Reconstruction Of The Criminal Justice System- Challenges In Implementing The BNSS, BNS And BSA 2023
Author: LawSphereX
Category: Criminal Law
Published:
Updated:
RECONSTRUCTION OF THE CRIMINAL JUSTICE
SYSTEM- CHALLENGES IN IMPLEMENTING THE BNSS,
BNS AND BSA 2023
Debopriya Chattaraj, BA LLB (H), St. Xavier’s University, Kolkata.
ABSTRACT
India has witnessed a new dawn in the light of the Criminal Justice System recently with the implementation of the Bharatiya Nagarik Suraksha Sanghita (B. N. S. S 2023), The Bharatiya Nyaya Sanghita( B. N. S 2023) and The Bharatiya Sakshya Adhiniyam (B. S. A 2023) that has been an attempt to replace the Indian Penal Code 1860, The Code of Criminal Procedure 1973 and The Indian Evidence Act 1872, respectively. 1st July 2024 has not only awaken a new spirit of the Indian Criminal Justice System but has also established a milestone in the journey of the three pillars of Criminal law being the Penal, the Procedural and the Adjective law. It is worthy to note that whenever there is a change, there is a challenge and this paradigm shift from the classical old colonial law to the modern law reforms i. e. The B. N. S. S, the B. N. S and the B. S. A is not an exception.
Ranging from the Judicial system to the police and the advocates, the challenges of implementing the new laws has also touched the students of law. Here in this paper we will deal with the reasons for implementation of the new laws, highlighting the key changes that the new laws have ushered in and thereby conclude by painting the picture of the post implementation scenario. Therefore as a student of law, it will be a humble attempt to highlight the challenges faced by the police, the judiciary and the students of law suggesting ways to combat this challenges. Keywords: Criminal Justice System, implementation, challenges, law reform, changes.
1. Introduction:
“Change is inevitable but growth is optional" – C. J Maxwell. 1st July 2024 has ushered in a new era in the Criminal Justice System by Reconstruction of the Indian Penal Code 1860, the Code of Criminal Procedure 1973 and The Indian Evidence Act 1872 in the form of the Bharatiya Nyaya Sanhita, the Bharatiya Nagarik Suraksha Sanghita and the Bharatiya Saksya Adhiniyam 2023. The advent of these new laws have shun away the colonial hangover as it is claimed by the erudite drafters of the legal reforms. However, it is to be noted that that where there is a change there is a challenge. The advent of the new legislation seems to have indulged not only in construction of a ‘Bharatiya ‘ criminal laws but has also brought with it a legal hotbed regarding implementing the new laws.
While it was a much needed change to lift the colonial hangover and drive towards the path of Modern Criminal justice system, the people at the destination of this drive faced challenges in implementation of the new legislation. Ever since its sanction from the Parliament the government has declared and accepted the new laws but how to implement it is nowhere mentioned. This remains a grey area till date and to jostle through this has bow become a day to day struggle of the Judges and others. The scrounge of the challenges have touched not only the Judiciary and the advocates but also the students of law and the common people who are absolutely helpless. The Savings and Repealing clause though have provides a respite as enunciated in sec 531 of the Bharatiya Nagarik Suraksha Sanghita ( B. N. S. S) 2023, the challenges to implement these new laws still remain.
2. Brief History:
Soon after the Revolt of 1857, the Crown felt the need of drafting a systematic code for the Indian Criminal Justice System. Though the proposal for drafting the Indian Penal Code began in the First law Commission in 1834 it was tabled on 1835 under the chairmanship of Lord Thomas Babington Macaulay and came into force in 1860 as The Indian Penal Code 1860. The history of The Code of Criminal Procedure (CrPC)1973 dates back to 1882 when it was first implemented as a need arising out of drafting the Indian Penal Code . Then eventually it was amended in 1894 and then finally amended in 1973 by the erudite draftsman K. G. Sundaram. While the Indian Evidence Act 1872 is a result of the Stephens Commission 1871 which was implemented in 1872 under the chairmanship of Sir James Fitzjames Stephen. Thus India was ornamented with a complete legal framework.
However was the legal frame work still a ‘complete legal framework’? – the question remains.
2.1 Reasons for implementation of the new laws: Ever since the 1860 era, where India was
ornamented with the Indian Penal Code, the Code of Criminal Procedure and The Indian Evidence Act, we experienced a colonial dominion over the Indian people. Though the rich ancient Indian civilization had golden framework of administration in the codified in the form of ‘Upanishad ‘, ‘Naradasmriti', ‘Manusanhita ‘, ‘Bhrigu Sanhita ‘, ‘Yagnavalkya smriti ‘, and other penal provisions, India seemed to have acceded before Her Colonial masters who framed the legal system in a parochial way. The Colonial Penal system was drafted craftily to safeguard the interest of the Crown and penalizing anyone who would rebel against the State in the name of ‘freedom’. For instance in the case of Virendra Singh and Ors V. State of Uttar Pradesh , on 29th April, 1954, the Bench by Vivian Bose, Mehar Chand Mahajan, B.
K Mukherjea and Natwarlal Bhagwati, it was observed that little rights were reserved for the Indians. Also in Forester V. Secretary of state for India, the similar lines were made. Further Lord Brougham in Mayor of Lyons V. East India Company, further extended the principle of alienating the citizens. The landmark judgement of I. C Golaknath V. State of Punjab 1967, established that little rights are vested with the citizens. Through the case of ADM Jabbalpur V. Shivakant Shukla , the miserable condition of the helpless citizens are abundantly clear and established that the helpless citizens lay at the mercy of the State. Thus the Colonial Law was so crafting drafted so as to orchestrate the law in the favour of the Crown.
New Laws that ae in vogue today. After much effort to bring a new reform in the Indian legal system, finally the Standing Committee Report , chaired by Mr. Brij Lal, submitted the proposal of implementation of B. N. S – the Bhartiya Nyaya Sanhita 2023 replacing the Indian Penal Code1860 on 10th November 2023. On similar footing the Bill for passing the Bharatiya Nyaya Sanhita B. N. S. S 2023 was also proved by the Standing Committee and present at the Lok Sabha on August 11th , 2023 and subsequently the report was submitted by the Standing Committee on 10th November, 2023. Prima facie, the proposal faced withdrawal from the Lok Sabha on December 12th 2023 but this was just a ‘pull back ‘ before releasing the upshot arrow of the new Criminal Laws. Just as an arrow is pulled back at the first instance to launch at a higher speed, the proposal was also pulled back for a better fate.
Finally on December 25th, 2023, the Bill received Parliamentary approval and India was ready to launch its Newly born Criminal Law – the Bharatiya Nagarik Suraksha Sanghita (B. N. S. S), the Bhartiya Nyaya Sanhita (B. N. S) and the Bhartiya Sakshya Adhiniyam (B. S. A).
2.3 Parliamentary Approval: It is a sine qua non for every bill to undergo the process
enunciated in Article 107 to Article 111 of the Indian Constitution to get approval for implementation and coming into force. The Bill was first passed by the Rajya Sabha on 20th December, 2023 and thereafter in Loksabha on 21st December 2023. Finally, the Bill received President’s Consent on December 25th 2023 and declared the enforcement of the new laws since July 1st , 2024. Indeed the new year of 2024 was ready to launch its Newly drafted Legal System.
3. Key Changes in B.N.S.S:
Section 23 Increases the power of fine imposition of a Magistrate of first class from Rs. 10,000 to Rs. 50,000, and of a Magistrate of second class from Rs. 5,000 to Rs. 10,000. These two classes have also been empowered with imposing community service as a form of sentence. Section 35(7) Prevents arresting and aged or infirm person unless charged for an offense punishable with not less than 3 years of imprisonment without prior permission of the officer not below the rank of Deputy Superintendent of Police. Section 63 Introduces summons by Court through electronic form authenticated by the image of the seal of the Court or digital signature. Section 66 This provision replaces the earlier verbatim of “some adult male member” contained in the CrPC.
Section 84 Provides that proclaimed offender can be declared in all the offences which are punishable with imprisonment of 10 years or more, or with life imprisonment, or with death. Section 145 Provides that the proceedings for maintenance can be initiated against a person at the place where either their dependent father or mother resides.
specific timeframe for the supply of medical reports and streamlines the overall process of supply of documents. Section 398 Mandates the preparation and notification of a witness protection scheme by every State Government. The necessity for a comprehensive witness protection scheme had been underscored by the Malimath Committee and various Law Commission Reports, including the 14th, 154th, 172nd, 178th, and 198th Reports. Additions:
1. Section 2, introduces and defines the “electronic communication” and “audio-video
electronic means” for various procedures on the usage of electronic mode for all trials and proceedings.
2. Section 105 of the B.N.S.S makes the videography of search and seizure, and the signing
of it by the witness mandatory.
3. Section 107 provides for conducting trials and pronouncing judgments ex parte against
absconding offenders evading trial.
4. Section 173 provides for registering First Information Report (FIR) electronically, signed
by the person giving it within three days.
5. Section 176 mandates forensic investigation for offences punishable with imprisonment of
7 years or more.
6. Section 185 mandates the audio-video recording of a search without a warrant.
7. Section 258 mandates that a judgment of acquittal or conviction must be passed within 30
days from the completion of arguments, that is extendable only by 45 days for specific reasons.
8. Section 346 provides that a trial or inquiry shall be on a daily basis.
9. Section 530 of B.N.S.S also provides for all trials, inquiries and proceedings held in
electronic modes.
10. Chapters VI, VII, and VIII provide for the attachment of the accused’s property in cases of
financial offences.
11. Provisions contained in Chapters XVII, XIX, XX, set timelines for different investigatory
stages to address delay in procedure. Deletion:
1. Provisions contained under the CrPC, dealing with ‘Metropolitan areas’ and ‘Metropolitan
Magistrates’ have been omitted from the BNSS.
2. The post of Judicial Magistrate of third-class and Assistant Sessions Judge was omitted to
bring uniformity.
3. Section 144-A of the CrPC which conferred power on the District Magistrate and the
State Government to prohibit the carrying of arms in procession or mass drill or mass training has been deleted.
3.1 Key Changes in B.N.S: The Bharatiya Nyay Sanhita 2023 seems to have updated itself
with new kind of offenses pertaining to the ‘post modern theory of Criminology:
1. Community Service has been included in BNS as a punishment for the first time for petty
offences: (Section 23) As a new feature of the Bharatiya Nyaya Sanhita, India has drawn the western concept of ‘Community Service ‘ as punishment for petty crime. The genesis of this was drawn from the case of Sanjeev Nanda V. NCT Delhi 2014 specially known as ‘The Delhi Hit and Run Case' , this new addition to the penal provision is in vogue and
4. New Offence of Petty Organised Crime (Section 112) : This feature seems to have found
itself from the case of State of Gujrat V. Omprakash Gupta and Ors 2023. Thus emerging out of day to day struggle of the people , the B.N.S seems to have updated itself by catering to the needs of the people.
5. New Offence of Terrorist Act: (Section 113) The present law defines terrorist activities and
also recognises it as a separate offence beside the TADA and POTA act. The Supreme Court in Mannargudi Bar Association V. U.O.I 2024 and in the case of Azad Singh V. U.O.I 2024 upheld the validity of Section 113 of B.N.S.
6. Changes in punishment in hit and run cases: Section 106(2) of the B.N.S limits the
punishment of hut and run cases up to 5 years.
7. Sedition made not punishable by omission of section 124A of IPC; Instead treason is made
punishable under new section 150 of BNS: The Supreme Court in the case Iqubal Singh V. State of Jammu and Kashmir on 8th November 2024 has upheld the validity of
‘Sedition’ in the Indian Penal Code.
8. Mere possession of fake currency notes is no more punishable: Though Section 180
provides that anyone found to be in possession of counterfeiting coins or currency notes is considered to have committed an offense under Section 180, the explanation of Section
180 provides that no person shall be punishable under Section 180 if it is established that
the counterfeited coins were taken from lawful source as held in the case of B. Aboobacker V. State of Kerela 2024.
9. Scope of offence of “theft” expanded to cover theft of intangible items: (Section 303) The
3.2 Key Changes in B.S.A: The main theme of the Bharatiya Saksya Adhiniyam 2023 is
premised on the ground of ‘digitalization' catering to the development of technology and tuning with the concept of ‘Digital India ‘.
1. Inclusive definition of electronic records as primary and secondary evidence: The
Bharatiya Sakshya Adhiniyam now includes electronic records such as recordings or videos that are now inured in the definition of primary and secondary evidence.
2. Updated Terminology: The inclusion of terms like electronic record, digital signature,
electronic evidence, makes it abundant clear that B.S.A has been enacted to update the legal system with the current developments in the field of Technology.
3. Admissibility of the electronic evidence: Now, electronic evidence is an admissible piece
of evidence. “Omnia Presumuntur Vitese Acta" – all documents produced by the Court is presumed to be true and correct, now extends to electronic evidence.
4. Oral Evidence: The Bharatiya Sakshya Adhiniyam 2023 allows oral evidence to be
admissible even in electronic mode which makes trial easier. For instance where a witness is out of station, his /her statement can be recorded electronically or can be included in the trial room via online meeting platforms
5. Section 112: Section 116 of the Indian Evidence Act 1872 provides that doctrine of
estoppel is applicable on landlord-tenant relationships. However, Section 112 of the Bharatiya Saksya Adhiniyam includes a wide scope of applications other than tenant – landlord relationships.
6. In the case of Sarwan Singh Yadav V. Rajeev Kumar Yadav 2024, the Court had
delivered its recent judgement on the application of B.S.A.
4. Challenges Faced:
readers through the lanes of challenges faced by the above-mentioned avenues of the Criminal Justice System.
4.1 Challenges faced by the Police: Police is the body of administration responsible for the
Executive functions. In the Mallimath Committee Report 2003, it was recommended to bring reforms in the Police Act 1861 to bring reforms in the Criminal Justice System. Since the Police plays a pivotal role in implementing the policies of the legislature, it is important to look into the challenges faced by one of the most important wings of the Criminal Justice System.
1. Certain provisions violative of Article 14 and 21: The Bharatiya Nagarik Suraksha Sanhita
provides for certain protocols but in the process have ignored the importance of Article 14,
19 and 21. For instance Sec 172 B.N.S.S 2023, provided for unwarranted arrest by police
officer upon refusal to cooperate with the police in investigation. The problem that arises here is that though the police is authorized to arrest any person on the above-mentioned ground, such act is questioned by Art.14, and 21. Hence, despite having the legal force, the police is crippled upon questions of constitutional validity. Drawing factual matrix from the Abhinandan Jha V. Finest Mishra judgement, questions come up on the preventive arrest by the police and the police is left helpless without being substantiated by legal ground.
2. Challenges on implementing Sec.187(3) B.N.S.S: Though Sec. 187(3) B.N.S.S provides
that the police may extend custody from 15 days to 60 days (for offenses punishable with imprisonment less than 7 years) or 90 days ( for offenses punishable with imprisonment for more than 7 years) which gives power to the police to prevent individuals from escaping police custody under fake grounds of medical emergency and other grounds, this substantially challenges the DK. Basu V. State of West Bengal, 1997 judgement along with the Suresh Bhai Patil Case and Arnesh Kumar Antil case. People have questioned the extent of police powers claiming these to be nothing but ‘legally based police atrocities
functionaries to implement these functions.
4. Lack of proper training: The Police Department, despite the various advancements made
in the Criminal Justice System, is not affluent in technology-based procedures. For instance the Raghunath Singh Tolia , Uttarakhand academy offered a three days training camp from November 25th, 2024 to November 27th, 2024 and The Sardar Vallabhai Patel National Police Academy, offered training for the police on the new Criminal Laws on December 11th, 2024. Though there are cyber experts in the various cyber cells of different area, the majority of the Police Department, still find difficulty in navigating the technology-based challenges. Moreover, not everybody trained in the Police Department is trained in cyber law. Therefore, the new B.S.A 2023, 2hich has ben set with the motto of ‘digitalization' seems challenging to the Police.
5. Lack of outreach of resources: Though the State Government has prompted in allocating
resources and organizing training camps and other seminars to address the various challenges faced due to the new B.N.S, B.N.S.S. and B.S.A 2023, the fruits of these government initiatives did not percolate through the interiors of the Police Department. The remote areas seem to be deprived from these government allocated resources due to lack of accessibility.
6. Network Problem in remote areas: The Police Department sparks across every lane of the
country and includes the remote areas where there is hardly any network connection. There are areas where there is lack of internet connection or very poor tower signals, which are still not development. For instance the area of Kheerganga in Himachal Pradesh,
documents. Case References: In Reshma V. The Commissioner of Police, March 2024 where the allegation was against a police officer to have forcefully entered and searched the room of a pardanasheen women, The court observed that the police have the right to identify the face of a pardanashin person if required, but they must do so with the same dignity as they would with any other woman. The court also observed that faith-based directions cannot be issued by the court for police officers. In another case, Mariam Fasihuddin & Anr. V. State by Adugodi Police Station & Anr, 22nd January, 2024, the police faced the challenge of proving that the accused cheated someone and dishonestly induced them to deliver property. In T. R Shivaprasad V. State of Karnataka, 2024, the police yet again faced the challenge of treating a WhatsApp message as an F. I. R.
Thus, these were some of the challenges the police is navigating with.
4.2 Challenges faced by the Judiciary: Judiciary is that pillar of the Criminal Justice System,
which is entasked with the function of adjudication disputes. It is the paramount forum of law and also acts as a guardian of the Indian Constitution. However, with the advent of the new B.N.S, B.N.S.S and B.S.A 2023, the judiciary is facing the challenge of moulding itself into the shape of the new Criminal Laws.
1. Adopting would require time : The Indian Judiciary which had moulded itself in the shape
"If six Indian Law Commissions have spent 13 years creating an Indian law, which was subsequently passed by the Parliament of India (in 1973), the present law cannot by any stretch of imagination be called ‘colonial’ in its outlook," he underlined there.
3. Pending cases towering high: As a matter of fact, the Indian Judiciary is already burdened
with the load of cases pending to get justice. Considering the escalating population of India, the number of judges are very few. In India there are 25 High Courts and one Supreme Court. In total, there are 1122 Judges sanctioned, out of which 846 are permanent judges and 276 are additional judges. However, according to a recent report, there are 371 seals vacant which amounts to 33% of the seats remaining vacant. In such a situation, where the Indian Judiciary was already overburdened with the heap of files towering, the disadvantages of introducing the new law is that it adds all the more to the shares of troubles of the Indian Judiciary. Thus now, the Court is in suspended dilemma whether to deal with the pending cases according to the new law or according to the old classical laws in which the cases were registered.
4.3 Challenges faced by the Common person: “ Courts are guardian of Human Rights and
the common man look upon it as a protector.” – J.V.R.Krishna Iyer. From this above doctrine by J.V.R. Krishna Iyer, the significance of the common public in the Criminal Justice System is clear, which exists to protect and safeguard the interest of the common men. It is true that without them, our Judicial System cannot find its existence. Therefore the challenges faced by them need to be addressed as of paramount importance.
1. Inaccessibility: It is a fact that the new laws have been enacted to keep itself updated with
the technology. However, it is noted that with its several technological advancements , the law makers have made accessibility to law, even more difficult for the common people. When I say so, I intend to draw the attention not towards the legal provisions but towards the roads leading to the accessibility of the legal provision.
2. Too much technical: Our society comprises people of every strata, and just as our five
Imagine a Carteret Accountant living in Delhi, being violated of his rights and a not so educated daily labourer living in the interiors of Bengal, being aggrieved with a legal issue. Where the former can easily access the law and comply with the technicalities, the latter will be all the more miserable first having been aggrieved and then facing jargon of technicalities to access the law.
3. The jargonistic provision: Certain provision of The B.N.S.S,2023 instead of making the
law and its procedure simpler have made it all the more complicated rendering it little helpful for the people for whom the law has been implemented. Here, it is noteworthy to mention the futile update on Section 173 BNSS. Popularly known as Zero FIR, this section provides that any person who has reasoned ground to lodge an FIR in any Police Station, can now do so even without coming to the Police Station in person. However, as a mandate the person should come and sign the same FIR in person within 3 days. Now, this is where the concern lies. When I say so, I intend to highlight the gap that exists between the provision and its applications.
Investing a few minutes in understanding this provision would drive us to the confusion that little purpose does it serve as a facility of ‘distant FIR' when the validity of such FIR ceases if the complainant fails to come in person and sign the same in the Police Station within a period of three days from lodging the FIR. What purpose does it serve when the complainant has to come in person within three days to prevent the FIR from becoming invalid is a question that this provision poses. Therefore this provision is nothing but a jargon of law.
4. Too much room for interpretation: Since the new laws are at a nascent stage, and few are
Government for these competitive exams suggest little on the probability of these new laws being relevant for the present year aspirants of these Competitive examination. Thus, creating difficulty for such students.
5. Analysing the current situation- The post implementation scenario:
After the brainstorming implementations of The Bharatiya Nyaya Sanhita, the Bharatiya Nagarik Suraksha Sanghita and the Bharatiya Saksya Adhiniyam, we stand in a position where hardly any person is affluent with the newly welcomed guests. The three pillars of law – The Indian Penal Code, The Code of Criminal Procedure and The Indian Evidence Act that existed from the days of Lord Macaulay and Stephen, now stands renovated into a new structure that has reconstructed the Criminal Justice System. This not only accords a new shape to the Criminal Justice Syst3m but also certain ‘comfort ‘ to be made with the new laws. This suggests that the present situation is such that the Judges, the Legal Practitioners and the Students of law are at the same footing trying to imbibe the new laws in themselves.
The classical laws that prevailed since the 19th century cannot be so easily done sway with as the new laws, though updated, takes its its shape and colour from the classical statutes. Especially, The Indian Evidence Act 1872 drafted by Stephen remains almost untouched even today, except for section 65-B that provides the digital certificates. Though the Indian Penal Code 1860, faced certain changes in case of enhancing the punishments and introducing community services, The Bharatiya Nagarik Suraksha Sanghita is the one that got considerably better as it faced the maximum changes as compared to the other two statutes.
5.1 Combating this challenge- The way Forward: So long we have been discussing the
challenges faced and now we have reached the juncture where we find certain suggestions as to how to deal with them:
1. Proper Training needed: The application of the idea of the new laws now needs proper
training to be organized by the Government and legal institutions for an Orientation program to train the minds about the nitty-gritty of the new law.
2. Expert Guidance required: In certain cases of digital evidence specially the ones
involving the task of hash value , we need the guidance of a cyber expert to guide the
Police Department and other Executive wings of law to better adapt and implement the law.
3. Explanation in a simple manner: The technicalities of the new laws seem complex to us
when it comes to implementation. The only method to eradicate this is to get simplified explanation or a step by step guidance to apply these laws. The doctrines in various textbooks that existed as a guide book for the classical laws are no more in vogue. Therefore, the need of the hour is to contribute by books and articles offering and addressing these concerns.
4. Section 531(2)(a): The Savings and Repealing clause of the B.N.S.S. provides relief in
this situation as it clarifies that the cases registered and in trial before 1st July 2024 shall be dealt according to CRPC 1973 and the cases registered after 1st July 2024, shall be dealt in accordance with the B.N.S.S 2023. However, how the continuing offenses or the Res Gestae cases shall be dealt with is nowhere mentioned, which again constitutes a grey area of the new laws.
6. Conclusion:
Thus in the light of this context it is abundantly clear that the new laws that has repealed the classical laws is not only an attempt to lift the colonial hangover government but also a drive towards the Criminal Justice System, victim compensation, etc. However, where updating the code with the modern day by means of digitalization is one of the sole motto of repealing the old law, the very concept of Zero FIR enunciated in section 173 B. N. S. S (implemented after the case of Lalita Kumari V. The state of U. P and 3 Ors, 2014) seems underwhelming as it defeats the purpose of the provision when it mandates the complainant to physically come to the Police Station and sign within 3 days to validate the FIR lodged. This apart, the positive aspect is reflected in section 175 B. N. S. S where the S. P can deputes the D. SP for investigation of cases involving high profile people.
Section 187 B. N. S. S that has now given discretion to the police to exercise their power of Police Custody for 15 days spread across America of 60 days (for offenses punishable with
imprisonment under 10 years) and 90 days (for offenses punishable with imprisonment above
10 years) has restricted the gate for certain offenders to misuse the period of the first 15 days
to escape Police custody. So technically, we are shackled by the jargon of law. Though this has also led to dissenting arguments on the ground that this has restricted the scope of default bail, the conclusion can be drawn that with the advent of the new laws, India will experience a new dawn in the Criminal Justice System.
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