DR.

RAM MANOHAR LOHIYA

NATIONAL LAW UNIVERSITY
SESSION 2019-20

FINAL DRAFT

SUBJECT – CRIMINAL PROCEDURE CODE

TOPIC - Rights of Victims in Indian Criminal Justice

System
SUBMITTED TO SUBMITTED BY
Dr. Prem Kumar Gautam NEHA GUPTA

ASST. PROF. OF LAW ROLL NO. 085

Vth SEMESTER

B.A.L.L.B (Hons.)
 INTRODUCTION
‘Tears shed for the accused are traditional and trendy but has the law done anything for the
victim of the crime, the unknown martyrs.’

This remark by the Hon’ble Justice Krishna Iyer aptly describes the plight of victims in the criminal
justice system in our country. The victim is almost a forgotten entity in the criminal system rather
the irony is that the victim sets the wheel of justice moving by giving information to the state
instrumentalities without which the entire system could collapse. But still, the role of victim in the
overall process is insignificant.

India derived its criminal justice system from the British model. The penal philosophy in India has
accepted the concepts of prevention of crime and treatment and rehabilitation of criminals, which
have been reiterated by many judgments of the Supreme Court. Victims have no rights under the
criminal justice system, and the state undertakes the full responsibility to prosecute and punish the
offenders by treating the victims as mere witnesses.

Victims have few legal rights to be informed, present and heard within the criminal justice system.
Victims do not have to be notified of court proceedings or of the arrest or release of the defendant,
they have no right to attend the trial or other proceedings, and they have no right to make a
statement to the court at sentencing or at other hearings. Moreover, victim assistance programs are
virtually non-existent.

The term victim is defined in Criminal Procedure Code 1973 section 2(wa) as ‘Victim’ means a
person who has suffered any loss or injury caused by reason of the act or omission for which the
accused person has been charged and the expression “victim" includes his or her guardian or legal
heir.

The primary goal of a criminal justice system is undoubtedly the protection of individual life,
liberty, and property. The modern criminal law is supposed to represent the ambitions and norms of
the society as well as to punish and reform the criminals but it overlooks the victim. The criminal
justice system in our country is based on the premise that ‘hundred guilty men should be let free,
but one innocent man should not be punished’.

The jurisprudence of our criminal system traces its roots in the reformatory theory of punishment
which aims to achieve societal balance by rehabilitating the criminals. The Indian Criminal
jurisprudence which is embodied mainly in Indian Penal Code (‘IPC’) and Code of Criminal
Procedure (‘CrPC) has umpteen provisions to ensure that the liberty of is not chained such as
presumption of innocence, the right to legal assistance, right to fair trial, right of the accused to be
informed of charges before trial, and right to present a defense. During the unending process of trial
in our country, the sufferings of victims are entirely overlooked by sympathy for the accused. But
of late, it has been realized by the courts that the ultimate wrong has been done to the victim and
his welfare is of the same importance as that of the accused. The attitude has begun to change.
Many countries around the world have recognized the need to provide rehabilitation and legal
assistance to help them recover from the effects of crime.

RESEARCH QUESTIONS
 What are the different rights available to victims?
 What are the changes made in CrPC for the betterment of the victims?
 How Judiciary protects the right of the victims?

OBJECTIVES
 To find out the rights which are available to victims in India.
 To find out the changes made in CrPC for the betterment of the victims.
 To analyze the role of Judiciary in protecting the rights of victims.

RESEARCH METHODOLOGY
My method of research is doctrinal and Qualitative. This project involves research and analysis of
existing research work and data, hence replacing a “secondary research methodology”. The data
abstraction sources include previous research paper on related topic as well as articles and journals.

RIGHTS AVAILABLE TO VICTIMS IN INDIA

Exactly who the law considers a "victim" entitled to a particular right. Victims of any violent crime,
whether felony or misdemeanor, victims of serious juvenile offences etc. The word ‘victim’ is
defined in section 2(wa) of CrPC. It was added in the statute in 2009 by an amendment.

It defines the victim as ‘A person who has suffered any loss or injury caused by reason of the act or
omission for which the accused person has been charged and the expression “victim” includes his
or her guardian or legal heir.’ Victims' rights to be extended to the surviving family members of a
homicide victim, or to the parent, guardian, or other relative of a minor, disabled or incompetent
victim, a victim's legal representative or another person designated by the victim may also exercise
rights on the victim's behalf.1 Along with general rights for crime victims, special rights for certain
groups of crime victims with unique needs are a must. These include victims of sexual assault,
domestic violence or stalking, or victims who are elderly, young children, or victims with
disabilities.

The core rights of victims include2 –

 The right to be heard, attend and participate in criminal justice proceedings

 The right to apply for compensation
 The right to protection from intimidation and harassment
 The right to restitution from the offender
 The right to prompt return of personal property seized as evidence
 The right to speedy trial
 The right to enforcement of these rights

RIGHT TO ATTEND AND PARTICIPATE IN PROCEEDINGS

Crime victims and their families be given the right to be present during criminal justice
proceedings. This right is important to victims, who often want to see the criminal justice process at
work. They may want to hear counsel’s arguments and view the reactions of the judge, witnesses
and the defendant.

The victim's right to attend proceedings includes the right to attend the trial, sentencing, and parole
hearing of the offender, but may include other proceedings as well. A victim’s right to attend the
trial is often limited in cases where the victim is also a witness in the criminal case. A longstanding
rule of evidence provides for the exclusion, or “sequestering,” of witnesses during the trial. This
rule was designed to prevent witnesses from being influenced by the testimony of other witnesses
in the case. Some jurisdictions require any witness to be excluded on the request of a party while
others leave exclusion to the discretion of the judge. Increasingly, jurisdictions are changing this
rule on witnesses to allow victims to remain in the courtroom even when they will be a witness, or
to require the court to first rule that the victim’s testimony is likely to be influenced by the
testimony of other witnesses before ordering the victim to be kept out of the courtroom.

RIGHT TO COMPENSATION

Crime victim compensation should be a government program designed to reimburse victims of

violent crime for their out-of-pocket expenses relating to the crime. Surviving or affected family

1
Jyosna Dighe, ‘Victims’ Right in India’ <http://www.legalservicesindia.com/article/1315/Victims-Rights-in-
India.html>.
2
Jyosna Dighe, ‘Victims’ Right in India’ <http://www.legalservicesindia.com/article/1315/Victims-Rights-in-
India.html>.
members may also be eligible for limited compensation. Generally, victims apply to the
compensation program of the state where they live or where the crime occurred. Compensation can
be paid even when no one is arrested or convicted for the crime.

Direct victims of violent crime, or to their surviving family members. Victims of serious financial
crime to seek compensation for counseling expenses. Those who pay a victim’s medical or funeral
expenses should be eligible for direct reimbursement from the compensation program. In order to
be eligible, the victim must generally have reported the crime and cooperated in the prosecution of
the case. They must also file an application for compensation within a certain time period. Victims
may be ineligible if their own misconduct contributed to their injuries—for example, if they were
injured while they were committing a crime.

Compensation programs will be medical expenses, counseling expenses, lost wages, and funeral
expenses.

RIGHT TO BE HEARD

One of the most significant rights for crime victims is the right to be heard during critical criminal
justice proceedings that affect their interests. Such participation is the primary means by which
victims play a proactive role in the criminal justice process. When a crime victim is allowed to
speak at the sentencing hearing, or to submit a victim impact statement regarding the impact of the
offence on the victim and the victim’s family, there is an acknowledgment by the criminal justice
system of the personal nature of the crime and of the harm suffered.

Prosecutor to obtain the views of the victim before a disposition is final, whether this involves a
plea agreement, dismissal of charges, or a pretrial diversion of the defendant. The prosecutor to
certify to the court that he or she has consulted the victim before a plea can be accepted.

RIGHT TO BE INFORMED

The criminal justice system is often required to provide general information of interest to victims.
Give victims or their families the right to be notified of important, scheduled criminal proceedings
and the outcomes of those proceedings. Notify victims when hearings have been cancelled and
rescheduled. Victims must have the right to be informed of various legal rights, including the rights
to: attend a proceeding and/or submit a victim impact statement; sue the offender for money
damages in the civil justice system; have a court order that they be protected from the offender
and/or the offender's family and associates.3

3
S Muridharan, ‘Rights of Victims in Indian Criminal Justice System’ [2004] http://www.ielrc.org/content/a0402.pdf>.
There are dozens of events or proceedings in the ordinary criminal justice process for which notice
may be required by statute. These commonly include:

 Arrest of the accused

 Arraignment of the defendant
 Bail release and related proceedings
 Pre-trial release and related proceedings
 Dismissal of Charges
 Negotiated pleas and entry of plea bargain
 Appeal process and related proceedings

RIGHT TO PROTECTION

Give crime victims the right to protection during the criminal justice process. This right may take
the form of a generally stated right to protection, or may include specific protective measures. Most
defined are criminal offences of intimidation of victims or witnesses.

Measures to protect crime victims take various forms. Some examples include:

 Police escorts to and from court

 Secure waiting areas separate from those of the accused and his/her family, witnesses and
friends during court proceedings;
 Witness protection programs
 Residence relocation
 Denial of bail or imposition of specific conditions of bail release—such as no contact
orders—for defendants found to present a danger to the community or to protect the safety
of victims and/or witnesses.4

RIGHT TO RESTITUTION

The term "restitution" generally refers to restoration of the harm caused by the defendant, most
commonly in the form of payment for damages. It can also refer to the return or repair of property
stolen or damaged in the course of the crime.

Restitution should cover any out-of-pocket losses directly relating to the crime, including:

 Medical expenses and therapy costs

 Prescription charges
 Lost wages

4
K Chockalingam, ‘Measures for victims of crim in Indian Criminal Justice System’ <
https://www.unafei.or.jp/publications/pdf/RS_No81/No81_11VE_Chockalingam.pdf>.
  Counseling costs
 Lost or damaged property
 expenses related to participating in the criminal justice process (such as travel costs and
child care expenses);
 Insurance deductibles
 Other expenses that resulted directly from the crime.

RIGHT TO SPEEDY TRIAL

The right to a speedy trial is first mentioned in that landmark document of English law, the Magna
Carta.5 Article 21 declares that “no person shall be deprived of his life or personal liberty except
according to the procedure laid by law.” Justice Krishna Iyer while dealing with the bail petition in
Babu Singh v. State of UP6 remarked, "Our justice system even in grave cases, suffers from slow
motion syndrome which is lethal to 'fair trial' whatever the ultimate decision. Speedy justice is a
component of social justice since the community, as a whole, is concerned in the criminal being
condignly and finally punished within a reasonable time and the innocent being absolved from the
inordinate ordeal of criminal proceedings."

THE RIGHT TO ENFORCEMENT/REMEDIES OF VICTIMS

Since crime victims have been afforded legal rights, there is need to ensure that those rights are
enforced. Enforcement Mechanisms The victims must have “legal standing” to assert their rights.
Because a crime victim is not a “party” to the case—that status is limited to the defendant and the
prosecuting jurisdiction (such as the state)—legal standing for victims must be automatic and must
be provided by statute or court ruling.

Aside from general “standing” to assert rights, some jurisdictions have other limited court options
for enforcement. They may permit a victim to seek a writ of mandamus, a court order directed to an
agency to comply with the law, or allow other limited actions. Creation of a designated entity to
receive, investigate, and attempt to resolve crime victim complaints. There must be an ombudsman
or state victim advocate; in others, it may be a committee or board. Give the investigatory agency
the ability to impose consequences on offending agencies or officials found to have violated a
victim’s rights.

5
Prateekhanda, ‘Constitutional Right to Speedy Trial’ < http://www.legalservicesindia.com/article/571/Constitutional-
Right-to-Speedy-Trial.html>.
6
Babu Singh v. State of UP, 1978 SCC (1) 579.
ROLE OF JUDICIARY IN PROTECTING RIGHTS
OF VICTIMS
Justice traditionally has been understood to involve prosecution, conviction and punishment of
guilty in order to restore public order, security and respect for rule of law. The victims, survivors
and witnesses go to the altar of the court for a variety of reasons: the desire for the truth to be
known, to speak for the dead, to demand accountability and to demand justice. Some years ago,
Justice Albie Sachs, a member of the Supreme Court of South Africa said: “Justice is not only in
the end result; it is also in the process”. These words spell out the expanded meaning of justice in
the present day’s context. The preoccupation of the justice delivery system ought to be not only
with whether a conviction or acquittal was secured, but whether the judicial system was able to
inspire the confidence of victims and witnesses to truthfully testify before it in order to ensure
conviction of the guilty.7

Access to justice is the availability of relief to the victim by various judicial or non-judicial
institutions. The victims who set the criminal justice system in motion by giving information are
left at the mercy of Station Inspector (SI) who sometimes even refuses to register the complaint.
The victim as an informant is entitled to a free copy of FIR but most of the times it is not given.
The position of women and children who happen to be a victim can be tragic especially in case of
rape victims where delay in collection of samples can render the entire case baseless.

In Sakshi v. Union of India8, the Supreme Court mandated ‘in-camera’ trials particularly when the
victim is a child or rape victim to maintain their dignity.

In Nirmal Singh Kahlon v. State of Punjab,9 the Hon’ble Apex Court observed that the right to
fair investigation and trial is applicable to the accused as well as the victim and such a right to a
victim is provided under Article 21 of the Constitution of India. Ergo, a victim of a crime is equally
entitled to a fair investigation.

In Bodhisattwa Gautam v. Subhra Chakraborty10, the Supreme Court held that if the court trying
an offence of rape has jurisdiction to award compensation at the final stage, the Court also has the
right to award interim compensation. The court, having satisfied the prima facie culpability of the
accused, ordered him to pay a sum of Rs.1000 every month to the victim as interim compensation
along with arrears of compensation from the date of the complaint.

7
Nida Zainab Naqvi, Rights of Victims in Indian Criminal Justice System – An Analysis, [February 22, 2016] <
https://www.eurasiareview.com/22022016-rights-of-victims-in-indias-criminal-justice-system-analysis/>.
8
Sakshi v Union of India, (2004) 5 SCC 518.
9
Nirmal Singh Kahlon v State of Punjab, (2009) 1 SCC 441.
10
Bodhisattwa Gautam v. Subhra Chakraborty, AIR 1996 SC 922.
Restitution can be defined as restoring to an earlier position or returning the stolen thing to the real
owner. The right of victims to restitution has not gained statutory recognition. The courts have
inclined to examine the plea of victims for redressal of the losses suffered during violent incidents
including riots and cast clashes.

The principle that is evoked is ‘culpable inaction’ under which the state instrumentalities are
expected to anticipate the losses or damage to public and private property where the victims have
no control. The courts have gone as far as to find the state liable only where a definite failure on its
part has resulted in a loss. In R. Gandhi v. Union of India11, the Madras High Court, acting on the
report of a commissioner appointed by it to assess the losses directed payment of varying amount of
compensation for the loss of property of Sikh community in Coimbatore.

The right of victim compensation has been well recognized under the CrPC but is available only
where a substantive sentence of the fine was imposed and was limited to the amount of fine
actually realized. Section 357(3) authorizes the magistrate to impose fine where fine has not been
imposed. However, this section is invoked sparingly and inconsistently by the courts. The 152nd
Report of the Law Commission had recommended the introduction of section 357-A prescribing
inter alia that compensation should be awarded at the time of sentencing to the victims of crime
amounting to Rs. 25,000/- in case of bodily injury, not resulting in death and Rs 1,00,000/- in case
of death. Since the recommendation of the report had not been incorporated by the government, the
154th Report mandated the incorporation of section 357-A.

The higher courts have established a base for victim compensation even in custodial deaths. The
Supreme Court in Nilabati Behera v. State of Orissa12 observed that “it was not enough to relegate
the heirs of victims of custodial deaths to the ordinary remedy of civil suit". The right to get relief
or compensation from public law courts exercising writ jurisdiction was explicitly recognized.

11
R. Gandhi v Union of India, AIR 1989 Mad 205.
12
Nilabati Behera v State of Orissa, (1993) 2 SCC 746.
CHANGES MADE IN CRPC FOR THE
BETTERMENT OF VICTIMS
Various changes were made in CrPC for the betterment of the victims. Some of them are as
follows:13

 Victim Can engage Advocate to support and help the Prosecution

Under section 24(8) the following proviso was inserted, namely— ‘Provided that the Court may
permit the victim to engage an advocate of his choice to assist the prosecution under this sub-
section.’

 Statement of the Victim to be done in a safe place or a place of her choice and by a
women police officer

In section 157(1), after the proviso, another provision was added, namely—

‘Provided further that in relation to an offence of rape, the recording of statement of the victim shall
be conducted at the residence of the victim or in the place of her choice and as far as practicable by
a woman police officer in the presence of her parents or guardian or near relatives or social worker
of the locality.’

 Use of Audio Video for Statements

In section 161(3), the following provisos was inserted, namely —

‘Provided that statement made under this sub-section may also be recorded by audiovideo
electronic means.’

 Use of Audio Video for Confession/Statement

In section 164(1), the following proviso was added -

‘Provided that any confession or statement made under this sub-section may also be recorded by
audio-video electronic means in the presence of the advocate of the person accused of an offence:

Provided further that no confession shall be recorded by a police officer on whom any power of a
Magistrate has been conferred under any law for the time being in force.’

 Investigations of Child Sex Abuse to be done in time bound

In section 173(1), the following sub-section was inserted, namely—

13
Changes in CrPC for the betterment of Victims, [June 23, 2009]
<https://indialawyers.wordpress.com/2009/06/23/changes-in-crpc-for-the-betterment-of-victims/>.
§173(1A) - The investigation in relation to rape of a child may be completed within three months
from the date on which the information was recorded by the officer in charge of the police station.’

In section 173(2), after clause (g), the following clause was inserted -

§173(2)(h) - whether the report of medical examination of the woman has been attached where
investigation relates to an offence under sections 376, 376A, 376B, 376C or 376D of the Indian
Penal Code.

 Witness Can Be Done By Using Electronic Means

In section 275(1) the following proviso was inserted, namely:—

‘Provided that evidence of a witness under this sub-section may also be recorded by audio-video
electronic means in the presence of the advocate of the person accused of the offence.’

 In Camera Trials and identity protection

In section 327(2), after the proviso, the following proviso was inserted- ‘Provided further that in
camera trial shall be conducted as far as practicable by a woman Judge or Magistrate.’

In section 327(3), the following proviso was inserted – ‘Provided that the ban on printing or
publication of trial proceedings in relation to an offence of rape may be lifted, subject to
maintaining confidentiality of name and address of the parties.’

 Victim Compensation

After section 357 the following section was inserted -

§357A – Victim Compensation Scheme:

(1) Every State Government in co-ordination with the Central Government shall prepare a scheme
for providing funds for the purpose of compensation to the victim or his dependents who have
suffered loss or injury as a result of the crime and who require rehabilitation.

(2) Whenever a recommendation is made by the Court for compensation, the District Legal Service
Authority or the State Legal Service Authority, as the case may be, shall decide the quantum of
compensation to be awarded under the scheme referred to in sub-section (1).

(3) If the trial Court, at the conclusion of the trial, is satisfied, that the compensation awarded under
section 357 is not adequate for such rehabilitation, or where the cases end in acquittal or discharge
and the victim has to be rehabilitated, it may make recommendation for compensation.
(4) Where the offender is not traced or identified, but the victim is identified, and where no trial
takes place, the victim or his dependents may make an application to the State or the District Legal
Services Authority for award of compensation.

(5) On receipt of such recommendations or on the application under sub-section (4), the State or the
District Legal Services Authority shall, after due enquiry award adequate compensation by
completing the enquiry within two months.

(6) The State or the District Legal Services Authority, as the case may be, to alleviate the suffering
of the victim, may order for immediate first-aid facility or medical benefits to be made available
free of cost on the certificate of the police officer not below the rank of the officer in charge of the
police station or a Magistrate of the area concerned, or any other interim relief as the appropriate
authority deems fit.

 Right to appeal for the Victim against the verdict of the Trial Court

In section 372 the following proviso was inserted -

‘Provided that the victim shall have a right to prefer an appeal against any order passed by the
Court acquitting the accused or convicting for a lesser offence or imposing inadequate
compensation, and such appeal shall lie to the Court to which an appeal ordinarily lies against the
order of conviction of such Court.’
 CONCLUSION
The Declaration of Basic Principles of Justice for Victims of Crime and Abuse of Power by
the United Nations (‘UN Declaration’) is considered as ‘Magna Carta’ of victims rights. The UN
Declaration has accentuated the need for minimum norms and standards in international law for the
protection of victims of crime. With regard to the dismal state of the criminal justice system in the
country, the government appointed the Malimath Committee to suggest reforms to the criminal
justice system. The Malimath committee report emphasizes on ‘justice to victims’ as one its
primary objectives. It aims to provide equity to victims of crime by permitting them, as an issue of
ideal, in criminal procedures and compensation. The UN Declaration recognized four major
components of the right of victims of crime – access to justice and fair treatment, restitution,
compensation, and assistance.

Providing assistance to victims of crime is of great significance because victims have suffered
irreparable damages and harm as a result of a crime. The problems of victims and the impact of
crime are long-lasting. Therefore, the agencies of the criminal justice system should be receptive to
the needs of the victims of crime and address their issues sincerely and empathetically. Various
efforts are made to improve the criminal justice system in India by the judiciary but there is a lot to
be done in order to make a conducive environment for victims. Measures including passing a
dedicated law for victims’ welfare to sensitizing the state agencies to the needs of a victim would
ensure victim welfare.

The courts should also seek victim approval of the sentence with the goal of improving victim
satisfaction with their involvement in the justice process. Seeking victim approval in sentencing is a
way for the system to recognize that beyond the role of the state, which is impersonal, there is an
individual who has personal interest in sentencing, was directly affected by the crime, and wants to
be heard. They should also be adequately compensated and restituted. The criminal justice officials
especially the police personnel should be given special knowledge and information on the rights of
the victims in the criminal justice system. There should be a separate fund for victims’ services and
their rehabilitation.

The entire criminal legal system functions primarily and substantially to provide justice to the
victim. Giving the victims and witnesses a voice to testify in court without fear, participate in the
court proceedings and have their rights and interests protected is of utmost importance for the
legitimacy of the justice delivery system. Moreover, the present day understanding of justice
necessarily includes accessibility to courts of law. Unless the judicial system is accessible to the
people who demand justice, the system would exist only in name and not in substance. Needless to
say, victims and witnesses would be amenable to accessing the system and give truthful testimonies
only if the system guaranteed a protection of their and their families’ Privacy, security, identity and
dignity.

Many a time the victims get ostracized and blamed for misfortune they face. It is easier for the
people to blame a helpless and shattered victim rather to hate the criminal or the offender. It’s the
society’s attitude towards victims of crime that the people usually blame the victim and don’t have
the empathy for them. The criminal or the offender doesn’t face such ostracization and he/she gets
mingled in the society without any problem. Had the law been tough on the criminals and took care
of the rights of victims of crime, the situation would have been much different. The whole criminal
justice system is offender oriented. The legislature, the executive and even many times the judiciary
are concerned with the rights of the accused or the criminal. Hence, a strong message regarding
victims’ rights is not forwarded to the people by them and therefore, the society does not feel the
sympathy for the distressed victims.
 BIBLIOGRAPHY

Cases

 R. Gandhi v Union of India, AIR 1989 Mad 205.

 Nilabati Behera v State of Orissa, (1993) 2 SCC 746.
 Sakshi v Union of India, (2004) 5 SCC 518.
 Nirmal Singh Kahlon v State of Punjab, (2009) 1 SCC 441.
 Bodhisattwa Gautam v. Subhra Chakraborty, AIR 1996 SC 922.
 Babu Singh v. State of UP, 1978 SCC (1) 579.

Books

 RV Kelkar, Lectures on Criminal Procedure

 SN Mishra, The Code of Criminal Procedure

Other Sources

 Nida Zainab Naqvi, Rights Of Victims In India’s Criminal Justice System – Analysis
https://www.eurasiareview.com/22022016-rights-of-victims-in-indias-criminal-justice-
system-analysis/
 Role of Judiciary in protecting Victims Rights,
http://www.legalservicesindia.com/law/article/8/5/Role-of-Indian-Judiciary-in-Protecting-
Victims-Rights-
 Victim Rights in India, http://www.legalservicesindia.com/article/1315/Victims-Rights-in-
India.html
 Changes in CrPC for the betterment of Victims, [June 23, 2009]
<https://indialawyers.wordpress.com/2009/06/23/changes-in-crpc-for-the-betterment-of-
victims/>.
 Prateekhanda, ‘Constitutional Right to Speedy Trial’ <
http://www.legalservicesindia.com/article/571/Constitutional-Right-to-Speedy-Trial.html>.
 K Chockalingam, ‘Measures for victims of crim in Indian Criminal Justice System’ <
https://www.unafei.or.jp/publications/pdf/RS_No81/No81_11VE_Chockalingam.pdf>.