Introduction of Alternative Dispute Resolution: Criminal Justice System and Non-Violent Crimes in India

Introduction of Alternative Dispute Resolution: Criminal Justice System and Non-Violent Crimes in India

Author: Divyanshu Modi,
3rd Year BA.LLB (Hons.),
School of Law, Christ (Deemed to be University), Bengaluru. 


Flooding Litigation and huge pendency of the cases nearing to almost 3.5 crore in the criminal judicial system has led to overburdening the judiciary to provide for a solution to the public legal issues. The trust towards the decision-making power of the courts is shaken. The major problem that lies in the Criminal Judicial System in the India is that there is no practical relief to the victim. A victim in the present Criminal justice system has near to no rights except to file for a Criminal law suit. India has a Court Dispute Resolution system in the form of plea bargaining but it has its own defects and is inefficient to solve the large number of cases. Further, the scope of Section 320, which deals with Compounding of Offences, of the Criminal Procedure Code, 1973 requires to be expanded in terms of Court Dispute Resolution. In this study the author has tried to analyze the fact that why there is a need for increased participation of the victim of an offence in the Criminal trial rather than the state sidelining the victim in his own case. Secondly, the author has tried to analyze the fact that why is Restorative Justice important and how it might be helpful in reaching a much more practical decision to the problems of the victim. Thirdly, the author has tried to analyze two major aspects of the Restorative Justice i.e. Victim Compensation and Victim Offender Mediation Programs. The author in the conclusion deals with the fact as to why is Victim Compensation and Victim Offender Mediation Programs important in ensuring a practical solution to the sufferings of the victim.
Keywords: Restorative Justice, Victim Offender Mediation, Criminal Justice System, Victim Compensation, Criminal Procedure Code


Flooding litigation has led to overburdening the judiciary to provide for a solution to the public’s legal issues. With a huge pendency of the cases nearing to 58,168 only in the Supreme Court[1] and a total of 3.5 crore cases[2] in the whole country, the decision-making power of the courts is shaken. The major problem that lies in the Criminal Justice System in India is that there is no practical relief to the victim even after a long litigation process.[3] A victim in a criminal case a no rights except to file for a Criminal law case. India has a Court Dispute Resolution System in the form of Plea Bargaining but it has proven to be inefficient in various scenarios.[4] Further the scope of the of section 320 of the Criminal Procedure Code, 1973 needs to be expanded in terms of Court Dispute Resolution.

The author through this has tried to highlight the fact that why there is a need for increased participation of the victim of an offence in the Criminal trial rather than the state sidelining the victim in his own case. Secondly, the author has tried to analyze the fact that why is Restorative Justice important and how it might be helpful in reaching a much more practical decision to the problems of the victim. Thirdly, the author has tried to analyze two major aspects of the Restorative Justice i.e. Victim Compensation and Victim Offender Mediation Programs.

The author in the first chapter has analyzed the recommendations of
Malimath Committee
[5] and various Law Commission Reports to understand the requirement for increased participation of the victim in a criminal case.

In the second chapter that author has highlighted the concept of Restorative Justice and the concept of Victim Compensation. In this Chapter the author discusses the fact as how important is Restorative Justice and how it may benefit over the conventional method of dispute resolution.[6]

In the last chapter the author tries to identify as to how can Victim-Offender Mediation can be utilized in order provide practical solutions to the victims of various non serious crime (i.e. offences which do not affect the society at large). [7]

The author in the conclusion deals with the fact as to why is Victim Compensation and Victim Offender Mediation Programs important in ensuring a practical solution to the sufferings of the victim.[8]

Chapter 1: Role and Rights of Victims:

The criminal justice system in our country cries for reforms and refinements on many fronts. The inadequacies and aberrations that have been haunting the criminal justice system are too well known to be emphasized. The crude methods of investigation in which the use of third degree methods reigns supreme, ill-trained and ill-equipped police personnel lacking in people- friendly orientation, inefficient prosecuting machinery, lack of coordination between investigating and prosecuting agencies, witnesses being subjected to intimidation, tardy and long-drawn trials, and lack of accountability for the failure of prosecution, are some of the disturbing features of the criminal justice system of the present day in our country. Though in the post-independence era, there has been an increased awareness regarding the improvement of the quality of recruitment and training of police personnel, and use of scientific methods of investigation, the percentage of crime detection and the rate of conviction for serious crimes remains to be quite low quite low.[9] Inadequate number of courts and ill- trained judicial officers have compounded the problems afflicting the system. The remedy or antidote to the ailments lies not merely in undertaking legislative measures, but in refining or perhaps revamping the present system at work, so as to invigorate the criminal justice delivery system, and to put in place a welfare- oriented machinery. Towards this end, one area in which both legislative reform as well as rigorous executive action is required is in respect of meting out justice to the victims[10] of crime.

In India, the prosecution is carried on by the Public Prosecutor (“P.P.”)  who is supposed to be fair and objective in his approach. He is considered to be an officer of the court, with a duty to assist the court in arriving at its decision. The P.P. is not supposed to identify himself with by any means, fair or foul. At times, the court may permit an advocate authorized by the informant or the victim to assist the P.P., but such advocate has no independent right to present the case. His role is that of assisting the P.P. who is in sole charge of the prosecution.

The relevant provisions of the Cr.P.C. deserve refrence. Section 225, Cr.P.C., enjoins that in every trial before a court of sessions, the prosecution shall be conducted by a P.P. Section 301 bears the heading “appearance by public Prosecutors “ Section 301(1) lays down that the Public Procecuter (P.P.) or the Assistant Public Prosecutor (“A.P.P.”) who is in charge of a case may appear and plead with no written authority. Then follows section 301(2), which relating to the appearance of P.P.s. It enjoins that where a private person instructs a lawyer to prosecute any person, the P.P. or the A.P.P shall conduct the prosecution, and the lawyer so instructed can only act under the directions of the P.P. or the A.P.P., as the case maybe. However, he can, with the permission of the Court, submit written arguments after the evidence is closed. That means that the counsel engaged by a private person such as a victim or the first informant can assist the Prosecutor with the permission of the court and submit written arguments after the evidence is closed. The role of a private counsel in such an event, as pointed out by the Supreme Court in Shivkumar v. Hukum Chand,[11] is more or less that of a junior counsel who assists a senior. He cannot act independent of the P.P.

It has been stated by various authors and criminologists that the exclusion of the victim from the prosecution scene is sought to be justified by the concept that crimes are directed against the society as a whole.[12] But it is important to understand the fact that in this present system, the state being a victim, fails to render the actual victim of the crime justice.

It is argued that the rights of the victims are to be given more importance rather than state being treated as the victim. It is argued that there should be increased participation of the victim in the criminal trial.[13] To understand why there should be increased participation of the actual victim rather than the state representing the victim, one needs to understand the concept of victim-offender relationship and punishments and compensation.

At the pre-trial stage, the victim must be heard before framing of the charges. In the course of the trial, the victim’s counsel should be given the opportunity to put supplemental questions to the witnesses. In the alternative, the court itself can put such questions after considering the submission victim. On behalf of the victim, arguments – written or oral – can be received. Of course, the victim should not be allowed to question interim orders that may be passed on the application of the victim or otherwise, as it has the inevitable effect of prolonging the trial. By allowing a limited role to victims in this approach as mentioned above, the criminal justice system will give victims the much-needed satisfaction of knowing that it cares for them. At the same time, the courts will help courts to arrive at a just decision, without pandering to the retributive spirit or vengeful attitude of the victims. It will not in any way diminish the presumption of innocence in favor of the accused, nor jeopardize the due rights of the accused.

A discussion on the role and rights of the victim is incomplete without referring to various Law Commission Reports. The 42nd Report of the Law Commission of India adverted to the topic of providing reparation to the victim of an offence. It highlighted that “in recent times, the compensation aspect is regaining its importance, as a recognized ancillary to the criminal proceedings, and of course, not as the principal aim of the same.”[14] After considering the legal systems prevalent in France and Germany, which enable the victim to make a claim for compensation during the course of the criminal proceedings, the Law Commission observed as follows: We do not think that any such elaborate procedure as is provided in France or Germany would be suitable for our criminal Courts. It would be unwise to create a legal right in the person or persons injured by the offence to join in the criminal proceedings from the beginning as a regular third party. This would only lead to a mixing up of civil and criminal procedures which in our legal system are kept separate, a confusion of issues and a prolongation of a trial.[15]

The 154th Law Commission Report, which dealt with Victimology, but confined itself to a discussion on victim compensation. It did not address the issue of participation of victims in investigation and prosecution.[16]

 The topic of “Justice to Victims” engaged the attention of the Committee on Reforms of Criminal Justice System, headed by Justice V.S. Malimath. The Committee provided for various recommendation with regard to victims’ participation in the criminal proceedings:[17]

It was recommended that the victim shall be allowed to participate
in cases involving serious crimes and shall also be given suitable compensation; secondly, If the victim is dead, the legal representative shall have the right to implead himself as a party, in case of serious or grave offences. Thirdly, it was suggested that the State should provide an advocate of victim’s choice to plead on his/her behalf and the cost has to be borne by the State if the victim can’t afford it. Fourthly, it recommended that providing the victim with adequate compensation is a State obligation in all serious crimes, also whether the offender is apprehended or not, convicted or acquitted. This is to be organized in a separate legislation. In this account, it suggested that a Victim Compensation Fund can be created under the victim compensation law and the assets confiscated in organized crimes can be made part of the fund.

Considering the Recommendations of the Malimath Committee and the Reports of the Law Commission with regards to the increased participation of Victims in the Criminal Trials, it has been suggested that there should be a proper division of the functions between the state, victims, offender and community.[19]

Thus, it is highlighted through the above discussion that the central question as to whether a new jurisprudence should be developed around the model of justice that gives more procedural and distributive fairness to victims without harming offender rights or public policy?[20] The answer is yes, to the fact that, as has been pointed out previously, in order to provide an effective and satisfactory solution to the victim’s problem, it is important that the victim be an integral part of the criminal justice process.

Chapter 2: The Need for Restorative Justice:

The Theory of “Restorative Justice” is a relatively recent phenomenon has gained popularity with policy makers and academics alike. Unlike, the other theories in Criminal Law, the idea and concept of Restorative justice is still in the process of being defined. The idea that Restorative justice consist of the elements that please both liberals and conservatives, making for strange bedfellows.[21] It has been suggested that Restorative Justice is a process wherein the parties involved in a specific offence collectively resolve the dispute and discuss as to how the aftermath of the offence and its implications in the future, shall be dealt.[22]

Empowerment, dialogue, negotiation and agreement are the major keynotes of the Restorative process. Professionals should not be dominant: the voices of the stakeholders should be the loudest. The stakeholders are assumed to be the victim, the offender and the community. Turning to restorative outcomes, what is to be restored is broadly stated as ‘whatever dimensions of restoration matter to the victims, offenders and communities affected by the crime’[23] Restoration is often seen as reintegration, of the community and of individuals. The Outcomes are measured primarily by the satisfaction of the stakeholders in each case, and not by comparing them with the outcomes of like cases.

Restorative Justice movement aims to replace forms of state justice for a wide range of offences and offenders, which basically means changing the focus of the term ‘criminal justice’ itself away from the assumption that it is a matter concerning only the state and the defendant/offender, and towards a conception that includes as stake holders the victim and the community.[24]

Now that we have understood what restorative justice is, we now will be discussing how is can be utilized in criminal trials in order to deliver effective justice to the victims. The fact that the present theories applicable under criminal law fail to provide a practical solution to the public. In order to understand the applicability of the concept of restorative justice, one is required to understand the concept of “victim compensation”.

Victim Compensation:

Other than participation and distinct role of the victim in a trial, the more important aspect of rendering justice to the victims, lies in providing monetary relief for the loss and suffering that the victim goes through.

The provisions of CrPC provide for a limited scope to grant compensation to the victims. Section 357(1) of the Criminal Procedure Code, provides that wherein a sentence of fine has been imposed (with or without imprisonment), the Court may order the whole or any part of the fine imposed to be applied for the payment of compensation to any person, for the loss or injury caused to him by the offence. Section 357 (3) enables the court to order the accused person to pay, by ay of compensation, a specified amount to the person who has suffered loss or injury by reason of the offending act. Such order can be passed even if the fine does not form part of the sentence imposed.

The supreme court in case of Hari Krishna vs Sukhbir Singh[25] has highlighted that the provisions under section 357 have been seldom invoked by the Courts trying criminal cases and has recommended that there should be a liberal exercise of this power. Similar have been cases wherein Supreme Court has invoked the provisions under section 357 (3) of CrPC, and has directed the payment of substantial compensation by the convict to the victim.[26] 

While the Supreme Court has been Active in promoting the interests of the Victims of Crimes, this is more by exercise of plenary or discretionary power vested with the highest Constitutional Courts, rather than through the vindication of the vested with the rights of the victims. It is regrettable that our Country lags behind others in recognizing and attending to victims’ rights and needs. The need for change in Indian law in this respect has been recognized time and again, by the law Commission.

It has been observed by the law Commission that, “with the emergence of the welfare state, the traditional notions of the state immunity are undergoing rapid change. The idea that the victim of the crime deserves more attention than the state as if the state fails to defend its citizens against violence, it can legitimately be called upon to compensate the victim is gaining ground in western countries.”[27]

The Law Commission referred to the English legal system where a non- statutory scheme of ex gratia payments by the State has been introduced, and the Criminal Injuries Compensation Board has been constituted. It also referred to similar programs in vogue in New Zealand, North Ireland and in some of the states in U.S.A. However, no specific recommendation was made on the point of the State compensating the victim.[28] At the same time, the Law Commission recommended appropriate statutory amendments giving power to the court to direct, while sentencing the accused, that the whole or any part of the fine realized from her shall be paid by way of compensation to the victim, if the court is of the opinion that such compensation is recoverable by means of a civil suit.[29] This recommendation led to the introduction of section 357(3) in the Cr.P.C.

In 152nd Report by the Law Commission of India, it made a limited reference to the issue of victim compensation. It recommended the introduction of a provision in the Cr.P.C., empowering the court to order payment of compensation by the Government as well as any public servant convicte
d of the offence of causing death or bodily injury to a person in custody. A minimum of Rs. 25,000/- in the case of bodily injury, and Rs. 100,000/- in the case of death, was fixed, and a provision for interim relief was also recommended.
[30] However, limited these recommendations have not yet been translated into action.

In its 154th Report, law commission again dealt with the state’s duty to compensate victims. Report. It proposed the introduction of a new provision- section 357- A[31]– in the Cr.P.C. to provide for the preparation of schemes by the Central and State Governments to establish funds to compensate victims; prescribe procedures for the determination and disbursal of the compensation, both in cases which have gone for trial, as well as cases in which the offender is not traced or identified; and provide free medical facilities to the victim.[32]

It has also been recognized by the Law Commission in its 222nd report. In this report the commission has suggested the advantages of Alternative Dispute Resolution. Even though this report dealt with introduction of ADR in the civil cases, but it also dealt with the scope of section 320 of the CrPC which deals with compounding of offences. [33]

Section 320[34] allows the parties to take recourse to ‘Compounding of cases’ in certain offences without the permission of court and in some cases with approval of the court. Compounding of offences has been seen as one of the popular mechanisms to achieve restorative justice. There are some offences which don’t affect the society at large but individuals. These offences can be compounded without the permission of the court under the Section 320(1) of the Criminal Procedure Code, 1973. The offences under this category are: hurting a persons’ religious feelings, hurt, confinement, mischief, criminal trespass, adultery, defamation, etc. The offences under subsection (2) of this law consists of those offences which are of grave nature and likely to affect society or community at large. These cannot be compounded without the permission of the court. The offences under this class include: grievous hurt, wrongful confinement, misappropriation of property, breach of trust involving heavy amount, fraud, counterfeiting, indecent behaviour towards women, etc.

Chapter 3: Victim Offender Mediation:

Of various techniques of Restorative Justice, Victim Offender Mediation (hereinafter mentioned as VOM) is one of the most common method that has been adopted by various countries.[35] There are more than 1300 programs in 18 countries utilizing VOM, across the world.[36]

To understand VOM in simpler terms, it serves to facilitate a conversation between an offender who is convicted and the victim or the sufferer of such offence committed.[37] VOM serves as a healing process for victims and offenders, under ideal situations or circumstances. With the help of this method the victims and offenders are able to discuss how the crime has impacted their lives, discuss the physical, emotional and financial impact of the crime, and receive answers to lingering questions related to the crime and to the offender.[38] It requires both offender and victim’s consent.[39]

Though each VOM program varies, the basic model is followed in every VOM. Firstly, there is an intake phase, followed by a preparation phase wherein the mediator meets with the victim and the offender individually and lastly, the victim offender meeting which includes an opening statement by the mediator, storytelling by the victim and offender, clarification of facts and feelings, reviewing victim losses and a closing statement from the mediator.[40]

Despite the necessity and importance of the first two phases, the face-to-face meeting is the crux of VOM.[41] This phase acts as the very embodiment of restorative justice’s goal to “bring victims and offenders together in an inclusive encounter aiming at a consensual resolution of the  prejudices caused by a crime., [42] The face-to-face meeting typically takes place in a neutral setting.[43] In an ideal scenario, the victim and the offender sit across from one another.[44] Following the  mediator’s opening comments, the victim and offender talk to each other.[45] First, the victim receives unlimited time to discuss the crime’s impact with the offender.[46] Then, the offender has equal opportunity to tell his or her side of the story.[47] From there, victims may ask questions and delve deeper into why the crime took place at all. [48] Finally, the two parties may come to an agreement for restitution; however, this sometimes comes in the form of community service or other “creative alternatives,” instead of financial restitution.[49] 

Victim Offender Mediation appears to be an ideal candidate to advance restorative justice. But eh question as to whether, there is a need for the introduction of Victim Offender Mediation in Criminal Judicial System in India still remains. As has been stated previously that the criminal justice system of the country faces criticism and still fails to account for victims adequately. VOM programs have great potential to assist in correcting prison overcrowding, recidivism, and other controversial aspects of criminal sentencing and the justice system. Additionally, these programs give victim a new role to play – one that allows them to cope with the crime’s impact in a meaningful way.[50]

With over 3.5 crore criminal cases pending in the Supreme Court, High Court and the Subordinate Courts,[51] it has been recorded that more than 70% of the victims are sidelined for decades together due to the various drawbacks that are prevalent in our Criminal Justice System. Therefore, adopting an alternative program for achieving justice like Victim Offender Mediation and other Restorative Justice methods becomes a mandate and not an option. [52]

Victim Offender Mediations programs can be utilized in various non serious crimes such as juvenile Crimes, various crimes relating to coins and government stamps, offences relating to weights and measures, various offences affecting the human body (except offences that involve killing of a human being by another), offences against property, offences relating to criminal breach of contracts of service, offences relating to marriage, defamation, criminal  intimidation, insult and annoyance.

Considering the problem of overcrowding in the prisons,[53] and a huge number of criminal cases pending in the country, VOM programs can help counteract many of these issues.[54] Advocates of VOM point to the method’s ability to reduce crime and recidivism as justification for incorporating it into the criminal justice system. [55] Using VOM as a partial or complete replacement for prison sentences clearly aids in decreasing incarceration overpopulation and subsequent costs. Further, the technique helps to prevent offenders from rationalizing their wrongdoing and put criminal activity behind them.[56] This turns offenders into “instruments of healing rather than harm,” brings accountability into criminal justice, and can decrease recidivism.’[57]


Throughout the Study the author has highlighted various circumstances in the Indian Criminal Justice System, wherein it fails to justify the practical needs of the victim. It has been clearly highlighted in the previous chapters that the Criminal Justice Systems has faced criticisms throughout its existence but has failed to adapt to changes in numerous situations.
The author has clearly in the article pointed out that there is a dire need for victims to be included in the criminal matters in order to provide them with the practical justice. It has also been highlighted that it is the duty of the state in order to consider the rights of the victims and that they should be allowed to be an integral part of the Criminal Justice System. This argument as been supported be various Law Commission reports and the recommendations of the Malimath Committee recommendations.

Further advocating the incorporation of the existing principles of Restorative Justice, the author is of the opinion that it can be incorporated in the form Victim-Offender Mediation, Family or Community Group Conferencing and Peacemaking or Sentencing Circles. As highlighted in previous chapters the Victim Offender Mediation can be utilized in non-violent crimes (see chapter 3 for reference).

In order for the effective implementation of the principles of Restorative Justice, it is suggested that the scope of the Section 320, Section 357, and Section 357A be expanded with regard to dispute resolution by way of including mediation in the procedural law (i.e. Criminal Procedure Code, 1973). It is further suggested that attention of the legislators be drawn towards the need for enactment of a statute incorporating the ideals of Restorative Justice, in order to address the grievances of victims. It is also suggested that it important to adopt the partie civile concept that is practiced in France, wherein the victims have a right to make their concerns in the court of law to their full satisfaction without waiting for the final verdict of the case.

Lastly, as it has been pointed out throughout the article the importance of Restorative Justice and the fact that it can be utilized as an alternative to the conventional method of Criminal Justice System, has been supported by the author on various optimistic accounts. But it is suggested that rather than it being used as an alternative, it is suggested that principle of Restorative Justice, to be utilized in addition to the existing Criminal Justice System. To take account for the protection and the redressal for victims, it shall be a primary concern of the state. The incorporation of the existing principles of Restorative Justice in the present Criminal Justice System, shall be a significant step towards this goal.

[1] National Crime Records Bureau, “Crime in India: Sta
tistics”, 2016

[2] id

[3] Justice (Retd.) PV Reddi, “Role of Victim in Criminal Justice Process”, (2006), 18(1), Student Bar Review, p. 1-24

[4] Sonam Kathuria, “The Bargaining has Struck: A case for Plea Bargaining in India”, (2007) Student Bar Review, p. 55-68

[5] V.S. Malimath Et Al., Report of the Committee on Reforms of Criminal Justice System 76 (2003)

[6] Heather Strang; Lawrence W. Sherman, “Repairing the Harm: Victims and Restorative Justice”, (2003) Utah Law Review, p. 15-42

[7] Mehak Bajpai, “Advancing of Restorative Justice in Criminal Law in India and Germany: A Comparative Study”, 2018, Journal of Victimology and Victim Justice, 1(1), 102-112

[8] Kaitlyn E Tucker, “Mediating Theft”, (2014), University of Florida Journal of Law and Public Policy, vol. 25, p. 23-50

[9] Supra 3

[10] Id

[11] (1999) 7 S.C.C. 467

[12] Supra 3

[13] Andrew Ashwoth, “Responsibilities, Rights and Restorative Justice”, (2002), 42(3), The British Journal of Criminology, 578-595

[14] Law Commission of India, 42nd Report on the Indian Penal Code, 1860

[15] Id

[16] Law Commission of India, 154th Report on Code of Criminal Procedure Code, 1973, (1996)

[17] Supra 5

[18] Supra 5

[19] Supra 13

[20] Supra 6

[21] A. Lakshminath, “Criminal Justice System in India Primitivism to Post-Modernism”, (2006), 48(1), Journal of the Indian Law Institute, p 26-56

[22] Tony F Marshall, “Restorative Justice an overview”, London : Crown (1999).

[23] John Braithwaite, “Restorative Justice and Responsive
Regulation”, Oxford University Press (2002)

[24] Supra 13

[25] (1988) 4 S.C.C 551

[26] Hari krishna vs Sukhbir Singh, (1988) 4 S.C.C. 551, Madhukar vs State of Maharashtra, AIR 1978 SC 1525; Venkatesh vs state of Tamil Nadu AIR 1993 SC 1230

[27] Supra 14

[28] Id.

[29] Id

[30] Law Commission of India, 152nd Report on Custodial Crimes 12.7 (1994)

[31] Ins. By Act 5 of 2009, sec. 28 (w.e.f. 31-12-2009)

[32] Law Commission of India 154th Report on the Code off Criminal Procedure, 1973, 15-17 (1996)

[33] Law Commission of India, 222nd Report on “Need for Justice-dispensation through ADR etc.”, (2009)

[34] Criminal Procedure Code, 1973, (2 of 1974)

[35] Mary Ellen Reimund, the law and restorative justice: friend or foe? A systematic look at the legal issues in restorative justice, 53 Drake L. Rev. 667, 673 (2005)

[36] Mark S. Umbreit ET AL., The impact of Victim Offender Mediation: Two Decades of Research in Restorative Justice for Juveniles: Conferencing Mediation and Circles 121-43 (Allison Morris & Gabrielle Maxwell eds., 2001)

[37] Tina S Ipka, Balancing Restorative Justice Principles and Due Process Rights in order to Reform the Criminal Justice System, 24 Wash U. J. L & Pol’y 301, 308 (2007)

[38] Id.

[39] Id.

[40] Supra 22.

[41] Id

[42] Id

[43] Supra 22

[44] Id

[45] Id.

[46] Id

[47] Id

[48] Id

[49] Id

[50] Harry Mika, The Practice and prospect of Victim Offender Programs, 46 SMU L. Rev. 2192, 2195-96 (1993)

[51] Supra 1

[52] Rakesh Kumar Handa, Restorative justice from Victimology Perspective and its Utility in India

[53] Supra 1

[54] Supra 37

[55] Id

[56] Lynn S. Branham, Plowing in hope: a three-part framework for incorporating restorative justice into sentencing and correctional systems, 38 Wm. Mitchell L. Rev. 1261,1267-68 (2012)

[57] Id

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