of Madras. The Government of India started addressing to the question of legal aid
for the poor in various conferences of Law Ministers and Law Commissions. In its XIVth
report, the law commission opined that free legal aid is a service which should be provided
by the state.

In 1960, acting to the recommendations by the law commission some guidelines was drawn
by the Govt. for legal aid schemes but due to lack of finances the scheme did not survive.

For again trying to revive the programme, the govt. of India formed the Krishna Iyer
committee, in 1973 to see how the states should go about devising and elaborating the legal
aid scheme. The committee came up with the most systematic and elaborate statement
regarding establishment of legal aid committees in each district, at state level and at the
centre.8 The report dealt with the nexus between law and poverty. It emphasized the need for

7
Supra n. 1
8
Supra n. 3

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an active and widespread legal aid system that enabled law to reach the people, rather than
requiring people to reach the law.9

In 1980, a Committee at the national level was constituted to oversee and supervise legal aid
programmes throughout the country under the Chairmanship of Hon. Mr. Justice P.N.
Bhagwati then a Judge of the Supreme Court of India. The committee encouraged the concept
of legal aid camps and nyayalayas in rural areas. The committee in its report recommended
introduction of the concept of legal aid in the constitution.

In 1980, the central govt. established its committee for implementation of legal aid schemes
(CILAS). It financed and supported various committees at different levels and started
monitoring legal aid activities throughout the country. The introduction of Lok Adalats added
a new chapter to the justice dispensation system of this country and succeeded in providing a
supplementary forum to the litigants for conciliatory settlement of their disputes.

In 1987 Legal Services Authorities Act, 1987 was enacted to give a statutory base to legal
aid programmes throughout the country at the national, state and district levels on a uniform
pattern. This Act was finally enforced on 9th of November 1995 after certain amendments
were introduced therein by the Amendment Act of 1994.

9
Varun Pathak; A Brief History Of Legal Aid; India Legal Services

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III. RIGHT TO FAIR TRIAL AND FREE LEGAL AID AS A FUNDAMENTAL

CONCOMITANT

Citizens agree to limitation on their freedom in exchange for peaceful coexistence, and they
expect that when conflicts between citizens or between the state and citizens arise, there is a
place that is independent from undue influence, that is trustworthy, and that has authority
over all the parties to solve the disputes peacefully.

It is also the responsibility of the State to ensure that fair and impartial justice is made
available at the door steps of the poor and economically weaker sections irrespective of their
caste, creed, religion, geographical position at free of cost.

An impartial independent judiciary is the guardian of individual rights in a democratic

society. In order for citizens to have faith in their court system, all people must have access
to the courts when necessary.

The widespread claim on free legal assistance, where liberty is in jeopardy, is obvious from
the Universal Declaration of Human Rights: 'Article 8:

Everyone has the right to an effective remedy by the competent national tribunal for acts
violating the fundamental rights granted by the Constitution or by law.'

Article 14 (3) of the International Covenant on Civil and Political Rights guarantee s to
everyone: "The right to be tried in his presence, and to defend himself in person or through
legal assistance of his own choosing, to be informed if he does not have legal assistance, of
his right; and to have legal assistance assigned to him in any case where the interests of
justice shall require, and without payment by him in any such case if he does not have
sufficient means to pay for it."

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IV. CONSTITUTIONAL PROVISION OF LEGAL AID

The concept of free legal aid to the poor and indigent is enshrined in Part IV of the
Constitution, DPSP, under Article 39-A of the constitution. Article 39-A has been inserted by
the constitution (Forty-second Amendment) Act, 1976, Section 8 which enacts as under:

39-A. Equal justice and free legal aid- The State shall secure that the operation of the legal
system promotes justice, on a basis of equal opportunity, and shall, in particular, provide free
legal aid, by suitable legislation or schemes or in any other way, to ensure that opportunities
for securing justice are not denied to any citizen by reason of economic or other disabilities.

This Article emphasizes on the fact that free legal service is an inalienable element of
'reasonable fair and just' procedure for without it a person suffering from economic or other
disabilities would be deprived of the opportunity for securing justice.

The word shall has been used twice in the article which emphasizes on the obligation of the
state to provide the poor and indigent with free legal aid by suitable legislation or schemes or
in any other way, leaving free legal aid no more as a function of charity.

Legal assistance to a poor and indigent accused who is arrested and put to jeopardy of his life
or personal liberty is Constitutional imperative mandated not only by Article 39-A but by
Article 14 and Article 21 of the constitution10. The court has exhorted the central and the state
govt. to introduce a comprehensive legal service programme in the country. In support of this
suggestion, the apex court has time and again invoked Article 39-A, which provides for free
legal aid and has interpreted Article 21 in the light of Article 39-A.

Articles 14 and 22(1) also make it obligatory for the State to ensure equality before law and a
legal system which promotes justice on a basis of equal opportunity to all.

10
Sheela Barse v. State of Maharashtra, (1983) 2 SCC 96: AIR 1983 SC 378: (1983) 1 crimes 602

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V. JOURNEY OF LEGAL AID THROUGH SUPREME COURT

PRONOUNCEMENT

The concept of legal aid has evolved over a decade, through various judicial pronouncements
by the Supreme Court. Judiciary has played a vital role in the development of the concept of
free legal aid in India. The issue of free legal aid to the poor and indigent had been
thoroughly discussed time and again by the apex court.

The linkage between Article 21 and Article 39-A, the right to free legal aid was forged in the
decision in Hussainara Khatoon v. State of Bihar.11 In this case the court was appalled at the
plight of thousands of under-trials languishing in the jails in Bihar for years on end without
ever being represented by a lawyer. The court held that the right to free legal services is
clearly an essential ingredient of reasonable, fair and just procedure for a person accused of
an offence and it must be held to be implicit in the guarantee of Article 21. This is a
constitutional right of every accused person who is unable to engage a lawyer and secure
legal services on account of reasons of poverty.

The court declared that "there can be no doubt that speedy trial, and by speedy trial, we mean
reasonably expeditious trial, is an integral and essential part of the fundamental right to life
and liberty enshrined in Article 21."

The question that whether the accused has to ask for lawyer or a lawyer should be made
available without being asked was answered in n the case of Khatri & others v. State of
Bihar.12 The apex court in this case ruled that,

the Magistrate or the Sessions Judge before whom an accused appears must be held to be
under an obligation to inform the accused that if he is unable to engage the services of a
lawyer on account of poverty or indigence, he is entitled to obtain free legal aid at the cost of
the State. We deplored, that in that case, where the accused were blinded prisoners, the
Judicial Magistrate failed to discharge his obligation and contended himself by merely
observing that no legal representation has been asked for by the blinded prisoners and hence
none was provided. We accordingly directed the Magistrates and Sessions Judges in the
country to inform every accused who appears before them and who is not represented by a
lawyer on account of his poverty or indigence that he is entitled to free legal services at the

11
AIR 1979 SC 1369 (1373) : (1979) 3 SCR 532 : (1980) 1 SCC 98 : 1980 SCC (Cr) 40],
12
(1981) 1 SCC 635:1981 SCC (cri) 235

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cost of State unless he is not willing to take advantage of the free legal aid provided by the
State. We also gave a general direction to every state in the country . . . to make provision for
grant of free legal service to an accused who is unable to engage a lawyer on account of
reasons such as poverty, indigence or incommunicado situations, the only qualification being
that the offence charged against an accused is such that on conviction, it would result in a
sentence of imprisonment and is of such a nature that the circumstances of the case and the
needs of social justice require that he should be given free legal representations.

The issue in the case of Sheela Barse v. State of Maharashtra13, was in relation to protection
in police lock-up. The Supreme Court adviced:

1. Whenever a person is arrested by the police without warrant, he must be immediately

informed of the grounds of his arrest and in every case of arrest it must immediately
be known to the arrested person that he is entitled to apply for bail. The Maharashtra
State Board of Legal Aid and Advice will forthwith get a pamphlet prepared setting
out the legal rights of an arrested person and the State of Maharashtra will bring out
sufficient no. of printed copies of the pamphlet in Marathi which is the language of
the people in the State of Maharashtra as also in Hindi and English and printed copies
f the pamphlet in all the three languages shall be a fixed in each cell in every police
lock-up and shall be read out to the arrested person in any of the three languages
which he understands as soon as he is brought to the policw station.
2. Whenever a person is arrested by the police and taken to the police lock-up, the police
will immediately give intimation of the fact of such arrest to the nearest legal aid
committee and such committee of legal aid will take immediate steps for the purpose
of providing legal assistance to the arrested person at state cost, provided he is willing
to accept such assistance. The state government will provide necessary funds to the
concerned legal aid committee for carrying out this direction.

The relation between legal aid and legal education and the payment of fees to a lawyer for
free legal service were discussed in the case of State of Maharashtra v. M.P. Vashi14, in
which the apex court held that in a fit case, the court can direct the ruling politicians to carry
out the Directive Principles of State Policy even though these are stated to be non-justiciable
in a court of law. Further, when there is inaction or slow action by the politicians and

13
(1983) 2 SCC 96: AIR 1983 SC 378: (1983) 1 crimes 602
14
(1995) 5 SCC 730

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administrative officers, the judiciary will intervene. The politicians cant plead paucity of
funds against such directions.

The Supreme Court clubbed legal aid with legal education and directed the state to restore
and restructure the deteriorating standards in legal education. The court felt the need of a vast
no. of persons trained in law and order to afford free legal aid. The absence of reasonable
facilities, infrastructure, competent teachers and staff and law colleges would adversely affect
the standard of legal education and could affect the quality in providing free legal aid.
Quality should on no account suffer in providing free legal aid and if its not so, the free legal
aid will only be force or make believe or illusory or a meaningless ritual. The Supreme Court,
in this case directed the state to provide grant in aid to recognize law colleges so as to enable
them to function efficiently and in a meaningful manner and turn out sufficient no. of well
trained or properly equipped law graduates. That in turn will enable the state to provide free
legal aid and ensure that opportunities for securing justice are not denied to any citizen on
account of any disability. These aspects necessarily flow from Article 21 and Article 39A of
the Constitution of India.

In the case of M.H. Hoskot v. State of Maharashtra15, the Supreme Court laid down some
banning prescription for free legal aid to prisoners which are to be followed by all courts in
India, such as furnishing of free transcript of judgment in time, to the sentences; where the
prisoners seeks to file an appeal or revision, every facility for excising such rights shall be
made available by the jail administration and if a prisoner is unable to exercise his
constitutional and statutory rights of appeal including special leave to appeal for want of legal
assistance, there is implicit in the court under Article 142, read with Article 21 and 39-A of
the Constitution of India, the power to assign counsel to the prisoner provided he does not
object to the lawyer named by the court.

The Apex Court has discussed the role and significance of voluntary organisations in the case
of Centre for Legal Research v. State of Kerala16. In this case a question was raised as to
whether voluntary organisations or social action groups in the legal aid programme should be
supported by the state government and is so to what extent and under what conditions. The
apex court in this case held that there can be no doubt that if the legal aid programme is to
succeed, it must involve public participation. The state govt. undoubtedly has an obligation

15
(1978) 3 SCC 544
16
(1986) 2 SCC 706: AIR 1986 SC 1322

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under Article39-A of the Constitution which embodies a Directive Principle of State Policy to
set up a comprehensive and effective legal aid programme in order to ensure that the
operation of the legal system promotes justice on the basis of equality. But it was accepted
that no legal aid programme could survive if its operation remained in the hands of
administration. Thus it was essential that people should be regarded as participants in the
programmes of legal aid. However this was not possible without voluntary organisations and
social action groups. These organisations work among the deprived and vulnerable sections
of the society at the grass root level and they know what are the problems and difficulties
encountered by these neglected sections of Indian humanity. They have their finger on the
pulse of the people, what are the sources of exploitation and injustice and reaching social or
distributive justice to them. The Court through Chief Justice Bhagwati expressed the view
that the voluntary organisations and social action groups must be encouraged and supported
by the state in operating the legal aid programme.

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REFERENCES

Books:

Dr. Mamta Rao, Public Interest Litigation, 2nd edition(Eastern Book Company
Lucknow 2002)
Dr. J.N.Pandey The Constitutional Law of India49th edition Publish in 2012 Central
law agency
M.P. Jain, Indian constitutional Law, 10th edition (Lexis Nexis, Wadhwa publication
Nagpur)

Web Sites:

http://www.legalserviceindia.com
http://www.civilserviceindia.com
http://www.lawyersclubindia.com
http://www.jstor.org/

Cases:

M.H. Hoskot V. State of Maharastra (AIR 1978,3 SCC 544)

Khatri v. State of Bihar [(1981) 1 SCC 635:1981 SCC (cri) 235]
Hussainara khatoon v. State of Bihar[AIR 1979 SC 1369 (1373) : (1979) 3 SCR 532
: (1980) 1 SCC 98 : 1980 SCC (Cr) 40]
State of Maharashtra v. M.P. Vashi [(1995) 5 SCC 730]
Centre for Legal Research v. State of Kerala, [(1986) 2 SCC 706: AIR 1986 SC 1322]
Sheela Barse v. State of Maharashtra, [(1983) 2 SCC 96: AIR 1983 SC 378: (1983) 1
crimes 602]

Articles:

Justice T. Mathivanan, Legal Aid Issues, Challenges and Solutions- An Empirical

Study
Varun Pathak, A Brief History of Legal Aid

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