Evidence law

A PROJECT REPORT ON THE TOPIC

Accomplice evidence

[Sections 10, 30, 114(B), 118,

133]

SUBMITTED TO: SUBMITTED BY:

MRS. SABINA SALIM DHRUVAL RANA
137/14
B. COM. LLB
 EVIDENCE LAW

ACKNOWLEDGEMENT

I take this opportunity to express my profound gratitude and deep regards to my guide Mrs.
Sabina Salim for her exemplary guidance, monitoring and constant encouragement throughout
the course of this project. The blessing, help and guidance given by her time to time shall carry
me a long way in the journey of life on which I am about to embark.

I also take this opportunity to express a deep sense of gratitude to the librarian staff, for their
cordial support, valuable information and guidance, which helped me in completing this task
through various stages.

Lastly, I thank almighty, my parents, brother, sisters and friends for their constant
encouragement without which this assignment would not be possible.

ACCOMPLICE EVIDENCE Page 2

 EVIDENCE LAW

TABLE OF CASES

NAME OF THE CASE CITATION PAGE NO

Ambar Ali v. Lutfe Ali AIR 1918 Cal 971 12

Badri Rai v. State AIR 1958 SC 953 9

Dagdu v. State of Maharashtra 1977 AIR 1579 14

Government of NCT of Delhi v. Jaspal Singh (2003) 10 SCC 586 10

Harihar Mohapatr v. Nabakishore Mohapatra AIR 1963 Ori 45 12

Jaganath v. Emperor AIR 1942 Oudh 221 6

Kashmira Singh v. State of MP AIR 1957 SC 54 11

Narain Chandra Biswas v. Emperor, AIR 1936 Cal 101 7

R v. Baskerville (1916)2 KB 658 16

R.K Dalmia v. Delhi Administration AIR 1962 SC 1821 6

Rameshwar v. The State Of Rajasthan 1952 AIR 54 15

Sarwan Singh v. State of Punjab AIR 1957 SC 637 16

State of Tamil Nadu v. Nalini AIR 1999 SC 2640 10

ACCOMPLICE EVIDENCE Page 3

 EVIDENCE LAW

TABLE OF CONTENTS

CONTENT PAGE NO
Introduction 5

Accomplice Evidence Diagram

Who Is An Accomplice 6

Accomplice Under English Law 7

Categories of Accomplice

Need For Accomplice Evidence: A Necessary Evil 8

Relevancy Of Accomplice Evidence 9-12

Statements Made By The Co Conspirators

Confession Made By The Co Accused In A Joint Trial

Difference Between Civil Law And Criminal Law 13

Competency Of Accomplice As Witness 14-16

Accomplice: A Competent Witness Under Section 118

Relation Between Section 114 And 133 17

Rule Regarding Corroboration: Rule Of Prudence 18-19

Assessment And Appreciation Of Accomplice Evidence

Nature Of Corroboration

ACCOMPLICE EVIDENCE Page 4

 EVIDENCE LAW

Conclusion 20

Bibliography 21

ACCOMPLICE EVIDENCE Page 5

 EVIDENCE LAW

INTRODUCTION

Section 133 of the Indian Evidence Act, 1872 1 is the only absolute rule of law dealing with
accomplice evidence.2 However it is the opinion of some that this section is redundant as Section
118 makes all persons competent to testify except those persons which the section specifically
bars. Moreover there is no rule which requires that the evidence of an accomplice should be
corroborated. But Section 133 might lead persons to suppose that the Legislature desired to
encourage convictions on the uncorroborated evidence of an accomplice. This interpretation
however cannot hold good in light of Section 114 (b) which lays down the presumption that an
accomplice is unworthy of credit unless he is corroborated in material particulars. Thus owing to
this conflict between Section 114(b) and Section 133 some experts feel that Section 133 should
have been omitted and the law relating to accomplice evidence would have been the same as it is
now and the awkwardness of appearing to sanction a practice so universally condemned would
have been avoided.3

However the Courts have resolved this apparent conflict between the two sections by
harmoniously reading Sections 114(b) and 133 together and held that while it is not illegal to act
upon the uncorroborated testimony of an accomplice it is a rule of prudence so universally
followed so as to amount almost to a rule of law that it is unsafe to act upon the evidence of an
accomplice unless it is corroborated in material respects so as to implicate the accused. 4 This in a
nutshell is the core of accomplice evidence and must be kept in mind at all times while dealing
with the subject of accomplice evidence.

1
Section 133- An accomplice shall be a competent witness against an accused person; and a conviction is not illegal
merely because it proceeds upon the uncorroborated testimony of an accomplice.
2
The procedural aspects relating to Accomplice Evidence are dealt with in Sections 306-308 and 315 of the Code of
Criminal Procedure, 1973.
3
B. Malik et al., Law of Evidence- Volume V (Allahabad: Law Publishers India Private Limited, 1990)at 4651.
4
Ibid at 4652.

ACCOMPLICE EVIDENCE Page 6

 EVIDENCE LAW
COMPETENT
ACCOMPLICE EVIDENCE WITNESS under
Section 188

BY PASSING THE
TEST
MADE SUBSTANTIVE
PIECE OF
RELEVEANT
EVDENCE

SECTION 114
Illustration (b)
SECTION 10 AND SECTION 133
30

Statements made by co
conspirators are relevant
against the other
conspirator
Even on the
An accomplice is uncorroborated
unworthy of credit. His testimony of the
evidence needs accomplice conviction
corroboration. can be based, if the test
of S 114 (b) satisfies

ACCOMPLICE EVIDENCE Page 7

 EVIDENCE LAW

WHO IS AN ACCOMPLICE

It is extremely important to und erstand what the term accomplice means and signifies as to
attract Section 133 a person must be an accomplice.

The word accomplice has not been defined by the Indian Evidence Act, 1872 and should
therefore be presumed to have been used in the ordinary sense by the legislature. However the
judiciary has dealt with this issue extensively and has tried to explain comprehensively as to who
an accomplice is.

An accomplice is one concerned with another or others in the commission of a crime or one who
knowingly or voluntarily cooperates with and helps others in the commission of crime.5

It was held in R.K Dalmia v. Delhi Administration 6 that an accomplice is a person who
participates in the commission of the actual crime charged against an accused. He is to be a
particeps criminis. There are two cases however, in which a person has been held to be an
accomplice even if he is not a particeps criminis. Receivers of stolen property are taken to be
accomplices of the thieves from whom they receive goods in a trial for theft. Accomplices in
previous similar offences committed by the accused on trial are deemed to be accomplices in the
offence for which the accused is on trial, when evidence of the accused having committed crimes
of identical type on other occasions be admissible to prove the system and intent of the accused
in committing the offence charged.

The Court in Jaganath v. Emperor7 explained that an accomplice is a guilty associate or partner
in crime, or who in some way or the other is connected with the offence in question or who
makes admissions of facts showing that he had a conscious hand in the offence.8

5
M.L Singhal, Sir John Woodroffe and Syed Amir Ali, Law of Evidence- Volume IV (Allahabad: Law Book
Company Private Limited, 1993)at 512.
6
AIR 1962 SC 1821.
7
AIR 1942 Oudh 221.
8
An accomplice is also a person who is a guilty associate in crime or who sustains such a relation to the criminal act
that he can be jointly indicted with the defendant (principal).

ACCOMPLICE EVIDENCE Page 8

 EVIDENCE LAW

ACCOMPLICE UNDER ENGLISH LAW

In order to be an accomplice a person must participate in the commission of the same crime as
the accused and this he may do in various ways. In English law the modes of complicity with
crime are treated under the heads of principals in the first degree or second degree and
accessories before or after the fact.

Categories of Accomplice :

A principal of the first degree is one who actually commits the crime;
A principal of the second degree is a person who is present and assists in the
perpetration of the crime;
An accessory before the fact is one who counsels, incites, connives at encourages or
procures the commission of a crime and
An accessory after the fact to a felony who, knowing a felony to have been committed
by another, receives, comforts or assists him in order to enable him to escape from
punishment or rescues him from arrest for the felony or having him in custody for the
felony allows him to escape or opposes his arrest.

It is to be noted that a married woman who receives, comforts, or relieves her husband knowing
him to have committed a felony does not thereby become an accessory after the fact.

In English Law the term accomplice in its fullness includes in its meaning all the persons
concerned in the commission of the crime-principals of the first degree, second degree and
accessories before and after the fact.

In India all accessories before the fact if the participate in the preparation for the crime are
accomplices but if their participation is limited to the knowledge that crime is to be committed
they are not accomplices.9

9
Narain Chandra Biswas v. Emperor, AIR 1936 Cal 101.

ACCOMPLICE EVIDENCE Page 9

 EVIDENCE LAW

NEED FOR ACCOMPLICE EVIDENCE: A NECESSARY EVIL

Usually most of the crimes are committed at secluded places where there will not be any eye
witness to testify regard to these offences, and it would not be possible for the police to get
sufficient evidence to prove the guilt of the accused. In such cases what police does is that it
picks up one of the suspects arrested who is usually least guilty and offers to him an assurance
that if he is inclined to divulge all information relating to the commission of the crime and give
evidence against his own colleagues, he will be pardoned. So any such person who is picked up
or who is taken by the police for the purpose of giving evidence against his own colleagues is
known as an accomplice or an approver.

ACCOMPLICE EVIDENCE Page 10

 EVIDENCE LAW

RELEVANCY OF ACCOMPLICE EVIDENCE

The evidence given by an accomplice under criminal law is made under section 10 and section
30 of the Indian evidence act

STATEMENTS MADE BY THE CO CONSPIRATORS

Under Section 10, where there is reasonable ground to believe that two or more person have
conspired together to commit an offence or an actionable wrong, anything said, done, or written
by any one of such person in reference to their common intention, after the time when such
intention was first entertained by any one of them, is a relevant fact as against each of the person
believed to be so conspiring, as well for the purpose of proving the existence of the conspiracy as
for the purpose of showing that any such person was a party to it.

This section is based on the theory of implied agency. So the things said or done by one
conspirator are admissible against the other if they relate to the conspiracy.

The general principal is that no person can be made liable for the acts of another except in cases
of abetment in criminal proceeding and contract of agency in civil proceeding. But in conspiracy
the persons who take part in conspiracy are deemed to be the mutual agent or confederates for
the purpose of the executive of the joint purpose.

In Badri Rai v. State10, it has been held that section 10 of the evidence act has been deliberately
in order to make such acts or statements of the co-conspirator admissible against the whole body
of conspirators, because of the nature of the crime. A conspiracy is hatched in secrecy, and
executed in darkness. Naturally, therefore it is not feasible for the prosecution to connect each
isolated act or statement of one accused with the acts or statement of the others, unless there is
common bound linking all of them together.

Requirements of Section 10:

1. Existence of the conspiracy: The operation of S10 is strictly conditional upon being
reasonable ground to believe that two or more persons have conspired together.

10
AIR 1958 SC 953

ACCOMPLICE EVIDENCE Page 11

 EVIDENCE LAW

In Government of NCT of Delhi v. Jaspal Singh11, it has been held that once there is sufficient
material to reasonable believe that there was concert and connection between persons charged
with a common design, it is immaterial whether they were strangers to each other, or ignorant of
actual role of each of them or they did not perform any one or more of such acts by joint efforts.
It is not necessary that all should have joined in the scheme from the first; those who come in at
later stage are equally guilty, provided the agreement is proved.

2. Things said, done, or written in reference to their common intention:

If the things are said, done, or written in reference to the common intention of the conspiracy
then only the things said, done, or written will be admissible in the court of law. But if anything
said, done, or written by any fellow conspirator after the conspiracy no longer exist and had
ended or ceased to exist, it will be inadmissible against other

3. Admissions of Evidences related to acts outside the period of conspiracy:

This is very clear with the bare text of S.10 that the things said, done, or written will be relevant
only then when such intention was first entertain by any one party to the conspiracy. Again the
thing is necessary to remember that the things said, done, or written is not relevant when the
conspiracy is over.

In the case State of Tamil Nadu v. Nalini12, it has been held that once it is shown that a person
snapped out of conspiracy, any statement made subsequently thereto cannot be used against other
conspirator under section 10 of Evidence Act.

CONFESSION MADE BY THE CO ACCUSED IN A JOINT TRIAL

Under Section 30, when more persons than one are jointly tried for the same offence, the
confession made by one of them, if admissible in evidence, should be taken into consideration
against all the accused, and not against the person who alone made it. It appears to be very
strange that the confession of one person is to be taken into consideration against another. Where

11
(2003) 10 SCC 586
12
AIR 1999 SC 2640

ACCOMPLICE EVIDENCE Page 12

 EVIDENCE LAW

the confession of one accused is proved at the trial, the other accused persons have no other
opportunity to cross examine him. It is opposed to the principle of jurisprudence to use a
statement against a person without giving him the opportunity to cross examine the person
making the statement. This section is an exception to the rule that the confession of one person is
entirely admissible against the other.

In Kashmira Singh v. State of MP , the accused kashmira who was an assistant food
procurement inspector, his services along with the another food inspector were terminated on a
report of the food officer when they were getting the rice polished in a rice mill. Kashmira was
heard twice saying that he would teach a lesson to the food officer. After a few months the son of
the food officer was found missing and his body was found in a well. Kashmira, gurudayal
brother of kashmira, prithipal son of gurudayal and one gurubachan, a rickshaw puller in this
case were tried of conspiracy and killing the child. The prosecution story was that prirthipal led
the child, when he was playing near the gurudwara, for some distance and then the child was
taken on the cycle by kashmira to a house where he was murdered. According to the judgment of
the sc guruibachan was not a rickshaw puller by profession and the rickshaw was hired only for
that night for the disposal of the body of the deceased.

Hence before the confession of one accused may be taken into consideration against others, it has
to be shown that:

1. the person confessing and the others are being tried jointly.
2. they are being tried for the same offence.
3. the confession is affecting the confessioner and the others.

ACCOMPLICE EVIDENCE Page 13

 EVIDENCE LAW

DIFFERENCE BETWEEN CIVIL LAW AND CRIMINAL LAW

Statement whether admission or confession made by a co plaintiff or co defendant or co

respondent is not made admissible against the other plaintiff, defendant or appellant under civil
law. Whereas the law is different under criminal law, any statement made by a co accused is
made relevant and admissible against the other accused under section 10 and 30 of Indian
Evidence Act.

Observed in the case of Harihar Rajguru Mohapatr v. Nabakishore Rajaguru Mohapatra13and

Reiterated in the case of Ambar Ali v. Lutfe Ali14

The admission of one co-plaintiff or co-defendant is not receivable against another, merely by
virtus of his position as a co-party in the litigation; if the rule were otherwise, it would in practice
permit a litigant to discredit an opponent's claim merely by joining any person as the opponent's
co-party, and then employing that person's statement as admissions. Consequently, it is not by
virtue of the person's relation to the litigation that the admission of one can be used against the
other; it must be, because of some privity of title or of obligation".

13
AIR 1963 Ori 45
14
AIR 1918 Cal 971

ACCOMPLICE EVIDENCE Page 14

 EVIDENCE LAW

COMPETENCY OF ACCOMPLICE AS WITNESS

An accomplice is a competent witness provided he is not a co accused under trial in the same
case. But such competency which has been conferred on him by a process of law does not divest
him of the character of an accused. An accomplice by accepting a pardon under Section 306
CrPC becomes a competent witness and may as any other witnesses be examined on oath; the
prosecution must be withdrawn and the accused formally discharged under Section 321 CrPC
before he can become a competent witness.

Even if there is an omission to record discharge an accused becomes a competent witness on

withdrawal of prosecution. Under Article 20(3) of the Constitution of India, 1950 no accused
shall be compelled to be a witness against himself. But as an accomplice accepts a pardon of his
free will on condition of a true disclosure, in his own interest and is not compelled to give self-
incriminating evidence the law in Sections 306 and 308, Code of Criminal Procedure is not
affected.

So a pardoned accused is bound to make a full disclosure and on his failure to do so he may be
tried of the offence originally charged and his statement may be used against him under Section
308.

ACCOMPLICE: A COMPETENT WITNESS UNDER SECTION 118

Section 118 of the Indian Evidence Act says about competency of witness. Competency is a
condition precedent for examining a person as witness and the sole test of competency laid down
is that the witness should not be prevented from understanding the questions posed to him or
from giving rational answers expected out of him by his age, his mental and physical state or
disease. At the same time Section 133 describes about competency of accomplices. In case of
accomplice witnesses, he should not be a co-accused under trial in the same case and may be
examined on oath.

ACCOMPLICE EVIDENCE Page 15

 EVIDENCE LAW

RELATION BETWEEN SECTION 114 AND 133

These are the two provisions dealing with the same subject. Section 114 of the Indian Evidence
Act says that the court may presume that an accomplice is unworthy of any credit unless
corroborated in material particulars.

Section 133 of the Indian Evidence Act says that an accomplice shall be a competent witness as
against the accused person and a conviction the accused based on the testimony of an accomplice
is valid even though it is not corroborated in material particulars.

The law was laid down in the case of Dagdu V. State of Maharashtra15

There is no. antithesis between s. 133 and illustration (b) to s.114 of the Evidence Act, because
the illustration only says that the Court 'may' presume a certain state of affairs. It does not seek to
raise a conclusive and irrebutable presumption. Reading the two together the position which
emerges is that though an accomplice is a competent witness and though a conviction may
lawfully rest upon his uncorroborated testimony, yet the Court is entitled to presume and may
indeed be justified in presuming in the generality of cases that no reliance can be placed on the
evidence of an accomplice unless that evidence is corroborated in material particulars, by which
is meant that there has to be some independent evidence tending to incriminate, the particular
accused in the commission of the crime.

15
1977 AIR 1579

ACCOMPLICE EVIDENCE Page 16

 EVIDENCE LAW

RULE REGARDING CORROBORATION: RULE OF PRUDENCE

Reading Section 133 of the Evidence Act along with Section 114(b) it is clear that the most
important issue with respect to accomplice evidence is that of corroboration. The general rule
regarding corroboration that has emerged is not a rule of law but merely a rule of practice which
has acquired the force of rule of law in both India and England.

The rule states that: A conviction based on the uncorroborated testimony of an accomplice is not
illegal but according to prudence it is not safe to rely upon uncorroborated evidence of an
accomplice and thus judges and juries must exercise extreme caution and care while considering
uncorroborated accomplice evidence.

Thus the Supreme Court laid down the principle in the case of Rameshwar v. The State Of
Rajasthan16

the rule which according to the cases has hardened into one of law is not that corroboration is
essential before there can be a conviction but that the necessity of corroboration as a matter of
prudence except where the circumstances make it safe to dispense with it must be present to the
mind of the judgebefore a conviction without corroboration can be sustained. The court also
made it clear that the corroboration should be such so as to render the prosecution story reliable
and safe to act upon

An approver on his own admission is a criminal and a man of the very lowest character who has
thrown to the wolves his erstwhile associates and friends in order to save his own skin. His
evidence, therefore must be received with the greatest caution if not suspicion. Accomplice
evidence is held untrustworthy and therefore should be corroborated for the following reasons:

An accomplice is likely to swear falsely in order to shift the guilt from himself.
An accomplice is a participator in crime and thus an immoral person.

16
1952 AIR 54

ACCOMPLICE EVIDENCE Page 17

 EVIDENCE LAW

An accomplice gives his evidence under a promise of pardon or in the expectation of an

implied pardon, if he discloses all he knows against those with whom he acted criminally,
and this hope would lead him to favour the prosecution.

The nature and extent of corroboration must necessarily vary with the circumstances of each case
and it is not possible to enunciate any hard and fast rule. But the guiding rules laid down in R v.
Baskerville17 are clear and beyond controversy. They are:

It is not necessary that there should be independent confirmation in every detail of the
crime related by the accomplice. It is sufficient if there is a confirmation as to a material
circumstance of the crime.
The confirmation by independent evidence must be of the identity of the accused in
relation to the crime, ie. confirmation in some fact which goes to fix the guilt of the
particular person charged by connecting or tending to connect him with the crime. In
other words, there must be confirmation in some material particular that not only has the
crime been committed but that the accused committed it.
The corroboration must be by independent testimony that is by some evidence other than
that of the accomplice and therefore one accomplice cannot corroborate the other.
The corroboration need not be by direct evidence that the accused committed the crime, it
may be circumstantial.

These rules have been restated by the Supreme Court of India with the declaration that the law is
exactly the same in India.

ASSESSMENT AND APPRECIATION OF ACCOMPLICE EVIDENCE

The Supreme Court in Sarwan Singh v. State of Punjab18 laid down the law with respect to
assessment and appreciation of accomplice evidence and also stated several principles and rules
regarding corroboration of accomplice evidence.

17
(1916)2 KB 658
18
AIR 1957 SC 637

ACCOMPLICE EVIDENCE Page 18

 EVIDENCE LAW

The Court stated: The problem posed by the evidence given by an approver has been considered
by the Privy Council and Courts in India on several occasions. It is hardly necessary to deal at
length with the true legal position in this matter. An accomplice is undoubtedly a competent
witness under the Indian Evidence Act. There can be, however, no doubt that the very fact that
he has participated in the commission of the offence introduces a serious stain on and Courts are
naturally reluctant to act on such tainted evidence unless it is corroborated in material particulars
by other independent evidence. It would not be right to expect that such independent
corroboration should cover the whole of the prosecution story or even all the material particulars.
If such a view is adopted it would render the evidence of the accomplice wholly superfluous.

On the other hand it would not be safe to act upon such evidence merely because it is
corroborated in minor particulars or incidental details because, in such a case corroboration does
not afford the necessary assurance that the main story disclosed by the approver can be
reasonably and safely accepted as true. But it must never be forgotten that before the court
reaches the stage of considering the question of corroboration and its adequacy or otherwise, the
first initial and essential question to consider is, whether, even as an accomplice, the approver is
a reliable witness. If the answer to the question is against the approver then there is an end of the
matter and no question as to whether evidence is corroborated or not needs to be considered.

In other words the appreciation of an approvers evidence has to satisfy a double test. His
evidence must show that he is a reliable witness and that is a test which is common to all
witnesses. If this test is satisfied the second test, which still remains to be applied, is that the
approvers evidence must receive sufficient corroboration. This test is special to the cases of
weak or tainted evidence like that of an approver

Thus these tests laid down by the Supreme Court are the guiding principles according to which
accomplice evidence must be appreciated.

ACCOMPLICE EVIDENCE Page 19

 EVIDENCE LAW

NATURE OF CORROBORATION

Generally speaking corroboration is of two kinds. Firstly the court has to satisfy itself that the
statement of the approver is credible in itself and there is evidence other than the statement of the
approver that the approver himself had taken part in the crime. Secondly the court seeks
corroboration of the approvers evidence with respect to the part of other accused persons in the
crime and this evidence has to be of such a nature as to connect the other accused with the crime.
The corroboration need not be direct evidence of the commission of the offence by the accused.
If it is merely circumstantial evidence of his connection with the crime it will be sufficient. The
corroboration need not consist of evidence which, standing alone would be sufficient to justify
the conviction of the accused. If that were the law it would be unnecessary to examine an
approver. All that seems to be required is that the corroboration should be sufficient to afford
some sort of independent evidence to show that the approver is speaking the truth with regard to
the accused person whom he seeks to implicate.

ACCOMPLICE EVIDENCE Page 20

 EVIDENCE LAW

CONCLUSION

The guiding principle with respect to accomplice evidence says that conviction may be based
upon the uncorroborated testimony of an accomplice and is not illegal or unlawful but the rule of
prudence says that it is unsafe to act upon the evidence of an accomplice unless it is corroborated
with respect to material aspects so as to implicate the accused.

Accomplice evidence is of extreme importance and can often play the decisive role in a criminal
trial. an accomplice can testify about the entire background and facts and circumstances of the
offence as he was involved in the commission of the offence and has first hand knowledge of
everything related to the offence. Thus Accomplice Evidence is a necessary evil.

To the lay man, accomplice evidence might seem untrustworthy as accomplices are usually
always interested and infamous witnesses but their evidence is admitted owing to necessity as it
is often impossible without having recourse to such evidence to bring the principal offenders to
justice. Thus accomplice evidence might seem unreliable but it is often a very useful and even
invaluable tool in crime detection, crime solving and delivering justice and consequently a very
important part of the Law of Evidence.

ACCOMPLICE EVIDENCE Page 21

 EVIDENCE LAW

BIBLIOGRAPHY

BOOKS REFERRED:

Tandon M.P., Indian Evidence Act, 1872, (Faridabad : Sri Sai Law Publication), 2006

Dhiraj Lal & Ratanlal, TheLaw of Evidence,(Nagpur : Wadhwa & Company), 2008

Singh Avtar, Priniciples of the Law of Evidence, (Allahabad : Central Law Publications),
2007

M.L Singhal, Sir John Woodroffe and Syed Amir Ali, Law of Evidence- Volume IV
(Allahabad: Law Book Company Private Limited, 1993).

WEB LINKS:

http://legal-dictionary.thefreedictionary.com/Accomplice+Witness Legal Definition of

Accomplice Witness

http://www.oppapers.com/essays/A-Critical-Analysis-Of-Accomplice-Witness/507650

An Essay on A Critical Analysis Of Accomplice Witness In India

http://legalsutra.org/507/accomplice-evidence/ Accomplice Evidence

http://www.airwebworld.com/articles/index.php?article=900 A Critical Analysis Of

Accomplice Witness In India

http://www.legalindia.com/accomplice-witness-and-its-admissibility-as-evidence/

http://www.legalservicesindia.com/article/article/accomplice-witness-&-its-admissibility-

as-evidence-906-1.html

ACCOMPLICE EVIDENCE Page 22