The entire administration of justice is impaired when there is any kind of undue influence or external pressure which is being imposed on a witness who is called upon for witness testimony in the court of law. As stated by Bentham, "witnesses are the eyes and ears of justice". Any kind of criminal intimidation or threat towards the witnesses pave the way for the witnesses to turn hostile, especially in high profile cases.

One of the crucial factors for achieving a fair trial is for the witnesses to come forward and render true statements which ensures justice for both the accused and the victim. The need for comprehensive witness protection laws has been a prime subject of discussion in the recent past, with various cases justifying the same. There is an evident urgency to introduce new statutory witness protection laws in order to curb false testimonies which are prevailing in India.

The role of a witness in a criminal trial is paramount to reach an equitable closure to the case. The witnesses are unable to fulfill their role in the court of law thereby resulting in the derailment of the trial. This paper aims to elucidate the laws and witness protection programs in India, and a brief into the witness protection laws across the world. This paper emphasizes on the reasons why the witnesses turn hostile and its impact on the criminal trials in India.

Moreover, the paper analyzes the effectiveness and outcomes of the Witness Protection Scheme, 2018. The paper concludes by underlining the pressing need for an independent legislature for witness protection in India, and the steps to be taken to safeguard a fair trial.

Introduction
Witnesses are considered to be crucial for a successful criminal justice system and fair prosecution of crimes. A Witness can be defined as a person who gives evidence in the form of statements or deposes before a judicial body. Under section 3 of the Indian Evidence act,1872, evidence means and includes oral and documentary evidence alone.

"All statements which the court permits or required to be made before it by a witness, in relation to the matter of fact under enquiry, is called oral evidence." Also, a Witness is defined under section 2(k) of the Witness Protection Scheme 2018 as "any person who possesses information or documents about any offense". Witnesses must be safeguarded against criminal suspects intimidation or physical threats in order to defend the rule of law. It is often observed that due to external pressures, there poses a hazard to witnesses.

The foundation of justice is purely based on the honest testimony of witnesses who are on oath. The statements of witnesses are vital for a fair trial as they decide the accused's conviction or acquittal. Hence, a witness should be impartial, unbiased and independent when called upon for his testimony.

The Code of Criminal Procedure and the Evidence Act comprehensively provide for the deposition of a witness and the rules and procedure regarding their admissibility in the proceeding of the court.

In the case of Swaran Singh v. State of Punjab, the Supreme Court highlighted the importance of witnesses in the justice delivery system in general. In many cases, witnesses have to face multiple ordeals in overall court proceedings starting from pendency of case adjourning from one date to another, thus delaying the trial.

Sometimes witnesses get killed, beaten up as no specific protection is available to them. Sometimes they are unnecessarily harassed during cross-examination for a long period of time. So common people often try to maintain distance from court & investigating authorities. In recent times, there has been a rapid increase in witnesses turning hostile indicating the need for legislators to make laws for the protection of witnesses.

Significance Of Witness Protection In The Judicial System

According to the 198Th Report On Witness Identity Protection And Witness Protection, 2006, there are three categories of witnesses:

1. victim-witnesses who are known to the accused;
2. victims-witnesses not known to the accused (e.g. as in a case of indiscriminate firing by the accused) and
3. witnesses whose identity is not known to the accused.

Category: requires protection from trauma and categories (ii) and (iii) require protection against disclosure of identity. In category (i) above, as the victim is known to the accused, there is no need to protect the identity of the victim but still the victim may desire that his or her examination in the Court may be allowed to be given separately and not in the immediate presence of the accused because if he or she were to depose in the physical presence of the accused, there can be tremendous trauma and it may be difficult for the witness to depose without fear or trepidation. But, in categories (ii) and (iii), victims and witnesses who are not known to the accused have a more serious problem if there is likelihood of danger to their lives or property or to the lives and properties of their close relatives, in case their identity kept secret at all stages of a criminal case, namely, investigation, inquiry and trial.

According to section 118 of the Indian Evidence Act, any person who is able to understand the question posed to them and is able to give rational answers based upon those questions qualifies to be a witness. A legally competent witness must provide evidence. Competency of a party is vital for a true testimony. Competency refers to the legal competency to provide evidence in a court of law. The competency of a person to testify as a witness is a condition precedent.

Protecting and supporting a witness on the stand is vital for the functioning of a fair trial as the evidence provided by the witnesses act as a major component of corroborative evidence. The absence of a standard and unbiased testimonial evidence will be violative of the right of the parties to a fair and informed judgment. A prominent part of the country's progress and development depends on a strong and effective judicial system. The cooperation of all the necessary parties to a criminal trial is key for constructive prosecution. It is also the statutory obligation of every witness who has the knowledge of the crime to assist the state in providing evidence.

However, getting the necessary cooperation from the witnesses is far-fetched due to the dull state of affairs in the country. The number of pending cases in the country keeps mounting day by day. Just because of the increase in the number of judges, there is no guarantee of a faster adjudication of cases. While the sanctioned strength of the judges has gone up in the past few years, the pace of work hasn't shown considerable or proportionate improvement. A layman seeking justice in the court of law would get cornered in the slow moving wheels of the judiciary.

When there prevails a slowly paced judicial system, this gives rise to vigilantism. Sufficient protection and support to the witnesses leads to necessary cooperation which in turn enables the criminal justice system to achieve a fair trial. When material witnesses are not heard, it makes room for an unfair trial.

A fair trial is one in which bias or prejudice for or against the accused, the witnesses, or the cause that is being tried is eliminated. The effectiveness of witness protection programs and schemes are paramount in bringing changes to the criminal administration of justice. Hence, bringing in reforms in India is the need of the hour to strengthen fair trial in the court of law. A witness must be protected at all means both before and after trial. Hence, bringing in new statutory witness protections is a cardinal emergency in India.

Vulnerable Witnesses & Child Witnesses

The people who are unable to testify or give evidence to the court due to certain additional difficulties like mental disorders, physically handicapped or are unable to cope due to intelligence impairments, and are below 18 years of age are termed as Vulnerable Witnesses. Section 3 of the Delhi High Court Guidelines, 2018 defines a "vulnerable witness" as a child who has not yet completed 18 years of age. The term vulnerable witness is not included under Section 118 of the Indian Evidence Act.

The Youth Justice and Criminal Evidence Act, 1999 of the United Kingdom mentioned certain measures for the protection of vulnerable witnesses. There are certain people who are unable to testify or give evidence to the court due to certain additional difficulties like mental disorders, physically handicapped or are unable to cope due to intelligence impairments, and are below 18 years of age.

Such people are termed as vulnerable witnesses. However, the Supreme Court of India while hearing a special leave petition in the case of Smruti Tukaram Badade v State of Maharashtra and Anr. orally remarked that the definition of the term 'vulnerable witness' might not be constrained to child witnesses.

A child can testify if the court thinks that he/she is able to answer the questions put forward rationally provided he/she is not a toddler. In the case of Dhanraj and Ors, v. State of Maharashtra, the witness was a child of class VIII. The Supreme Court held that a child of class VIII who is not very small will be having enough intelligence to understand the facts and answer the questions put forward. Hence the testimony of the child was heard. Witnesses who are small children or people with certain disabilities are bribed or threatened to change their stand. Due to this, many times such people are not ready to give their testimonies. The protection of vulnerable witnesses in criminal proceedings has become a burning issue in India.

As mentioned earlier, the Delhi High Court in the 2018 came up with Guidelines for recording of evidence of vulnerable witnesses in criminal matters. These guidelines primarily aim to secure the evidence given by the witnesses by striking a balance between the fairness of the trial and ensure that the witnesses are able to give evidence and to reduce secondary victimization and harm caused to vulnerable witnesses as a result of their contribution to the criminal justice system. In State of Maharashtra v. Bandu, the victim was a deaf and dumb 14-year-old girl who was raped allegedly by the respondent i.e Bandu.

The High Court set aside the conviction of the respondent on the ground that the victim was not cross-examined. The case went to the Apex Court who held that, even though the victim was not cross-examined, there was plenty of evidence to prove that she was raped by the respondent. After passing its Order, the Court looked into a suggestion stating that special examination centres must be set up for examining vulnerable witnesses so as to make them comfortable to give their statements. The Court further asked for the status of setting up vulnerable witness deposition centres and pressed for the same.

In recent developments, the Supreme Court in 2017, ordered for the immediate establishment of at least two vulnerable witness deposition centres under every High Court's jurisdiction. These centres are specially set up for child witnesses, and victims turned witnesses in heinous crimes like rape, sexual assaults, etc. who need protection. These centres will have all the protective measures in place to ensure a safe haven for the witnesses.

In 2019, Gujarat established its first vulnerable witness deposition centre in Vadodara. The centre was directly attached to the Chhota Udaipur District Court with a special entry and exit system. The centre was designed in a way that there won't be any direct or indirect contact between the witness and people outside. Furthermore, the centre has a separate washroom, pantry, television set, children's play area, etc.

On the other hand, the guidelines for a child witness has been provided in Sakshi vs. Union of India the court laid down the following guidelines on the procedure of taking of evidence from a child witness:

• The judges shall allow the use of a videotaped interview of the testimony of the child in the presence of a child-support person.
• A child could be permitted to testify through closed circuit television or from behind a screen to acquire an honest and frank account of the acts complained of without any fear.
  Only the judge should be allowed to cross-examine a minor on the basis of the questions given by the defence in writing after the examination of the minor.
• During the testimony of the child, sufficient intervals should be provided as and when she requires it.
   

Primary Reasons For Witnesses Turning Hostile

A witness is considered to be hostile when he gives a statement before police with respect to commission of an offence out of his knowledge but retracts it or changes his stance when deposing before the court during trial. One of the main reasons for witnesses to turn hostile is that they are not accorded appropriate protection by the State.

The 4th National Police Commission Report, noted that "prosecution witnesses are turning hostile because of pressure from the accused and there is need of regulation to check manipulation of witnesses". The trend of witnesses turning hostile is due to various other factors. It could be fear of testifying against the accused/delinquent, political pressure, family pressure, or other sociological issues. It is also possible that witnesses are corrupted with monetary considerations.

A witness may turn hostile at any stage during the trial, which may be the initial stage, or during examination-in-chief or during cross examination. In certain cases, where the witness even if turns hostile and is declared under section 154 as a hostile witness, the testimony will not be discarded from consideration altogether, simply because the witness is hostile. The court will look into the testimony , if it could be corroborated with any other facts or reliable evidence, for the truth to prevail in a matter submitted.

While there is nothing to declare a witness as hostile under the Indian Evidence Act, Section 154 vests discretion in the court to permit a person who calls a witness to put any question to him which might be put in cross-examination. Section 145 of the Act permits cross-examination of any witness as to previous statements made by him in writing. A witness is said to be hostile if he tries to suppress the truth thereby injuring the cause of the party that calls him. Such evidence should be discarded as unworthy of credit. However, every inconsistency in the statement of a witness cannot be used to contradict the case of prosecution per se.

In Zahira Habibullah Sheikh v. State of Gujarat, the court said:
"The State has a definite role to play in protecting the witnesses, to start with at least in sensitive cases involving those in power, who have political patronage and could wield muscle and money power, to avert trial getting tainted and derailed and truth becoming a casualty".

In another landmark case, Ramesh and Others vs. State of Haryana, the court attributed the following reasons for witnesses retracting their statements and turning hostile:

1. Threat/Intimidation.
2. Inducement by various means.
3. Use of muscle and money power by the accused.
4. Use of stock witnesses.
5. Protracted trials.
6. Hassles faced by the witnesses during investigation and trial.
7. Non-existence of any clear-cut legislation to check hostility of witnesses.

Moreover, the Sohrabuddin fake encounter case also faced the same setback where around 80 witnesses turned hostile. Such deliberate cases of witnesses turning hostile reveal the extreme side of influence and power in a country where seeking justice is already in a miserable state. There are numerous reasons for witnesses turning hostile during a trial. In most of the cases, witnesses face the rage of accused persons who hold power or are in a position of authority.

In the infamous case of Sidhartha Vashisht @ Manu Sharma v. State (NCT of Delhi), 80 witnesses had turned hostile, which led to his acquittal by the lower court, though reversed by the higher courts. Such blatant cases of witnesses turning hostile portray the extreme side of influence and power in a country where seeking justice is already in a dismal state.

The evidentiary value of a witness is analyzed by the Supreme Court in Basappa @ Basavaraj S/O Chandappa v The State of Karnataka, stating that "In a criminal prosecution when a witness is cross-examined and contradicted with the leave of the court, by the party calling him, his evidence cannot, as a matter of law, be treated as Washed off the record altogether. It is for the Judge of fact to consider in each case whether as a result of such cross-examination and contradiction, the witness stands thoroughly discredited or can still be believed in regard to a part of his testimony.

If the Judge finds that in the process, the credit of the witness has not been completely shaken, he may, after reading and considering the evidence of the witness, as a whole, with due caution and care, accept, in the light of the other evidence on the record, that part of his testimony which he finds to be creditworthy and act upon it.In Syad Akbar v. State of Karnataka , the Supreme Court held that declaring a witness hostile is no ground by itself to reject his testimony in toto. His testimony not shaken on material points in cross-examination cannot be brushed aside.

Statutory Witness Protection In India

Generally, the duty of a witness who stands in a witness box is to speak the truth which helps in favour of the victim. At the same time, it is the duty of the state to protect such a witness from the threats to his life or property in numerous areas.

When a witness is threatened or slaughtered or hassled, it is not just a threat nevertheless the violation of the fundamental right of a citizen who aims to have a fair trial. However, in our country's present scenario, we do not have a law which shields the well-being of the witnesses. Provisions pertaining to victim help and witness safeguards exist in various statutes. However, there is absence of a single combined law that exclusively extends safety to witnesses.

Indian Penal Code, 1860:
Section 228A of the IPC provides the provisions barring the publishing of identity of the victim of certain offences relating to rape while providing for certain circumstances under which the identity can be disclosed. Hence, there must not be any printing or publishing of any matter in relation to any of the mentioned offences without prior permission of the court.

Section 195A of the Indian Penal Code states that whoever threatens another with any injury to his person, reputation or property or to the person or reputation of anyone in whom that person is interested, with intent to cause that person to give false evidence shall be punished with imprisonment of either description for a term which may extend to seven years, or with fine, or with both.

Section 193 of the Indian Penal Code provides for the punishment for false evidence. Whoever intentionally gives false evidence in any stage of a judicial proceeding, or fabri­cates false evidence for the purpose of being used in any stage of a judicial proceeding, shall be punished with imprisonment of either description for a term which may extend to seven years, and shall also be liable to fine, and whoever intentionally gives or fabricates false evidence in any other case, shall be punished with imprisonment of either de­scription for a term which may extend to three years, and shall also be liable to fine.

Code of Criminal Procedure, 1973:
According to Section 177 of the Code, in order to secure unbiased and independent evidence, the witness on his way to court shall not be required to accompany a police officer and shall not be subjected to needless restraint or trouble. Section 299 lays down the right of the accused to cross-examine the prosecution witnesses. In certain exceptional circumstances where the accused is absconding and cannot be produced before the court, the section provides for examination of witnesses by the prosecution in the absence of the accused. Hence, the accused is lawfully denied his right to cross-examine a prosecution witness in an open court. Open court trial is provided for in Section 327 of the Code.

However, where the presiding Judge or Magistrate is of the opinion that the public shall not have access for a particular reason, at any stage of any inquiry into or trial of, any particular case, the access to the general public may be denied. Where the offence in question is rape, Section 372(2) provides for in camera trial. Trial in camera would not only be keeping the self-respect and confidence of the victim of the crime and in tune with legislative intent but is also likely to improve the value of evidence of a prosecutrix because she would not be so cautious or diffident to depose in a frank manner vis-à-vis in an open court in front of the public.

The Supreme Court in State of Maharashtra v. Dr. Praful B. Desai, held that recording of evidence by way of video conferencing is admissible. A deposition through video conferencing will enable the victim or witness in giving honest answers without any external pressure.

Indian Evidence Act, 1872 :
Section 3 of the Act provides for the Evidence of Witnesses and documentary evidence. The testimony of a single witness is abundant if the court considers it worthy even without corroboration provided the credibility is not shaken by any adverse circumstances appearing on the record against him. Section 134 of the Act prescribes that no particular number of witnesses is required to prove a fact and gives recognition to the maxim "evidence has to be weighed and not counted".

Courts consider the quality over the quantity of evidence. Section 132 of the Act provides a defense to the witness that any answer he is "compelled to give" shall not subject him to any arrest or prosecution or be proved against him in any criminal proceedings except prosecution for giving false evidence. One of the earliest decisions under the English law to have dealt with privilege afforded to a witness is Fisher v. Ronalds.

Section 146 of the Act gives protection to a victim of rape from unnecessary and vexatious questioning regarding her past character that has no relevance to the issues of the case. n. Section 148 empowers the Court to decide whether a question proposed to be asked to a witness is proper or improper based on its relevance to the suit or proceeding.

Section 138 of the Act lays down the manner of examining a particular witness and also impliedly bestows upon the party, a right of examination-in chief, cross-examination and re-examination. Under Section 33, in certain exceptional circumstances, where cross examination cannot take place, previous deposition of the witness can be taken into consideration as relevant for the purpose of subsequent proceedings on satisfying certain conditions given in the section.

Juvenile (Care and Protection of Children) Act, 2000:
The Juvenile Justice Act (JJA) pertains to provisions for children found in conflict with the law in India. It also gives provisions for children in need of care and protection.

Under Section 21 of the Act, it provides for a rule against publication of name, address or other particulars relating to juveniles in conflict with law, which can lead to determination of identity of the juvenile. Disclosure of identity may be allowed in the interests of the juvenile provided permission is granted for the same by recording reasons in writing. Making any picture of the juvenile public is also prohibited.

The Unlawful Activities (Prevention) Amendment Act, 2004:
Unlawful Activities (Prevention) Act is an Indian law aimed at prevention of unlawful activities associations in India. Its main objective was to make powers available for dealing with activities directed against the integrity and sovereignty of India. Section 44 of the Act provides for protection of witnesses and is on the same lines as S. 30 of POTA, 2002. It includes unlawful activities inclusive of terrorist acts.

Prevention of Terrorism Act, 2002 : (POTA)
The Prevention of Terrorism Act, 2002 (POTA) was an Act passed by the Parliament of India in 2002, with the objective of strengthening anti-terrorism operations. The Act was enacted due to several terrorist attacks that were being carried out in India and especially in response to the attack on the Parliament. The witnesses who willingly come forward to provide testimony in cases of terrorist acts pose a greater risk to their life and family.

Anonymity of witnesses is to be provided only in exceptional circumstances when the Special Court is satisfied that the life of witnesses is in jeopardy. Section 30 of the Act aims to grant protection to such a witness and protect anonymity. In PUCL v. Union of India, the validity of this section is upheld. But, POTA has been repealed with effect from 21th October.2004.

Witness Protection Scheme, 2018

The Ministry of Home Affairs prepared "Witness Protection Scheme, 2018" in consultation with the National Legal Service Authority, Bureau of Police Research & Development and the State Governments. Witness Protection Scheme provides for protection of witnesses based on the threat assessment and protection measures inter alia includes protection/change of identity of witnesses, their relocation, installation of security devices at the residence of witnesses, usage of specially designed Court rooms, etc.

On December 5th 2018, the Supreme Court approved the Witness Protection Scheme 2018 which aimed at enabling a witness to depose fearlessly and truthfully. The need to protect witnesses has been emphasized by Law Commission reports and court judgments for years.

In the State of Gujarat v. Anirudh Singh (1997), 14th Law Commission Report and Malimath Committee Report recommendations have been made for the witness protection scheme. Victims and witnesses of serious crimes are particularly at risk when the perpetrator is powerful, influential, or rich and the victims or witnesses belong to a socially or economically marginalized community. Victims and witnesses of serious crimes are particularly at risk when the perpetrator is powerful, influential, or rich and the victims or witnesses belong to a socially or economically marginalized community.

Women who report sexual violence are often even more vulnerable and face extreme pressure or direct threats from the accused. Also, witnesses need to have the confidence to come forward to assist law enforcement and prosecutorial authorities. They need to be assured that they will receive support and protection. Until now, there have been ad hoc steps such as few dedicated courtrooms for vulnerable witnesses mostly child victims and concealing the identity of witnesses in anti-terrorism etc have been unsuccessful to prevent witnesses. Hence, legislative measures to emphasize prohibition against tampering of witnesses have become the imminent and inevitable need of the day.

The scheme lays down three categories as per threat perception. They are:

Category A: Those cases where threat extends to the life of witness or family members during the investigation, trial or even thereafter.

Category B: Those cases where the threat extends to safety, reputation or property of the witness or family members during the investigation or trial.

Category C: Cases where the threat is moderate and extends to harassment or intimidation of the witness or his family members, reputation or property during the investigation, trial or thereafter.

This scheme aims to ensure that witnesses receive appropriate and adequate protection. It provides support to the threatened and vulnerable witnesses by gaining their confidence in delivering justice. Facilities such as camera trial, proximate physical protection and anonymizing of testimony and references to witnesses in the records would provide better protection to the witnesses.

Hence, the Witness Protection Scheme, 2018 is a first attempt at the National level to holistically provide for the protection of the witnesses which will go a long way in eliminating secondary victimization. The witnesses being eyes and ears of justice, play an important role in bringing perpetrators of crime to justice. This scheme attempts at ensuring that witnesses receive appropriate and adequate protection. This will go a long way in strengthening the Criminal Justice System in the country and will consequently enhance the National Security Scenario of India.

Due to the pressure from the judiciary, there are some witness protection laws and schemes under state level and they contain similar provisions as that of Witness Protection Scheme ,2018. The schemes and legislation made by the state governments are Delhi Witness Protection Scheme, 2015, Maharashtra Witness Protection and Security Act, 2017, Odisha- Witness Protection Scheme, 2019, Haryana Witness Protection Scheme, 2020.

However, the scheme does have its drawbacks. There is no provision to protect the dignity of the witness and it is silent about appointing an official to provide assistance to the witness as recommended by the Malimath committee. The scheme does not mention providing proper facilities for the comfort of the witnesses in the courtroom, such as seats, relaxing, restroom, drinking water, and so on. Scheme does not contain provision for T.A. or DA. The scheme has also not discussed issues related to adjournment of cases and does not contain provision to protect witnesses from harassment.

According to the witness protection scheme, 2018, the State Governments must bear the expenditure of "Witness Protection Programmes" ,which is completely opposite of the recommendation made by the 198th law commission's report that the costs of "Witness Protection Programs" must be shared equally by the Central and State governments. Moreover, the protection only lasts for three months as against 198th Law Commission Recommendations.

Conclusion
Witnesses have and always will play a primary role in delivering justice. In Krishna Mochi v. State of Bihar, the Supreme Court observed," the society suffers by both wrong convictions and wrong acquittals". Witnesses must be capable to testify in court or participate in investigations without fear of being threatened or intimidated in order to protect the rule of law. Statistically, in 2018, the court conviction rate was 50%, and in 2019, the court conviction rate was 50.4 percent. Finally, the rate of court convictions in 2020 was 59.2 per cent, the highest in five years.

As a result, we can assume that the Witness Protection Scheme of 2018 contributed to the increased conviction rate. The Witness Protection Scheme, 2018 has made way for various criminal justice reforms. Effective witness protection programmes are an important part of a comprehensive criminal justice strategy to protect persons who are critical to the deconstruction of organized crime groups.

Furthermore, it is crucial for a witness to be treated with utmost respect and dignity when called upon to the court for the purpose of deposition. In Swaran Singh v. State of Punjab, the Supreme Court emphasized on the pitiful condition of witnesses. It stated that witnesses come from far off places to depose before the court only to see the matter adjourned multiple times. They are subjected to prolonged examinations, not given a place to sit in the courtroom and harassed a lot throughout the trial. Therefore, there is an emerging need for independent witness protection laws in India.

References

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Written By: Bhuvanesh Mahesh, V th Year BA LLB, Seshadripuram Law College, Bengaluru