{"id":400852,"date":"2026-11-09T13:00:38","date_gmt":"2026-11-09T07:30:38","guid":{"rendered":"https:\/\/www.scconline.com\/blog\/?p=400852"},"modified":"2026-11-07T23:26:55","modified_gmt":"2026-11-07T17:56:55","slug":"bhagalpur-blinding-case-evolution-of-free-legal-aid-in-india","status":"publish","type":"post","link":"https:\/\/www.scconline.com\/blog\/post\/2026\/11\/09\/bhagalpur-blinding-case-evolution-of-free-legal-aid-in-india\/","title":{"rendered":"National Legal Services Day: From Bhagalpur to NALSA — The Constitutional Promise of Free Legal Aid"},"content":{"rendered":"
\n

What does justice look like when the people waiting for it cannot see, the institutions meant to deliver it cannot be seen, and the law itself seems to operate in the dark?<\/p>\n

Between 1979 and 1980, Bhagalpur in Bihar became the site of one of the worst episodes of custodial violence in independent India. Prisoners held in police custody and in the Bhagalpur Central Jail, most of them awaiting trial, were blinded by police officers. The incident was not simply a question of police excesses or custodial brutality. It raised a much deeper question about the relationship between an individual and the State. What happens when the very institution entrusted with protecting citizens becomes the source of their suffering?<\/p>\n

For those prisoners, the struggle did not end with the loss of their eyesight. They were also confronted with the challenge of seeking justice against a powerful State machinery. The litigation that followed, Khatri (II)<\/span> v. State of Bihar<\/span><\/a>1<\/sup><\/a>, is remembered for what it did to Article 21. It held that the State must provide free legal aid to an indigent accused from the moment he is first produced before a Magistrate, and that the Magistrate must tell him of that right. This article retells that history, traces how the Supreme Court and Parliament built on it, and asks whether the right has reached the people for whom it was created. The story of Bhagalpur, therefore, is not merely the story of prisoners who suffered custodial violence. It is also a story about the meaning of justice, the responsibility of the State and the constitutional promise that no person should be left without legal assistance merely because they cannot afford it.<\/p>\n

A city, a prison and a horrifying incident: The Bhagalpur blinding case<\/p>\n

\"\"<\/p>\n

In the winter of 1980, the Supreme Court was confronted with an account that seemed almost impossible to believe. The victims were prisoners: Men accused, but not yet convicted, whom the criminal justice system is bound to treat as presumptively innocent. The record before the Court described most inhuman torture imaginable as their eyes being pierced with needles, bicycle spokes and similar instruments, and acid being poured into the wounds.2<\/sup><\/a> According to the court, six prisoners were blinded between October 1979 and May 1980, and another 12 between 11 June and 25 July 1980.3<\/sup><\/a><\/p>\n

Press accounts gave different figures. A contemporary report put the number at 24,4<\/sup><\/a> and a Times of India<\/span> report 30 years later put it at 33.5<\/sup><\/a> The court’s figures cover the cases that came before it, which may account for the difference. The episode later reached popular cinema: Prakash Jha’s Gangaajal<\/span> (2003) drew loosely on it.<\/p>\n

For months, the story remained buried inside the machinery of the criminal justice system. Complaints were made. Petitions were written from the jail. Officials received them. Yet the prisoners remained prisoners, and the violence that had taken their sight seemed destined to disappear into the same institutional silence that had allowed it to happen. When letters and newspaper reports describing the atrocity reached the Supreme Court, the court did something procedurally unusual for its time, it treated the correspondence itself as a writ petition under Article 32, and began the proceedings that became Khatri<\/span> v. State of Bihar<\/span><\/a>6<\/sup><\/a>. The medical reports placed before the Supreme Court revealed the extent of the injuries. In one representative case, the report recorded the collapse of both eyeballs and the complete loss of eyesight, with the injuries attributed to the use of a corrosive substance and a sharp instrument.7<\/sup><\/a> The court observed that the medical findings revealed a flagrant violation of constitutional safeguards and acknowledged that the physical damage appeared irreparable.8<\/sup><\/a><\/p>\n

The tragedy of Bhagalpur, therefore, exposed the helplessness of persons who, despite being under the protection of the Constitution<\/a>, appeared unable to secure even the most basic guarantees of human dignity and personal liberty. And perhaps the most unsettling question was not merely how such an incident could occur, but how those who suffered it would ever find a way to be heard.<\/p>\n

The prisoner who asked for a lawyer, and the system replied: “There is no provision”<\/p>\n

There was another injury, less visible but equally important to the constitutional history of India. Most of these men had no lawyer. The story of Bhagalpur becomes even more troubling when one moves beyond the incident itself and examines what followed. For the prisoners, the immediate challenge was not only to survive the injuries inflicted upon them, but also to find an avenue through which their suffering could reach the authorities capable of acting upon it. One of the earliest documented complaints came from a prisoner named Arjun Goswami. After being admitted to Bhagalpur Central Jail on 26 October 1979, he addressed an application to the Chief Judicial Magistrate on 20 November 1979, seeking an inquiry into the torture inflicted upon him, particularly the blinding of his eyes.9<\/sup><\/a> The complaint was forwarded to the magistrate, but the problem was far from resolved. Subsequently, 11 other prisoners made similar complaints, which were forwarded to the Sessions Judge, Bhagalpur, on 30 July 1980. What followed revealed another disturbing dimension of the episode. Instead of directing a comprehensive inquiry into the allegations, the Sessions Judge, in a communication dated 5 August 1980, observed that there was “no provision in the Criminal Procedure Code, 1973<\/a> (CrPC), for providing a lawyer to persons seeking to prosecute a criminal complaint”10<\/sup><\/a> and forwarded the petitions to the Chief Judicial Magistrate for necessary action.11<\/sup><\/a> The reply was, in a narrow sense, correct. Section 304<\/a> CrPC<\/a> provided legal aid at State expense to an accused in a sessions trial; it said nothing about a prisoner who wanted to prosecute the police<\/p>\n

The prisoners had, therefore, lost more than their sight. They were accused persons awaiting trial, and they were victims who needed a lawyer to set the law in motion against the officers who had blinded them. The Sessions Judge’s letter shows that the law then treated the second need as nobody’s responsibility. This is what makes the Bhagalpur Blinding case<\/span> a constitutional story to confront a question that was both simple and more fundamental — “what does a right to justice mean if one cannot afford a lawyer?”12<\/sup><\/a> The answer would emerge not in a single judgment, but through a series of orders in what came to be known as the Bhagalpur Blinding cases<\/span>.<\/p>\n

When the Supreme Court was called upon to intervene<\/p>\n

Reports in the Indian Express<\/span> brought the blinding to national attention in 1980.13<\/sup><\/a> On 9 October 1980, 10 of the blinded prisoners filed a habeas corpus petition in the Supreme Court under Article 32, seeking their production before the court, medical examination by a board of doctors, compensation and action against the officers responsible.14<\/sup><\/a> They were represented by Kapila Hingorani, the advocate who had brought the Hussainara Khatoon<\/span> petition the year before.15<\/sup><\/a> The court called for medical reports, which showed that 8 of the 10 petitioners had lost their sight wholly or partly, and had the prisoners brought to Delhi for examination. On 1 December 1980, it directed the Registrar and other officers to visit the jail and record the prisoners’ statements out of the hearing of police and jail officials.16<\/sup><\/a> The proceedings produced a series of orders and judgments rather than a single ruling. The Supreme Court’s intervention thus brought to light not only the gravity of the allegations but also the difficulties faced by prisoners attempting to bring their grievances before the judicial system.<\/p>\n

From charity to constitutional duty: Hoskot, Hussainara and Khatri<\/p>\n

The Supreme Court had begun this work before Bhagalpur<\/span>. In M.H. Hoskot<\/span> v. State of Maharashtra<\/span><\/a>17<\/sup><\/a>, Krishna Iyer J. held that a prisoner who cannot afford counsel for an appeal is entitled to legal assistance as part of fair procedure under Article 21, and that providing it is the State’s duty rather than the Government’s charity. In Hussainara Khatoon (IV)<\/span> v. State of Bihar<\/span><\/a>18<\/sup><\/a>, decided on 9 March 1979, the court held that free legal services to an indigent accused are an essential ingredient of a reasonable, fair and just procedure, reading Article 21 together with Article 39-A, which the 42nd Amendment had added to the directive principles of State policy in 1976. An earlier order in the same litigation had recognised speedy trial as part of Article 21.19<\/sup><\/a><\/p>\n

The case of Khatri<\/a><\/span> carried this forward to the stage at which most accused persons first meet the courts. In its judgment of 19 December 1980, a Bench of P.N. Bhagwati and A.P. Sen JJ held that the State’s duty to provide free legal services arises not only at trial but when the accused is first produced before the Magistrate, and again whenever he is remanded.20<\/sup><\/a> The State could not avoid this obligation by pleading financial or administrative inability.21<\/sup><\/a> Nor was it enough that legal aid existed in law. The court held that the right would be illusory unless the magistrate or Sessions Judge before whom the accused appears informs him of it: Leaving a poor and illiterate accused to ask would make a mockery of legal aid, which would become merely a paper promise.22<\/sup><\/a> The court also expressed its unhappiness that the judicial magistrates had not asked the blinded prisoners, when they were first produced, whether they wanted legal representation.23<\/sup><\/a> The burden thus moved to the State. It was no longer for the accused to know of legal aid and ask for it; the State, acting through its courts, had to offer it.<\/p>\n

What if accused never even asked? — Suk Das: Giving the Duty to Inform a Consequence<\/p>\n

\"\"<\/p>\n

So, what happens when an accused, out of sheer ignorance, never asks for it? Does his silence amount to an implied waiver of a right he did not know he possessed?<\/p>\n

This is where this article moves beyond the historical incident and reaches a deeper constitutional question. The case of Khatri<\/a> stated the duty to inform, but it did not say what follows when a court ignores it. That question reached the court five years later in Suk Das<\/span> v. State (UT of Arunachal Pradesh)<\/span><\/a>24<\/sup><\/a>. Suk Das had been tried and convicted without a lawyer, and nobody had told him that he could have one at the State’s expense. It was urged that he had never applied for legal aid.25<\/sup><\/a> The court, speaking through Bhagwati CJ, rejected the argument. Observing that a large part of the population was poor and illiterate and could not be expected to know of the right, it reaffirmed the duty laid down in Khatri<\/a> and held that the trial had violated Article 21.26<\/sup><\/a> The conviction was set aside.27<\/sup><\/a><\/p>\n

A right that depends entirely on the rights-holder’s prior awareness of its existence, the court reasoned, was not really a right at all but merely a paper promise.28<\/sup><\/a> The court, on given reasoning, held that Magistrates and Sessions Judges are under a positive, self-executing obligation to inform every unrepresented accused of his entitlement to free legal aid, irrespective of whether he has asked for it, and that failure to discharge this obligation vitiates the resulting trial as a violation of Article 21.29<\/sup><\/a><\/p>\n

Suk Das<\/span><\/a> thus supplied the sanction that Khatri<\/a> had left open. A court’s failure to tell an unrepresented accused about legal aid could no longer be excused by pointing to his silence; it vitiated the trial. The court has since reaffirmed that the right arises when the accused is first produced before a Magistrate.30<\/sup><\/a> After this judgment, ignorance of a right could never again be treated, in Indian criminal procedure, as a knowing waiver of it.<\/p>\n

Constitutional promise and the role of legal institutions<\/p>\n

A constitutional promise, however noble, cannot fulfil its purpose merely by finding a place in the pages of the Constitution<\/a>. It must travel beyond the courtroom, reach the ordinary citizen and become a reality in the life of someone who has neither the financial resources nor the social influence to defend themselves. The Supreme Court of India played a significant role in bridging this gap by transforming the idea of legal aid into an essential component of the right to a fair procedure. Even before the Bhagalpur case<\/span>, the court had begun to recognise the plight of those who remained imprisoned for years without their trials being concluded. In Hussainara Khatoon (IV) v. State of Bihar<\/a>31<\/sup><\/a>, the court drew attention to the disturbing condition of undertrial prisoners in Bihar and emphasised that speedy trial was an essential part of Article 21. It also recognised the State’s responsibility to provide free legal services to indigent accused persons.32<\/sup><\/a> This judicial concern acquired further significance in Khatri (II)<\/span> v. State of Bihar<\/span><\/a>33<\/sup><\/a>, arising out of the Bhagalpur blinding incident. In its judgment dated 19 December 1980, the Supreme Court made it clear that free legal services were an essential ingredient of a reasonable, fair and just procedure under Article 21.34<\/sup><\/a> More importantly, the court refused to confine this obligation to the stage of trial. It held that an indigent accused must be provided legal assistance even when first produced before a Magistrate and at subsequent remand proceedings. The court also recognised that a right to legal aid would become nothing more than a paper promise if a poor and illiterate accused person was expected to know of that right and demand it themselves. The responsibility, therefore, extended to informing the accused of their entitlement to legal assistance. The court further made it clear that the State could not escape this constitutional obligation by pleading financial or administrative difficulties.35<\/sup><\/a> The principle was subsequently reinforced in Suk Das<\/span> v. State (UT of Arunachal Pradesh)<\/span><\/a>36<\/sup><\/a>, wherein the court emphasised that an accused person who is unable to afford legal representation shall be provided free legal assistance.37<\/sup><\/a><\/p>\n

\"\"<\/p>\n

Judicial recognition could not by itself create a system that reached every police station and jail. Parliament enacted the Legal Services Authorities Act, 1987<\/a> to provide one. It came into force on 9 November 1995, the date now observed as National Legal Services Day.38<\/sup><\/a> The Act created the National Legal Services Authority (NALSA), State Legal Services Authority, District Legal Services Authority, and Taluk Committee to provide free and competent legal services and to organise Lok Adalat.39<\/sup><\/a> Of particular relevance to the story of Bhagalpur, Section 12(g<\/span>) of the Legal Services Authorities Act, 1987, which expressly recognises persons “in custody” as a category entitled to free legal services, thereby ensuring that access to legal representation is not denied merely because an individual is incarcerated.40<\/sup><\/a> This provision gives particular significance to the plight of prisoners and undertrial accused persons, whose circumstances often make them dependent upon the State for access to legal representation. The Code’s legal-aid provision has since been carried into the Nagarik Suraksha Sanhita, 2023<\/a>.41<\/sup><\/a> What Khatri<\/a> and Suk Das<\/span><\/a> established as constitutional duties now rests on statute and on standing institutions.<\/p>\n

Has justice finally reached those behind bars<\/p>\n

The Bhagalpur prisoners were, above all, undertrials, and their successors are numerous. At the end of 2023, 389,910 of the 530,333 people in Indian prisons, or 73.5 per cent, had not been convicted.42<\/sup><\/a> Most of them depend on legal aid to obtain bail and a fair trial. NALSA has also introduced a Legal Aid Defense Counsel System, under which full-time defence counsel attached to legal services authorities represent accused persons in criminal cases.43<\/sup><\/a><\/p>\n

The Bhagalpur blinding incident serves as an important reminder of the vulnerability of prisoners and the need to protect their legal and human rights.44<\/sup><\/a> However, the question today is whether prisoners are actually receiving justice under the present legal aid system. India has established institutions such as the NALSA to ensure that poor and disadvantaged people, including prisoners, receive free legal assistance.45<\/sup><\/a> However, the existence of these institutions does not necessarily mean that every prisoner receives quality legal representation. Even today, several challenges remain. Many prisoners may be unaware of their right to free legal aid, face difficulties in accessing legal aid lawyers or receive inadequate assistance due to poor communication, lack of preparation and delays in legal proceedings.46<\/sup><\/a> Simply appointing a lawyer does not guarantee proper advice, effective representation or a fair opportunity to defend oneself.47<\/sup><\/a> NALSA has undoubtedly created an important framework for providing free legal services, but its effectiveness depends on proper implementation, regular access to lawyers, accountability and the quality of legal assistance provided.48<\/sup><\/a><\/p>\n

Therefore, the real question is not whether legal aid exists, but whether it reaches those who need it the most. Ultimately, there is a significant difference between having a legal right and being able to exercise that right. A prisoner entitled to free legal assistance gains little unless the assistance reaches him and is competent.<\/p>\n

Conclusion: A final reflection<\/p>\n

Bhagalpur exposed what happens when the State that holds a prisoner also controls his only route to a remedy. Khatri<\/a> answered with a duty: Legal aid from first production, offered without waiting to be asked. Suk Das<\/a> made that duty enforceable by setting aside a conviction obtained in breach of it, and the Legal Services Authorities Act<\/a> gave it institutions.<\/p>\n

And so, on Legal Services Day<\/span>, perhaps the question we must ask is not merely how far our legal aid system has progressed, but how many people has actually managed to reach. Because justice should not depend upon one’s ability to demand it, one’s awareness of the law or one’s capacity to afford it. When legal aid fails to reach the powerless, justice does not merely become delayed or denied, it becomes a privilege available only to those who can afford to seek it.<\/p>\n<\/div>\n\n

*Editorial Assistant, EBC Publishing Pvt. Ltd. Author can be reached at: disha.dheeman@ebcpublishing.in<\/a><\/span><\/strong><\/p>\n

1.<\/a> (1981) 1 SCC 627<\/a>.<\/p>\n

2.<\/a> Anil Yadav<\/span> v. State of Bihar<\/span><\/a>, (1982) 2 SCC 195<\/a>, para 1.<\/p>\n

3.<\/a> Anil Yadav<\/span> v. State of Bihar<\/span><\/a>, (1982) 2 SCC 195<\/a>, para 1.<\/p>\n

4.<\/a> The 1980 UPI Report, 2026 United Press International, 28-11-1980, available at <https:\/\/www.upi.com\/Archives\/1980\/11\/28\/Paper-charges-prisoners-were-blinded-by-police\/3880344235600\/<\/a>>.<\/p>\n

5.<\/a> Faizan Ahmad, “Blind Rage and Anguish, 30 Yrs on”, Times of India<\/span>, 16-4-2010, available at <https:\/\/timesofindia.indiatimes.com\/city\/patna\/blind-rage-and-anguish-30-yrs-on\/articleshow\/5814134.cms<\/a>>.<\/p>\n

6.<\/a> (1981) 1 SCC 627<\/a>.<\/p>\n

7.<\/a> Anil Yadav<\/span> v. State of Bihar<\/span><\/a>, (1982) 2 SCC 195<\/a>, para 3. See<\/span>, the medical report concerning prisoner Anil Yadav, which records the condition of his eyes and the nature of the injuries.<\/p>\n

8.<\/a> Anil Yadav<\/span> v. State of Bihar<\/span><\/a>, (1982) 2 SCC 195<\/a>, para 4. The Supreme Court’s observations on the medical findings and violation of constitutional safeguards.<\/p>\n

9.<\/a> Anil Yadav<\/span> v. State of Bihar<\/span><\/a>, (1982) 2 SCC 195<\/a>, para 2. Arjun Goswami’s application, 20-11-1979.<\/p>\n

10.<\/a> Anil Yadav<\/span> v. State of Bihar<\/span><\/a>, (1982) 2 SCC 195<\/a>.<\/p>\n

11.<\/a> Anil Yadav<\/span> v. State of Bihar<\/span><\/a>, (1982) 2 SCC 195<\/a>. The same paragraph records the 11 prisoners’ complaints dated 30-7-1980 and the Sessions Judge’s response dated 5-8-1980.<\/p>\n

12.<\/a> Hussainara Khatoon (IV)<\/span> v. State of Bihar<\/span><\/a>, (1980) 1 SCC 98<\/a>.<\/p>\n

13.<\/a> Arun Sinha, “The Bhagalpur Blindings”, The Indian Express<\/span>, 22-11-1980.<\/p>\n

14.<\/a> Anil Yadav<\/span> v. State of Bihar<\/span><\/a>, (1982) 2 SCC 195<\/a>, para 3.<\/p>\n

15.<\/a> Khatri (2)<\/span> v. State of Bihar<\/span><\/a>, (1981) 1 SCC 627<\/a>.<\/p>\n

16.<\/a> Anil Yadav<\/span> v. State of Bihar<\/span><\/a>, (1982) 2 SCC 195<\/a><\/p>\n

17.<\/a> (1978) 3 SCC 544<\/a>.<\/p>\n

18.<\/a> (1980) 1 SCC 98<\/a>; Constitution of India<\/a>, Art. 39-A<\/a>.<\/p>\n

19.<\/a> Hussainara Khatoon (I)<\/span> v. State of Bihar<\/span><\/a>, (1980) 1 SCC 81<\/a>.<\/p>\n

20.<\/a> Khatri (2)<\/span> v. State of Bihar<\/span><\/a>, (1981) 1 SCC 627<\/a>.<\/p>\n

21.<\/a> Khatri (2)<\/span> v. State of Bihar<\/span><\/a>, (1981) 1 SCC 627<\/a>.<\/p>\n

22.<\/a> Khatri (2)<\/span> v. State of Bihar<\/span><\/a>, (1981) 1 SCC 627<\/a>, para 6.<\/p>\n

23.<\/a> Khatri (2)<\/span> v. State of Bihar<\/span><\/a>, (1981) 1 SCC 627<\/a>, para 6.<\/p>\n

24.<\/a> (1986) 2 SCC 401<\/a>.<\/p>\n

25.<\/a> Suk Das<\/span> v. State (UT of Arunachal Pradesh)<\/span><\/a>, (1986) 2 SCC 401<\/a>.<\/p>\n

26.<\/a> Suk Das<\/span> v. State (UT of Arunachal Pradesh)<\/span><\/a>, (1986) 2 SCC 401<\/a>, paras 5—6.<\/p>\n

27.<\/a> Suk Das<\/span> v. State (UT of Arunachal Pradesh)<\/span><\/a>, (1986) 2 SCC 401<\/a>, paras 6-7.<\/p>\n

28.<\/a> Suk Das<\/span> v. State (UT of Arunachal Pradesh)<\/span><\/a>, (1986) 2 SCC 401<\/a>, para 6.<\/p>\n

29.<\/a> Suk Das<\/span> v. State (UT of Arunachal Pradesh)<\/span><\/a>, (1986) 2 SCC 401<\/a>, paras 6-7.<\/p>\n

30.<\/a> Mohd. Ajmal Amir Kasab<\/span> v. State of Maharashtra<\/span><\/a>, (2012) 9 SCC 1<\/a>; see also Rajoo<\/span> v. State of M.P.<\/span><\/a>, (2012) 8 SCC 553<\/a>.<\/p>\n

31.<\/a> (1980) 1 SCC 98<\/a>.<\/p>\n

32.<\/a> Hussainara Khatoon (IV)<\/span> v. State of Bihar<\/span><\/a>, (1980) 1 SCC 98<\/a>.<\/p>\n

33.<\/a> (1981) 1 SCC 627<\/a>.<\/p>\n

34.<\/a> Khatri (II)<\/span> v. State of Bihar<\/span><\/a>, (1981) 1 SCC 627<\/a>.<\/p>\n

35.<\/a> Khatri (II)<\/span> v. State of Bihar<\/span><\/a>, (1981) 1 SCC 627<\/a>, particularly the Court’s observations concerning the obligation to provide legal assistance at the first production before a Magistrate and subsequent remand proceedings, and the duty to inform indigent accused persons of their right to legal aid.<\/p>\n

36.<\/a> (1986) 2 SCC 401<\/a>.<\/p>\n

37.<\/a> Suk Das<\/span> v. State (UT of Arunachal Pradesh)<\/span><\/a>, (1986) 2 SCC 401<\/a>.<\/p>\n

38.<\/a> Legal Services Authorities Act, 1987<\/a>.<\/p>\n

39.<\/a> Legal Services Authorities Act, 1987<\/a>, Ss. 3, 6, 9, 11-A and 19.<\/p>\n

40.<\/a> Legal Services Authorities Act, 1987<\/a>, S. 12(g<\/span>).<\/p>\n

41.<\/a> Nagarik Suraksha Sanhita, 2023<\/a>, S. 341<\/a>.<\/p>\n

42.<\/a> National Crime Records Bureau, Prison Statistics India, 2023<\/span>, (2025), Tables 2.1-2.2, available at <PSI-2023.pdf<\/a>>.<\/p>\n

43.<\/a> National Legal Services Authority, Legal Aid Defense Counsel Scheme, 2022, available at <https:\/\/uttarpradesh.nalsa.gov.in\/scheme\/legal-aid-defense-counsel-scheme-modified-scheme-2022\/<\/a>>.<\/p>\n

44.<\/a> Khatri (2)<\/span> v. State of Bihar<\/span><\/a>, (1981) 1 SCC 627<\/a>.<\/p>\n

45.<\/a> Constitution of India<\/a>, Art. 39-A<\/a>; The Legal Services Authorities Act, 1987<\/a>, Ss. 4<\/a> and 12(g<\/span>)<\/a>.<\/p>\n

46.<\/a> Legal Services Authorities Act, 1987<\/a>, S. 12(g<\/span>)<\/a>.<\/p>\n

47.<\/a> Hussainara Khatoon (IV)<\/span> v. State of Bihar<\/span><\/a>, (1980) 1 SCC 98<\/a>; Khatri (2)<\/span> v. State of Bihar<\/span><\/a>, (1981) 1 SCC 627<\/a>.<\/p>\n

48.<\/a> National Legal Services Authority (Free and Competent Legal Services) Regulations, 2010<\/a>, Regs. 8<\/a>, 10<\/a>; Legal Services Authorities Act, 1987<\/a>, S. 4<\/a>.<\/p>\n","protected":false},"excerpt":{"rendered":"

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