GURU NITHYA CHAITHANYA YATHI LAW COLLEGE AND RESEARCH

CENTRE (G-CLAR)
KAYAMKULAM
Affliated to University of Kerala

ASSIGNMENT ON “ FREE LEGAL AID UNDER INDIAN CONSTITUTION ”

SUBMITTED BY: SUBMITTED TO:

NAME :SNEHA.J NAME: VISMAYA.S.NAIR
CANDIDATE CODE :47320556033 ASST.PROFESSOR
COURSE : INTEGRATED FIVE YEAR BA.LL.B DEGREE DEPT OF LAW
BATCH: 2020 -25

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 TABLE OF CONTENTS

TABLE OF CASES……………………………………………………………………………3
1.1 INTRODUCTION………………………………………………………………………….…4-5
2.1 FREE LEGAL AID ……………………………………………………………………..……6 -21
2.2 MEANING OF LEGAL AID …………………………………………………………...……6 -7
2.3 KINDS OF LEGAL AID……………………………………………………………….…… 7-9
2.3.1 PRE -LITIGATION LEGAL AID………………………………………..………..7
2.3.2 LEGAL AID DURING PROCEEDING OF LITIGATION……………………..8-9
2.4 CRITERIA FOR PROVIDING LEGAL AID ………………………………………………….9
2.5 WHEN CAN LEGAL SERVICE BE REJECTED……………………………………………..9
2.6 VARIOUS CASES IN WHICH FREE LEGAL AID IS NOT PROVIDED………………….10
2.7 WHOM TO APPROACH FOR FREE LEGAL AID …………………………………………10
2.8 HOW TO APPROACH FOR FREE LEGAL AID ………………………………………..…10
2.9 DUTIES OF AIDED PERSON……………………………………………………………….10-11
2.10 MODE OF LEGAL SERVICES…………………………………………………………..…..11
2.11 IMPORTANCE OF LEGAL AID ……………………………………………………….…..11-12
2.12 CONSEQUENCE OF NOT PROVIDING FREE LEGAL AID …………………………....12-13
2.13 AIMS OF FREE LEGAL AID ……………………………………………………………....13-14
2.14 FREE LEGAL AID UNDER INDIAN CONSTITUTION ………………………………....15-21
2.14.1 OBJECT OF ARTICLE 39 -A OF INDIAN CONSTITUTION ………………...….18-21
3.1 SUGGESTIONS /RECOMMENDATIONS ……………………………………………….…21-22
4.1 CONCLUSION………………………………………………………………………………..22-23
5.1 BIBLIOGRAPHY ………………………………………………………………………….....23 -24

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 TABLE OF CASES

Abdul Hassan vs Delhi Vidyut Board AIR1999 II AD Delhi 105

Anokhi lal vs State of Madhya Pradesh AIR 2020 SC 232
C
Centre For Legal Research vs State of Kerala AIR 1986 SC 1322: 1986 (2) SCC 706
Central Coal Field Ltd and Others vs Jaiswal Coal Co AIR 1980 SC 2125: 1980 Sup 720
G
Gopalanachari vs State of Kerala AIR 1981 SC 674 , 1981 SCR (1) 1271
K
Kamlesh vs State of Rajastan 2023 Rjjp 003249
Khathri and others vs State of Bihar ,AIR 1981 SC 928
Kishore Chand vs State of Himachal Pradesh 1990 Cri.LJ 2289 SC
R
Ranjan Dwivedi vs UOI ,AIR 1983 SC 224 :( 1983 ) 3 SCC 307
S
Suk Das vs. Union Territory of Arunachal Pradesh ,AIR 1986 SC 991: (1986) 2 SCC 401

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 1.1 INTRODUCTION
“The concept of seeking justice cannot be equated with the value of dollars. Money plays no role in
seeking justice”
- Justice Blackman in Jackson v Bish -

Legal aid to the poor and weak is necessary for the preservation of rule of law which is necessary
for the existence of the orderly society. Until and unless poor illiterate man is not legally assisted, he is
denied equality in the opportunity to seek justice. Therefore as a step towards making the legal service serve
the poor and the deprived; the judiciary has taken active interest in providing legal aid to the needy in the
recent past. The Indian Constitution provides for an independent and impartial judiciary and the courts are
given power to protect the constitution and safeguard the rights of people irrespective of their financial status.
Since the aim of the constitution is to provide justice to all and the directive principles are in its integral part
of the constitution, the constitution dictates that judiciary has duty to protect rights of the poor as also society
as a whole. The judiciary through its significant judicial interventions has compelled as well as guided the
legislature to come up with the suitable legislations to bring justice to the doorsteps of the weakest sections
of the society. Public Interest Litigation is one shining example of how Indian judiciary has played the role
of the vanguard of the rights of Indian citizens especially the poor. It encouraged the public spirited people
to seek justice for the poor. For that Supreme Court relaxed procedure substantially. Apart from Public
Interest Litigation and judicial activism, there are reforms in the judicial process, where it aims to make
justice cheap and easy by introducing Lok Adalat system as a one of the methods to provide free legal aid
and speedy justice at the door steps of the poor. In this article the author highlights the importance of free
legal aid in a constitutional democracy like India where a significant section of the population has still not
seen the constitutional promises of even the very basic fundamental rights being fulfilled for them. Legal
Aid implies giving free legal services to the poor and needy who cannot afford the services of a lawyer for
the conduct of a case or a legal proceeding in any court, tribunal or before an authority. Legal Aid is the
method adopted to ensure that no one is deprived of professional advice and help because of lack of funds.
Therefore, the main object is toprovide equal justice is to be made available to the poor, down trodden and
weaker section of society. In this regard Justice P.N. Bhagwati rightly observed that:

“The legal aid means providing an arrangement in the society so that the missionary of
administration of justice becomes easily accessible and is not out of reach of those who have
to resort to it for enforcement of its given to them by law, the poor and illiterate should be
able to approach the courts and their ignorance and poverty should not be an impediment in
the way of their obtaining justice from the courts. Legal aid should be available to the poor
and illiterate, who don't have access to courts. One need not be a litigant to seek aid by means of

4
 legal aid.”
Therefore, legal aid is to be made available to the poor and needy by providing a system of government
funding for those who cannot afford the cost of litigation. Legal aid strives to ensure that constitutional
pledge is fulfilled inits letter and spirit and equal justice is made available to the poor, downtrodden and
weaker sections of the society. It is worthy to mention that the Constitution of India providesthat State shall
secure that the operation of the legal system promotes justice on a basis of equal opportunity, and shall in
particular, provide free legal aid, by suitable legislation or schemes or in any other way, to ensure that
opportunities for securing justice are not denied to any citizen by reason of economic or other disability.
Constitution of India also makes it obligatory for theState to ensure equality before law and a legal system
which promotes justice on a basis of equal opportunity to all. The expression Legal Aid has not been defined
anywhere in Legal Services Authorities Act, 1987. However, it is generally defined that - Legal Aid is the
provision of assistance to people otherwise unable to afford legal representation and access to the court
system. Legal aid is regarded as central in providing access to justice by ensuring equality before the law,
the right to counsel and the right to a fair trial. 17 The very idea of legal aid is to make sure that people
irrespective of their different social strata are given a level-based platform to have their rights determined so
as to enable the whole society to get justice in the true sense.
The Constitution constitutes for the fundamental set off laws of the land from which all other
laws infer their legitimacy.The State is under a Constitutional mandate to provide free legal aid to an
accused person who is unable to secure services on account of indigence and whatever is necessary for the
purpose has to be done by the State. The State may have its financial constraints and its priorities in
expenditure, but the law doesn‟t permit any Government to deprive its citizens of constitutional rights on a
plea of poverty.1 Legal Aid was incorporated in the Constitution of India only in the year 1976 by 42nd
Amendment by adding Article 39-A in Part IV of the Constitution (Directive Principles of State Policy) with
effect from 3.1.77. After the introduction of Article 39-A by the 42nd Amendment in 1976, a number of
states framed legal aid and advice schemes and resolutions of their Government.The Constitution of India is
among the few in the world that contain specifically worded and well documented provisions for legal aid.
The Preamble of the Indian Constitution, which is the „object and policy‟ of the core law inter-alia provides
for securing to all citizens‟ equality of status and of opportunity and justice- social, economic and political.
Both the objectives have inter-connection and underpinning. This objective can only be achieved if
Constitution of India provides special provisions for legal aid.2

1
Shodhganga.inflibnet.ac.in
2
jenning, Ivor, The Law of Constitution,University of London Press, 1963, 3rd Edition 1995, p. 49, Para IV

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 2.1 FREE LEGAL AID

Since independence, the percentage of people in India who can afford a good lifestyle has been
increasing steadily, while the percentage of people under the poverty line has decreased considerably. This
change can undeniably be linked as a direct or indirect consequence of the policies of the government for
upliftment of the poor people. Yet many people still have not been able to reap the benefits of these policies
and provisions and the associated economic growth. This has resulted in the widening of the gap between
the rich and the poor. As such, the poorer sections of the society feels ostracized and face various social
injustices. Compounding their problems, it is seen that they don‟t have anyone to represent them before the
court to face judicial procedings and thus, are deprived of justice. Although all problems cannot be solved to
the core, nonetheless our Constitution as well aslegislations provides a solution for the poorer and needy
sections of the society, who do not have the means to avail legal services, by providing them with free legal
assistance. This free legal assistance is called legal aid.

2.2 MEANING OF LEGAL AID

According to Cambridge Advanced Learners‟ Dictionary “Legal Aid” means a system of providing free
advice about the law and practical help with legal matters for people who are too poor to pay for it. 3

In the traditional sense legal aid is understood as financial assistance to a person who wishes to assert
or defend his rights in a court of law and who would not be able to do so without such assistance in view of
his financial means. 4 The general meaning of the term “Legal Aid”, therefore is a legal support, social
security, and social arrangement, for extending and providing special assistance or help to the poorer and
weaker members to enable them to enforce their legal rights through legal process.Therefore, the provision
of legal aid is essential for the safe walk of democracies on the track of Rule of Law and the Equal
Protection of Laws.5 Legal aid conveys the assistance provided by the society to its weaker members in their
effort to protect their rights and liberties, bestowed upon them by the laws. There is no justice unless there is
a sure uniformity about it. In a country like India, where the poor are neither aware of their rights nor have

3
http://dictionary.Cambridge.org/dictionary/british/legal-aid

4
narain, Jagat, Legal Aid-Litigational or Educational:An Indian Experiment, Journal of the Indian Law Institution, Volume 25,
1983.

5
The Concept of Legal Aid and Social Justice available at http://www.indiasocialstudy.com/2009/04/concept-of-legal-aid-social-
justice.html.

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 money to engage lawyers to defend them in the court, justice ends up becoming a rich man‟s
indulgence. The object behind free legal services for the poor is to ensure equal and uniform justice.

The very idea of legal aid is to ensure that people irrespective of their different social strata are given a
level-playing platform to have their rights determined so as to enable all of the society to get justice in the
true sense.Free legal aid implies giving free legal services to the poor and needy who cannot afford the
services of a lawyer for the conduct of a case or a legal proceeding in any court, tribunal or before an
authority6.
Legal aid scheme was first introduced by Justice P.N. Bhagwati under the Legal Aid Committee formed in
1971. In the words of Justice P.N. Bhagwati:
“Legal aid means providing an arrangement in the society so that the machinery of
administration of justice becomes easily accessible and is not out of reach of those who have
to resort to for enforcement of the rights given to them by law.”
According to Pollock, Legal aid is an instrument by which poor can approach to get justice, otherwise
deprived of and also can enforce their human rights.
Legal aid is the method adopted to ensure that no one is barred from professional advice and help
because of lack of funds. Thus, the provisions of legal aid to the poor are based on humanitarian
considerations and the main aim of these provisions is to help the poverty-stricken people who are socially
and economically backward. Legal aid simply means free legal support given to the weaker and inferior
sections of the society in judicial proceedings by the court of law. It is an effort for providing free legal aid
to those persons who are unable to enforce their rights given by law.
The main object of legal aid is to provide social justice. Thus, the general meaning of the term legal aid
is a social arrangement extending and providing special assistance or help to the poor and the weaker section
of the society. Thus, legal aid means the free legal assistance to the poor and weaker sections of
the society with the objective of providing them the opportunites to exercise the rights
given to them by law.

2.3 KINDS OF LEGAL AID

There are basically two types of legal aid -
a) Pre-litigation legal aid,
b) Legal aid during the proceeding of litigation.

2.3.1 PRE- LITIGATION LEGAL AID

6
Pathak,varun, “Brief History of Legal Aid”
7
 It has been rightly said that prevention is better than cure. Increase in the number of cases is a matter of
harsh concern. Litigation should be the last resort. Matters should be resolved without restoring to the
complicacies of the legal framework of the country.
Such pre- litigation legal aid includes -
● Legal education
● Legal advice
● Legal awareness
● Seminar on legal aid
● Pre- litigation settlement.
● Arrange legal aid camp
In order to remove complexity, more and more emphasis should be laid on pre-litigation services.
Litigation should be used as the last resort. If pre-litigation services are properly rendered then both time and
expenditure could be saved. In pre-litigation services there will be minimum financial burden upon the state.
Therefore, priority is given to pre- litigation services in the country.

2.3.2 LEGAL AID DURING PROCEEDING OF LITIGATION

The basic aim of legal aid during the proceeding of litigation is to provide free legal services to poor
and socially downtrodden people after the commencement of litigation and during proceeding. The Supreme
Court has warned on many occasions that only experienced lawyers may be put on the panel ainexperienced
lawyers may not represent the complaints of the poor in a proper manner. Legal community must respond in
a wholehearted manner. Well structured and effective planning for operation of the provisions of Legal
Services Authorities Act must be evolved .
The scope of free generous legal aid is broader than the legal assistance to poor or indigenous
people.Legal aid conveys the meaning of equality and assistance provided by the society and Government to
its financially and other weaker and deprived sections of the society to carry out the judicial process that is
Administration of Justice in the following respect -
● To ensure justice at cheap cost or free of cost
● To provide justice at door step.
● To provide legal awareness.
● To provide legal education.
● To provide para- legal aid.
● To provide social and economic justice.
● To provide civil justice system
● To provide criminal justice.
● To protect legal rights.
● To protect constitutional rights.
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 ● To protect human rights.
● To provide distributive justice

2.4 CRITERIA FOR PROVIDING FREE LEGAL AID

Every person who has to file or defend a case shall be entitled to legal services under this Act if that
person is:
● a member of a SC or ST;
● a victim of trafficking in human ;
● a woman or child;
● disabled person, including mental disability;
● a victim of mass disaster;
● an industrial workman;
● a person in custody;
● person whose annual income is less than rupees nine thousand or such other higher amount as may be
prescribed by the State Government if the case is before a court other than the Supreme Court and less
twelve thousand or such other higher amount as may be prescribed by the Central GovernmentIf the case
is before the Supreme Court.
● unable to engage a lawyer and secure legal service on account of reasons
such as poverty, indigence situation etc.,
In addition to the above, legal service may be granted for -
● a case of great public importance,
● special cases considered deserving of legal services.
Women and children, members of ST and SC, industrial workmen, disabled persons and persons
whose annual income does not exceed Rs. 1 Lakh (in the Supreme Court Legal Services Committee the limit
is Rs. 1, 25,000/-; the income limit for legal aid is under revision) should be entitled with the provision of
free legal aid as they represent the poorer and weaker sections of the society and cannot afford the services
of lawyers and also to meet other required costs for the conduct of a case. On the other hand, victims of mass
disaster, violence, flood, drought, earthquake, industrial disaster, persons in custody and victims of human
trafficking and people going through dire conditions and as such, they need free legal assistance for getting
justice.

2.5 WHEN CAN LEGAL SERVICES BE REJECTED

A legal service be rejected if the applicant
i. Has adequate means to access justice;
ii. Does not fulfil the eligibility criteria;
iii. Has no merit in his application requiring legal action.
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 2.6 VARIOUS CASES IN WHICH FREE LEGAL AID IS NOT PROVIDED
In the following cases legal aid is not available-
● Defamation,
● Malicious prosecution,
● Contempt of court,
● Perjury,
● Lying under oath,
● Proceedings relating to election;
● Cases where the fine imposed is not more than Rs.50/-;
● Economic offences,
● Offences against social laws
● The proceedings and whose interests will not be affected.

2.7 WHOM TO APPROACH FOR FREE LEGAL AID

The person who needs free legal aid can approach the Legal Services Authority at any level- national,
state, district and taluk. The request can be made to-
● The Senior Civil Judge nominated as the Chairperson of the Mandal/
Taluk Legal Services Authority;
● The Secretary, District Legal Services Authority at the District level;
● The Secretary, High Court Legal Services Committee at the State level;
● The Secretary, Supreme Court Legal Services Committee at the higherlevel;
● The Member Secretary of the State Legal Services Authority;
● The magistrate before whom she/he is produced; or
● The custodial authorities, if under detention.

2.8 HOW TO APPROACH FOR LEGAL AID

● A written application can be made to the concerned authority.

● Where the person cannot read or write, the Legal Services Authority will
record his/her statement along with thumb impression. Such a statement is treated
as an application. The person who claims legal aid has to file an affidavit of his income.

2.9 DUTIES OF AIDED PERSON

The aided person must -
i. Comply with directions given by the Secretary of the Legal Services
Authority;
10
 ii. Attend the office of the committee or Court as well as of the advocate
assigned, as when required;
iii. Furnish full and true information to the advocate rendering legal service;
and
iv. Not pay any fees or expenses to the advocate rendering legal service.

2.10 MODE OF LEGAL SERVICES

Free legal services include the following:
i. Payment of court fees, process fees and all other charges payable or
incurred in connection with any legal proceedings,
ii. Providing Advocate in legal proceedings,

iii. Obtaining and supply of certified copies of orders and other documentsin legal proceedings,
iv. Preparation of appeal, paper book including printing and translation of
documents in legal proceedings.

2.11 IMPORTANCE OF LEGAL AID

Rule of Law, is the fundamental principle of a democracy. If the rule of law does not prevail in a
society, the order and equipoise cannot be preserved and promoted in it.And obviously, the disorder and
disturbance in the society leads to its disintegration and destruction, which no society desires or can even
afford. Thus, for a peaceful and prospering society, more so if it is a democracy, it is necessary that there
prevails rule of law and not the rule of some individuals, how mighty and haughty such persons may be. But
there can be no rule of law, analyses the Gujarat Report on legal aid,“unless the common man, irrespective
whether he is rich or poor, is able to assert and vindicate the rights given to him by law‟.
“Law” it underscores, ‘is useless, a futile exercise of legislative power, unless actively effective and it
is the machinery of justice that gives life to the law and makes it actively effective. The machinery of justice
must, therefore, be readily accessible to all equally irrespective of their social, economic, geographical, and
biological or any other types of differences. Underlining the importance of legal aid, the Fourteenth Report
of Law Commission of India emphasized that without legal aid, equality before law, an integral
part of the rule of law, cannot be achieved. The following words of the Report are self speaking:
“…Equality is the basis of all systems of jurisprudence and administration of justice… In so far as a
person is unable to obtain access to a court of law for having his wrongs redressed or for defending himself
against a criminal charge, justice becomes unequal and laws which are meant for his protection have no
meaning and to that extent fail in their purpose. Unless some provision is made for assisting the poor man

11
 for the payment of court fees and lawyers‟ fees and other incidental costs of litigation, he is denied
equality in the opportunity to seek justice.7
Legal aid as a part of Administration of Justice, is of much importance for the developing and developed
societies alike, however, for the former its importance is much more because it is to act as a catalyst for
achieving the standards of social and economic development. Nonetheless, legal aid is to remain relevant
and important for such societies in their future too. The reason for this is obvious. Legal aid is an important
provision in the judicial administration, pulling up the weak and the meek to stand equal before the strong
and a resourceful adversary. In short, legal aid is a platform for the unequal in a society, facing litigation, to
make them look of „equal-size‟ as that of the long-statured opposing party Inequality has been prevailing in
the past, continues today, thereby giving us a foresight that it will continue in future also. Therefore, till
inequality prevails in a society, the need and importance of legal aid will remain to be there. Moreover,
inequality, in its economic, social, physical, cultural and geographical sense is existing in the developed,
developing and the under developed societies in the world over. 8

The provision of legal aid is therefore, essential for the safe walk of democracies on the path of rule of
law and the equal protection of laws. And when the laws, in the present day world have included the whole
of life of the people and the statutes have gained higher degrees of complexities and technicalities, the
importance and need of legal aid becomes more express. It is necessary for a society so as to remain peaceful
and prospering that „law must not only speak justice but also behave justly to do justice and this can be done
only by filling of legal aid in arteries of legal system‟.

2.12 CONSEQUENCES OF NOT PROVIDING FREE LEGAL AID

Legal aid is essential to establish equality of all people before the law and to ensure justice to all. A
presumption of a welfare state is meaningless without the existence of free legal aid. If free legal aid to the
Poor is not provided, it will result in breach of legal provisions, increasing chaos in the society, failure of the
rule of law, increasing conflict between have and have-nots and failure of the concept of social justice.
Moreover denial of free legal aid to the needy may also result in people adopting certain violent methods to
get justice, widening of the gap between the rich and the poor and strife between haves and have-nots”
If free legal aid to poor is not provided in time it will result in-
● Breach of legal provisions.
● Increasing chaos in the society.
● Failure of rule of law.
● Increasing conflict between have and have-nots.

7
Law Commission of India, Fourteenth Report, 1958, p.587
8
Sharma, Shyam Sunder., Legal Aid to the Poor:The Law and Indian Legal System, (1993), Deep and Deep Publications, F-
159,Rajouri Garden, New Delhi-110027,(1993), p.4
12
 ● Failure of the concept of social justice.
Moreover, denial of free legal aid to be needy may also result in the following-
● People will adopt certain extra ordinary method to get justice.
● The gap between rich and poor will increase.
● It may lead to agitation and class struggle.
Summing up the general importance of legal aid in the modern societies, it can be safely said that the
Goddess of Justice can now dispense justice blind-folded only if the administrators, dispensers and
practitioners of justice keep their eyes wide open and the poor and destitute in the society are being helped to
stand equal to their dominating and prosperous adversaries. And this can be ensured only by way of effective
provisions of legal aid in all societies; developed, developing or the under develop.

2.13 AIMS OF FREE LEGAL AID

Now the states are welfare states. Legal aid has a close relationship with the welfare state. The
provision of legal aid by the state is an attempt towards the achievement of the goal of welfare. Legal aid is a
welfare provision by the state to people who could not otherwise afford access to the legal system.Legal aid
also helps to ensure that welfare provisions are enforced by the state providing it to people entitled to
welfare provisions, such as social housing, with access to legal advice and the courts. Historically, legal aid
has played a strong role in ensuring respect for economic, social and cultural rights which are engaged in
relation to social security, housing, social care, health and education service, which may be provided
publicly or privately, by means of enforcement of law and anti-discrimination legislation.9Justice P.N.
Bhagwati rightly states the poor and the illiterate should be able to approach the courts and their ignorance
and poverty should not be an impediment in the way of their obtaining justice from the courts.10

The first and foremost aim of legal aid is to provide free legal services to the poor and needy section of
the society. Apart from this, it also encompasses the principles of equality, justice, rule of law and provision
of assistance to people otherwise unable to afford legal representation and access to the court of law. As such,
it should also strive to provide legal awareness, para-legal service, educate people regarding existing
provisions of law and promote legal literacy and create legal awareness among the weaker sections of the
community. Legal aid has a close relationship with the welfare state and the provision of legal aid by a state
is prejudiced by attitudes towards welfare. Legal aid is a welfare provision by the state to people who could
otherwise not afford access to the legal system.
Legal aid, in its common sense, conveys the assistance provided by the society to its weaker members in
their effort to protect their rights and liberties. The provisions of legal aid to the poor are based on charitable

9
http: //en Wikipedia org/wiki/Legal Aid Equality .

10
Report of Legal Aid Committee 1971, Published by Gujrat Government, p.5, Para.III
13
 conditions and the main aims of these provisions are that people who are socially and
economicallybackward get social justice. The following can be described as aims of legal aid in broad
prospective –
● First and foremost aim of legal aid is to provide free legal service to the poor
and needy section of the society.
● To provide equality.
● To provide justice.
● To implement rule of law.
● To provide legal awareness.
● To arrange for legal aid camp.
● To make available speedy justice.
● To provide para- legal service.
● To establish social justice.
● To educate people regarding existing provisions of law.
● The provisions of legal aid to the poor are based on humanitarian conditions
● Legal aid is the provision of assistance to people otherwise unable to afford
legal representation and access to the court of law.
● To promote legal literacy and create legal awareness among the weaker
● sections of the community.
● To organize legal aid camp.

2.14 FREE LEGAL AID UNDER INDIAN CONSTITUTION

The Constitution of India is a sacred document of Nation. In the words of Justice Anand –
The Constitution of India, the treasure of wisdom, was drafted and handed over to the citizens of this
country by those who were passionately driven by our dream of securing social, economic and political
justice. Their notion of justice was based on the principle of Equality before Law. We have an expanding
Constitution which learns from the past, manages the present and cares for the future. 11
The Constitution is known as the basic law of the land from which all other laws derive their
sanctity or validity. Therefore, Constitution is a living and growing lawmeans it is able to cope with the
newer situations and development. That is why, as and when it is felt that a special situation has arisen and
the present constitutional provisions are not adequate to meet up that situation and cannot deal with the new

11
Anand, Dr. A.S.,- „ Speech on the Occasion of Law day‟ on 26th November 1998 , Nyaya Deep ,the
official News letter of National Legal Services Authority, New Delhi-110011, Vol-2, Issue -
1,January 1999, p.21, Para II.

14
 development effectively, then the parliament amends it from time to time, and legal aid is such one
provision which was incorporated in the Constitution by the 42nd Amendment in the year 1976.12
The Constitution of India is among the few in the world that contains specific provisions for legal aid.
The Preamble of the Indian Constitution, which is the „object and policy‟ of the core law inter-alia provides
for securing to all citizens equality of status and of opportunity and justice- social, economic and political.
Both the objectives have inter-connection and underpinning. These objectives can only be achieved if the
Constitution of India provides special provisions for legal aid.13
Under the Indian Constitution, there is no express provision of legal aid as afundamental right, but
there are many instructions in our Constitution directly or indirectly regarding legal aid. Naming legal aid as
a human right, and by recognizing it under the Constitution of India as a fundamental right, a three-Judge
Bench of the Apex court of the country, in ,Gopalanachari vs. State of Kerala 14 reminded the Courts to
preserve and promote this right . In the words of Justice V.R. Krishna Iyer:
“…The poor are picked up or brought up, habitualy witnessess swear away their freedom and courts
ritualistically commit them to prison; Article 21 is for them a freedom from this practice which is under total
eclipse. Courts are guardians of human rights. The common manlooks upon the trial court as a protector. The
poor and the illiterate, who have hardly the capability to defend themselves, are nevertheless not „non-
persons” the trial judges must remember…we direct the trial magistrates to discharge their duties, when
trying cases under Section 110, with great responsibility and whenever the counter-petitioner is a prisoner to
give him the facility of being defended by counsel. Now Article 21 has been reinforced by Article 39-A” 15
So, to secure equality of status, opportunity as well as social justice to all the citizens of India following
provisions were in force until the incorporation of Article 39-A in the Constitution.
 Preamble
● Article 14.
● Article 21.
● Article 22(1).
● Article 38 and
● Article 39(A)

The Preamble of the Constitution of India epitomizes the philosophy underlying the basic rights of the
citizens. The objectives which are intended to be secured by the Constitution are set forth in the Preamble. It

12
Shastri, S.C., Environmental Law, Eastern Book Company 1267,Kashmere Gate,Old Hindu College
Building, Delhi-110006, Second Edition 2005, p.39

13
Basu, Durga Das. , Constitutional Law of India, Prentice Hall of India Pvt. Ltd., New Delhi, 1991, p.1
14
AIR 1981 SC 674,1981 SCR(1) 1271
15
AIR 1981 SC 677

15
 aims at reaching the ideal of establishing social, economic and political justice for citizens in the country.
It endeavours to secure to the citizens‟ liberty, equality and fraternity. It emphasizes the inherent dignity of
the
individual at the level and the unity and integrity of the Nation. For realizing the objectives set out in the
Preamble, the Constitution enshrines Fundamental Rights, Directive Principles of State Policy and
Fundamental Duties in Part III, IV and IV-A respectively

Article 14 of the Constitutionof India guarantees equality before law and equal protection of laws.
Equality before law necessarily involves the concept that all the parties to a legal proceeding must have an
equal opportunity of access to the court. Justice and access to the court would remain a myth for the people
who are unable to pay the court fees and lawyers‟ fees etc. because of their poor economic conditions and
thus they loose the opportunity of access to the court. Moreover, the cumbersome amount of legislations and
complex procedures involved have made the situation even more difficult for the common people to know
what his rights are unless he has ample means of legal representation in a court. The inequality therefore,
instead of being lessened, has enormously increased in a welfareState. Therefore, under Article 14, provision
of legal services to the poor litigant is not just a provision of procedural law but a question of a fundamental
character.
Article 21 of the Constitution of India provides the right to life and personal liberty. This right cannot
be taken away except by procedure established by law. Procedure should be just, fair and reasonable. Right
to hearing is an essential part of natural justice. As a corollary to that, the right to counsel or to legal aid is
equally essential to fair trial, Further counsel for the accused must be given time and facility for preparing
his defense. Breach of these safeguards of fair trial would invalidate the trial and conviction even if the
accused did not ask for legal aid.

Article 22(1) of the Constitution of India provides that a person arrested should not be detained in
custody without being informed of the grounds for such arrest and should not be denied the right to consult
and be defended by a legal practitioner of his choice.

Article 38 of the Constitution of India urges that the State should endeavour to promote the welfare of the
people by securing and protecting as effectively as it may be a social order in which justice: social, economic
and political shall inform all the institutions of national life.

Article 39 -A Parliament became too aware about the need and utility of legal aid after submission of
various reports by Central Committees and the Central Government. So under the vibrant Leadership of Mrs.
Indira Gandhi in the year 1976, Parliament of India by 42nd Amendment inserted Article 39- A in order to
ensure equal justice.
16
 Thus, Article 39-A reads- “The states shall secure that the operation of the legal system promotes justice
on the basis of equal opportunity and shall in particular provide free legal aid by suitable legislation or
schemes or in any other way to ensure that opportunities for securing justice are not denied to
any citizen by reason of economic or other disabilities.”Finally, under the provision of this Article that
provides free legal aid to the poor now becomes a fundamental right.

A broad interpretation of Article 21 expresses that, the state is duty bound to pay reasonable
remuneration to the defence counsel. That will help in upgrading a rich defence, reasonable facility for
conducting appeal for free and fair procedure. Legal aid arises till the production of the accused before
magistrate and continues throughout the trials, it extends even to security proceedings, etc.Art 39-A ordains
the state to secure a legal system which promotes justice on the basis of equal opportunity. The language of
Article, 39-A is couched in mandatory terms as is clear by the use of the word „shall‟ twice therein.
In the words of the Delhi High Court, “It is emphasized that the legal system should be able to deliver
justice expeditiously on the basis of equal opportunity andshould provide free legal aid to ensure that
opportunities for securing justice are not denied to any citizen by reasons of economic or other disabilities”.
Article 39-A puts stress upon legal justice. Put simply, the directive requires the state to provide free
legal aid to deserving people so that justice is not denied to any one merely because of economic disability.
Article 39-A has been read with Article 21 and, thus, free legal assistance at state cost has been raised to the
status of a Fundamental Right of a person accused of an offence which may involve jeopardy to his life or
personal liberty. The Court has also ruled that it would make a mockery of legal aid if it were to be left to a
poor, ignorant and illiterate accused person to ask for free legal aid. Accordingly, the Presiding Judge has
been obligated to inform the accused that he can obtain free legal service at the cost of the state if he is
unable to engage a lawyer because of his indigence.16The Supreme Court has ruled that it cannot issue a writ
of mandamus to enforce Article 39-A.
Article 39-A makes it clear that the social objective of equal justice and free legal aid has to be
implemented by suitable legislation or by formulating schemes for free legal aid.17Although the mandate in
Article 39-A is addressed to the legislature and the executive yet, as the courts can indulge in some judicial
law-making within the interstices of the Constitution or any statute before them for construction, the courts
too are bound by this mandate. The Supreme Court has emphasized that under Article 39-A, the State
Government undoubtedly has an obligation to set up a comprehensive and effective legal aid programme in
order to ensure that the operation of the legal system promotes justice on the basis of equal opportunity. For
the legal aid programme to succeed it is necessary to involve public participation and, for this purpose, the

16
Suk Das vs. Union Territory of Arunachal Pradesh, AIR 1986 SC 991: (1986) 2 SCC 401.
17
Ranjan Dwivedi vs. Union of India, AIR 1983 S.C. 224: (1983)3 SCC 307
17
 best way is to operate through voluntary organization and social action groups. The state should
encourage and support such bodies in operating the legal aid programme.18
The Supreme Court hs also stated with reference to Article 39-A that court-fees should be correlated to
expenditure on administration of justice, as high court-fees bar effective access to justice. The Supreme
Court may have to consider some day whether such high court-fees are just or legal.19
The Supreme Court in the case of Kishore Chand vs. State of H.P. 20commented on this situation as
under:-
“Though Article 39-A of the Constitution provides fundamental rights to equal justice and free legal aid
and though the State provides amicus curiae to defend the indigent accused, he would be meted out with
unequal defence if, as is common knowledge the youngster from the Bar who has either a little experience or
no experience is assigned to defend him. It is high time that senior counselpracticing in the Court concerned
volunteers to defend such indigent accused as a part of their professional duty.”
In Abdul Hassan vs. Delhi Vidyut Board,21the Delhi High Court observed that–
“It is emphasized in Article 39- A that the legal system should be able to deliver justice expeditiously on
the basisof equal opportunity and should provide free legal aid to ensure that opportunities for securing
justice are not denied to any citizen by reasons of economic or other disabilities .It was in this context that
the Parliament enacted Legal Services Authorities Act, 1987. One of the aims of the Act is to organize Lok
Adalat to secure that the operation of legal system promotes justice on the basis of an equal opportunity. The
provisions of the Act, based on indigenous concept are meant to supplement the court system. They will go a
long way in resolving the dispute at almost no case to the litigants with minimum delay. The Act is a
legislative attempt to decongest the courts of heavy burden of cases.”

2.14.1 OBJECT OF ARTICLE 39 -A OF THE INDAIN CONSTITUTION

The main object behind the insertion of Article 39-A is to mitigate inequalities so that justice
reaches to the door of the poor and weaker sections of the society. In other words, a person should not be
denied justice merely on the grounds of poverty or on the ground that he is not a position to engage a lawyer
to conduct his case. The principle contained in Article 39-A are fundamental and cast a duty on the state to
secure that the operation of legal system promotes justice, on the basis of equal opportunities and further
mandate to provide free legal aid in any way by legislation or otherwise so that justice is not denied to any
citizen by reason of economic or other disabilities. The crucial words are to provide free legal aid “by
suitable legislation or by schemes” or in any other way. These words used in Article 39-A are of very wide
importance. In order to enable the state to afford free legal aid and to guarantee speedy trial a vast number of

18
Center for Legal Research vs. State of Kerala, AIR 1986 S.C. 1322 : 1986 (2) SCC 706
19
Central Coal Fields Ltd And Anr vs. Jaiswal Coal Co. AIR 1980 SC 2125 : 1980 Supp720
20
1990 Cri.LJ 2289 (SC)
21
1999 IIAD Delhi 105,AIR 1999 Delhi 88,77(1999) DLT 640, 1999 (48) DRJ 483
18
 persons trained in law are essential. Legal aid is required in many forms and at various stages, for
obtaining guidance, for resolving disputes in courts, tribunals or other authorities. The need for a continuing
and well organized legal education is absolutely essential in view of new trends in the world in order to meet
the ever growing challenges. For this purpose a vast number of persons trained in different branches of law
are needed every year. This is possible only when adequate number of law colleges with proper
infrastructure including expertise law teachers and staff are established. As in this case, a sole Government
law college cannot cater to the needs of legal educationor requirement in a city like Bombay. If the State is
unable to start colleges of its own, it should allow private law colleges duly recognized by the University or
the Bar Council of India or other appropriate authorities and they should be offered reasonable facilities to
function effectively and in a meaningful manner. Under the label of self financing institution, the college
should not be permitted to hike the fees to any extent in order to meet their expenses. The private law
colleges may not afford the huge cost required for this purpose. The standard of legal education and
discipline is bound to suffer. The Court said that if this is allowed the “free legal aid” will only be a farce
and therefore, it is necessary to afford them grant-in-aid by the Sate as it will facilitate and ensure the
recognized private law colleges to function effectively and in a meaningful manner and turn out sufficient
number of well-trained or properly equipped law graduates in all branches every year. This will enable the
state to provide free legal aid and to ensure that opportunities for securing justice are not denied to any
citizen on account of any disability. 22
Article 39-A of the Constitution gives constitutional status to free legal services to the poor. The
objective of Article 39-A has been explained by Supreme Court as –
“… It is clear from the terms of Article 39-A, the objective of Constitution is to ensure social and equal
justice so that legal aid has to be implemented by comprehensive schemes. Directive principles and
fundamental rights have no disharmony as both are aiming at the same goal of bringing about a social
revolution and the establishment ofa welfare State, which is envisaged in the Preamble. Primarily Article 39-
A is addressed to the Legislature and Executive, but as far as the court of justice can indulge in judicial law
making, within the ambit of the Constitution, the courts too are bound by this mandate.” 23

Article 39-A of the constitution gives constitutional status to free legal services to the poor. In India with
Article 39-A of the constitution, equal justice is assured to unequal persons. This newly introduced Directive
Principles enshrined in Article 39-Aobligating the state to provide legal aid services impelled to further
specify the way in which prisoners rights in this regard were to be protected. The Supreme court of India in
famous leading case has explained the object of Article 39-A thus–

22
Pandey, Dr. J. N., Constitutional Law of India, Central Law Agency, 40th Edition 2003, pp. 363-
364.

23
Ranjan Dwivedi vs. U.O.I AIR 1983 SCR (2) 982,1983 SCC(3) 307
19
“It is clear from the terms of Article 39-A, the objectives of the Constitution is to ensure social justice, so
that legal aid has to be implemented by comprehensive schemes. Directive Principles and Fundamental
Rights have no disharmony as both are aiming at the same goal of bringing about a social revolution and the
establishment of a welfare state, which is envisaged in the Preamble. Primarily Article 39-A is addressed to
the Legislature and Executive, but so far as the court of justice can indulge in judicial lawmaking within
interstice of the constitution the court too are bound by this mandate”.
Article 39-A is an interpretative tool for Article 21. But no writ can be granted, to enforce Article 39-A.
The Supreme Court in Rajan Dwivedi case clearly laid down that the petitioner is not entitled to grant of writ
of mandamus for the enforcement of Article 39-A. The Supreme Court of India has taken cognizance of
Article 39-A of the Constitution of India in administering justice in criminal cases. When the accused
is .unable to engage a lawyer owing to poverty or similar circumstances, the trial would be vitiated unless
the state offers free legal aid for his defence by engaging a lawyer to whose engagement the accused does
not object. It is interpreted that the right to an indigent accused arises from the moment he is first produced
before a Magistrate. 24In the absence of legislation, implementing Article 39-A, an accused cannot
compel the state to supply him a lawyer, at the cost of the state, through a writ petition. The remedy of an
indigent accused lies in the application to Session Court under Section 304(1) of the Code of Criminal
Procedure, 1973.25When a lawyer is engaged by the court for an indigent accused it becomes the duty of the
state to pay remuneration to counsel not as charity but equality as fixed by court. The state must provide
reasonable facility to such counsel for conducting the appeal as a condition of a “reasonable, fair and just”
procedure which is postulated inArticle 21 of the Constitution of India. Thus the Article 39-A may be used
as an aid to the interpretation of Article 21.
In Anokhi Lal vs State of MP 26, the learned amicus curiae also referred to article 39-A of the
constitution and re -emphasized that Right to free legal aid is clearly an essential ingredient of
fair ,reasonable ,and just ,procedure for a person accused of an offence and it must be implicit in guarantee
of Article 21 of Indian constitution .Additionally ,it is not necessary for an accused to ask for legal assistance
and the court dealing with the case is obliged to inform him or her of the entitlement to free legal aid .
In kamlesh vs State of Rajastan 27 ,it is said that freelegal aid and a high speed trial are two pre-
requisites of a fair trial without any injustice ,prejudice, arbitrariness and unreasonableness .
Gandhiji, the father of the nation always dreamt for an India in which “The poorest shall feel that it is
their country in whose making they have an effective voice: An India in which all communities shall live in
perfect harmony.”Following the ideals, the Constitution of India tries to protect every citizen with equality,

24
Khatri And Others vs. State of Bihar, AIR 1981 SC 928.

25
Ranjan Dwivedi vs. U.O.I AIR 1983 SCR (2) 982,1983 SCC (3) 307

26
AIR 2020 SC 232
27
2023 Rjjp 003249
20
 liberty and fraternity. But it is also not unacceptable that tears of the common people still exist in India
due to some barriers. The Constitution treats all citizens as being equal and provides them equal protection
under law. Yet common persons face barriers to access justice. Illiteracy, lack of financial resources and
social backwardness are major factors that hinder the common person from accessing justice. There are other
invisible barriers like lack of courage to exercise legal rights, the proclivity to suffer silently the denial of
rights and geographical and spatial barriers are examples.

3.1 SUGGESTIONS
Inspite of the various efforts made by the Executive, Legislature and the Judiciary with respect to
providing free legal aid to the poor and needy people of the society and thereby ensuring the true prevalence
of welfare state in India, there are many problems in implementing the very idea of legal aid in its true sense
in the Indian society. Though the implementation of the legal aid programme has been yielding favourable
results at least in some sense, yet more reformation is necessary in this regard. To achieve the objectives of
legal aid following suggestions are forwarded:
● The electronic media can come forward to sensitize the masses about the existing laws of legal aid.
● The existing laws of legal aid can also be popularized through articles published in newspapers and
magazines.
● The Government should introduce a helpline number that will provide information on legal aid.
● The process of legal aid should be made simple and clear so that people, especially the poor and
illiterate,finds it easy to understand.
● There is no law in India which compels an advocate to provide legal assistance to the poor section of the
society. So the Government should frame a law by which the lawyers are bound to provide legal aid.
● The Government should form an independent monitoring agency who will monitor the different activities
of the Legal Services Authority.
● Legal Aid Clinic should be attached to the Law Colleges and Courts so as to provide people with a quick
and easy access to information and provisions associated with free legal aid.
● Incorporation of the use of the various modes of Alternative Dispute Resoluton Systems like Arbitration,
Conciliation, Negotiation and Mediation towards extending legal aid can prove to be an effective tool,
especially in the settling of cases involving matrimonial problems, family disputes, land disputes and cases
which can more effectively be tried by these quasi-judicial bodies.
● The Government should provide adequate facilities and other financial support to important organizations
like National Legal Services Authorities so that they can effectuate the upliftment of the weaker section of
the society.
● Lack of awareness is a major obstacle in realizing effective legal aid. The Government should direct the
organizations associated with the execution of legal aid to organize awareness camps in remote areas to

21
highlight the existing legal aid provisions for the economically backward classes of the society. The
Government can appoint employees who will work for the same.
● Legal Aid is a service pivotal for the growth of our society towards a liberal and democratic nation in its
truest sense. Therefore, not just the State alone, but the welfare and voluntary organizations too should adopt
and work for the execution of this scheme.
● For the legal aid programme to succeed, it is necessary to involve public participation by organizing legal
aid awareness programme.
● Qualified and experienced advocates should be appointed by the Government to provide free legal aid to
the needy people. The name and contact number along with their address should be displayed in a specific
corner of the court campus to have easy access to those advocates.
● There should be a machinery to collect oral and written complaint from the needy client against the
engaged advocate regarding any unethical professional activities, in case it exists.
● Free legal aid must not be read synonymously with poor or inferior legal services. The lawyers in the
panel should be experienced.
● Law schools can also play a vital role in promoting legal awareness by organizing legal aid camps, as is
already prescribed as part of their course-work. Through the legal aid camps law college students canprovide
legal assistance as well as awareness to the socially and economically backwards classes of the society.

4.1 CONCLUSIONS
The idea of Legal aid is devoting free legal assistance to the poor, needy, weaker and downtrodden
population of the society. The important element of legal aid is to exercise those rights borne to every citizen
under the Constitution of India. But their unawareness towards the benefit has failed to make the concept a
successful one. Illiteracy and poverty could be said to be the two main reasons for the same. In order to
secure fairness of justice in true sense of the term there should not be any discrimination between the rich
and the poor in availing proper legal service. There should be reasonable, fair and just procedure to be
provided for each and every citizen of the country.
The Preamble of the Constitution of India has defined and affirmed an universal objective for its citizens
as “to secure to all the citizens of India, Justice: social, economic and political; Liberty of thought,
expression, belief, faith and worship; Equality of status and of opportunity; and to promote among them all
Fraternity assuring the dignity of the individual and the unity and integrity of the Nation. It is the primary
responsibility of the State under our Constitution to maintain equality among the citizens for upholding an
orderly society.
Legal aid is regarded as predominant in providing guarantee to justice by ensuring equality before law,
right to counsel and right to reasonable, just and fair trial. Article 39-A of the Constitution of India provides
that State shall secure that the operation of the legal system promotes justice on a basis of equal opportunity,

22
 and shallin particular, provide free legal aid by suitable legislation or schemes or in any other way to
ensure that opportunities for securing justice are not denied to any citizen by reason of economic or other
disability.
Articles 14 and 22(1) also make it obligatory for the State to ensure equality before law and legal
system which promotes justice on the basis of equal opportunity to all. The main aim behind the enactment
of the Legal Services Authorities Act, 1987 is to put into operation the constitutional mandate enshrined
under Articles 14 and 39-A of the Constitution of India. It is the duty of the judiciary not only to protect the
rightsof the individual but also of the society as a whole. Thus the judiciary has taken efficient step in
providing legal aid to help the poor and underprivileged section of the society in availing proper legal
services.In a democratic society, an independent and impartial judiciary is the protector of the rights of every
individual. The Indian Constitution provides for an independent and impartial judiciary to protect the rights
of the individual and providing fair justice without any fear or favour.
We are all acquainted with the fact that in every State and District level, Legal Services Authority has
been constituted under Legal Services Authorities Act, 1987 to implement legal service programmes in the
State and District level. It is the right of the accused to seek free legal aid as a necessary supplement to the
Rule of Law. Legal aid is not a charity, donation, offering or bounty, but it is the requirement of the State
which would safeguard and ensure the rights and privileges asserted to its citizens for smooth functioning of
the society. The doctrine of legal aid is an ingredient of the Directive Principles of State Policy. Though
there are number of precedents in addition to legislations to sustain theright to free legal aid but it is very
unfortunate that the whole efforts are merely limited to paper works as against their proper implementation
in reality. With the changing situations, provision of legal aid has become obligatory for the courts through
Judicial Decisions and Legislations to follow rather than just being a directive. The main motive of
providing legal services to the masses on the whole is to facilitate them with proper access to justice in a
realistic approach. But the cry for free legal aid for fair, just and reasonable justice is still lacking behind due
to social obligations, lack of interest of the lawyer, poverty, lack of illiteracy, lack of legal awareness and
improper implementation of law on the part of lower judiciary and State authorities.
Therefore, in India the awareness as well as knowledge of free legal aid is like a basic necessity to
bestow social justice to each and every personage without any discrimination. Thus the present need of the
hour is that poverty-stricken, deprived, underprivileged and illiterate people should be made educated and
imparted with legal knowledge on their basic right which should be implemented from the grass root level.

5.1 BIBLIOGRAPHY
Books

1. Basu, Durga Das. , Constitutional Law of India, Prentice Hall of India Pvt. Ltd., New Delhi, 1991
2. Pandey, Dr. J. N., Constitutional Law of India, Central Law Agency, 40th Edition 2003, pp. 363-
23
 364
3. Shastri, S.C., Environmental Law, Eastern Book Company 1267,Kashmere Gate,Old Hindu College
Building, Delhi-110006, Second Edition 2005, p.39

Articles
4. Anand, Dr. A.S.,- „ Speech on the Occasion of Law day‟ on 26th November 1998 , Nyaya Deep ,the
official News letter of National Legal Services Authority, New Delhi-110011, Vol-2, Issue -
1,January 1999, p.21, Para II.
5. Bhagirahi ,panigrahi “Law school and legal aid”,Cuttak Law Times ,1993,76:pp.15 -17.
“Legal aid to the poor :An Analysis”,Cuttak Law Times 1993,75:pp21-30
6. jenning, Ivor, The Law of Constitution,University of London Press, 1963, 3rd Edition 1995, p. 49, Para
IV
7. Law Commission of India, Fourteenth Report, 1958, p.587
8. narain, Jagat, Legal Aid-Litigational or Educational:An Indian Experiment, Journal of the Indian Law
Institution, Volume 25, 1983.
9. Pathak,varun, “Brief History of Legal Aid”
10. Report of Legal Aid Committee 1971, Published by Gujrat Government, p.5, Para.III
11. Sharma, Shyam Sunder., Legal Aid to the Poor:The Law and Indian Legal System, (1993), Deep and
Deep Publications, F-159,Rajouri Garden, New Delhi-110027,(1993), p.4
Websites

12. http://legalservice.com
13. http://supremecourtonline.com
14. http://supremecourtcases.com
15. http://en.wikipedia.org/wiki/lawsindia.com
16. http: //en Wikipedia org/wiki/Legal Aid Equality .
17. http://dictionary.Cambridge.org/dictionary/british/legal-aid
18. The Concept of Legal Aid and Social Justice available at
http://www.indiasocialstudy.com/2009/04/concept-of-legal-aid-social-justice.html.
19. Shodhganga.inflibnet.ac.in

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