CHAPTER I

INTRODUCTION
The term public servant is of wider amplitude. It is a general term and includes all servants
employed in public services. The person employed in defence establishment or defence
services are all public servants. Article 309 uses the expression public servant. A law can
regulate the recruitment, and lay down conditions of service in public services and post in
connection with the affairs or the Union or any States. On the other hand, the term civil
servant means a member of civil service of the Union or a State or a person holding a civil
post under the Union or a State.
A public servant is generally a person who is employed by the government, either through
appointment or election. Examples include, among others, police officers, paid and volunteer
fire-fighters, health officers, the public works director and designees, city clerk and
designees, code enforcement personnel, and other city personnel authorized to enforce city
ordinances, statutes, and codes.
The following is one state's definition of a public servant:
Everyone who is a chief executive of, or a statutory officer or employee in, a Department in
the Public Service is a public servant. Contractors in a Department who are not employees are
not public servants. For the purposes of the Electoral Act, "public servant" is defined more
broadly, notably including a person employed in the Education Service as defined in the State
Sector Act.
First lets give the meaning of the words public and servant and see how they really
intertwine. Public, according to Webster, means "of people as a whole." Our next word
servant means, "A person devoted to another or to a cause." So basically a public servant is
one who is devoted to the entire community and doing what is the best for them. Now you
might be thinking that could be anyone but in reality it takes a special kind of person to fill
the shoes of a public servant. One of the few things that a public servant needs is humbleness.
If it is hard for you to help around the house for example, it is very doubtful that you would
be able to help someone else willingly. They can not be a person who puts themselves above
others. If this occurs the only desire to help will be out of pity.
The masterpiece work has been to deal with various legal, constitutional and fundamental
rights of a civil servant. But the picture would be incomplete without a statement of the
remedies available where such rights have been infringed. The general rule is that where there
is a right there is a remedy the maximum being ''ubi jus ibi remedium''. Hence the problem of
this branch of law requires besides an examination of the rights and obligations of the
Government and the civil servant a study of the remedies available to each party if the other
violates the obligations imposed on him. The enforcement of the formal rules of law on the
civil servant is comparatively easy because the Government being the pay-master and the
1

holder of the power of all grades of termination of employment upto dismissal can, generally
speaking act on its own. In India the powers of such Judicial Review has been
constitutionally mandated and expressly allowed through Article 32 before the Supreme
Court and under Article 226 in the respective High Courts. By virtue of such provision it is
considered that the judiciary is the safest possible safeguard, not only to ensure independence
of judiciary, but also in order to prevent it from the vagaries of the executives because the
judiciary corrects the executive abuse of power, or legislative excesses. Whenever an
aggrieved civil servant wants redress he has to seek the general remedies available to all
others and there exist no privileges or status in this regard. A civil servant is answerable for
his misconduct, which constitutes an offence against the state of which he is a servant and
also liable to be prosecuted for violating the law of the land. Apart from various offences
dealt with in the Indian Penal Code, Section 161 to 165 thereof, a civil servant is also liable to
be prosecuted under Section 5 of the Prevention of Corruption Act, 1947 (which is
promulgated specially to deal with the acts of corruption by public servants). A government
servant is not only liable to a departmental enquiry but also to prosecution. If prosecuted in a
criminal court, he is liable to be punished by way of imprisonment or fine or with both. But in
a departmental enquiry the highest penalty that could be imposed is dismissal. Therefore,
when a civil servant is guilty of misconduct which also amounts to an offence under the penal
law of the land the competent authority may either prosecute him in a court of law or subject
him to a departmental enquiry or subject him to both simultaneously or successively. A civil
servant has no right to say that because his conduct constitutes an offence, he should be
prosecuted nor to say that he should be dealt with in a departmental enquiry alone.
Public servant within the meaning of Section 2 of the Maharashtra Co-operative Societies
Act, 1960 is not a public servant within the meaning of Section 2 of the Prevention of
Corruption Act, 1947 by virtue of the provisions of Section 161 of the Maharashtra
Cooperative Societies act, 1960, read with Section 21 of the Indian Penal Code, 1860. It is
undoubtedly true that the Co- operative Societies Act has been enacted by the State
Legislature and their powers to make such Legislation is derived from Entry 32 of List II of
the Seventh Schedule to the constitution. The Legislature no doubt in Section 161 of the act
has referred to the provisions of Section 21 of the Indian Penal Code but such reference
would not make the Registrars and other Officers under Co operative Societies act public
servant within section 21 of the IPC.1

1 State of Maharashtra v. Laljit Rajshi Shah, (2000) 2 SCC 699 : AIR 2000 SC 97
2

Under the terms of Section 54 of the Income Tax Act, it is clear that the public servant
referred to is a public servant to whom disclosure has been made under the Income tax Act in
the case of Emperor v. Osman Chotani. 2 The words public servant in section 6 (1) mean a
person who is in service at the time when the court is called upon to take cognizance of the
offence, Section 6 (1) Bombay Land Requisition Act, 1946, section 6, has consequently on
application to the case of Public servant who is no longer in service as observed in State of
Bombay v. vVshwakant3. In Mahan Singh v. Rana Pratap 4, Section 42 (1) Punjab Gram
Panchayat Act, 1953 provides that no Panchayat shall take cognizance of any offence under
the Indian Penal code in which either the accused or the complainant is a public servant.
Under the definition Section 3 (1) a public servant includes a Panch and Sarpanch. It
follows from these provisions that no cognizance of any offence could be taken against
public servant after he had become a Panch and Sarpanch. The trial was not vitiated by the
election of one of the accused persons as a Panch after trial has commenced. The Sarpanch
and the Upasar- panch respectively, are deemed to be public servants by virtue of provisions
under Section 145 of the Hyderabad Gram Panchsayats Act, but Section 197, CrPC does not
afford protection to all public servants but only to certain category of public servants, namely,
including those who are not removable from office protected by or with the sanction of a
State Government or the Central Government as the case may be. Accordingly a Sarpanch or
as Upa- Sarpanch is not a public servant not removable from his office save by or with the
sanction of the State Government; nor is he a person employed in connection with the
officers of the State.5
The terms of Section 2 of the Prevention of Corruption Act, 1947 as substituted by section 3
of the Kerala Law Amendment act, 1962are absolutely clear and vivid and when they lay
down that the expression public servant shall have a special meaning for the purpose of the
act, that meaning must be given to the expression wherever it occurs in the act. For the
purpose of the act, surely means for the purposes of all and not only some of the provisions
of the Act. Section 2 of the said Act as substituted by the Kerala Act does not reproduce the
definition of the expression public servant as contained in section 161 of the Indian Penal
Code, but defines in so many words that the expression shall have the meaning assigned to t it
in the Explanation to the said Section 161. It follows that what is brought into Section 2 of
the 1947 act is that meaning of the expression as contained in the Explanation and not the
complete Explanation itself, so that the words for the purposes of this section and Sections
162, 163, 164, 165, and 165- A appearing in the Explanation are not transplanted into
2 (1942) 10 ITR 429 at 433.
3 AIR 1954 Bom 109 at p. 112: 22 Bom CrC 101
4 AIR 1960 Punj 160 at 161, 162 : ILR (1957) 1 Punj 687 : (1960) 61 CrLJ 400.
5 K. Narayana v. B. Veerayya, AIR 1959 AP 27 at 27, 28: (1958) 2 An WR 553 :
1958 An LT 731: 1958 MLJ Cr 897 : 60 (1959) CrLJ 21.
3

section 2 of the 1947 Act as substituted. The argument that the enlarged definition of the
expression public servant would not have been adopted in the form of the Explanation to
Section 161 of the Indian Penal Code but would have been added in Section 21 thereof if it
was to apply to the 1947 Act as a whole, though quite attractive at first sight, was hed to be
without any substance. The method adopted is not purposeless. Had the definition been
enhanced by an amendment of Section 21 of the code, it would have made the eight new
categories of persons brought by it within the ambit of the expression public servant liable
to punishment not only for offences under Section 161 to 165- A of the Indian Penal code but
also for many other offences as specified in the code relating to public servants, as also to
offences so related and created by other Acts wherein the definition of public servant
occurring in section 21 of the code has been adopted as such. It was expected to avoid such a
result and to limit the scope of the applicability of the definition to bribery, criminal
misconduct, and related offences committed by public servants that the legislature in its wits
adopted the device of amending Section 161 of the Code by adding the Explanation to it and
by providing also that the enlarged definition shall govern all the provisions of the 1947 Act.
Not finding any merit in the pleas raised on behalf of the appellants in M. K. Kochu Devassy
v. State of Kerala,6 it was held that the enlarged definition of the expression public servant
as contained in the Explanation added to Section 161 of the Indian Penal Code by Section 2
of the Kerala Criminal Law Amendment Act, 1962 controls all the provisions of the Act of
1947, that the appellants were public servants within the meaning of that enlarged definition
by reason of the language used in clause (iv) of the Explanation and that, therefore, the
offences under Clause (c) of sub- section (1) of Section 5 of the 1947 Act said to have been
committed by them were triable exclusively by Special Judges appointed under the Criminal
Law Amendment Act, 1952.
The Prevention of Corruption Act, 1947, Section 2 substantially incorporates the definition of
the words public servant of Section 21 of IPC. The words public servant denotes a person
falling under any of the descriptions, hereinafter following, namely..... Ninth. Every officer
whose duty it is, as such office to take, receive, keep or expend any property on behalf of (the
Government), or to make any survey, assessment or contract on the behalf of Government, or
to execute any revenue process, or to investigate, or to make, authenticate or keep any
document relating to the pecuniary interests of the Government, or to prevent the infraction
of any law of the protection of the pecuniary interests of the Government. Every officer in the
service or pay of the Crown or remunerated by fees on the commission for the performance
of public duty. Shiv Bahadur Singhs case 7, shows that every officer in the service or pay of
the Government is a public servant. In 1962, the Santhanam committee was constituted by the
Parliament which recommended changes in the definition of public servants in Section 21.8

6 (1979) 2 SCC 117 at pp. 122, 123, 124.

7 195 Cri L J 1480
4

The distinction drawn in that judgement between a body corporate and a corporation in
relation to a nationalised bank is a erroneous and that the view that a nationalised bank is not
a corporation could not be sustained. Thus, it now rests settled that the nationalised bank is a
corporation which is established by a Central act and is owned and controlled by the central
Government, atre the employees of Corporations which are owned and controlled by the
Cenral Government and are established by the Central act, public servant in Union of India
v. Ashok Kumar9.
In Institution of A. P. Lokayukta/ U. P. Lokayukta, A. P. V. T. Rama Subba Reddy10, it was
held that a chief Executive Officer appointed by Managing Committee in a Cooperative
Society is not a public servant. A person appointed as Business Manager not a member of
managing committee, is not a public servant. A person appointed as Doctor in the dispensary
run by corporation not in charge of Managing Committee is not a public servant. A person
appointed as Divisional Manager not in charge of Managing Committee and also not
connected with affairs of the state cannot be a public servant. Officers appointed in A. P. State
Road Transport Corporation or in registered cooperative societies not in connection with
affairs of the State Government, are not public servants.
It was observed in State of Maharashtra v. Prabhakarrao, 11 that although the definition of
public servant as given in IPC was adopted in Prevention of Corruption Act, 1947 but in
that Act the definite on of public servant is different and members of Co-operative Societies
are public servant.
Also, in Ram Avtar Shah v. State of Bihar12, it was held that a person doing survey work for
consolidation is a public servant.
In Union of India v. Ashok Kumar Mitra,13 it was observed by the Calcutta High Court that
the Branch Manager of Bank of India is not a public servant under Section 21 of IPC.

8 Nar Bahadur Bhandari v. State of Sikkim, 1996 CrLJ 341: (1996) 1 Cur Cri Rep
550 (Sik).
9 1995 CrLJ 3633 (SC)
10 1997 (9) SCC 42
11 2002 (2) JCC 1004 at 1006
12 2002 (2) BCCR 68 at p. 72
13 1995 Bank J. 560 (SC).
5

CHAPTER II
WHO FALLS WITHIN THE PERVIEW OF PUBLIC
SERVANT???

1. Whether a Member of Parliament is a "Public Servant"?

It is the crucial question agitating the mind of the general public in the country. The C.B.I
acting under the supervision of the Supreme Court of India has filed charge sheets against
several politicians for offences allegedly committed by them as members of the Parliament
perhaps believing that though they are covered by the definition of 'Public Servants' and
hence liable to be prosecuted under the Prevention of Corruption Act1988, no sanction for
their prosecution is necessary as Section 19 of the Act does not prescribe any competent
authority for the purpose. This was also the view of the Orissa High Court in Habibullah
Khan v. State of Orissa wherein it was held that a MLA is a public servant under clause (viii)
of the sec.2(c) of the Act but no sanction for his prosecution is necessary as Sec. 19 does not
prescribe any competent authority for the purpose. Though the petitioner preferred appeal
against this judgement in the Supreme Court, the court upheld the prosecution holding the
petitioner was being prosecuted for offences committed as a 'Minister' which office he has
ceased to hold. In view of this decision, the question posed above remains alive needing
detailed consideration.
In P. V. Narsimha Rao v. State (CBI/SPF) 14 a five- judge Bench of the Supreme Court by 3:2
majority has held that the scope of protection of immunity available to the Members of
Parliament is quite wide and is not confined only against judicial proceedings but is available
to them against all civil action and criminal proceedings for anything said or any vote given
14 AIR 1998 SC 2120
6

by them in the House of Parliament. The object of the protection is to enable members to
speak their mind in Parliament freely and fearlessly. The Court held that MPs who had taken
bribe and voted in Parliament against no confidence motion brought against the Narsimha
Rao Government are entitled to the protection of Article 105 (2) and are not answerable in a
court of law for alleged conspiracy and agreement. But the MPs who had given bribe but not
voted on the no- confidence motion are not entitled to the protection of Article 105 (2) and an
action can be initiated against them under the relevant law. In this case, a very important issue
arose before the court of law that whether a Member of Parliament is a Public Servant?
As regards to this question, the Supreme Court held that the Members of Parliament holds an
office and discharges public duties and therefore under Section 2 of the Prevention of
Corruption Act, 1988; is a public servant.
2. Whether Ministers are Public servant?
In M. Karunanidhi v. Union of India15, the question raised before the Supreme Court was
whether a Chief Minister or a Minister was a public servant within the meaning of Section 21
(12) of Indian Penal Code. The Court held that the first part of Section 21 (12) of IPC
signifies a relationship of master and servant and not applicable to a Chief Minister. But the
second part of Section 21 (12) namely, in the pay of the Government is of much wider
amplitude so as to include within its ambit to even public servant who may not be a regular
employee receiving salary from his master. A Chief Minister or a Minister is a public servant
within the meaning but upheld the validity of the settlement of Section 21 (12) of the IPC and
therefore can be prosecuted and no prior sanction of the Governor is necessary.

3. Is the Chief Justice of India a public servant?

Chief Justice of India K G Balakrishnan's contention that the CJI was not a public servant but
a constitutional authority flies in the face of a 1991 ruling by a five-judge Bench of the
Supreme Court which held that all judges of the apex court and high courts were "public
servants". Justice Balakrishnan recently said, "The Chief Justice is not a public servant. He is
a constitutional authority. RTI does not cover constitutional authorities." This assertion
appears contrary to the ruling of the five-judge Bench, which by a 4:1 majority, held that "a
judge of the high court or the Supreme Court is a 'public servant' within the meaning of
Section 2 of the Prevention of Corruption Act". The RTI Act had not been conceived at that
time and the SC could not debate whether a person categorised as public servant under PC
Act would retain his classification under the RTI Act. In the judgment given on July 25,
1991, the apex court had rejected the plea of a former HC chief justice, K Veeraswamy,
seeking quashing of criminal proceedings initiated against him by the CBI for accumulating
disproportionate assets during his tenure as CJ. Justices K J Shetty, B C Ray, L M Sharma
and M N Venkatachalliah unanimously came to the conclusion that all judges of the superior
courts were "public servants". Justice J S Verma dissented. "A judge or chief justice of a high
15 AIR 1979 SC 899
7

court is a constitutional functionary, even though he holds a public office and in that sense, he
may be included in the wide definition of a public servant." He said that as there was no
authority nominated in the PC Act to sanction prosecution of SC and HC judges, they could
not be classified as public servants under the anti-corruption law. The majority did not agree
with Justice Verma. They said for sanctioning prosecution of a judge of the Supreme Court or
high court in a corruption case, the President would be the competent authority, though no
criminal case would be registered without first consulting the chief justice of the court where
the judge was working.
"If the Chief Justice of India himself is the person against whom allegations of criminal
misconduct are received, the government shall consult any other judge or judges of the
Supreme Court," the majority verdict said.
Duties of Public servantIt is the duty of all public servants to ensure that the public's money is spent as efficiently as
possible and that programs are provided effectively, without discrimination or prejudice, with
transparency and without waste of money or resources. Most public servants work in the
administrative functions related to public service program provision. This may include:
managing and administering budgets; processing applications for federal benefits such as
Social Security, Medicaid and disability; monitoring pollution with the Environmental
Protection Agency; providing military veterans with services and benefits; providing ranger
services at national parks; advising the public on housing options; helping the unemployed
find employment; and providing front-of-office services to the public at agency offices
throughout the country.

CHAPTER III
LEGISLATIVE PROVISIONS

Section 21 of the Indian Penal Code describes Public Servant as-

21. "Public Servant"

The words "public servant" denote a person falling under any of the descriptions hereinafter
following; namely:
Second Every Commissioned Officer in the Military, Naval or Air
Forces of India;
Third Every Judge including any person empowered by law to discharge, whether by
himself or as a member of any body of persons, any adjudicatory functions;
Fourth Every officer of a Court of Justice (including a liquidator, receiver or
commissioner) whose duty it is as such officer, to investigate or report on any matter of law
or fact, or to make, authenticate, or keep any document, or to take charge or dispose of any
property, or to execute any judicial process, or to administer any oath, or to interpret, or to
preserve order in the Court, and every person specially authorized by a Court of Justice to
perform any of such duties;
Fifth Every juryman, assessor, or member of a panchayat assisting a
Court of Justice or public servant;
Sixth Every arbitrator or other person to whom any cause or matter has been referred for
decision or report by any Court of Justice, or by any other competent public authority;
Seventh Every person who holds any office by virtue of which he is empowered to place
or keep any person in confinement;
Eighth Every officer of the Government whose duty it is, as such officer, to prevent
offences, to give information of offences, to bring offenders to justice, or to protect the public
health, safety or convenience;
Ninth Every officer whose duty it is, as such officer, to take, receive, keep or expend any
property on behalf of the Government, or to make any survey, assessment or contract on
behalf of the Government, or to execute any revenue process, or to investigate, or to report,
on any matter affecting the pecuniary interests of the Government, or to make, authenticate or
9

keep any document relating to the pecuniary interests of the Government, or to prevent the
infraction of any law for the protection of the pecuniary interests of the Government ;
Tenth Every officer whose duty it is, as such officer, to take, receive, keep or expend any
property, to make any survey or assessment or to levy any rate or tax for any secular common
purpose of any village, town or district, or to make, authenticate or keep any document for
the ascertaining of the rights of the people of any village, town or district;
Eleventh Every person who holds any office in virtue of which he is empowered to
prepare, publish, maintain or revise an electoral roll or to conduct an election or part of an
election;
Twelfth Every person
(a) In the service or pay of the Government or remunerated by fees or commission for the
performance of any public duty by the
Government;
(b) In the service or pay of a local authority, a corporation established by or under a Central,
Provincial or State Act or a Government company as defined in section 617 of the Companies
Act, 1956 (1 of 1956).

Article 309 of the Constitution reads as follows: -

"309. Recruitment and Conditions of Service of Person Serving the Union or a State
"Subject to the provisions of this Constitution, Act of the appropriate Legislature may
regulate the recruitment, and conditions of service of person appointed to public services and
posts in connection with the affairs of the Union or of any State:
"Provided that it shall be competent for the President or such person as he may direct in the
case of services and posts in connection with the affairs of the Union, and for the Governor of
the State or such person as he may direct in the case of services and posts in connection with
the affairs of the State, to make rules regulating the recruitment, and the conditions of service
of persons appointed, to such services and posts until provision in that behalf is made by or
under an Act of the appropriate Legislature under this article, and any rules so made shall
have effect subject to the provisions of any such Act".

Section 2 (c) of the Prevention of Corruption Act, 1988, defines the public
servant as under:-

i) Any person in the service or pay of the Government or remunerated by the Government by
fees
or
commission
for
the
performance
of
any
public
duty;
ii) Any person
in
the
service
or
pay of
a
local
authority;
iii) Any person in the service or pay of a corporation established by or under a Central,
Provincial or State Act, or an authority or a body owned or controlled or aided by the
Government or a Government company as defined in section 617 of the Companies Act,
10

1956;
iv) Any judge, including any person empowered by law to discharge, whether by himself or
as a member of any body of persons, any adjudicator functions;
v) Any person authorised by a court of justice to perform any duty, in connection with the
administration of justice, including a liquidator, receiver of commissioner appointed by such
court;
vi) Any arbitrator or other person to whom any cause or matter has been referred for decision
or report by a court of justice or by a competent public authority;
vii) Any person who holds an office by virtue of which he is empowered to prepare, publish,
maintain or revise an electoral roll or to conduct an election or part of an election;
viii) Any person who holds an office by virtue of which he is authorised or required to
perform
any
public
duty;
ix) Any person who is the president, secretary or other office-bearer of a registered cooperative society engaged in agriculture, industry, trade or banking, receiving or having
received any financial aid from the Central Government or a State Government or from any
corporation established by or under a Central, Provincial or State Act, or any authority or
body owned or controlled or aided by the Government or a Government company as defined
in
section
617
of
the
Companies
Act,
1956;
x) Any person who is a chairman, member of employee of any Service Commission or Board,
by whatever name called, or a member of any selection committee appointed by such
Commission or Board for the conduct of any examination or making any selection on behalf
of
such
Commission
or
Board;
xi) Any person who is a vice-chancellor or member of any governing body, professor, reader,
lecturer or any other teacher or employee, by whatever designation called, of any University
and any person whose services have been availed of by a University or any other public
authority
in
connection
with
holding
or
conducting
examinations;
xii) Any person who is an office-bearer or an employee of an educational, scientific, social,
cultural or other institution, in whatever manner established, receiving or having received any
financial assistance from the Central Government or any State Government, or local or other
public
authority;
Explanation 1 - Persons falling under any of the above sub-clauses are public servants,
whether
appointed
by
the
Government
or
not.
Explanation 2 - wherever the words .Public Servant occur, they shall be understood of every
person who is in actual possession of the situation of a public servant, whatever legal defect
there may be in his right to hold that situation.

11

CHAPTER IV
JUDICIAL ANALYSIS
1. S. S. Dhanoa v. Delhi Municipality16
It was held in this case that a member of the Indian Administrative service working on
deputation with a co-operative society registered under Co-operative Societies Act is
not a public servant for the purposes of Section 197 of CrPC because during this
period he was not in the service or pay of the Government, nor was he in service of a
local authority, a corporation established by or under an Act or a Government
Company.
2. Dattatraya v. State of Maharashtra17
It was observed that any person who was not a public servant appointed as a chairman
of the District advisory Committee may not be a public servant because the office of
chairman of committee is not such that would make him a public servant. But the
position would be different when he, under the instructions issued by the Government
in exercise of its executive power which is co- extensive with the legislative power of
the State, is appointed the chairman of the committee. Therefore, where a Minister is
asked by the Government notification to preside over the meeting of the District
Advisory Committee constituted under such notification, he was discharging his duty
as a public servant. Here the Minister is a public servant.
3. R. S. Nayak v. A. R. Antulay18
It was held by the Humble Apex Court in this case that looking to the history of
section 21 of IPC, it is clear that till 1964 M.L.A. could not be comprehended in the
expression public servant. The Santhanam Committee did not recommend its
inclusion in the definition of a public servant. The amendment of the year 1964 also
did not bring any change in the position. So, M.L.A is not a public servant.
4. A. R. Puri v. State19
16 1981 Cri. L. J. 871 (SC)
17 1975 Cri. L. J. 1490 (SC)
18 1984 Cri. L. J. 613 (SC)
19 1988 Cri. L. J. 311 (Delhi)
12

It was held that an Insurance surveyor holding a licence issued by the Controller of
Insurance appointed by an insurance company to survey and assess the loss of the
insurance claimant is not on the staff of the insurance company. He does not perform
ay duty assigned by the Central or State Government. He receives his remuneration in
the form of his professional charges on contract basis from the insurance company
depending on the nature of the claim and the work involved. On these facts i was held
that his position was that of a contractor and a mere contractor will not be a public
servant although his contract may be with the Government and he is paid on a
commission basis.

CHAPTER V
CONCLUSION

13

ANNEXURE

1.
2.
3.
4.
5.
6.

The Constitutional Law of India - Dr. J. N. Pandey

The Constitutional Law of India
- Durga Das Basu
The Constitution of India
- N. K. Acharya
The Constitution of India
- P. M. Bakshi
Constitutional Law of India
- V. N. Shukla
Judicial Officer Law Lexicon
- Justice C. K. Thakkar

7. www.wikipedia.org/
8. www.manupatra.com
9. www.indiankanoon.org

14