This article is written by Harshita Chandak of BALL.B of 3rd Semester of RNB Global University, Bikaner, an intern under Legal Vidhiya.
ABSTRACT
That appeal and revision couple with their academic discourse would provide for the very correctness of a judicial decision unconditionally or midway restore authority to exercise law. In that regard, technical coincidentally, appeal and revision shall ensure that legal processes are credible and just. While purposefully both may be identical, yet their contexts, relatedness, and modes within the system diversely differ. The authors have sought to carry out a comparison-oriented study of appeal and revision considered under intricate angles with regards to their system-specific characteristics in the paper. This input summarizes the statutory provisions and procedural guidelines that guide appeals and revisions and communicates their applicability in a very nuanced fashion in different legal particulars. It talks about the hierarchy of courts, the borders of permissible jurisdiction, and the point of view between substantive rights and procedural guarantees. The exposition will subscribe to relevant leading authorities and demonstrate how the appellate and revisional powers were exercised as correlative systems in correcting judicial errors of law, fact, and procedure while correlatively balancing the rights of individuals with the authority of the court. This research addresses questions surrounding the discretionary nature of revisions and the rights-based framework of appeals to provide a perceptive view of the developments of these legal remedies.
KEYWORDS
Appeal, Revision, Error of law, Error of fact, Civil Procedure Code(CPC), Criminal Procedure Code(CrPC).
INTRODUCTION
Understanding the differences between appeal and review is very crucial in the legal set up, mainly when it concerns handling aggrieved parties emerging from the judgments of courts. More often than not, even before the person bringing the suit out there receives the court’s decision, she feels it is unfair or not addressed well enough, prompting her to include or appeal into these legal remedies. An appeal is defined, basically, as legal entitlement which an aggrieved party is said to possess to challenge a ruling given by male courts. This is more than a procedural aspect, by virtue of the fact that it includes substantive elements that deal with possible mistakes that have a bearing on the outcome of the case, such as misapplication of law, mistakes in findings of fact, and breaches or incorrect procedures. For the litigants, an appeal is an opportunity afforded to the higher court for the presentation of arguments thereby seeking an evaluation of the case from established legal principles. Not the least, this is going towards rectification as well as public confidence in the judicial system vis- -vis demonstration towards a firm belief in fairness and justice. Yet more, there is no limit to the number of appeals-the escalating dispute-and hence leaves the possibility of an extended judiciary review. Revisions are therefore minus all sorts of other question and usually invoke to cure jurisdictional or procedural defects rather than substantive issues of fact or law. Revisions thereby are exercised in the form of an examination of decisions on lower courts by a superior court, the most common example being the High Court with respect to the subordinate courts. They look at correctness and legality in the whole process of judicial proceedings but do not go into any minutiae of the case. This supervisory nature is critical for the protection of the integrity of the judicial process, since it allows higher courts to meddle where extremely gross error made might lead to miscarriage of justice. Neither of them makes mistakes in justice nor does it shake public confidence in the outcomes of law. Revisions cannot be compared with appeals, these not being enforced by any right, generally allowing but one revision per case. This also brings to light the difference between procedure and substance highlighting how revisions come as lesions against the inherent evils that may occur in lower court decisions. In terms of correcting judicial error as appeal and revision do, the process functions under different principles and has a different role in the legal scheme. It is thus pertinent that lawyers, scholars, and policymakers be aware of the differences in appeal and revision, as this choice would have great implications on how errors made in the trial courts would be corrected and finally how the justice system is accessed. Each of these mechanisms serves a different need of the legislation for different kinds of litigants faced with some challenges in seeking justice. At its core, the comprehension of such processes will benefit individuals as they relate to guiding them through navigating the intricacies of legal recourse as well as reinforcing the larger vision of ensuring fair trial rights to parties in the judicial system. Ultimately, it is through this mechanism that appeals and revisions bring shape into a vibrant legal rural setting where the justice of a party can seek justice through proper channels.
UNDERSTANDING APPEAL AND REVISION
Definition of Appeal
An appeal is a statutory right that a litigant, aggrieved by a decision made or judgment rendered in any inferior forum, obtains from a higher appeal court other than the one wherein the error was raised. At this level, the High Court exercises adequate scrutiny of all matters placed before it and sanctioned with evidence to determine if justice has been dispensed justly. Appeals are one of the bedrocks of the legal process and a mechanism by which justice can be obtained to a litigant whose case is believed to have been built on some error of law or fact.
Types of Appeals
- First Appeal: In this instance, it relates to a decision or decree from the first lower court where the aggrieved party may appeal before the appellate court. The appellate court can revise both facts and legal issues de novo. The court can evaluate how rightly the lower court reached its findings of fact, and it applies the law to those facts. In India, the First Appeal is as per Section 96 of the Code of Civil Procedure, 1908 (CPCs)[1] where appeals are entertained against the decrees passed by the original courts unless the decree is one consent.
- Second Appeal: A second appeal typically arises in cases where the questions of law involved are substantial rather than of fact. This second appeal has a more limited scope than the first since it does not allow the re-examination of the factual findings except when there is a legal basis for attacking them. These second appeals in India are dealt with under Section 100 of the CPC[2], which restricts the application of such appeals to certain instances requiring clarification or interpretation of substantial questions of law. Such appeals are always brought to It must be noted that every second class of high court is known either as the High Court or, depending on the jurisdiction, the Supreme Court.
Provisions for Appeals in Indian Laws
Code of Civil Procedure, 1908, contains these provisions:
- Section 96: This section grants the right to file an appeal against a decree passed by a court exercising original jurisdiction. An appeal is preferred on legal grounds upon an exception of decrees being passed with the consent of the parties.
- Section 97[3]: A preliminary decree can only be disturbed on a first appeal; a party which wishes to appeal against a final decree must first appeal against the preliminary decree. If no appeal is filed, the party loses the right to later appeal based on those grounds.
- Section 100[4]: This governs “second appeals” and therefore limits the acceptability of only such second appeals on substantial questions of law. This mandates that the appellant should clearly state the substantial question of law involved, and the day of hearing shall be fixed only after such a question has been formulated.
- Sections 101-103[5]: Procedural provisions on second appeals, the discretion of the appellate court in determining questions of fact, and so on for resolving legal issues.
Criminal Appeals: Provisions under the Code of Criminal Procedure, 1973
- Sections 372-374[6]: Section 372 sets down the law that there can be no appeal unless otherwise provided; sections 373 and 374 define under what conditions appeals may be lodged. Such circumstances include conviction, acquittal, and insufficient punishment.
- Section 377[7]: The state can appeal for the enhancement of a sentence.
- Section 378[8]: These lay down a procedure for appealing acquittals by the state or complainant after obtaining leave from the appellate court.
- Sections 380-394[9]: Deal with the procedural aspects of criminal appeals such as hearing and disposal, powers of the appellate court, etc., with a view to just restraining further appeals.
Definition of Revision
Unlike the appeal, revision is not a right which is available as a matter of course to any aggrieved party; it is according to superior courts in their discretion to correct irregularities and errors committed by subordinate courts regarding jurisdiction. The primary aim of revision is to regulate the actions of lower courts within the limits prescribed by law and to act upon the legal principles in vogue. Unlike appeals, revisions do not permit re-examination of facts or evidence; it is much narrower in scope and focuses on the correctness, legality, and propriety of the lower court’s judgment.
Provisions for Ceasing very different from Appeals
Revisions under the Code of Civil Procedure, 1908 – Section 115[10] Where a subordinate court has:
a) Exercised a jurisdiction which is not vested in it by law,
b) Is failing to exercise a jurisdiction vested in it,
(c) Or acted in the exercise of its jurisdiction illegally or with material irregularity,
The discretionary powers of this high court to revise under this section of the CPC are not intended to add a layer of appeal but more of a supervisory process aimed at preventing the lower courts from overreaching or abusing their jurisdiction. Importantly, revisionary jurisdiction under Section 115 does not apply to trifling irregularities, only serious errors that can lead to substantial injustice or affect the legal rights of the party. For example, if in any given case, a trial court appears to be mistakingly doing an act that evidently exceeds its powers, the High Court may take it upon itself to correct the grievance by orders of revision. It must be clear that hearings on the merits of cases by the High Court or re-appreciating evidence would not be correct; rather, the High Court would see whether or not jurisdiction has been properly exercised by the trial court in the action at hand.
With Criminal Procedure Code, 1973
Revisions for the cases of crimes are more elaborately provided under sections 397 to 401 of the CrPC. These sections empower both Sessions Court and the High Court to call for the records of proceedings made by the lower courts to inspect them with respect to their legality or propriety or regularity.
- Section 397[11]: By virtue of this section, the High Court or Sessions Court has the power to call for and examine the records of any proceeding before a subordinate criminal court. The use of this section is generally meant for correcting jurisdictional mistakes or procedural irregularities which might lead to a grave miscarriage of justice.
- Section 399[12]:Allows supervisory authority to Sessions Courts with the same limitations imposed earlier but, where a party is aggrieved by an order passed in exercise of revision, it is possible to carry its case forward to the High Court under the provisions of section 401 of the CrPC.
- Section 401[13]:Section gives High Court a much wider range of powers in revision, permitting it to modify, set aside, or even reverses the decisions of subordinate courts. It should, however, be pointed out that the High Court must exercise caution so as not to allow itself to act in place of an appeal any further. Example; In a criminal case when a magistrate pronounces a sentence without having followed the required due process, or would pronounce, usually, punishment of a lower discipline than he is supposed to, a revision grants decree upon it to ensure the absolute legality of the particular process employed therein.
KEY FEATURES AND OBJECTIVE
Appeal
In an important letter appeal, parties concerned in the case can seek a higher court or tribunal to reconsider an appellate verdict against a lower court or tribunal. The most prominent aspect of appealing from one trial to another is that the same must be sought based on probable legal, factual, or procedural errors. In case of a decision from the lower court, the party affected gets an appeal to a higher court where they put forth their argument that the judgment rendered was incorrect or unjust. This is how an appellant makes a case for particular mistakes or misinterpretations that occurred during the trial, either about the application of law, recognition of the facts, or the procedures followed. However, it should be remembered that an appeal is not a re-trial. The higher court is not going to consider all the evidence adduced in the former case; it is going to be focusing on the legal issues put up by the appellant, which may include the misapplication of principles of law, inappropriate interpretation of laws, or unfairness of the trial process. Most of the time, appeals are lodged on grounds of wrong application of law, omission of main evidence, or procedural irregularities affecting the integrity of the case. The appellate process can generate various results: the endorsement, modification, or reversal of the original order. In some cases, the higher court might mandate the re-trial or remand to the lower court for reconsideration in the light of its findings. Most importantly, appeals serve a much larger function in the justice system than just these. They preserve the integrity and consistency of legal interpretation such that like cases receive similar treatment at law; they also guard against wrongful convictions or tainted decisions, making available remedies for mistakes which otherwise would have very serious consequences.
Revision
Revision is an avenue available in law through which a higher court or authority has the chance to reconsider the decision of a lower court, albeit with a different angle than that of an appeal. Appeals primarily consider errors in law, facts, or procedure, but revision aims at making sure that justice was done, meaning that the lower court’s decision was fair and reasonable. One of the most important things about revision is that it has the ability to correct decisions which are manifestly incorrect or perverse or result in injustice even if no formal appeal has been made. It acts as a safety net against abuse of power, wrongful decisions, or errors which have not been caught up in the normal appellate processes. Unlike an appeal, what revision is different in that it is invoked more often by a higher court or judicial authority, and often not by any petition from the parties, although a party may seek that recourse sometimes. It also does not focus on trying to re-examine the entire case but to guarantee that the lower court did not exceed its jurisdiction or make exceptionally unjust decisions. Most often, this circumstance arises when there is a patent infraction of legal principles or when something looks unreasonable on the surface. While revision doesn’t re-try the case or look at the evidence in detail, it does ensure that the legal system remains fair, just, and free from errors that may harm the rights of individuals. Basically, revision acts as a safety net in the legal structure, supplying additional reinforcement against and scrutiny of lower court decisions to preserve justice. It upholds the integrity of the judicial system by catching grave errors or inconsistencies that might get past usual mechanisms, securing the rights of those affected by the halls of justice.
KEY DIFFERENCE BETWEEN APPEAL AND REVISION
Basis for Comparison | Appeal | Revision |
Meaning | An appeal is a request made to a higher court to re-examine a judgment made by lower courts. | The other aspect of the phenomenon is revision; this is the process of revising, reexamining, and where necessary, amending a judgment into a just and fair decision. |
How many times it is allowed? | Many of these | Only one |
What is it? | Substantive Right | Discretionary power of the court |
Where Preferred? | Superior Court, which can be a district court or high court. | High Court |
Who can apply? | Party to suit | Party to suit and court can also apply Suo moto |
Involves | Court Hearing | Rewriting and reworking |
Against | Decree and appealable orders. | Decision passed by the subordinate court. |
Abatement | It is abated on the death of the aggrieved party, if the legal representative fails to bring the proceedings on record within time. | The petition can be further revised even if the party dies during the application for the same |
Grounds | An appeal can be made on the grounds of the question of law and fact. | A revision may be made on the basis of the error of jurisdiction. |
JUDICIAL PRECEDENTS
Appeal
- The case law is really thrown open regarding the use of appellate jurisdiction. The Supreme Court, in its 2016 ruling in Pankajakshi v. Chandrika[14], has thrown light on the scope of second appeals pertaining to the necessity of substantial legal questions. Appealed on fundamental grounds rather than inputted on trifling contents is further elucidated in 1983 by Laxmi Bai v. Bhagwant Buwa[15].
- The ruling dealt in the case of Satya Pal Singh vs State of Madhya Pradesh[16] before the Hon’ble Supreme Court that a father of a deceased will have locus standi to present an appeal before the High Court under the proviso of Section 372 as a definition of ‘victim’ exists to challenge the correctness of judgment and order of acquittal of accused. The same sets of rules and procedures are used to govern appeals to be heard in the Sessions Courts and those in the high courts . Supreme Court is the last and highest court of the country regarding appeal; consequently, it has all the possible discretionary and plenary powers in cases of appeals to it.
- Smt. Ganga Bai vs. Vijai Kumar AIR 1974 SC 1126,[17] There is a fundamental difference between the right to suit and the right to appeal. Every human being has an inherent right to file a civil suit, and unless a suit is barred by statute, one might sue at his peril. Even if the claim is wholly deserving of ridicule, the law does not give an Ans to such a condition. The suit does not require any authority of the law for its maintenance; it suffices for its maintenance that no statute forbids it. But the position with respect to appeals is wholly different. No one has an inherent right of appeal, and hence a right of appeal must have a clear authority of law for its maintenance. Appeal only against decree and not mere adverse findings.
Revision
- State of Rajasthan vs Fateh Karan Mehdu. 2017 SCC Online Raj 430,[18] Reaffirming “This basically reiterated the fact that revisions are mostly meant for jurisdictional error or procedural irregularity and not for factual disputes”. Aundal Ammal vs. Sadasivan Pillai, 1987 (2), SCC 295.[19]
- In the case of Amit Kapoor vs Ramesh Chander & Anr[20], “The revisional jurisdiction becomes available where the controllable findings are glaringly wrong, or there is non-compliance with the provisions of law, or the finding recorded is based on no evidence, or material evidence ignored or where judicial discretion has been exercised arbitrarily or perverse.”
- Amir Hasan Khan vs Sheo Bakshi Singh (1884) 11 IA 237[21]Interpreting the words “or to have acted in the exercise of its jurisdiction illegally or with material irregularity,” PC observed as follows: The question then is whether the judges of the Lower Courts in this case acted illegally. It appears that they had complete jurisdiction to determine the question which was before them, and indeed, they determined it. Whether rightly or wrongly, they had jurisdiction to determine that case; and even if they determined wrongly, they did not exercise their jurisdiction illegally or with material irregularity.
- N.S. Venketagiri Ayyangar vs. H.R.E. Board, AIR 1949 PC 156 S. 115, C.P.C.,[22] applies only when no appeal is possible and where the legislature has not conferred any right of appeal, the manifest intention is that the order of the trial Court, right or wrong, shall be final. The section empowers the High Court to satisfy itself upon three matters (1) that the order of the Subordinate Court is within its jurisdiction; (2) that the case is one in which the Court ought to exercise jurisdiction; and (3) that in exercising jurisdiction the Court has not acted illegally, i.e., in breach of some provision of law or with material irregularity, i.e., by committing some error of procedure in the course of the trial which is material in that it may have affected the final outcome. If High Court found itself satisfied upon those three matters, it has no power to interfere, however far it differed from the conclusions of the Subordinate Courts upon questions of fact or law.
- The High Court has the power of Suo-motu or upon petition by an aggrieved party or any other party to take up a revision petition for consideration. Allahabad High Court held so in Faruk @ Gaffar vs State Of U.P[23]. whenever, it said, ‘the matter is brought to the notice of the Court and the Court is satisfied that in the facts and circumstances of the case, a case is made out for exercising the revisional powers Suo motu, it can always do so in the interest of justice’. However, certain statutory limitations have been imposed on the High Court for the exercise of the above.
PRACTICAL IMPLICATIONS
Appeal – Litigants have a right to appeal in order to obtain a remedy and ensure justice. However, this process is often quite slow and costly, delaying the determination of disputes for an even longer period. This lengthy period may dissuade some litigants from taking this recourse, particularly in less significant matters or where there is urgency and limited financial capacity. Abuse of appellate remedies with parties even filing appeals just to delay enforcement give a huge blow to judicial efficiency.
Revision – It plays an essential role as judicial discipline and procedural integrity; however, its discretionary nature may lead to different applications. For instance, while some courts might take a liberal view in entertaining revisions, others might take a stricter one, thus denying access to the remedy. This divergence emphasizes the necessity for uniform norms governing revisional jurisdiction to bring predictability and equality therein.
SIMILARITIES
While it is true that appeals and revisions are different from each other in objective and scope, the two have many functions in common whereby they’re treated as legal remedies. Both the mechanisms allow the challenging of a judgment or order of a subordinate court or tribunal, with the result that any factual or legal errors therein might be redressed, such that justice becomes obtainable. Instead, through either of them, a higher court is requested to review the matter, normally after the pronouncement of the final judgment or order. The possible responses by the higher court include its overturning, varying, or confirming the initial ruling based on the surface merits of the matter(s). In other cases, the court may direct a fresh trial or hearing to reassess the facts or the law concerned.
Both appeals and revisions have to be filed within strict limitations, accentuating the need for time within which such action takes place to be received from the litigants. Under the procedures, they require parties to file their legal briefs or arguments prestated before the higher court, giving reasons why the original decision has to be set aside. Oral hearings may occur but are not mandatory depending on the nature of the case and the discretion of the court. However, notwithstanding these procedural aspects, the appeal and revision rules may differ based on jurisdictions and specific circumstances of the case. Finally, both modes provide safety for the legal process, granting individuals the opportunity to correct their mistakes and ensure fairness in judicial decisions. As appeals and revisions give force to higher courts to monitor and correct, when necessary, the lower court decisions, so they strengthen the principles of accountability and establishment and increased emphasis on the notions of transparency and justice in the legal system. Such processes denote that no decision is immune from scrutiny, revealing the system’s commitment to fairness and rule of law.
BROADER CONTEXT AND FUTURE PERSPECTIVE
The evolving trends in the law necessitate the adaptation of appeal and revision mechanisms to contemporary challenges. The digitization of court records and artificial intelligence, for instance, in legal research, should significantly enhance the efficiency of conduct and processes of appeal and revision. Of course, these must take into account legal and procedural delays, improve accessibility, and ensure a uniform application of legal principles. Besides, increasing awareness of the public regarding the differences between appeal and revision is also significant. Litigants and legal practitioners need to have sufficient knowledge to wise use of these remedies; thus curtailing unnecessary litigation and promoting judicious judgements.
CONCLUSION
It is the importance of appeals and revisions as part of the delivery system for justice that is in most cases cited against them. These are in-house legal remedies that neither appeal nor revision can redress as an injury caused to them by the order of the lower court. They provide remedy based on a critical right for an aggrieved party from the order of the lower court; like revision, they serve an equally important function concerning the supervisory role of a higher court over legal procedure and miscarriage of justice. They contribute to judicial misdeeds and maintain the system’s integrity by ensuring transparency and accountability. Being aware of the important differences between appeals and revisions is significant to legal practitioners, litigants, and anyone concerned with the judicial firmament. It would help them make informed decisions as to the appropriate legal options available in solving different problems, ultimately facilitating the effective and efficient operation as well as promoting a fairer and more transparent judgment process. The litigant may learn his rights and what avenues are available for the pursuit of justice, while for the legal professional, it becomes an important tool in upholding the rule of law. Future studies may focus on investigating emerging trends in appellate and revisional jurisdictions, particularly in light of the changes introduced by technological advancements and judicial reforms on the scene. Virtually all aspects of court proceedings have been increasingly relying on technology, such as virtual hearings and digitized records, causing significant alterations in these traditional arrangements. Understanding these new approaches is a critical aspect in ensuring the continued efficacy of appeals and revisions amid an ever-evolving legal landscape.
REFERENCES
- Leverage.edu, What is the Difference between Appeal and Revision, https://leverageedu.com/discover/general-knowledge/diffierence-between/difference-between-appeal-and-revision/ (last visited – 1 January 2025)
- Indian Kanoon, Difference between appeal and revision, https://indiankanoon.org/search/?formInput=difference%20between%20appeal%20and%20revision&pagenum=1 (last visited – 1 January 2025)
- Ipleaders blog, Review, appeal, revision; All you need to know about it https://blog.ipleaders.in/review-appeal-revision-all-you-need-to-know-about-it/ (last visited – 1 January 2025)
- Testbook, Difference Between Appeal and Revision, https://testbook.com/key-differences/difference-between-appeal-and-revision (last visited – 1 January 2025)
- Scribd , Difference Between Appeal and Revision https://www.s cribd.com/document/467640399/Difference-Between-Appeal-and-Revision#:~:text=expand%20document%20information-,The%20key%20differences%20between%20an%20appeal%20and%20revision%20are%3A%20%2D%20An,of%20a%20lower%20court’s%20decision. (last visited – 1 January 2025)
[1] Code of Civil Procedure, 1908, Section 96, No. 5, Act of Parliament, 1908 (India)
[2] Code of Civil Procedure, 1908, Section 100, No. 5, Act of Parliament, 1908 (India)
[3] Code of Civil Procedure, 1908, Section 97, No. 5, Act of Parliament, 1908 (India)
[4] Code of Civil Procedure, 1908, Section 100, No. 5, Act of Parliament, 1908 (India)
[5] Code of Civil Procedure, 1908, Section 101-103, No. 5, Act of Parliament, 1908 (India)
[6] Code of Criminal Procedure, 1973, Section 372- 374, No. 2, Act of Parliament, 1974 (India)
[7] Code of Criminal Procedure, 1973, Section 377, No. 2, Act of Parliament, 1974 (India)
[8] Code of Criminal Procedure, 1973, Section 378, No. 2, Act of Parliament, 1974 (India)
[9] Code of Criminal Procedure, 1973, Section 380-394, No. 2, Act of Parliament, 1974 (India)
[10] Code of Civil Procedure, 1908, Section 115, No. 5, Act of Parliament, 1908 (India)
[11] Code of Criminal Procedure, 1973, Section 397, No. 2, Act of Parliament, 1974 (India)
[12] Code of Criminal Procedure, 1973, Section 399, No. 2, Act of Parliament, 1974 (India)
[13] Code of Criminal Procedure, 1973, Section 401, No. 2, Act of Parliament, 1974 (India)
[14] Pankajakshi(Dead) Through L.Rs. & Ors vs Chandrika & Orsi AIR 2016 SUPREME COURT 1213, AIR 2016 SC (CIVIL) 1091, (2016) 3 CURCC 14, 2016 (5) SCC 223
[15] Laxmi Bai vs. Bhagwant Bua (2013)4 SCC 97
[16] Satya Pal Singh vs State Of MP And Ors on 6 October, 2015 Equivalent citations: AIR 2017 (NOC) 528
[17] Smt. Ganga Bai vs. Vijai Kumar AIR 1974 SC 1126,
[18] State of Rajasthan v. Fateh Karan Mehdu, (2017) 3 SCC 198
[19]Aundal Ammal vs Sadasivan Pillai on 9 December, 1987 AIR 203, 1987 SCR (1) 485, AIR 1987 SUPREME COURT 203, (1987) 1 KER LT 53
[20] Amit Kapoor vs Ramesh Chander & Anr on 13 September, 2012 Equivalent citations: AIRONLINE 2012 SC 668
[21] Amir Hasan Khan vs Sheo Bakshi Singh (1884) 11 IA 237
[22] N.S. Venketagiri Ayyangar vs. H.R.E. Board, AIR 1949 PC 156 S. 115,
[23] Criminal Misc. Application No. 227273 of 2012 in Criminal Appeal No. 98 of 2008. Case: Faruk @ Gaffar Vs State of U.P. High Court of Allahabad (India)
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