Dominus litis is a Latin phrase meaning “master of the suit” (dominus = master or owner; litis = of the suit or lawsuit). In Indian courts it is used for the party who controls a case. In a civil suit that party is the plaintiff: he decides whom to sue and what to claim, and, in the Supreme Court’s words, “the plaintiff in a suit, being dominus litis, may choose the persons against whom he wishes to litigate and cannot be compelled to sue a person against whom he does not seek any relief” (Mumbai International Airport v. Regency Convention Centre, 2010).
The plaintiff’s control is not unlimited. The court may still add or strike out parties under Order I Rule 10(2) of the Code of Civil Procedure, 1908 (CPC), and withdrawing or dropping part of a claim has consequences under Order XXIII Rule 1 and Order II Rule 2. In a criminal case started on a police report, the prosecution is run by the State through the Public Prosecutor, and the Supreme Court has said that even “the proposition that State is the dominus Litis in criminal cases, is not an absolute one” (Union Carbide v. Union of India, 1991).
Dominus litis at a glance
- Meaning: Latin for “master of the suit”: the party who controls the litigation.
- Civil suit: the plaintiff is dominus litis; he chooses his opponents and cannot be compelled to sue a person against whom he seeks no relief (Supreme Court, 2010 and 2026).
- Court’s power: the court may strike out a party improperly joined or add a necessary or proper party “at any stage of the proceedings” (Order I Rule 10(2) CPC).
- Withdrawal: the plaintiff may abandon the suit at any time, but cannot file again on the same subject-matter unless the court grants liberty (Order XXIII Rule 1(3) and (4) CPC).
- Criminal case on a police report: only the Public Prosecutor may withdraw, with the court’s consent and after hearing the victim (Section 360 BNSS, formerly Section 321 CrPC).
- Complaint case: the complainant may withdraw a summons-case complaint with the Magistrate’s permission (Section 280 BNSS, formerly Section 257 CrPC).
- Hindi: no official Hindi term for the Latin phrase; the CPC’s Hindi text calls the plaintiff वादी and the parties पक्षकार.
Reviewed and updated by Century Law Firm, Delhi – October 2026. Statutory references are to the Acts as in force on that date. The Code of Civil Procedure, 1908 is quoted from India Code (as on 10 January 2026) and its official Hindi text on India Code, the Bharatiya Nagarik Suraksha Sanhita, 2023 from India Code (as on 6 October 2025) and its official Hindi Gazette text, and the Supreme Court judgments from the Court’s own copies on api.sci.gov.in.
What does dominus litis mean?
Dominus litis means the master of the suit. “Dominus” is Latin for master or owner, and “litis” is a form of “lis”, a suit or dispute. Indian judgments still use “lis” in this sense: in Kasturi v. Iyyamperumal (2005) the Supreme Court spoke of “the lis between the appellant and the respondent Nos.2 and 3”.
In law, the expression describes control over a case: who starts it, against whom, for what relief, and whether it goes on. The Code of Civil Procedure does not use the Latin words, but it sets the limits within which that control operates.
Dominus litis, dominus litus or dominis litis: which spelling is correct?
The correct Latin form is dominus litis. “Dominus litus”, “dominis litis”, “dominos litis” and “dominus littis” are misspellings of the same phrase; the misspelling “dominus litus” even appears in the Supreme Court’s own text of Kasturi.
Plaintiff is dominus litis: what it means in a civil suit
In a civil suit the plaintiff is the dominus litis. The Supreme Court stated the general rule in Mumbai International Airport Pvt. Ltd. v. Regency Convention Centre & Hotels Pvt. Ltd. (judgment of 6 July 2010):
“The general rule in regard to impleadment of parties is that the plaintiff in a suit, being dominus litis, may choose the persons against whom he wishes to litigate and cannot be compelled to sue a person against whom he does not seek any relief. Consequently, a person who is not a party has no right to be impleaded against the wishes of the plaintiff. But this general rule is subject to the provisions of Order I Rule 10(2) of Code of Civil Procedure …”
In practice this control covers four choices:
- Whom to sue. The plaintiff names the defendants; if in doubt from whom he is entitled to redress, he “may join two or more defendants” (Order I Rule 7).
- Where to sue. Subject to the earlier rules (for example, suits about immovable property go to the court where the property is situate, Section 16), Section 20 CPC allows a suit where the defendant resides, carries on business or personally works for gain, or where “the cause of action, wholly or in part, arises”; where more than one court qualifies, the plaintiff picks one.
- What to claim. The plaintiff frames the reliefs, but must include “the whole of the claim” (Order II Rule 2, below).
- Whether to continue. The plaintiff may abandon the suit or part of the claim “at any time after the institution of a suit” (Order XXIII Rule 1(1)), and may compromise it under Order XXIII Rule 3.
The flip side is that the plaintiff carries the risk of his choices. In NAK Engineering Company Pvt. Ltd. v. Tarun Keshrichand Shah (2026 INSC 8, judgment of 5 January 2026) the Supreme Court said that the plaintiffs “are dominus litis and it is for them to choose their adversaries. If they do not array the proper and necessary parties to the suit, they do it at their own risk. However, they cannot be compelled to add a party to defend a suit against their wishes.”
Dominus litis in CPC: Order I Rule 10 and the court’s power to add parties
The main limit on the plaintiff’s control is the court’s own power over parties in Order I Rule 10(2) CPC, headed “Court may strike out or add parties”:
“The Court may at any stage of the proceedings, either upon or without the application of either party, and on such terms as may appear to the Court to be just, order that the name of any party improperly joined, whether as plaintiff or defendant, be struck out, and that the name of any person who ought to have been joined, whether as plaintiff or defendant, or whose presence before the Court may be necessary in order to enable the Court effectually and completely to adjudicate upon and settle all the questions involved in the suit, be added.”
The Supreme Court has explained that this sub-rule “is not about the right of a non-party to be impleaded as a party, but about the judicial discretion of the court to strike out or add parties at any stage of a proceeding”, and that the discretion “can be exercised either suo moto or on the application of the plaintiff or the defendant, or on an application of a person who is not a party to the suit” (Mumbai International Airport, 2010).
Necessary party and proper party
In Kasturi v. Iyyamperumal (three judges, 25 April 2005) the Supreme Court stated two tests for a necessary party: “(1) there must be a right to some relief against such party in respect of the controversies involved in the proceedings (2) no effective decree can be passed in the absence of such party.”
| Who | Test (Mumbai International Airport, para 8) | Can the court add him against the plaintiff’s wishes? |
|---|---|---|
| Necessary party | A person “in whose absence no effective decree could be passed at all by the Court” | Yes. If the plaintiff opposes, the court may instead dismiss the suit (Mumbai International Airport, para 12.3) |
| Proper party | A person “whose presence would enable the court to completely, effectively and adequately adjudicate upon all matters in disputes in the suit” | The court has discretion; “no person has a right to insist that he should be impleaded as a party, merely because he is a proper party” |
| Neither | No right to relief against him, and the decree can be passed without him | No: “the court has no jurisdiction to implead him, against the wishes of the plaintiff” |
Kasturi v. Iyyamperumal (2005): the plaintiff “cannot be forced to add parties”
Kasturi had sued for specific performance of an agreement to sell property. Outsiders who were not parties to the agreement, and who claimed independent title and possession, were added as defendants by the trial court and the High Court. The Supreme Court set those orders aside. It held that “a third party or a stranger to the contract cannot be added so as to convert a suit of one character into a suit of different character”. It then said that the plaintiff “is dominus litus and cannot be forced to add parties against whom he does not want to fight unless it is a compulsion of the rule of law”.
Mumbai International Airport v. Regency Convention Centre (2010)
Here Regency Convention Centre & Hotels had sued the Airports Authority of India (AAI) for specific performance of an agreement concerning a piece of airport land. The company to which AAI had leased the airport for its operation, management and development, and which might also get the suit land on lease if AAI won the suit, applied to be added as a defendant. The Supreme Court refused. It restated the dominus litis rule quoted above, explained the court’s discretion under Order I Rule 10(2), and held that a person who only expects a future lease from the defendant is neither a necessary nor a proper party.
NAK Engineering v. Tarun Keshrichand Shah (2026)
In a suit by property owners to recover service charges, another company applied to be added as a defendant “to participate and contest” the suit. Relying on Kasturi and Mumbai International Airport, the Supreme Court held that the plaintiffs, as dominus litis, could not be compelled to add it, and directed that the decree “would not be used against the appellant and would not be implemented against it”.
What if the plaintiff leaves out a necessary party?
Order I Rule 9 CPC says that no suit “shall be defeated by reason of the misjoinder or non-joinder of parties”, but its proviso adds: “nothing in this rule shall apply to non-joinder of a necessary party.” So the plaintiff’s freedom ends where the suit cannot be decided without a particular person. Unless the court directs otherwise, the plaint must be amended and served on a defendant added later; subject to the law of limitation, the proceedings against him are treated as beginning only when he is served with summons (Order I Rule 10(4) and (5)).
Withdrawal, abandonment and relinquishment: control with consequences
Order XXIII Rule 1: withdrawing a suit
Order XXIII Rule 1(1) says: “At any time after the institution of a suit, the plaintiff may as against all or any of the defendants abandon his suit or abandon a part of his claim”. If he simply abandons or withdraws without the court’s permission, he is liable for costs and “shall be precluded from instituting any fresh suit in respect of such subject-matter or such part of the claim” (Rule 1(4)). He can file afresh only if the court, being satisfied that the suit “must fail by reason of some formal defect” or that there are “sufficient grounds”, grants “permission to withdraw … with liberty to institute a fresh suit” (Rule 1(3)).
A minor (or other person covered by Order XXXII) cannot abandon a suit “without the leave of the Court” (proviso to Rule 1(1)); one of several plaintiffs cannot do so “without the consent of the other plaintiff” (Rule 1(5)); and in a suit under Order I Rule 8 (one person suing for many with the same interest), no part of the claim may be abandoned and the suit may not be withdrawn until the court has given notice, at the plaintiff’s expense, to all persons interested (Order I Rule 8(4)); and a compromise in a representative suit needs the court’s leave (Order XXIII Rule 3B).
Order II Rule 2: relinquishing part of a claim
The plaintiff decides how much to claim, but Order II Rule 2(2) makes that decision final: “Where a plaintiff omits to sue in respect of, or intentionally relinquishes, any portion of his claim, he shall not afterwards sue in respect of the portion so omitted or relinquished.” Similarly, a person entitled to more than one relief on the same cause of action who omits one “except with the leave of the Court” cannot sue for it later (Rule 2(3)). In the Code’s illustration, where A sues his tenant B only for the rent due for 1906, “A shall not afterwards sue B for the rent due for 1905 or 1907”.
For the related rules on filing a suit and choosing the right court, see our guides to the suit for declaration and the court fee and jurisdiction calculator.
Prepared by Century Law Firm from the Code of Civil Procedure, 1908 (Order I Rules 9 and 10, Order II Rule 2, Order XXIII Rule 1) and the Bharatiya Nagarik Suraksha Sanhita, 2023 (Sections 280, 360 and 413), official India Code texts, and the Supreme Court judgments named in this post.
Dominus litis in criminal cases: the State and the Public Prosecutor
In a criminal case taken up on a police report (the report the police send to the Magistrate after completing the investigation, Sections 2(1)(t) and 193(3) BNSS), the prosecution is not in the informant’s hands. The case is prosecuted by a Public Prosecutor: Section 18 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS, formerly Section 24 CrPC) provides for appointing Public Prosecutors for conducting “any prosecution, appeal or other proceeding on behalf of the Central Government or the State Government”, and “In every trial before a Court of Session, the prosecution shall be conducted by a Public Prosecutor” (Section 248 BNSS, formerly Section 225 CrPC). In this sense the State is described as dominus litis in a criminal case. The Supreme Court used the phrase this way in Union Carbide Corporation v. Union of India (five judges, 3 October 1991), where it said: “It is the Union of India, as the dominus litis, that consented to the quashing of the proceedings.” (In the same review judgment the Court noted that it had, “upon review”, set aside that part of the earlier order.)
The victim or informant may engage a private advocate, but that advocate works under the prosecutor. Section 338(2) BNSS (formerly Section 301 CrPC) says that where a private person instructs an advocate, the Public Prosecutor “shall conduct the prosecution, and the advocate so instructed shall act therein under the directions of the Public Prosecutor”, and may, with the court’s permission, submit written arguments after the evidence is closed.
For how a criminal case starts, see how to file a police complaint and FIR; for the meaning of “PP”, see PP full form in court.
Withdrawal from prosecution: Section 360 BNSS (formerly Section 321 CrPC)
In a police-report case, withdrawal is the prosecutor’s step, taken with the court’s consent. Section 360 BNSS says: “The Public Prosecutor or Assistant Public Prosecutor in charge of a case may, with the consent of the Court, at any time before the judgment is pronounced, withdraw from the prosecution of any person either generally or in respect of any one or more of the offences for which he is tried”. If the withdrawal is before a charge is framed, the accused is discharged; if after, he is acquitted.
The BNSS added a new safeguard for victims: “Provided further that no Court shall allow such withdrawal without giving an opportunity of being heard to the victim in the case.” This proviso has no counterpart in Section 321 CrPC.
“Not an absolute one”: the limits on the State’s control
The State’s position is also limited. In Union Carbide the Supreme Court said: “The proposition that State is the dominus Litis in criminal cases, is not an absolute one. The society for its orderly and peaceful development is interested in the punishment of the offender.” In the same paragraph it quoted an earlier ruling (Sheonandan Paswan v. State of Bihar, 1987) that where the offence is “an offence against the society and not merely an individual wrong, any member of the society must have locus to initiate a prosecution as also to resist withdrawal of such prosecution, if initiated”.
Besides the hearing before withdrawal, the victim has a right of appeal. The proviso to Section 413 BNSS (formerly Section 372 CrPC) says: “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”. “Victim” includes the guardian or legal heir of the person who suffered loss or injury (Section 2(1)(y) BNSS).
Complaint cases: the complainant’s control
A case started by a private complaint to a Magistrate is different. A “complaint” is an allegation made to a Magistrate that some person has committed an offence, and it “does not include a police report” (Section 2(1)(h) BNSS). Here the complainant has a larger say:
- Withdrawal: in a summons-case, if the complainant “satisfies the Magistrate that there are sufficient grounds for permitting him to withdraw his complaint”, the Magistrate may permit it and “shall thereupon acquit the accused” (Section 280 BNSS, formerly Section 257 CrPC).
- Absence or death: if the complainant does not appear in a summons-case begun on complaint, the Magistrate, “after giving thirty days’ time to the complainant to be present”, shall acquit the accused unless he decides to adjourn; but if the complainant is represented by an advocate or by the officer conducting the prosecution, or his personal attendance is not necessary, the Magistrate may dispense with his attendance and proceed (proviso). This also applies where the complainant has died (Section 279 BNSS, formerly Section 256 CrPC; the thirty-day period is new in the BNSS).
Proceedings pending on 1 July 2024, when the BNSS came into force, continue under the Code of Criminal Procedure, 1973 (Section 531(2)(a) BNSS), so the old CrPC section numbers still apply to those cases. Use our CrPC to BNSS comparison tool to find the matching section.
डोमिनस लिटिस का हिंदी में अर्थ – हिंदी में सारांश (Dominus Litis Meaning in Hindi)
“Dominus litis” लैटिन भाषा का शब्द-समूह है, जिसका अर्थ है “मुकदमे का स्वामी” या “वाद का स्वामी”। यह हिंदी अर्थ फर्म का अपना सारांश है; सिविल प्रक्रिया संहिता या भारतीय नागरिक सुरक्षा संहिता के आधिकारिक हिंदी पाठ में इस लैटिन शब्द का कोई आधिकारिक हिंदी रूप नहीं मिलता, क्योंकि ये अधिनियम इस शब्द का प्रयोग ही नहीं करते। सिविल प्रक्रिया संहिता, 1908 के आधिकारिक हिंदी पाठ में plaintiff को “वादी”, defendant को “प्रतिवादी” और parties को “पक्षकार” कहा गया है; आदेश 1 का शीर्षक है “वादों के पक्षकार”।
दीवानी मुकदमे (civil suit) में वादी ही dominus litis होता है। वह तय करता है कि किसके विरुद्ध वाद लाना है, कौन-सा अनुतोष (relief) माँगना है और वाद को जारी रखना है या नहीं। सुप्रीम कोर्ट ने Mumbai International Airport (2010) में कहा कि वादी उन व्यक्तियों को चुन सकता है जिनके विरुद्ध वह मुकदमा लड़ना चाहता है, और उसे ऐसे व्यक्ति पर वाद लाने के लिए बाध्य नहीं किया जा सकता जिससे वह कोई अनुतोष नहीं माँगता।
लेकिन यह नियंत्रण पूर्ण नहीं है। आदेश 1 नियम 10(2) का आधिकारिक हिंदी शीर्षक है “न्यायालय पक्षकारों का नाम काट सकेगा या जोड़ सकेगा”। इसके अनुसार न्यायालय कार्यवाही के किसी भी प्रक्रम में अनुचित तौर पर जोड़े गए पक्षकार का नाम काट सकता है और ऐसे व्यक्ति को जोड़ सकता है जिसे वादी या प्रतिवादी के रूप में जोड़ा जाना चाहिए था, या जिसकी उपस्थिति सभी प्रश्नों के प्रभावी और पूर्ण निपटारे के लिए आवश्यक है। आदेश 1 नियम 9 के परंतुक का आधिकारिक हिंदी पाठ है: “परंतु इस नियम की कोई बात किसी आवश्यक पक्षकार के असंयोजन को लागू नहीं होगी।” अर्थात् आवश्यक पक्षकार (necessary party) को छोड़ देने पर वाद विफल हो सकता है।
वादी अपना वाद वापस भी ले सकता है। आदेश 23 का आधिकारिक हिंदी शीर्षक है “वादों का प्रत्याहरण और समायोजन”, और नियम 1(1) कहता है कि “वाद संस्थित किए जाने के पश्चात् किसी भी समय वादी सभी प्रतिवादियों या उनमें से किसी के विरुद्ध अपने वाद का परित्याग या अपने दावे के भाग का परित्याग कर सकेगा”। परंतु यदि न्यायालय ने नया वाद लाने की छूट (liberty) नहीं दी है, तो उसी विषय पर नया वाद नहीं लाया जा सकता (नियम 1(4))।
आपराधिक मामलों में स्थिति अलग है। पुलिस रिपोर्ट (जाँच पूरी होने पर पुलिस द्वारा मजिस्ट्रेट को भेजी गई रिपोर्ट) पर चलने वाले मामले में अभियोजन राज्य की ओर से लोक अभियोजक (Public Prosecutor) चलाता है, इसलिए राज्य को dominus litis कहा जाता है। भारतीय नागरिक सुरक्षा संहिता, 2023 की धारा 360 (पहले दंड प्रक्रिया संहिता की धारा 321) का आधिकारिक हिंदी शीर्षक है “अभियोजन वापस लेना”; इसके अनुसार मामले का भारसाधक लोक अभियोजक “न्यायालय की सम्मति से” ही अभियोजन वापस ले सकता है। नया परंतुक कहता है: “परंतु यह और कि कोई न्यायालय उस मामले में पीड़ित को सुनवाई का अवसर दिए बिना ऐसी वापसी अनुज्ञात नहीं करेगा।” धारा 413 के परंतुक के अनुसार पीड़ित को दोषमुक्ति, कम अपराध के लिए दोषसिद्धि या अपर्याप्त प्रतिकर के आदेश के विरुद्ध अपील करने का अधिकार है।
सुप्रीम कोर्ट ने Union Carbide (1991) में कहा कि यह प्रस्थापना कि आपराधिक मामलों में राज्य dominus litis है, पूर्ण (absolute) नहीं है, क्योंकि अपराधी को दंड मिलने में समाज का भी हित है। निजी परिवाद (complaint case) में परिवादी का नियंत्रण अधिक होता है: समन-मामले में वह मजिस्ट्रेट की अनुमति से परिवाद वापस ले सकता है (धारा 280), और ऐसा होने पर अभियुक्त दोषमुक्त हो जाता है।
Frequently asked questions
Dominus litis is Latin for “master of the suit”. In Indian law it refers to the party who controls a case. In a civil suit that is the plaintiff, who, “being dominus litis, may choose the persons against whom he wishes to litigate” (Supreme Court, Mumbai International Airport v. Regency Convention Centre, 2010). In a criminal case on a police report, the State, acting through the Public Prosecutor, is usually described as dominus litis.
It means the plaintiff controls his suit: he decides the defendants and the reliefs, and cannot be compelled to sue a person against whom he seeks no relief. A person who is not a party “has no right to be impleaded against the wishes of the plaintiff”; but the court may, in its discretion, add him under Order I Rule 10(2) CPC if it finds him a necessary or proper party (Mumbai International Airport, 2010). The plaintiff also bears the risk: if he leaves out a necessary party, the suit can fail (proviso to Order I Rule 9 CPC).
Yes, if that person is a necessary party (no effective decree can be passed without him) or a proper party (his presence is needed to decide all the questions in the suit): Order I Rule 10(2) CPC lets the court add him “at any stage of the proceedings”. If the person is neither, “the court has no jurisdiction to implead him, against the wishes of the plaintiff” (Mumbai International Airport, 2010). Where the plaintiff opposes adding a necessary party, the court may instead dismiss the suit.
Only if the court grants permission to withdraw with liberty to file a fresh suit, which it may do where the suit “must fail by reason of some formal defect” or there are “sufficient grounds” (Order XXIII Rule 1(3) CPC). If the plaintiff abandons or withdraws without that permission, he is liable for costs and is “precluded from instituting any fresh suit in respect of such subject-matter” (Rule 1(4)).
In a case started on a police report, the State, through the Public Prosecutor. Only the Public Prosecutor or Assistant Public Prosecutor in charge may withdraw from the prosecution, with the court’s consent and after the victim is heard (Section 360 BNSS, formerly Section 321 CrPC). A private advocate engaged by the victim acts “under the directions of the Public Prosecutor” (Section 338(2) BNSS). The Supreme Court has said that the State’s position as dominus litis “is not an absolute one” (Union Carbide v. Union of India, 1991).
In a complaint case tried as a summons-case, yes: the Magistrate may permit withdrawal if the complainant shows “sufficient grounds”, and the accused is then acquitted (Section 280 BNSS, formerly Section 257 CrPC). In a case started on a police report the complainant has no such power; only the Public Prosecutor can apply to withdraw under Section 360 BNSS. A settlement may instead support compounding where the offence is compoundable (Section 359 BNSS) or a petition to the High Court under its inherent powers (Section 528 BNSS, formerly Section 482 CrPC).
Yes. Under the second proviso to Section 360 BNSS, “no Court shall allow such withdrawal without giving an opportunity of being heard to the victim in the case”. Under the proviso to Section 413 BNSS (formerly Section 372 CrPC), the victim may appeal against an order acquitting the accused, convicting for a lesser offence or imposing inadequate compensation. “Victim” includes the guardian or legal heir of the person who suffered loss or injury (Section 2(1)(y) BNSS).
The correct Latin spelling is dominus litis (“litis” means “of the suit”). “Dominus litus”, “dominis litis” and “dominos litis” are common misspellings of the same phrase, and the Supreme Court’s own text of Kasturi v. Iyyamperumal (2005) prints “dominus litus”.
In simple Hindi, dominus litis means “वाद का स्वामी” or “मुकदमे का स्वामी” (master of the suit). This is the firm’s rendering: the official Hindi texts of the CPC and BNSS do not use the Latin phrase. The official Hindi CPC calls the plaintiff वादी, the defendant प्रतिवादी and the parties पक्षकार, and the heading of Order I Rule 10(2) reads “न्यायालय पक्षकारों का नाम काट सकेगा या जोड़ सकेगा”.
Conclusion
Dominus litis means the master of the suit. In civil cases it is the plaintiff’s right to choose his opponents (applied by the Supreme Court from Kasturi (2005) to NAK Engineering (2026)) and to frame and withdraw his claim within the CPC. That control works within the CPC: the court may add a necessary or proper party under Order I Rule 10(2), and withdrawal or relinquishment can shut out a later claim under Order XXIII Rule 1 and Order II Rule 2.
In police-report cases the State, through the Public Prosecutor, controls the prosecution, but that control is “not an absolute one”: withdrawal needs the court’s consent and a hearing for the victim, who may also appeal. In complaint cases the complainant may withdraw a summons-case complaint with the Magistrate’s permission. More maxims are explained in our Legal Maxims Explained hub.
Sources used for this post: the Code of Civil Procedure, 1908, Sections 16 and 20, Order I Rules 7, 8, 9 and 10, Order II Rule 2, Order XXIII Rules 1, 3 and 3B (India Code, a1908-05.pdf, as on 10 January 2026) and its official Hindi text (India Code, h19085.pdf, the headings of Orders 1 and 23, Order 1 Rules 9 and 10 and Order 23 Rule 1, read from the printed pages); the Bharatiya Nagarik Suraksha Sanhita, 2023, Sections 2(1)(h), 2(1)(t), 2(1)(y), 18, 193, 248, 279, 280, 338, 359, 360, 413, 528 and 531 (India Code, A2023-46.pdf, as on 6 October 2025), with the CrPC correspondences from the firm’s section-by-section data checked against the Gazette text, and its official Hindi text (India Code, 202346.pdf, Sections 360 and 413); and the following Supreme Court judgments: Kasturi v. Iyyamperumal & Ors. (printed “Uyyamperumal” in the official header), Appeal (Civil) No. 2831 of 2005, judgment of 25 April 2005, https://api.sci.gov.in/jonew/judis/26967.pdf; Mumbai International Airport Pvt. Ltd. v. Regency Convention Centre & Hotels Pvt. Ltd. & Ors., Civil Appeal No. 4900 of 2010, judgment of 6 July 2010, https://api.sci.gov.in/jonew/judis/36428.pdf; NAK Engineering Company Pvt. Ltd. v. Tarun Keshrichand Shah & Ors., Civil Appeals arising out of SLP (C) Nos. 6024–6025 of 2022, 2026 INSC 8, judgment of 5 January 2026, https://api.sci.gov.in/supremecourt/2022/9053/9053_2022_9_1501_67145_Judgement_05-Jan-2026.pdf; and Union Carbide Corporation etc. v. Union of India etc., judgment of 3 October 1991, https://api.sci.gov.in/jonew/judis/12603.pdf.
