AG Leventis Plc (AGLEVE.ng) listed on the Nigerian Stock Exchange under the Industrial holding sector has released it’s 2015 annual report.For more information about AG Leventis Plc (AGLEVE.ng) reports, abridged reports, interim earnings results and earnings presentations, visit the AG Leventis Plc (AGLEVE.ng) company page on AfricanFinancials.Document: AG Leventis Plc (AGLEVE.ng) 2015 annual report.Company ProfileThe A.G. Leventis Group is a leading manufacturing and distribution company in Nigeria and West Africa supplying a variety of products and services across a range of industries including general dealerships, motor dealerships and real estate. The company has business interests in supplying power and gas products, consumer foods and bakery products and printing supplies as well as offers products and services for the real estate, hotel and commercial vehicles sectors. AG Leventis (Nigeria) Plc operates through a number of subsidiaries; Leventis Foods Plc, Leventis Motors, Abuja (Capital Motors) Plc, Mainland Hotels, Leventis Real Estate, Druckfarben Nigeria Plc and Chrisstahl Nigeria Plc. The company was established by Chief AG Leventis in Ghana in 1937 and mainly supplied local and imported textile products. It devolved into Leventis Motors Plc, Leventis Stores Plc, Leventis Technical Plc whilst it retained ownership of valuable freehold and leasehold property throughout Nigeria. Through a series of mergers and schemes of arrangement, the independent companies were dissolved and AG Leventis (Nigeria) Plc was established. The company’s head office is in Lagos, Nigeria. AG Leventis (Nigeria) Plc is listed on the Nigerian Stock Exchange
Morning Light Co Ltd (MOLI.mu) listed on the Stock Exchange of Mauritius under the Tourism sector has released it’s 2016 abridged results.For more information about Morning Light Co Ltd (MOLI.mu) reports, abridged reports, interim earnings results and earnings presentations, visit the Morning Light Co Ltd (MOLI.mu) company page on AfricanFinancials.Document: Morning Light Co Ltd (MOLI.mu) 2016 abridged results.Company ProfileMorning Light Co. Limited engages in the tourism and leisure industry. Morning Light Co. Limited is headquartered in Beau Bassin, Mauritius and owns a resort hotel under the Hilton Mauritius Resort & Spa name. Morning Light Co. Limited is listed on the Stock Exchange of Mauritius.
I would like to receive emails from you about product information and offers from The Fool and its business partners. Each of these emails will provide a link to unsubscribe from future emails. More information about how The Fool collects, stores, and handles personal data is available in its Privacy Statement. Enter Your Email Address Peter Stephens owns shares of British Land Co and Imperial Brands. The Motley Fool UK has recommended British Land Co and Imperial Brands. Views expressed on the companies mentioned in this article are those of the writer and therefore may differ from the official recommendations we make in our subscription services such as Share Advisor, Hidden Winners and Pro. Here at The Motley Fool we believe that considering a diverse range of insights makes us better investors. Simply click below to discover how you can take advantage of this. Stock market recovery: 3 things UK investors should know now Image source: Getty Images. 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For example, the global financial crisis took some time to recover from in an economic perspective. However, stock markets responded positively to the potential for better economic performance.Through buying a diverse range of UK shares now, an investor may benefit from a likely stock market rally. Certainly, it may not be a smooth road to recovery. However, today’s cheap shares are likely to deliver capital growth in the coming years. Click here to claim your copy now — and we’ll tell you the name of this Top US Share… free of charge! Peter Stephens | Tuesday, 8th December, 2020 See all posts by Peter Stephens I’m sure you’ll agree that’s quite the statement from Motley Fool Co-Founder Tom Gardner.But since our US analyst team first recommended shares in this unique tech stock back in 2016, the value has soared.What’s more, we firmly believe there’s still plenty of upside in its future. 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2018 Year: “COPY” ShareFacebookTwitterPinterestWhatsappMailOrhttps://www.archdaily.com/903982/villa-nature-saraiva-plus-asociados Clipboard Projects CopyAbout this officeSaraiva + AssociadosOfficeFollowProductsWoodGlassConcrete#TagsProjectsBuilt ProjectsSelected ProjectsResidential ArchitectureHousingApartmentsQuarteiraPortugalPublished on October 19, 2018Cite: “Villa Nature / Saraiva + Associados” [Villa Nature / Saraiva + Associados] 19 Oct 2018. ArchDaily. Accessed 11 Jun 2021.
Students prepping for research symposium Twitter Students paint bacteria in cross campus learning The College of Science and Engineering Dean, Phil Hartman, retires after 40 consecutive years Students debut performances of drag personas as part of unique new course Joe Kimball, winner of the spring 2015 3MT competition, gives his speech. Art, science departments to continue zoo enrichment course Connie Beltranhttps://www.tcu360.com/author/connie-beltran/ Connie Beltranhttps://www.tcu360.com/author/connie-beltran/ Facebook Connie Beltranhttps://www.tcu360.com/author/connie-beltran/ Previous articleSGA to offer winter break shuttles to DFW, Love FieldNext articleVietnamese Student Association seeks to bring cultural diversity to campus Connie Beltran RELATED ARTICLESMORE FROM AUTHOR Twitter + posts printAfter having passed the preliminary process, six TCU graduate students will present their three minute thesis for the final competition.It is the second time that the College of Science and Engineering hosts the competition. The competition, which originated in the University of Queensland, encourages and challenges graduate students to present their research and its importance in a three minute thesis presentation.Andria Beal, one of the finalists, decided to participate because of the opportunities and challenges of the competition.“I decided to participate in this competition because it was not only a chance for me to tell the public about what I do and why it is important, [but] it also challenged me to be able to put my work into terms that the general public could understand,” Beal wrote in an email.The competition also allows participants to improve or gain new skills.“Most scientists love to talk, and I’m not an exception,” finalist Josh Donor wrote in an email. “The exercise of cramming everything I’ve done over the last year into a three minute speech, that actually had to mean something, to someone who perhaps has never seen a star cluster before, definitely improved my ability to communicate my research.”Senior associate dean Magnus Rittby said it is hard to condense so much information into a three minute speech.“It’s a lot to cover in three minutes [and] to do it really well,” Rittby said.Rittby said the competition is very difficult, and he is proud of all the students who are trying it.Contestants will be judged based on how well they communicate their research and how engaged they are with the audience.Prizes will be awarded to the first prize winner, runner up and people’s choice.The final competition will be held at the Fort Worth Museum of Science and History on Saturday, Nov. 7.Having the competition outside of school was a chance to “bring our students to the museum and give them an opportunity to perhaps meet or present in front of an actual lay audience,” Rittby said.“I’m also looking forward to a larger audience! Like I said, scientists love to talk,” Donor wrote. Connie Beltranhttps://www.tcu360.com/author/connie-beltran/ Facebook Linkedin Connie Beltran Linkedin ReddIt Connie Beltran is a senior at TCU majoring in journalism and minoring in French. She covers the College of Education and the College of Science and Engineering for TCU 360. ReddIt Boykin, Doctson among 14 football players graduating Saturday Condensed semester, lost week to snowstorm adding to some students stress during finals week
What to watch during quarantine Twitter Jared Janczak recorded 11 strikeouts on Opening Day. Photo courtesy of gofrogs.com Facebook Previous articlePolitiTalk: Russia indictment, gun control, Romney for senateNext articleWomen’s basketball will honor Kay Yow in annual “Play4Kay” game Robbie Vaglio RELATED ARTICLESMORE FROM AUTHOR Facebook Twitter TCU wants ex-professor’s discrimination suit dismissed Robbie Vagliohttps://www.tcu360.com/author/robbie-vaglio/ The inning all started with first-year student and second baseman Coby Boulware rocking a line drive base hit up the middle. Designated hitter Connor Wanhanan stayed alive at the plate and worked a nine-pitch walk to put the tying runs on base. Watson’s hit came with one out, and sophomore catcher Zach Humphreys gave the Horned Frogs the lead with a sacrifice fly.The Horned Frogs had multiple opportunities to crack the scoreboard before the ninth inning. Humphreys was left on third base after a base hit in the fifth inning and an interference call in the seventh inning led to a double-play.Grand Canyon struck first in the bottom of the first inning as a ground-out scored a runner from third. The Antelopes extended their lead with a tw0-out, bases-loaded wild pitch.Pitching kept the Horned Frogs within striking distance all night. TCU starting pitcher Jared Janczak recorded 11 strikeouts in his second career opening day start. He allowed one earned run on four hits in six-and-two-thirds innings. In relief, Cal Coughlin and Durbin Feltman proved to be the difference makers. Coughlin picked up the win with one-and-a-third innings of scoreless relief, and Feltman shut it down in the ninth, retiring the side in order to earn the save.TCU’s first win of the season continues a trend established in last season’s NCAA Tournament: strong pitching. The Horned Frogs have only allowed a maximum of three runs in its past 10 games.Game two of the opening series is set for Saturday with first pitch at 2 p.m. Sophomore left-hander Nick Lodolo will get the start on the mound. Snow temporarily stepping down as honors dean Linkedin Robbie Vaglio ReddIt printLupton Magic made an appearance in Phoenix Friday night. The No. 3 Horned Frogs scored three runs in the ninth inning to rally from a 2-0 deficit over Grand Canyon University.Left fielder Josh Watson’s two-run triple in the ninth was the difference maker in the ball game. Robbie Vagliohttps://www.tcu360.com/author/robbie-vaglio/ Robbie Vagliohttps://www.tcu360.com/author/robbie-vaglio/ ReddIt + posts Two students joined harassment and discrimination lawsuit against TCU Linkedin Robbie Vagliohttps://www.tcu360.com/author/robbie-vaglio/ I am the executive editor of TCU 360 from Raleigh, North Carolina. If you walk by my desk in the newsroom you’ll immediately know I’m Post Malone’s biggest fan. I’m always looking for a good story to tell! If you have any story ideas, feel free to reach out! Go Panthers! TCU rowing program strengthens after facing COVID-19 setbacks Another series win lands TCU Baseball in the top 5, earns Sikes conference award TCU baseball finds their biggest fan just by saying hello
REDWOOD CITY, Calif.–(BUSINESS WIRE)–Feb 23, 2021– Reltio, an award-winning provider of the only master data management SaaS platform born in the cloud and used by companies worldwide to succeed in the digital economy, today announced it was named to the Constellation ShortList™ for Master Data Management (MDM) in Q1 2021. The technology vendors and service providers included in this program deliver critical transformation initiative requirements for early adopter and fast follower organizations.Reltio has been shortlisted for Master Data Management in Q1 2021. Just six of more than 15 vendors evaluated by Constellation Research make the list.2021 is the fourth consecutive year that Reltio appears on the Constellation ShortList for Master Data Management.Constellation Research evaluated more than 15 solutions categorized in this market and determined the ShortList based on client inquiries, partner conversations, customer references, vendor selection projects, market share, and internal research.Reltio disrupted the master data management (MDM) software market when it launched the first cloud-native MDM software-as-a-service (SaaS) platform. “We are honored to be listed among a select group of master data management solution companies by Constellation Research,” said Manish Sood, CTO and Founder of Reltio. “Reltio Connected Data Platform meets the complex multi-domain MDM requirements of enterprises in real-time. Our Enterprise 360, Connected Customer 360, and Identity 360 cloud services uniquely provide the flexibility, scalability, security, business continuity, and choice that only a cloud-native MDM SaaS platform can deliver.” “As leaders adjust to a compressed state of digital transformation, they want to know which vendors matter the most based on technology investment, use cases, strategic vision, customer value, executive leadership and price,” noted R “Ray” Wang, chairman and founder at Constellation Research. “Our analysts have a pulse on what’s working, what’s not and are constantly in touch with other buy side executives. The ShortList does this in the most efficient and effective manner.” Constellation Research advises leaders on leveraging disruptive technologies to achieve business model transformation and streamline business processes. Products and services named to the Constellation ShortList meet the threshold criteria for this category as determined through client inquiries, partner conversations, customer references, vendor selection projects, market share and internal research. The portfolio is updated at least once per year as the analyst team deems necessary based on market conditions. About Reltio Reltio disrupted the master data management (MDM) software market when it launched the first cloud-native MDM software-as-a-service (SaaS) platform nearly a decade ago. The Reltio Connected Data Platform is a proven multi-tenant, multi-domain MDM platform that masters all data types in real-time and at-scale. Customers benefit from agility, scale, simplicity, security, and performance unmatched by Reltio’s competitors. Reltio Connected Data Platform uniquely features big data architecture to manage massive data volumes in real-time for operational, analytical, and data science use cases, an API-first SaaS business model for rapid configuration and responsive data management, and Connected Graph technology to discover relationships. About Constellation Research As an award-winning Silicon Valley-based strategic advisory and futurist analyst firm, Constellation Research serves leaders and organizations navigating the challenges of digital strategy, business-model disruption and digital transformation. Constellation works closely with solution providers, partners, C-suite executives, board of directors, and its Constellation Executive Network of buy-side leaders to lead the way in research coverage and advise clients how to achieve valuable business results. Disclaimer Constellation Research does not endorse any solution or service named in its research. View source version on businesswire.com:https://www.businesswire.com/news/home/20210223005166/en/ CONTACT: Chas Kielt Senior Director, Industry Solutions Marketing and Corporate Communications Reltio +1 855-360-DATA x360 [email protected] KEYWORD: CALIFORNIA UNITED STATES NORTH AMERICA INDUSTRY KEYWORD: SOFTWARE TECHNOLOGY DATA MANAGEMENT SOURCE: Reltio Copyright Business Wire 2021. PUB: 02/23/2021 08:00 AM/DISC: 02/23/2021 08:02 AM http://www.businesswire.com/news/home/20210223005166/en By Digital AIM Web Support – February 23, 2021 Local NewsBusiness Pinterest Facebook TAGS WhatsApp WhatsApp Facebook Twitter Twitter Pinterest Reltio Named to Constellation ShortList™ for Master Data Management Previous articleLemonade Announces Q&A Platform For Shareholders Ahead of Q4 2020 Earnings ReleaseNext articleToshiba Introduces Touch Free App for Multifunction Printers Digital AIM Web Support
News Facebook PSNI and Gardai urged to investigate Adams’ claims he sheltered on-the-run suspect in Donegal 365 additional cases of Covid-19 in Republic Pinterest Twitter Pinterest Main Evening News, Sport and Obituaries Tuesday May 25th RELATED ARTICLESMORE FROM AUTHOR The Managing Director of Largo Foods’ Donegal plant has confirmed that 60 full and part time jobs are to go.Ray Coyle said the jobs are going in the packing department, which to be automated.Mr Coyle concluded that if the jobs losses are not implemeted as part of a cost cutting exercise, then the Gweedore plant will close and production will move to the UK.Mr Coyle told Highland Radio News this is part of a wider plan to ensure the future of the Donegal plant…………[podcast]http://www.highlandradio.com/wp-content/uploads/2012/05/coyle1pm.mp3[/podcast] Man arrested on suspicion of drugs and criminal property offences in Derry By News Highland – May 21, 2012 Previous articleMan arrested in connection with Derry pipe bomb incidentNext articleGAA – Minors Take First Championship Win In Four Years News Highland Largo MD confirms 60 full and part time jobs will go in Gweedore Google+ WhatsApp WhatsApp Twitter Google+ 75 positive cases of Covid confirmed in North Further drop in people receiving PUP in Donegal Facebook
ColumnsA Charter For Reform In Procedural Criminal Laws Ensuring ‘Justice” In The Criminal Justice System Bharat Chugh16 Aug 2020 2:21 AMShare This – xNothing affects our lives and our liberty more directly than criminal law, and yet, nothing has been treated with greater disdain as far as law reform is concerned. We’ve talked about it a lot indeed. It has just not been important enough to implement, for some reason. We’ve forgotten that what separates a ‘Criminal System’ from a ‘Criminal Justice System’ (“CJS”) is Justice and an antiquated…Your free access to Live Law has expiredTo read the article, get a premium account.Your Subscription Supports Independent JournalismSubscription starts from ₹ 599+GST (For 6 Months)View PlansPremium account gives you:Unlimited access to Live Law Archives, Weekly/Monthly Digest, Exclusive Notifications, Comments.Reading experience of Ad Free Version, Petition Copies, Judgement/Order Copies.Subscribe NowAlready a subscriber?LoginNothing affects our lives and our liberty more directly than criminal law, and yet, nothing has been treated with greater disdain as far as law reform is concerned. We’ve talked about it a lot indeed. It has just not been important enough to implement, for some reason. We’ve forgotten that what separates a ‘Criminal System’ from a ‘Criminal Justice System’ (“CJS”) is Justice and an antiquated CJS can’t be expected to do justice.Criminal law, I’ve always argued, should be an area of greater concern, and its reform – the top-most priority. Unfortunately, CJS reform in India, historically, hasn’t received the attention that it really deserves. At least not until recently. Arguably, the primary reason for this disdain is the fact that most people who find themselves in the throes of the CJS are people who don’t really have much of a voice. Also, certain vested interests have always gained from the system being weak, lest it starts questioning them and bringing them to justice. Whatever may be the reason, we can all agree that there is a lot to be done. CJS reform has been in the news lately. A committee has been formed to look into this. This was long over-due and is surely a welcome step. In a three-part series, I seek to share my views on the changes that are urgently needed in our CJS. This part is dedicated to recommendations in the context of Procedural Criminal Laws. Why so much attention to the procedure, you ask? Well, as a Magistrate, and now as a defence lawyer, I’ve often seen procedure becoming the handmaid of injustice, instead of justice – as it is really supposed to be. Procedure and design can defeat or serve justice. It can frustrate or protect due process. This column is an attempt to just put some ideas out there; things that I feel would ensure that the CJS really protects due process while, at the same time, not impacting the pursuit of truth. Here are some thoughts: Reconsideration of the higher threshold for Bail in certain laws – Some acts require the accused to practically prove innocence in order to be entitled for bail and before the matter goes to trial. They require the accused to demonstrate that there are “no reasonable grounds to believe” that the accused is guilty of the offence alleged. (See: Section 212(6) of the Companies Act, 2013, Section 37 of the Narcotic Drugs and Psychotropic Substances Act, 1985 (“NDPS”), Section 21 of Maharashtra Control of Organized Crime Act, 1999 (“MCOCA”), and earlier, Section 45 of The Prevention of Money Laundering Act, 2002 (“PMLA”)). Anyone with even an elementary understanding of criminal jurisprudence and constitutional due process would scoff at this; these provisions are constitutionally suspect as they put the burden on the accused to establish her innocence – that too – at the time of bail; at a stage where the accused is structurally incapacitated from leading evidence in his defence. These provisions turn the presumption of innocence right on its head and place an often-insurmountable burden on the accused to prove prima facie (or even more than prima facie) innocence at the stage of bail. Fortunately, Section 45 of the PMLA has been held to be unconstitutional by the Supreme Court. Other provisions mentioned above should be reconsidered too, if bail hearings are not to be turned into verdicts before trials. Introduction of mandatory notice to the victim/complainant for all crimes. As of writing this article, there are no provisions requiring mandatory notice to the informant, except in Sexual Assault/ Protection of Children from Sexual Offences Act, 2012/Scheduled Castes and Tribes (Prevention of Atrocities) Act, 1989 cases, etc. This is important. Victims should be given a say even in cases of other prosecutions. Scope of a bail hearing: The scope of a court’s jurisdiction at the time of deciding a bail application needs to be laid down with precision and clarity. For instance, it needs to be clarified that bail in a case cannot be denied solely on the ground of alleged ‘gravity’ of the case; this is for the simple reason that an accused is entitled to presumption of innocence, especially when the other factors are in favour of the accused and there is no chance of accused running away from law or otherwise tampering with evidence. I’d further stick my neck out and suggest that it needs to be clarified explicitly that inadmissible evidence cannot be relied on in order to make a finding as to the seriousness of the case and deny bail on that ground. Alternatives to monetary bail: Alternatives to monetary bail should be considered seriously; for instance, GPS monitoring of the accused is a possible option which can be explored. It is extremely disconcerting that most inmates in prisons are under-trials, many of whom, given our dismal conviction rates, would ultimately be acquitted. How do we plan to repay them for the time spent behind the bars as an under-trial. Under-trial incarceration should be avoided, as far as may be. The use of lookout circulars, passport suspension, and other supervisory orders, ought to be preferred to an altogether denial of bail. Further, to make a better assessment of the risks of abscondment, at the time of bail, the judge should have a Risk Assessment Study which would help determine the least intrusive method of policing and investigating offences, maintaining a balance between individual liberty and community safety. All with an aim that: As long as participation in investigation and trial can be secured through other means, police/judicial custody ought to be avoided. Some jurisdictions have tried using AI systems and integrated data across departments to help the judge make better bail or jail judgments. Time limit for disposal of bail applications: Bail matters, since they involve personal liberty, ought to be taken up at priority and disposed-of within a time-bound manner, and in no case, more than a week from filing of the bail application. Laying down – with greater precision, the scope of the hearing would help us achieve this and prevent the bail hearing from degenerating into a mini-trial. Regulating the practice of sealed envelopes: The Supreme Court recently in the case of P. Chidambaram v. Directorate of Enforcementhas denounced the practice of routinely introducing evidence in opposition of bail applications in sealed envelopes. This seriously undermines accused’s right to know the charges against him and answer them appropriately. Given the possible mischief and prejudice, their use ought to be minimised, by legislative intervention, and confined only to the most extreme cases and allowed after due application of mind. If redacted information is provided to the accused, redactions also should be kept at the bare minimum and justified in each case. Anticipatory Bail to Juvenile: The position regarding the availability of Anticipatory Bail (“AB”) to juveniles needs to be clarified. Given the absence of legislation & any pronouncement by the Supreme Court on the issue, various High Courts have taken conflicting views on this. As a result – Jury is still out on the question of applicability of Section 438 of The Code of Criminal Procedure, 1974 (“CrPC”) in case of a Juveniles. In Kamlesh Gurjar v. The State of Madhya Pradesh the court held that, in the absence of any specific provisions in the Juvenile Justice (Care and Protection of Children) Act, 2015 (“JJ Act”), a juvenile is not entitled to move an application under Section 438 of the CrPC seeking AB, and JJ Act is a self-contained law in relation to juveniles. Other High Courts have taken a different view holding that S. 438 is offence agnostic and, being a beneficial provision, should not be unduly limited and should equally apply to JJ Act offences. The Rajasthan High Court, for instance, has held that merely because S. 10 of the JJ Act provides for apprehending a child in conflict with law and not for arresting him, it cannot be held that an application u/s 438 by him or her is not maintainable. Semantic differences need not limit a substantive right. This needs to be clarified. It also needs to be clarified as to where such an application would be required to be filed; this is important since, as per S.438, the power vests in the Sessions Court or the High Court, but otherwise, a juvenile is to be dealt with in a non-stigmatising juvenile justice board, for all purposes. Need some guidance here. Clarity on which court can grant Anticipatory Bail: Doubts remain as to which court has the jurisdiction to grant an AB. The courts of the place where the accused resides (and apprehends arrest), or it is only the court with the jurisdiction to actually try the offence that must entertain an AB application. Though most of the High Courts have taken the view that the courts of the place where the accused apprehends arrest indeed has the power to grant AB, but an amendment to Chapter XXXIII (Dealing with Bail) is needed to clarify this. Chapter XIII in CrPC, which otherwise deals with jurisdiction, kicks-in only at the stage of inquiry and trial and not at the stage of bail and may not apply here. The position of law in such cases needs to be clarified. Proper intimation of rights of arrestee and videography: The process of arrest, explanation of due process rights – such as the right to have a lawyer, protection against self-incrimination, medical examination, right to bail, must all be read out in the clearest language and in vernacular to the accused, and all of this should be videographed and open to inspection by the Magistrate concerned. Presence of a lawyer during interrogation: The presence of a lawyer should be mandatory at the time of interrogation. Without the presence of a lawyer, rights such as the right to silence/protection against self-incrimination are all rendered nugatory and illusory. For the informed exercise of these, a person needs to have proper legal counsel, from the very start itself. Section 41-D of the CrPC needs to be amended to that extent. If a person cannot afford a counsel, a remand counsel ought to be provided not just at the stage of first remand/production before the court but soon after arrest, and at the police station level itself. These measures would help check police arbitrariness and cases of custodial torture/excesses.Safeguards from illegal arrest to be extended to sexual minorities and senior citizens. Section 46(4) of the CrPC, which provides for arrest by women officers and no arrest after sunrise and sunset (without a special order) should be extended to certain sexual minorities (who identify as such/being a woman). The safeguard in the context of the time of arrest should also be extended to senior citizens. Section 91 of the CrPC to be amended to respect privilege: Section 91 of the CrPC, in the shape that it is currently, does not respect privileges such as ‘attorney-client communication’. In the present shape, only Sections 123 and 124 of the Evidence Act constitute exceptions to a request u/s 91 CrPC. There is no reason as to why other privileged information should not similarly be exempt from disclosure. A privilege would be worth very less if the same is compelled to be disclosed to the police but privileged during trial. Privilege should extend from investigation right till trial. This is important because it has been seen recently that sometimes investigators seek information shared between client and counsel in a notice u/s 91 of the CrPC. Any defence of privilege is not entertained at the stage of investigation simply because only S.123 and S.124 of Evidence Act (providing for privilege to information as official acts/affairs of state, etc) have been carved out as exceptions (See S.91(3). This presents an ethical conundrum to the lawyer who is bound under the Bar Council Rules (over and above the Evidence Act) to respect privilege but otherwise compelled or compellable to disclose things to police. In a nutshell, Section 91 of the CrPC ought to be amended to carve out other privileges too, within S.91 by amending subsection (3). Such questions need to be addressed during investigation itself and need not await trial, when the court determines the question of admissibility. Mandatory Video recording of all statements u/s 161/164 of the CrPC: This is long over-due. There should be mandatory video recording of all S. 161 and 164 statements. There is absolutely no justification for not doing it, except so-called budgetary constraints. Budgetary and logistical constraints are not justified. CJS needs to be prioritised. Nothing affects life and personal liberty more intimately than CJS. Digitisation of court proceedings and records: All court proceedings including statements of witnesses under Sec. 161/164, all examinations in chief, cross examinations and all other documents relied on by either side should be digitised and uploaded on an online portal which can conveniently be accessed by the accused and his counsel so that an effective defence can be prepared. A central case docket, especially in times such as these, is imperative. Magisterial power to supervise investigations: A lot of investigative lapses and excesses can be checked by more pro-active magisterial involvement right from the start. We must legislatively implement the judgment of the SC in Sakiri Vasu v. State of UP and lay down -with precision and clarity, the power of the Magistrate to supervise the investigation and the kind of orders that the magistrate can pass to make investigations more effective, fair, impartial and objective. Empower the magistrate to record 164 statements suo motu: We must empower the Magistrates to pro-actively record statements u/s 164 of the CrPC – suo motu, and not just statements of only those witnesses who are proposed/forwarded by the IO, which is the case currently. For instance, a witness who may offer sterling exculpatory evidence should also be examined u/s 164 of the CrPC and not just witnesses deposing as to incriminating facts and supporting the police case. Further, SC has already ruled that statements of all eye witnesses ought to be recorded u/s 164 of the CrPC (to give them corroborative effect at trial) , however, the implementation leaves a lot to be desired. Implementing this in the statute itself is going to be apposite. Section 164 Statements should be allowed to be used in trial as examination in chief: Further, Section 164 statements, if recorded properly by the Magistrate and duly video-recorded, should be permitted to be used as statements in lieu of examination in chief. The current system of an eye-witness/victim deposing at least thrice (S.161 statement before police > S. 164 statement before magistrate > Examination in Chief before trial court) by the time matter comes to trial, is too onerous and hardly satisfactory. Many people are put-off at the idea of being witnesses and we must treat them better and make it easier for them. We need to take care of the ‘eyes and ears’ that these witnesses are to the system. Witness Protection Law– Witness protection guidelines, made law by SC through its judgment in Mahender Chawla v. Union of Indiaought to be implemented and writ into the CrPC itself. Anything else would mean that they would continue to be disregarded, by and large. CCTV footage in police stations: This-again- has been needed for long. CCTV in police stations and supervision by the Magistrate is imperative to minimise/rule out chances of custodial torture and, along with, video recording of statements would ensure transparency in the investigation. This is presently being examined by the Supreme Court in Paramvir Singh Saini v. Baljit Singh. Further, the Magistrate should be empowered to visit and inspect police stations within his jurisdiction at any time. The looming fear of a “Magistrate’s Inspection” can keep a check on custodial torture and the rampant practice of ‘off the record arrests’. Prompt delivery of occurrence report: Email of Occurrence Report/FIR, within minutes of registration, to the Magistrate concerned to bring in magisterial supervision at the earliest. Process u/s 82 CrPC during the investigation: CrPC may be tweaked to allow issuance of Non-Bailable Warrants (“NBWs”) and Process for Proclamation u/s 82 CrPC against an absconding accused, to be issued even during investigation, with a view to assist the Investigating Officer (“IO”) in the apprehension of the accused. Sometimes, an NBW/Process u/s 82 CrPC is needed by the IO to initiate issuance of Red Corner Notices, etc, and apprehension of the accused. There is a currently a divergence of judicial opinion here. Some decisions opine that NBWs/Process u/s 82 of the CrPC ought to be issued only for the purpose of securing the appearance of the accused at the time of trial, while others permit issuance of NBWs/Process u/s 82 CrPC at the stage of the investigation itself. Latter appears to be a more practical way of looking at things. Power to take voice samples: Supreme Court has already ruled that an accused can be compelled to give voice samples during the investigation. CrPC must be amended to implement this legislatively, with the necessary safeguards. Compulsory Psychological evaluation of arrestee as part of Medical Examination: There should be a compulsory psychological evaluation of the person arrested as part of standard medical examination. This would ensure that a better picture of the accused’s psyche is captured, right after the crime when the same is still afresh. This would be helpful not only in assessing culpability but also assist the court while deciding the appropriate sentence for the accused, at the final stage of the case. Clarity on power to compel disclosure of passwords/fingerprints: This requires some thought but I’d still put it out there. Mobile phones, these days, have become an extension of the human mind. They are privy to our darkest secrets and our deepest desires. Our phones possibly know us better than our families and friends, and arguably, better than we know ourselves. Everything that we do on our cell phone: from liking cute cat videos, navigating to a location on GPS, to shopping online, we are leaving digital footprints everywhere. All of this also constitutes crucial evidence. Now in this context, picture this: a suspect in a criminal case is compelled to provide his fingerprint or a face scan or his password to unlock his phone. Can he be so compelled? What about the constitutional protection of not being compelled to be a witness against herself? Does disclosure of a person’s mobile password or getting a face scan amount to compelling a person to be a witness against herself? What about the right to privacy implications? We need to regulate this. Simply speaking, providing a fingerprint to unlock one’s phone may not amount to being compelled to be a witness against oneself, given the fact that one’s fingerprint may not really be something ‘testimonial’ in nature, and, therefore, arguably, not protected by Article 20(3) of the Constitution. But would the answer be different if, instead of a fingerprints, it is a password instead. Also, privacy concerns remain. Given these concerns, this needs to be well thought out. I’d leave that to better minds to ponder this. All I would say is, if implemented, there should be safeguards to ensure that the investigation remains focussed and search narrowly-tailored, so that privacy concerns are respected and phone searches do not become roving enquiries and fishing expeditions. Codify the prosecutorial duty of disclosure within CrPC. Section 173 and 207 of the CrPC should be recast. There should be a duty on the IO and prosecution to collect and disclose all evidence that is material to the case and not just incriminating evidence that the ‘prosecution seeks to place reliance on’. This would be in line with the prosecutorial duty of disclosure as outlined under the Bar Council Rules and various judgments such as Manu Sharma, V K Sasikala, Nitya Dharmananda, etc. Further, if the IO has spoken to any witnesses who are not made prosecution witnesses, for whatever reason, that also should be disclosed to the defence with a view to give them a fair opportunity. These safeguards and disclosures are important because an accused does not have the benefit of the investigative apparatus of the State to dig out evidence and put up a good defence and complete disclosure would help the accused make out a fair defence case. We need to help ease the information asymmetry between accused and the prosecution and provide level playing field. Proper disclosure of electronic records: In cases where prosecution relies upon electronic record evidence; for instance, a hard disk; a clone copy or image should be provided, and not just a backup. In other words, an exact clone is what the accused should get, in the interests of fullest disclosure and so that he can extract exculpatory evidence from the same too, if posssible. S.173/207 CrPC, therefore, may be amended in that regard adopting the ruling in Dharambir vs Central Bureau of Investigation (Also see : Gopalakrishnan v. State of Kerala)Legislate and streamline the process of mediation in compoundable cases. Currently, the area of law is governed by the judgment of the High Court in Dayawati v Yogesh Kumar Gosain, in so far as cases u/s 138 of the NI Act are concerned. (Full disclosure: The undersigned, whilst serving as a Magistrate, made the reference to the Hon’ble High Court leading to the above decision). We need to amend S.320 of the CrPC and provide for mediation specifically as a mode of resolution and compounding. We must provide for serious consequences of non-compliance of mediation agreements. Currently, a mediation settlement leads to an acquittal (as the case stands compounded by virtue of Section 320 of the CrPC), however, where the accused reneges on the settlement later on (for instance, in a case of the amount required to be paid in several instalments), since an acquittal already stands recorded, the court cannot revive the trial and the only option available to the court is to recover the settlement amount as an ‘amount directed to be deposited by the court’ by virtue of Sections 421 r/w 431 of the CrPC. Though this is the best option available in the present legal regime, however, in some cases, it is shown to have limitations. The real deterrent for compliance of a mediation settlement agreement is the revival of the case and possible prison sentence. Section 320 may be amended to provide for the revival of trial in case a mediation settlement/terms of compounding are violated. The meaning and import of “assistance” by a victim’s counsel: CrPC provides that the victim can only “assist” the prosecution and not conduct the prosecution itself. The scope and meaning of what assistance means needs to be laid down with precision, right from the stage of opposition of bail, right till the sentence hearing.Legal assistance to the investigators during the investigation: An overwhelming number of cases fail on account of (totally avoidable) defects in the investigation. Either due to lack of proper training of investigators, heavy case load, or simply, an attitude of general apathy to rules and procedural requirements. Failure to maintain proper records, improper management of documentary evidence, and delay in recording witness statements are some of the factors afflicting the investigative process. Most, if not all, of these infirmities, can be corrected by timely intervention on behalf of the prosecutor who should carefully handhold & advice an investigator (who is not usually a trained legal mind) in investigating properly. The prosecutor, or at any rate a legally trained lawyer/advisor, while not investigating the case herself, must be involved in the investigative process and not just after the filing of the charge-sheet. The Investigator should have the option of seeking legal advice from the prosecutor/legal advisor as and when the need arises. Crown Prosecution Service (“CPS”) in the UK does that. This would ensure that the prosecutor is not incapacitated in the prosecution of the case due to the terrible quality of an investigation and not handed a fait accompli each time. Timely interventions by the prosecutors may go a long way in ensuring qualitative investigations and better results/outcomes. This would require legislative/policy changes. What is notable in this regard is that, recently, under the directions of MHA/GOI, the Delhi Police vide order dated 23.04.2020 has resolved to set up a separate Directorate of Prosecution for Delhi Police tasked with the responsibility of rendering legal assistance to Investigating Officers during the investigation. Prior to this, the police would usually forward the charge-sheet to the prosecutor concerned for his views. This exercise, in my opinion, was bereft of legal sanction and not in consonance with CrPC, as it stands. Streamlining and codifying the process of E-Service of summons: Ad-hoc judicial decisions permitting this lead to inconsistency. The provisions relating to service of summons may be amended to provide for service through email/SMS. Having said that, instead of being relegated to the parties, this should be carried out by the administrative office attached to the court and with the unique digital signatures provided to each court. The process needs to be streamlined. The practice of parties sending summons through email and then later filing an affidavit of compliance is, at best, a stop-gap arrangement and not entirely satisfactory. Making substituted service gender-neutral: In case the person on whom the summons are to be served is unavailable, the statute provides for service through adult “male” member of the family u/s 64 of the CrPC. The same must be amended to mean “any adult family member” so as to be gender-inclusive and consider non-cisgender identities respecting the spirit of National Legal Services Authority vs. Union of India and Navtej Singh Johar v Union of India.Allow petty cases, attracting only fine to be conducted online: For cases involving fine not more than a few thousand rupees, we must make them triable online by amending the chapter in CrPC dealing with summary trials. We must let the accused plead guilty on the court portal and deposit fine through debit card/credit card and, only if the accused seeks to contest – should the matter come to court. Widening the definition of the term “wife” of purposes of maintenance: The term “Wife” under section 125, CrPC may be amended to include a de-facto wife. This has already been laid down in Badshah vs Sou. Urmila Badshah Godse & Anr Also, like provisions for maintenance in the Hindu Marriage Act, this also may be made gender-neutral. Mandatory Victim Impact Assessment and Crime Impact Assessment Reports at the earliest stages of the case, so as to assist the court pass appropriate bail and compensation orders. Mandatory Admission and Denial: Provide for mandatory admission/denial of evidence in criminal trials, to ensure that witnesses, whose testimony is not in dispute, are not needlessly called. This would greatly expedite trials. A lot of time is wasted in repetitive evidence of formal character. More pro-active use of Section 296 CrPC to receive evidence of formal witnesses on affidavit and use of Section 294 of the CrPC to record admission and denials would be desirable. Section 294 CrPC may be mandatorily worded, on the same lines as the provision in CPC. Amend s. 309, CrPC to allow for the imposition of real/actual costs on the party who causes delay in proceedings. Provision of leniency/tender of pardon to a corporation: Indian investigators have been seen to be reluctant in the more pro-active use of ‘approvers’ and ‘accomplices’ in making out a good prosecution case. Complex white-collar investigations require that the investigators take the help of insiders and companies’ rabbis to guide them through the transactions. Since even the smartest ‘outsiders’ are unable to make sense of or rely on the documents, they almost always have to get someone from the inside to flip and that can happen only when this ‘insider’ is provided proper protection and the right incentives. Making a company ‘insider’ capitulate and turncoat is of profound importance in a white-collar crime investigations, given the nature of the crime and the sophistication with which they are committed and considering how carefully they are hidden. We also need to put in place robust leniency/pardon mechanisms for companies willing to disclose any criminality on their part (or on the part of any of their executives), and willing to make amends/restitution. A similar mechanism for disclosure for companies is already there in the competition law regime. We need a parallel here in criminal law. The existing system of tendering pardon to an accused (under the CrPC)- with a view to get a true and fair disclosure from her about the case – may be unsuited in its application to a corporation. Introduce a provision on discharge during summons trials in the CrPC. Currently, the Summons trial chapter in the CrPC does not contain a provision for discharge. The Delhi HC has, however, in R Narayanan vs. State commented on the possibility of discharge but did not pass an order on the same. A reference to this effect is pending with the Delhi High Court. Section 251 of the CrPC only provides for communication of substance of accusation to an accused and not discharge. This is unlike Warrant trials/Court of Sessions Trials where discharge is possible u/s 239/227 of the CrPC. The differential treatment was called for because at the time Section 251 was conceived, it was thought, and for good reason, that summons trials are an abridged form of trial (given the maximum sentence in such cases is 2 years) and there is no need to have an elaborate discharge hearing, which is going to only delay matters, without contributing much. Well, this view does not hold true anymore when summons trial remain pending for pretty much as long as any other trial. They are an abridged form of trial only on paper. Also, a two-year sentence cannot be called that short also that one makes serious inroads into a vital safeguard that the accused has: that is seeking discharge – in the nature of a threshold challenge. Discharge in summons case needs to be introduced statutorily. Arbitrary Conditions on Grant of Bail: Circling back to bail again. Bail conditions such as planting of trees, condition of apologizing for a tweet, condition of depositing money with the court, especially in economic offences, condition of not saying “anti-national” things, condition of marrying the complainant, in a domestic law case etc. may not be appropriate conditions that may be imposed at the time of bail. Some of these conditions are punitive in nature and do not have nexus with bail and the need to ensure that the accused does not abscond from the process of law. Protection to Whistle-Blowers: In order to encourage whistle-blowers to come forward, a robust and inclusive statute is required to ensure that a safe environment is provided to the whistle-blowers. The Whistle Blowers Protection Act, 2014 has not yet been enforced and as per some reports might get dilute before it sees the light of day. We need to properly incentivise whistle-blowers who risk their own lives to blow the whistle on crimes within large organisations and government departments. After all, the key reason why whistle-blowing is successful in the US is its incentive scheme. With organisations like The Securities and Exchange Commission and The Internal Revenue Service having given out incentives running into millions of dollars, it is no surprise that the scheme works as well as it does. Some Indian agencies do provide for a rewards scheme for informants which can be adopted for white collar crimes. E.g. – The Informants Rewards Schemes used by the Central Board of Direct Taxes (“CBDT”) or the provisions for Informant Reward under the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 (“PIT”). It must be kept in mind, however, that the need to provide incentives is over and above the protection that a whistle-blower should be provided. The remedy lies in proper incentives and protection. The fate of the Whistle Blowers Protection Act, 2014, which is yet to come in force and might get diluted, shows the legislature’s lackadaisical approach towards providing a safe harbour to whistle-blowers. Further, except a few provisions under the CA which protect employees from dismissal during an investigation conducted by the Serious Fraud and Investigation Office and provide safeguards against victimisation of employees and directors, there is nothing in any other law providing similar protection. This is by no means an exhaustive list. Just some points to kindle an active debate. Discussing these, I feel, is important. Some points are consciously framed so as to be assaults on our senses and the status quo, which, I feel, is unsatisfactory in many respects and ought to be re-examined and made better.Views are personal only.(The Author is a Former Judge, Delhi, currently practising as an Advocate in Delhi) *A huge shout-out to Shreyash and Rohit for their valuable inputs. This article was first published here P. Chidambaram v. Directorate of Enforcement, 2019 SCCOnline SC 1549 Kamlesh Gurjar v. The State of Madhya Pradesh MCrC 10345/2019 Sagar Through Guardian v. State of Rajasthan, SB Crl Misc Bail Appln No. 11432/2019  Sakiri Vasu v. State of UP (2008) 2 SCC 409 Doongar Singh vs The State Of Rajasthan (2018) 13 SCC 741 Mahender Chawla v. Union of India (2019) 14 SCC 615 Paramvir Singh Saini v. Baljit Singh SLP (Crl) DN 13346/2020 Ritesh Sinha v State of UP (2019) 8 SCC 1 Sidhartha Vashisht @ Manu Sharma vs State (NCT Of Delhi) AIR 2010 SC 2352 V K Sasikala v. State (2012) 9 SCC 771 Nitya Dharmananda v. Gopal Sheelum Reddy (2018) 2 SCC 93 Dharambir vs Central Bureau Of Investigation 148 (2008) DLT 289 Gopalakrishnan v. State of Kerala AIR 2020 SC 1 Dayawati v Yogesh Kumar Gosain 243 (2017) DLT 117 National Legal Services Authority vs. Union of India AIR 2014 SC 1863 Navtej Singh Johar v Union of India AIR 2018 SC 4321 Badshah vs Sou. Urmila Badshah Godse & Anr (2014) 1 SCC 188 R Narayanan vs. State 2019 CriLJ 1761 Court on Its Own Motion vs. State Crl.Ref. 4/2019 Soman v. Kerala (2013) 11 SCC 382 State Of M.P vs Bablu Natt AIR 2009 SC 1810 State Of Punjab vs Prem Sagar & Ors (2008) 7 SCC 550 Next Story
FacebookTwitterLinkedInEmailCEDAR CITY, Utah (AP) — Jacob Calloway scored 20 points, Maizen Fausett had 12 points and 14 rebounds and Southern Utah routed NAIA-member San Diego Christian 111-64 on Thursday night.Southern Utah (4-1) rebounded from its only loss of the season, 76-71 at UNLV on Friday.The Thunderbirds shot 51 percent (41 of 81) from the floor that included 15 3-pointers. Kenton Eskridge, a 6-foot-2 freshman from Atlanta, added a career-high 16 points for Southern Utah. Brandon Better had 15 points and Cameron Oluyitan 11. Calloway and Eskridge each made four shots from long range.Derek Novsek made six 3-pointers and scored a season-high 30 points to lead San Diego Christian.The Thunderbirds jumped out on a 23-7 lead and built a 56-32 halftime advantage. Calloway’s 3-pointer stretched the lead to 84-53 with about nine minutes to play. Written by November 29, 2018 /Sports News – Local Southern Utah hits 15 3s, routs San Diego Christian 111-64 Tags: SUU Thunderbirds Basketball Associated Press