LEGAL AID
FINAL SUBMITTED IN FULFILLMENT OF THE COURSE ADR,
SEMESTER VI DURING THE ACADEMIC YEAR 2020-21
SUBMITTED BY:-
SWATI KUMARI
Roll No-171571,B.A.LL.B(hons)
SUBMITTED TO:-
Mr. Hrishikesh Manu
Faculty Of ADR
AUGUST 2019
CHANAKYA NATIONAL LAW UNIVERSITY
NYAYA NAGAR, MITHAPUR, PATNA
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Table of Contents
Declaration 3
Acknowledgement 4
Research Methodology 5
Chapter 1 – Introduction 6
Chapter 2 –History of Legal aid 7
Chapter 3 – The concept of Legal Aid 10
Chapter 4 – Free legal aid in India: Contribution of judiciary 13
Chapter 5- legal aid: Statutory Recognition 15
Chapter 6- Bodies under the Act and their Hierarchy 17
Chapter 7- Recent amendments made under Legal Service authority act 19
Chapter 8-Constitutional Provision 20
Chapter 9- legal aid: Legal aid under CPC And CrPC 21
Conclusion
Bibliography
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Declaration By the Candidate
I hereby declare that the work reported in the BB.A. LL.B (Hons.) Project Report entitled “legal aid”
carried out under the supervision of Hrishiksh Manu , ADR, Chanakya National law
University.I have not submitted this work elsewhere for any other degree or diploma. I am fully
responsible for the contents of my Project Report.
SWATI KUMARI
Chanakya National Law University, Patna
20/05/2020
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ACKNOWLEDGEMENT
It gives me immense pleasure to express my gratitude towards all those who have helped and
encouraged me for the completion of this project. They all rendered their valuable time and
services in making this project a success.
Firstly, I would like to thank the all mighty God for blessing and giving me support in
completing this project. I take this opportunity to express my deep regards to my guide,
Hrishikesh Manu for his exemplary guidance, monitoring and constant encouragement
throughout the course of this thesis.
At last, but not the least, I express my sincere thanks to my parents for their generous support
and cooperation throughout the project.
Swati Kumari
6th Semester
B.A. LL.B. (Hons) Chanakya National Law University
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AIMS & OBJECTIVE OF THE STUDY
The objective of the researcher is:
To know the nature & scope of the concept of Legal Aid.
To find out how it is applicable in the law.
To know the pros & cons of this law & how it can be used.
RESEARCH METHODOLOGY
Doctrinal method :- Books, internet, journals, judgements etc.
Researcher is mainly relying on library based study.
SOURCES OF DATA COLLECTION
Primary sources- Theories of Jurisprudence, statutes, precedent & other official documents.
Secondary sources- statement of judges, websites, articles, news paper, books, journals etc
LIMITATION & SCOPE OF THE STUDY
Due to lack of time and lack of resources my research work is wholly based on doctrinal
method of research, my research work doesn’t rely on non-doctrinal research or empirical
research.
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Chapter-1
INTRODUCTION
Legal aid to the poor and weak is necessary for the preservation of rule of law which is
necessary for the existence of the orderly society. Until and unless poor illiterate man is not
legally assisted, he is denied equality in the opportunity to seek justice. Therefore as a step
towards making the legal service serve the poor and the deprived; the judiciary has taken
active interest in providing legal aid to the needy in the recent past.
Lawful guide to poor people and powerless is vital for the conservation of administer of law
which is essential for the presence of the precise society. Until and unless a poor uneducated
man isn't legitimately helped, he is denied fairness in the chance to look for equity. In this
way as a stage towards influencing the lawful administration to serve poor people and the
denied; the legal has taken a dynamic enthusiasm for giving lawful guide to the penniless in
the current past. The Indian Constitution accommodates an autonomous and fair legal and the
courts are enabled to secure the constitution and shield the privileges of individuals
independent of their money related status. Since the point of the constitution is to give equity
to all and the order standards are in its indispensable piece of the constitution, the constitution
manages that legal has an obligation to ensure privileges of the poor as likewise society all in
all. The legal through its huge legal intercessions has constrained and guided the assembly to
think of the reasonable enactment to convey equity to the doorsteps of the weakest areas of
the general public. Open Interest Litigation is one sparkling case of how Indian legal has
assumed the part of the vanguard of the privileges of Indian residents particularly poor
people. It energized the general population lively individuals to look for equity for poor
people. For that Supreme Court loose method generously. Aside from Public Interest
Litigation and legal activism, there are changes in the legal procedure, where it expects to
make equity modest and simple by presenting Lok Adalat framework as one of the techniques
to give free legitimate guide and fast equity at the doorsteps of poor people. In this article, the
writer features the significance of free lawful guide in a sacred majority rule government like
India where a huge area of the populace has still not seen the protected guarantees of even the
extremely essential thing rights being satisfied for them.
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Chapter-2
HISTORY OF LEGAL AID
Lawful Aid infers giving free legitimate administrations to poor people and destitute who
can't bear the cost of the administrations of an attorney for the lead of a case or a lawful
continuing in any court, council or before a specialist. The most punctual Legal Aid
development gives off an impression of being of the year 1851 when some authorization was
presented in France for giving legitimate help to the poverty stricken. In Britain, the historical
backdrop of the sorted out endeavors with respect to the State to give legitimate
administrations to poor people and penniless goes back to 1944, when Lord Chancellor,
Viscount Simon named Rushcliffe Committee to ask about the offices existing in England
and Wales for giving lawful guidance to poor people and to influence proposals as seem to be
alluring for guaranteeing that people needing lawful counsel are given the same by the State.
One need not be a litigant to seek aid by means of legal aid. Legal aid is available to anybody
on the road. Justice Blackmun in Jackson v. Bishop says that; "The concept of seeking justice
cannot be equated with the value of dollars. Money plays no role in seeking justice."
Article 39A of the Constitution of India gives that State might secure that the activity of the
lawful framework advances equity on a premise of equivalent opportunity, and should,
specifically, give free legitimate guide, by appropriate enactment or plans or in some other
route, to guarantee that open doors for securing equity are not denied to any subject by reason
of financial or other incapacity. Articles 14 and 22(1) likewise make it compulsory for the
State to guarantee fairness under the watchful eye of the law and a legitimate framework
which advances equity on a premise of equivalent chance to all. Legitimate guide endeavours
to guarantee that sacred promise is satisfied in its letter and soul and equivalent equity is
made accessible to poor people, oppressed and weaker areas of the general public. Sec. 304,
Criminal Procedure Code: The Constitutional obligation to give legitimate guide emerges
from the time the denounced is delivered before the Magistrate out of the blue and proceeds
at whatever point he is creating on remand.
Since 1952, the Govt. of India likewise began addressing the question of legal aid for the
poor in different conferences of Law Ministers and Law Commissions. In 1960, a few
guidelines were drawn by the Govt. for legal aid schemes. In different states, legal aid
schemes were coasted through Legal Aid Boards, Societies, and Law Departments. In 1980, a
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Committee at the national level was constituted to direct and supervise legal aid programs all
through the country under the Chairmanship of Hon. Mr. Justice P.N. Bhagwati then a Judge
of the Supreme Court of India. This Committee came to be known as CILAS (Committee for
Implementing Legal Aid Schemes) and began monitoring legal aid exercises all through the
country. The introduction of Lok Adalats added a new chapter to the justice dispensation
arrangement of this country and prevailing with regards to providing a supplementary forum
to the litigants for conciliatory settlement of their disputes. In 1987 Legal Services
Authorities Act was enacted to give a statutory base to legal aid programs all through the
country on a uniform pattern. This Act was finally enforced on ninth of November 1995 after
certain amendments were introduced therein by the Amendment Act of 1994.
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Chapter-3
THE CONCEPT OF LEGAL AID
Legal Aid implies giving free legal administrations to the poor and needy who cannot afford
the administrations of a legal advisor for the conduct of a case or a legal proceeding in any
court, tribunal or before a specialist. Legal Aid is the strategy adopted to ensure that no one is
deprived of professional counsel and help in view of absence of funds. Therefore, the main
question is to provide break even with justice is to be made accessible to the poor,
downtrodden and weaker section of society. In such manner, Justice P.N. Bhagwati rightly
observed that:1
“The legal aid means providing an arrangement in the society so that the missionary of
administration of justice becomes easily accessible and is not out of reach of those who have
to resort to it for enforcement of its given to them by law, the poor and illiterate should be
able to approach the courts and their ignorance and poverty should not be an impediment in
the way of their obtaining justice from the courts. Legal aid should be available to the poor
and illiterate, who don't have access to courts. One need not be a litigant to seek aid by
means of legal aid.”
Therefore, legal aid is to be made available to the poor and needy by providing a system of
government funding for those who cannot afford the cost of litigation.
Lawful guide endeavors to guarantee that protected vow is satisfied in its letter and soul and
equivalent equity is made accessible to poor people, discouraged and weaker segments of the
general public. It is qualified to specify that the Constitution of India gives 2 that State should
secure that the activity of the legitimate framework advances equity on a premise of
equivalent opportunity, and might, specifically, give free lawful guide, by appropriate
enactment or plans or in some other route, to guarantee that open doors for securing equity
are not denied to any native by reason of financial or other inability. Constitution of India
likewise makes it compulsory for the State to guarantee correspondence under the watchful
1
peaking through the Legal Aid Committee formed in 1971 by the State of Gujarat on Legal Aid with its
Chairman, Mr. P.N. Bhagwati along with its members, Mr. J.M. Thakore, A.G., Mr. VV Mehta, Deputy Speaker,
Gujarat Vidhan Sabha, Mr. Madhavsinh F. Solanki, M.L.A, Mr. Girishbhai C. Patel, Principal, New Lal College,
Ahemdabad. His Lord ship answered to the question of inequality in the administration of justice between the
rich and the poor
2
Article 39A of the Indian Constitution
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eye of the law and a lawful framework which advances equity on a premise of equivalent
chance to all 3 .
3
Articles 14 and 22(1) of the Indian Constitution.
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Chapter-4
FREE LEGAL AID IN INDIA: POSITIVE CONTRIBUTION OF
JUDICIARY
The Supreme Court of India got a noteworthy chance to make a vehement proclamation in
regards to the privileges of poor people and destitute in judgment of Hussainara Khatoon 4
where the solicitor conveyed to the notice of Supreme Court that the vast majority of the
under trails have just experienced the discipline substantially more than what they would
have had they been sentenced immediately. The postponement was caused because of the
failure of the people required to draw in a legitimate guidance to protect them in the court and
the primary purpose for their powerlessness was their neediness. Therefore, in this case, the
court pointed out that Article 39-Aemphasized that free legal service was an inalienable
element of reasonable, fair and just‘ procedure and that the right to free legal services was
implicit in the guarantee of Article 21.
Two years later, in the case of Khatri singh v. State of Bihar 5 , the court addressed the inquiry
the privilege to free lawful guide to poor or indigent blamed who are incapable for engaging
legal advisors. It held that the state is will undoubtedly provide such guide at the phase of
trial as well as when they are first created before the judge or remanded every now and then
and that such a privilege can't be prevented on the ground from securing financial constraints
or administrative inability or that the charged did not request it. Justices and Sessions Judges
must inform the blamed for such rights. The privilege to free legitimate services is a
fundamental ingredient of sensible, reasonable and only technique for a man blamed for an
offense and it must be held certain in the certification of Article 21 and the State is under a
protected command to provide an attorney to a blamed individual if the conditions for the
case and the necessities of equity so require… The State can't avoid this commitment by
pleading financial or administrative inability or that none of the aggrieved detainees
requested any lawful guide.
6
In Suk Das v. Union Territory of Arunachal Pradesh , Justice P.N. Bhagwati, emphasized
the need of the creating the legitimate awareness to the poor as they don't have the foggiest
idea about their rights all the more particularly appropriate to free lawful guide and further
4
Hussainara Khatoon v. State of Bihar, (1980) 1 SCC 98.
5
Khatri v. State of Bihar, AIR 1981 SC 262
6
AIR 1986 SC 991
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observed that in India a large portion of the people are living in provincial zones are
uneducated people and don't know about the rights conferred upon them by law. Even
educated people don't know what are their rights and entitlements under the law. It is this
absence of legitimate awareness they are not approaching an attorney for consultation and
advise. Moreover, due to their ignorance and lack of education, they cannot end up
independent and they cannot even help themselves. That is the reason the promotion of
legitimate proficiency has dependably been recognized as one of the principal things of the
program of the lawful guide movement in the country. I would state that even appropriate to
education would not satisfy its genuine objective if education about legitimate entitlements
isn't influenced available to people to and our constitutional promise of bringing justice to the
doorsteps of the people would remain an illusion.
Justice Krishna Iyer, who is crusader of social justice in India, had properly said that if a
detainee condemned to detainment is practically unfit to practice his established and statutory
right of claim comprehensive of unique leave to the Supreme Court for need of lawful help,
there is understood in the Court under Article 142 read with Articles 21 and 39A of the
Constitution, the ability to appoint direct for such detained individual for doing complete
justice.7
It is a statutorily recognized public duty of each great branch of government to obey the rule
of law and uphold the tryst with the constitution by making rules to effectuate legislation
meant to help the poor8.Though the law has been enacted to protect the poor the governments
are lazy to implement the enacted law. The same was observed by Supreme Court in State of
Haryana v. Darshana Devi9 , that "the poor shall not be priced out of the justice market by
insistence on court-fee and refusal to apply the exemption provisions of order XXXIII, CPC.
The state of Haryana, mindless of the mandate of equal justice to the indigent under the
Magna Carta of therepublic, expressed in article 14 and stressed in article 39A of the
constitution, has sought leave to appeal against the order of the high court which has rightly
extended the 'pauper' provisions to auto-accident claims. Order XXXIII will apply to
tribunals, which have the trappings of the civil court”…even court also expressed its poignant
feeling that ― “no state has, as yet, framed rules to give effect to the benignant provision of
legal aid to the poor in order xxxiii, rule 9A, civil procedure code, although several years
have passed since the enactment. Parliament is stultified and the people are frustrated. Even
7
M.H. Hoskot v. State of Maharashtra (1978) 3 SCC 81
8
Order 33, Rule 9A,Code Civil Procedure,1908
9
AIR 1972 SC 855
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after a law has been enacted for the benefit of the poor, the state does not bring it into force
by wilful default”.
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Chapter-5
LEGAL AID IN INDIA: STATUTORY RECOGNITION
Despite the fact that there was a statutory technique giving free legal guide by delegating the
backer for shielding the criminal case and by exempting court expenses in common cases, it
was not so much having any noteworthy effect on the capacity of the underprivileged
individuals to get the legal redressal for their grievances. Henceforth under huge protected
influence from the Supreme Court the Legal Services Authorities Act, 1987 was passed by
the parliament of India. The Act prescribes the criteria for giving legal services to the eligible
persons. It makes a person eligible for assistance under the act if he is –
a) A member of a Scheduled Caste or Scheduled Tribe;
b) A victim of trafficking in human beings or begar as referred to in Article 23 of the
Constitution;
c) A woman or a child;
d) A mentally ill or otherwise disabled person;
e) A person under circumstances of undeserved want such as being a victim of a mass
disaster, ethnic violence, caste atrocity, flood, drought, earthquake or industrial
disaster; or
f) An industrial workman; or
g) In custody, including custody in a protective home or in a juvenile home
h) If in a psychiatric hospital or psychiatric nursing home within the meaning of
i) A person whose annual income less than rupees fifty thousand or such other higher
amount as may be prescribed by the State Government10.
This farthest point on pay can be expanded by the state governments. Impediment with
regards to the wage does not matter on account of people having a place with the booked
stations, planned clans, ladies, youngsters, disabled, and so on. Therefore by this, the Indian
Parliament stepped forward in making the lawful guide conceivable in the nation.
As per the Act, the 'court' is a common, criminal or income court and incorporates any
council or some other specialist constituted under any law for now in compel, to practice
legal or semi legal capacities11. Under the Act 'lawful administration' incorporates the
rendering of any administration in the direct of any case or another lawful continuing under
10
Section 12 of the Legal Services Authorities Act, 1987
11
Section 2(1) (a) of the Legal Service Authority Act,1987
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the watchful eye of any court or other specialist or council and the giving of exhortation on
any lawful issue.12
Lawful Services Authorities in the wake of analyzing the qualification criteria of a candidate
and the presence of an at first sight case to support him give him guide at State cost, pay the
required Court Fee in the issue and bear every single accidental cost regarding the case. The
individual to whom lawful guide is given isn't called upon to spend anything on the suit once
it is upheld by a Legal Services Authority.
Chapter-6
12
Section 2(1) (a) of the Legal Service Authority Act,1987
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BODIES UNDER THE ACT AND THEIR HIERARCHY
An across the country arrange has been conceived under the Act for giving legitimate guide
and help. National Legal Services Authority is the pinnacle body constituted to set down
strategies and standards for making lawful administrations accessible under the arrangements
of the Act and to outline best and sparing plans for lawful administrations.
In each State, a State Legal Services Authority is constituted to offer impact to the
arrangements and headings of the Central Authority (NALSA) and to give lawful
administrations to the general population and lead Lok Adalats in the State. State Legal
Services Authority is going by the Chief Justice of the State High Court who is its Patron-in-
Chief. A serving or resigned Judge of the High Court is named as its Executive Chairman.
Local Legal Services Authority is constituted in each District to execute Legal Aid Programs
and Schemes in the District. The District Judge of the District is its ex-officio Chairman.
Taluk Legal Services Committees are likewise constituted for each of the Taluk or Mandal or
for a gathering of Taluk or Mandals to arrange the exercises of legitimate administrations in
the Taluk and to compose Lok Adalats. Each Taluk Legal Services Committee is going by a
senior Civil Judge working inside the purview of the Committee who is its ex-officio
Chairman.
Keeping in mind the end goal to give free and capable legitimate administration, the NALSA
has surrounded the National Legal Service Authority (Free and skillful Legal administration)
Regulations, 2010. The striking component of Regulation is drawing in senior skilled legal
advisors on instalments of general expenses in exceptional cases like where the life and
freedom of a man are in risk.
Incomparable Court of India has additionally set up Supreme Court Legal Services
Committee (SCLSC) to guarantee free lawful guide to poor and underprivileged under the
Legal Services Authorities Act. It is going by a judge of Supreme Court of India and has
recognized individuals assigned by Chief equity of India. The SCLSC has a board of
equipped Advocates on record with a specific least number of years of experience who
handle the cases in the Supreme Court. Aside from that, the SCLSC has full-time Legal
Consultant who gives legitimate counsel to poor prosecutors either on an individual visit or
through the post.
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Chapter-7
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RECENT AMENDMENTS MADE TO THE LEGAL SERVICE
AUTHORITY ACT 1987
The Legal Services Authorities Act, 1987 was enacted to constitute legal services authorities
for giving free and capable legal services to the weaker areas of the general public to
guarantee that open doors for securing equity were not denied to any resident by reason of
financial or other inabilities and to arrange Lok Adalats to guarantee that the activity of the
legal framework advanced equity on a premise of equivalent opportunity. The arrangement of
Lok Adalat, which is an imaginative component for elective debate determination, has
demonstrated successful for settling question in a soul of assuagement outside the courts.
Be that as it may, the significant disadvantage in the current plan of association of the Lok
Adalats under Chapter VI of the said Act is that the arrangement of Lok Adalats is primarily
in view of bargain or settlement between the gatherings. On the off chance that the gatherings
don't touch base at any trade off or settlement, the case is either come back to the official
courtroom or the gatherings are encouraged to look for cure in an official courtroom. This
causes superfluous deferral in the agreement of equity. On the off chance that Lok Adalats
are enabled to choose the cases on merits in the event that gatherings neglects to touch base at
any trade off or settlement, this issue can be handled all things considered. Further, the cases
which emerge in connection to open utility services, for example, Mahanagar Telephone
Nigam Limited, Delhi Vidyut Board, and so forth., should be settled critically so individuals
get equity immediately even at pre-case stage and consequently a large portion of the
insignificant cases which should not to go in the normal courts would be settled at the pre-suit
organize itself which would bring about diminishing the workload of the general courts as it
were. It is, therefore, proposed to revise the Legal Services Authorities Act, 1987 to set up
Permanent Lok Adalats for giving a necessary pre-litigative component for appeasement and
settlement of cases identifying with open utility services.
THE SALIENT FEATURES OF AMENDMENT
1) To accommodate the foundation of Permanent Lok Adalats which might comprise of
a Chairman who is or has been a locale judge or extra region judge or has held a legal
office higher in rank than that of the region judge and two other people having
satisfactory involvement in broad daylight utility services;
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2) The Permanent Lok Adalat might practice locale in regard of at least one open utility
services, for example, transport services of travellers or products via air, street and
water, postal, transmit or telephone utilities, supply of energy, light or water to
general society by any foundation, open conservancy or sanitation, services in clinics
or dispensaries; and protection services;
3) The monetary ward of the Permanent Lok Adalat should be up to rupees ten lakhs.
Notwithstanding, the Central Government may expand the said monetary locale
every now and then. It should have not purview in regard of any issue identifying
with an offense not compoundable under any law;
4) It additionally gives that before the question is brought under the watchful eye of any
court, any gathering to the debate may make an application to the Permanent Lok Adalat
for settlement of the question;
5) Where it appears to the Permanent Lok Adalat that there exist components of a
settlement, which might be adequate to the gatherings, it should plan the terms of a
conceivable settlement and submit them to the gatherings for their perceptions and in the
event that the gatherings achieve an assention, the Permanent Lok Adalat might pass a
honor in wording thereof. In the event that gatherings to the question neglect to achieve
an understanding, the Permanent Lok Adalat might choose the debate on merits; and
6) Each honor made by the Permanent Lok Adalat should be last and official on every
one of the gatherings thereto and might be by a lion's share of the people constituting the
Permanent Lok Adalat.
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Chapter-8
CONSTITUTIONAL PROVISIONS RELATING TO LEGAL AID
legal aid a constitutional right - Articles 21 and 39-A of the Constitution are as under:-
“21. Protection of life and personal liberty – No person shall be deprived of his life or
personal liberty except according to procedure established by law.
“39A. 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”.
Article 21 is a fundamental right conferred under Part III of the Constitution. Whereas Article
39-A is one of the directive principles of the State Policy under Part IV of the Constitution. It
has been held by the Constitution Bench of Supreme Court in Chandra Bhawan Boarding and
Lodging, the Bangalore V. State of Mysore, AIR 1970 SC 2042 at 2050, para 13 that “While
rights conferred under Part III are fundamental, the directives given under part IV are
fundamental in the governance of the country. There is no conflict on the whole between the
provisions contained in Part III and Part IV. They are complementary and supplementary to
each other.
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Chapter-9
LEGAL AID UNDER CPC AND CRPC
S. 304(1) "Lays down that when accused facing a trial. The concept of free legal aid scheme
under legal services Authority. The act is only when accused facing trial in court. When a
person is VV poor, then he can get legal aid. In the absence of a lawyer, the entire trial
becomes vitiated and then case to be remanded back to the trial court. Court to ask the
accused, whether he has services to engage a lawyer or not. If not, the court is bound to give
him a lawyer from the bar, who should be well versed in the law and to be getting paid by St.
Govt. The court cannot sympathize with a lawyer. The lawyer must be a competent one...." is
amicus curiae (friend of the court). S. 304, CrPC plays a very important role."
OREDER 33,RULE 17, CPC
Suit by or against an indigent person. When a plaint along with the petition, that person
unable to avail services of a lawyer, then court exempts him from court fees.
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CONCLUSION
Legal guide isn't a philanthropy or abundance however is a commitment of the state and
right of the nationals. The prime protest of the state ought to be equivalent equity for all‖.
In this manner, legal guide endeavors to guarantee that the sacred vow is satisfied in its
letter and soul and equivalent equity is made accessible to the oppressed and weaker
areas of the general public. Be that as it may, regardless of the fact that free legal guide
has been held to be an important subordinate of the administer of law, the legal guide
development has not accomplished its objective. There is a wide hole between the
objectives set and met. The real snag to the legal guide development in India is the
absence of legal mindfulness. Individuals are as yet not mindful of their fundamental
rights because of which the legal guide development has not accomplished its objective
yet. It is the nonappearance of legal mindfulness which prompts misuse and hardship of
rights and advantages of poor people.
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BIBLIOGRAPHY
Books:
OUP India, Alternative Dispute Resolution,
Website:
https://www.academia.edu/38407521/concept_of_legal_aid_in_Indian_Constitution
http://www.commonlii.org/in/journals/NALSARLawRw/2013/13.pdf
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