INTERNATIONAL JOURNAL OF RESEARCH AND ANALYSIS VOLUME 4 ISSUE 1

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1 JUDICIARY: A CHECK TO CRIMINALIZATION IN INDIAN POLITICS *BINISH KUMAR I. INTRODUCTION Apart from terrorism, Indian democracy is facing criminalization of politics. At times, the concern has been expressed against the obnoxious growth 1 proving bad element to electoral politics in the country. Indian people are the sovereign with a republican government of its own. Certain fundamental rights are provided to citizens through constitution by ensuring equality, liberty, fraternity and justice. To ensure safeguard to these right judicial measures is the most important. So that people have every right to elect a government of its own and in return claim to get good governance. II. CRIMINALIZATION IN INDIAN POLITICS From Political Party system to System of Political Criminalization:- A criminal for the most part starts criminal movement at local level with unimportant wrongdoings. In enormous urban communities, he starts with nation liquor, betting, wagering and prostitution. The lawmakers use lawbreakers for their egotistical finishes and the offenders and their syndicates look for their assurance and support to bear on their criminal and antinational activities. Vohra Committee observed that all over India wrongdoing syndicates have turned into a law unto themselves even in rural areas and small towns muscle men have turned into the order of the day. The report finds vile connection amongst media and antinational components on one hand and civil servants and government officials on other hand. Criminals help politician in intimidating voters, booth capturing, and proxy voting for winning the election. It has become a very grim threatening for the country 2. While highlighting the presidential message on 14 Aug 1989 which emphasises: Using of money or muscle power, booth capturing, proxy voting offend the very essence of socio-economic order 3 1 A mere reference to Vohra Committee Report would be sufficient in this connection. 2 See Infra note 5 at R.Y.S. Peri Shastry, Elections: A Code of Conduct for Contestants, 37 JPI, 153,

2 Corrupt practices which were prevalent from Gandhi s time as he received many letters containing allegations of corrupt practices. However number of election offences has gone up in recent years because of entry of criminals 4. Earlier criminals were working from behind the scenes but now they are contesting election and also becoming ministers 5. While highlighting the Rao observation: Several criminal groups with an average strength of 500 every, some of them on bail, lakhs of authorize and similarly overwhelming unlicensed and indigenous weapons separated from limitless amounts of ammo and bombs constitute on basic part of the election scenario situation in states like UP and Bihar specifically and others in general. Slaughtering of party workers and candidates has ended up basic spot making it resemble our inward dangers to democratic system are significantly more savage than the external 6. He further notices that two states UP and Bihar accounted for 870 candidates with such a criminal record. 7 The chances of getting conviction of criminals in significant offences have turned out to be progressively troublesome if not outlandish. The political obstruction in the examination of offence by police and at various phases of trial seems to disintegrating the criminal justice delivery system. Large number of acquittals taking advantage of lacuna in law and making mockery of judiciary system. National Commission on the review and working of the Constitution notes: A phase now has achieved when the government officials transparently gloat of their criminal associations. A Bihar minister announcement in the get together that he disparaged and would keep on patronizing hoodlums to battle and win decisions is a pointer to the developing wonders where criminal background has turned into an imperceptible imperative to win elections 8. 4 Editorial, Criminalization of Elections, C & MLJ, 5 (1996). It also notes that in the first general elections of 1952, 1250 offences were recorded and in 42 cases polling was adjourned. In 1954, there were 6358 cases of impersonation. In 1964, there were 6358 such cases. In 1964 elections, in 256 cases repelling was ordered. 5 See S.N. Sharma, Booth Capturing: Judicial Response, 41 JILI, 44 at (1999) 6 GRS Rao, Electoral Reforms: Touchstone of the Basic Process of Power, 3 Politics India 18, 20 (1998). 7 Id at 20-21, Nearly 700 out of 4072 were involved in crimes and trials pending against them in 25 states and union territories. 8 B.P.C. Bose & MVS Koteswara Rao, Criminalisation of Politics: Need for Fundamental Reform,66 IJPS 733,

3 According to annual report of 1984, Election Commission found that booth capturing is the main problem and came up with numerous recommendation to get rid of it 9. The Supreme Court of India in Sasangouda V SB Amarbhed 10 observes: Booth capturing completely invalidates the election procedure and subverts the democratic set up which is the fundamental element of our constitution. Amid the post independent period ten parliamentary decisions have settled in vote based commonwealth in this nation which cannot be allowed to be dissolved by demonstrating laxity in the matter of booth capturing 11. Committee Report: Dinesh Goswami Committee (1990) proposed that legislative measures must be taken to check booth capturing, rigging and terrorizing of voters. In its 170th report, the Law Commission of India suggested that in electoral offences and certain different genuine offences encircling of charge by the court ought to itself be a ground of exclusion notwithstanding conviction 12. The commission also noticed: There are several persons charged with serious crimes like rape, murder, dacoity etc. are contesting election pending their cases in court and moving under police protection 13. The first report of the Ethics Committee of Rajya Sabha embraced on 1 Dec on criminalization of politics and remedial measures noticed that procurements exist in different statutes and the standards of technique yet the laws and rule, be that as it may, had not the craved impact. It felt that the issues of criminalization of political issues and its circumstances and end results couldn't be handled by enactment alone. It additionally noticed that disqualifying persons with criminal record or those with questionable refinement is an extremely complex issue and effort should be made to prevent persons with criminal background from contesting the elections Annual Report, Election Commission of India, 1984, Sasangouda V SB Amarbhed AIR 1992 SC Id at 1167; for booth capturing see S.N. Sharma, Booth Capturing: Judicial Response,41 JJLI 44,55 (1999) th Law Commission of IndiaReport, on the Reform of the Electoral Laws, chapter 3( 1999) of Independent Candidates to Contest Lok Sabha(last seen on 28/5/) 13 (last seen on 28/5/). 14 Larrdis, the First Report of the Ethics Committee of Rajya Sabha, 45 JCPS, 21,27, 23,24 59

4 III. Has Election Commission fulfilled its responsibility to prevent corrupt persons and criminals from entering the parliament and assemblies? Argument Suggesting Election Commission Has Power: Article 324 In Kanhiya Lal Omar's vs R.K. Trivedi 15 case the court translated the expressions 'superintendence, direction and control' in article 324(1) the expressiveness "superintendence, course and control" "conduct of all elections" (under Article 324 of the Constitution) and its essentials are not extensively set down. The terms are of wide amplitude and engage the Election Commission to take plan of action to address the issue of decriminalization of politics. Significantly, without Casus Omission (instance of Omission in Law), however the Judiciary can't change by formal means, it can translate and give the important points of interest to fill the lacuna or non-liquet (law is not clear), wherein the statute can be advanced and engage the Election Commission. In Union of India Vs Association for Democratic Reforms and another 16 it was observed that jurisdiction of Election Commission is wide enough to include all power for conducting smooth elections and the term election is used in a wide sense to include the entire process of election which consists of several stages and embraces many steps. Inherent powers Election Commission has the inherent power 17 to ban those persons from challenging decision against whom corruption and criminal allegations have been conceded in the court. As expressed before in common cause 18 case the court managed the dispute that election in the country are battled with the assistance of cash which originates from the dark sources. On the off chance that on testimony an applicant is required to unveil the assets held by him at the season of election, voter can choose whether he could be chosen or not. 15 Kanhiyalal Omar vs R.K. Trivedi & Ors AIR see also TN Seshan v Union of India and Ors (1995) 4 SCC Union of India Vs Association for Democratic Reforms and another (2002) 5 SCC Election Commission Of India order No. 3/ER/2003/JS-II No. 3/ER/2003/JS-II also available on last seen on 5/6/ 18 Common Cause v Union Of India (1996) 2 SCC

5 Argument suggesting Election Commission has no such power: However, Election commission cannot exercise unrestricted power under article 324. It traces its power either from constitution or law made from article 327 and 328. Otherwise it would become an imperium in imperio which means no one is under our constitutional order 19. Judicial Intervention: Some Justifications: When the executive has lost consciousness to govern the country as per the soul of the constitutional law and the legislature was in disarray, it was responsibility on the judiciary to play the role in a positive direction to defend Indian democracy (Gehlot, 1998) 20. IV. PROVISIONS IN THE CONSTITUTION, INDIAN PENAL CODE, 1860 AND REPRESENTATION OF PEOPLE S ACT 1951 Criminalization in Indian politics issues is firmly identified with the legislators; however other backup causes are there. In this way some procurements has been enshrined in the constitution to prevent legislators having criminal background from taking passage into the legislatures. Both in Article 102(1)(e) and 191(1)(e) it is specified that "if he is so disqualified by or under any law made by parliament (Shukla and Sen,2004) 21. Chapter IX A of IPC manages offences relating to elections. It contains nine areas. It characterizes and provides punishments for offences, for example, bribery, undue impact and personating at elections 22 etc. The maximum punishment for the offence of bribery is one year's imprisonment of either portrayal or fine or both but bribery by treating is punishable with fine. Essentially the greatest punishment for undue influence or personating at a election is one year's imprisonment of either description or fine or both 23, Sec. 171 G provides the punishment of fine for false statement regarding elections and for illegal payment regarding elections.sec 171 H provides the punishment of fine up to Rs As per Sec 171 E, if there is failure to keep election accounts, the offender might be rebuffed with fine not surpassing Rs Hence, in IPC, procurements have been made 19 Supra 15 TN Seshan v Union of India and Ors 1995) 4 SCC Gehlot, N.S, Hawala Revolution in Indian Politics, Deep and Deep Publications, New Delhi, p.456(1998), 21 Shukla and Sen,The Constitution of India, Kamal Law House,Kolkotta, pp.95,160(2004)., 22 These three offences have been defined by SS 171B, 171C and 171D, Indian Penal Code, 1860 respectively 23 Ss. 171E, 171F & 171G, Indian Penal Code,

6 to check election evils but nominal punishment have been given and intrigue is not taken in prosecution of election offenders. These procurements have neglected to check criminalization of politics. Sec. 8 of the Representation of People s Act, 1951(hereafter referred as RP Act) seems more impediment as it gives preclusion on conviction of specific offences. Sec. 8(1) gives that a person convicted of an offence specified therein 24 and sentenced to imprisonment for at least six months should be disqualified from the date of such conviction. S. 8(2) gives that a person convicted to the contradiction of certain law mentioned in it 25 and sentenced to imprisonment for not less than six months might be disqualified from the date of such conviction and should keep on being excluded for a further time of six years since his discharge. S. 8(3) which lays down an important provision runs as under: When a person found guilty of any offence and sentenced to imprisonment for not less than two years other than any offence alluded to in subsection (1) or subsection (2) should be excluded from the date of such conviction and might keep on being disqualified for a further time of six years since his release 26. In any case, the exclusion under sub-sections (1), (2) and (3) might not produce results in case of a person who on the date of the conviction is a member of parliament or state legislature until three months have slipped by from that date or if within that period an appeal or application for revision is gotten admiration of the conviction or the sentence until that appeal or application is disposed by the court Offences punishable under SS. 153 A, 171E, 171F, 376 (1)&(2), 376A, 376B, 376C, 376D, 498A, 505(2) 2(3) IPC, the Protection of Civil Rights Act, 1955, S. 11 of the Customs Act, Ss of the Unlawful Activities (Prevention) Act, 1967, the Foreign Exchange Regulation Act, 1973; the Narcotic Drugs and Psychotropic Substances Act, 1985, Ss 3 or 4 of the Terrorist and Disruptive Activities (Prevention) Act, 1987; Sec. 7 of the Religious Institutions (Prevention of Misuse) Act, 1988, Ss. 125, 135, 135A, S. 136(2) of the Representation of People Act, 1951; S. 6 of the Place of Worship Act, 1959, Ss 2&3 of the Prevention of Insults to National Honours Act, (a) any Law Providing for the Prevention of the Hoarding or Profiteering. (b) any Law Relating to the Adulteration of Foods or Drugs. (c) any Provisions of the Dowry Prohibition Act, (d) any Provisions of the Commission of Sati (Prevention) Act, S. 8(3), Representation of People Act, Id. S.8 (4). 62

7 V. JUDICIAL APPROACH TO CHECK CRIMINALIZATION IN INDIAN POLITICS Before bringing up issue about the legitimacy of sub-section 4 of section 8 of Representation People s Act 1951 the judiciary has been persistently endeavouring to avert criminality and unethical exercises rehearsed by legislators interpreting different laws of the country said in sub-section 1 and 2 of Representation People s Act 1951.But, the circumstance had turned out to be more regrettable. On 28th August 1997, the Election Commissioner G.V.G. Krishnamurti startled the country by uncovering an abnormal statistics, demonstrating politicization of criminals. Hence Lok Sabha passed a resolution of 31st August 1997 saying that, more particularly, all political parties should embrace all such steps as will accomplish the goal of freeing of our polity of criminalization or its impact". Yet, it remained a devout resolution. On May 2, 2002, the Supreme Court gave a historic decision. In the light of decision of the Supreme Court, the Election Commission issued order requiring the candidates looking for elections, to file affidavit mentioning their criminal records, education qualification and assets and liabilities. This was implemented amid the Lok Sabha election held in April - May 2004, yet strangely, it has not been conceivable to prevent persons with criminal records from entering Lok Sabha (Minch, 2013) 28. Meanwhile judiciary has been confronting much inconvenience so far the provisions of RP Act 1951 to keep clean the legislatures. The remedies provided in IPC have not turned out to be effective because once the election is over, everything is forgotten. Then again, convictional preclusion for candidature seems more successful. However judicial interpretation of S. 8(3) R.P. Act has not been satisfactory. An order of remission does not wipe out the conviction. 29 For actual disqualification, what is necessary is the actual sentence by the court. 30 It is not within the power of the appellate court to suspend the sentence; it can just suspend the execution of the sentence pending the appeal. The suspension of the execution of the sentence (imprisonment of not less than two year) does not remove the 28 Minch Mallikarjun I, Criminalization of Politics and Indian Administration Spectrum, A Journal of Multidisciplinary Research Vol. 2 Issue 10, Sarat Chandra V Khagendra Nath AIR 1961 SC V.K. Dewan, Election Law

8 disqualification, when a lower court convicts an accused and sentences him, the presumption that accused comes to an end. 31 There has been discussion as to the start of preclusion on the ground of conviction. A person sentenced for an offence is excluded for being a candidate in a decision. S. 8 of the R.P. Act sets different standards for various offences. In S. 8(3) a person convicted of any offence and sentenced to imprisonment for not less than two years (other than the offences mentioned in S. 8(1) and (2)) should be disqualified from the date of such conviction and shall continue to be disqualified for a further period of six years since his release. In K. Prabhakaran V P. Jayarajah 32 the Court considered various issues. It considered the question whether for attracting preclusion under S. 8(3) the sentence of imprisonment for not less than two years must be in admiration of a solitary offence or the aggregate period of two years of imprisonment for various offences. The respondent was discovered blameworthy of offences and sentenced to undergo imprisonment. For any offence, he was not awarded imprisonment for a period surpassing two years however the sentences were coordinated to run continuously and along these lines the total period of imprisonment came to two years and five months. On appeal, the session court directed the execution of the sentence of imprisonment to be suspended and the respondent be discharged on bail during the hearing of the bail. During this period, he filed his nomination paper for contesting election from a legislative assembly seat. Amid the investigation, the appellant protested on the ground that the respondent was convicted and sentenced to imprisonment for a period surpassing two years. The complaint was overruled and nomination was acknowledged by returning officer on the ground that albeit respondent was convicted of numerous offences however he was not sentenced to for any offence for a period not less than two years. The High Court took the similar view but Supreme Court by majority took the different view. 33 Chief justice Lohati on majority side held that the use of the objective "any" with "offence" did not imply that the sentence of imprisonment for not less than two years must be in admiration of a solitary offence. The court emphasized that the reason for enacting S. 8(3) was to counteract criminalization of politics. 34 By adopting purposive interpretation of 31 B.R. Kapur V State of T.N. AIR 2001 SC 3435; see also Dr. Mrs Kiran Jain & P.C. Jain, Chawla s Elections: Law & Practice, 35 (7th ed. 1999, repr. 2002). 32 K. Prabhakaran V P. Jayarajah AIR 2005 SC The bench consisted of Chief Justice Lohati and Justices S.V. Patil, B.N. Srikrishna, G.P. Mathur, K.C.Balkrishnan. Majority judgment was delivered by Justice R.C. Lohati whereas Justice K.C. Balkrishnan wrote dissenting opinion. 34 Supra note 16 at

9 S. 8(3), the Court held that its applicability would be decided on the basis of the total term of imprisonment for which the person has been sentenced. The court also considered the subject of the impact of absolution by the appellate court on disqualification. It might be reviewed that the Supreme Court in Vidyacharan Shukla V Purushottam Lal 35 had taken a bizarre perspective V.C. Shukla was convicted and sentenced to imprisonment surpassing two years by the Sessions Court on the date of filing nomination yet the returning officer unlawfully acknowledged his nomination paper. He also won the election in spite of the fact that conviction and sentence both were effective. The defendant candidate filed an election petition and when it came to the High Court, the M P High Court permitted the criminal appeal of Shukla putting aside the conviction and sentence. While giving the decision in favour of returned candidate, the court relied on Mannilal V Parmailal 36 and held that the acquittal had the impact of retrospectively wiping out the disqualification as totally and viably as though it had never existed. However Vidyacharan Shukla which had the impact of approving the unlawful activity of the returning officer and empowering criminalization of politics was overruled by Prabhakaran. The Supreme Court observed: Whether an applicant is qualified or not qualified or excluded for being filled the seat must be controlled by reference to the date for the scrutiny of nomination The returning officer can't postpone his decision nor make it restrictive upon what may happen subsequent to that date. 37 It is submitted that the view taken in the instant case is correct and would be helpful in checking the criminalization of politics. Sec. 8(4) of the RP Act provides advantage to a sitting Member of Parliament or legislative assembly if convicted for criminal offence. For such member, no preclusion should produce results until three months have passed from the date of conviction or if within that period appeal or application for revision is acquired admiration of conviction or sentence until that appeal or application is disposed by the court. The questionable issue is whether the advantage of this procurement proceeds even after the dissolution of the house. There have been instances where the members taking advantage of this provision contested the 35 Vidyacharan Shukla V Purushottam Lal (1981) 2 SCC Mannilal V Parmailal (1970) 2 SCC Supra note 34 at 699; The Court also overruled Mannilal V Parmai Lal, (1970) 2 SCC

10 subsequent election in spite of the faction by the court during the tenure of the house. The Supreme Court considered the unethical aspect also in Prabhakaran case. The court considered the structural position of S. 8(4) and avocations for its retention. It held that subsection 4 would stop to apply no sooner the house is dissolved or the person has ceased to be a member of that house. 38 Thus, it is another exertion of the Court to entirely check the criminalization of politics Lily Thomas and Lok Prahari vs. Union of India however, two public interest Litigations were filed by Lily Thomas and a NGO Lok Prahari in 2005 scrutinizing the legitimacy of section 8(4) of Representation of People Act, since it gives unique shield to the sitting MPs and MLAs who have been convicted an offence and whether section 8(4) of the Representation of People Act is Ultra Vires to the constitution. The Hon ble Court after going through the arguments held that once a sitting member becomes disqualified by or under any law made by parliament under article 102(1)(e) and 191(1)(e) of the constitution, his seat will get to be empty instantly by virtue of article 101(3)(a) and 190(3)(a) of the constitution. It further held that the parliament can't make provisions as in area 8(4) of the Act to concede the date of disqualification on which the disqualification of a sitting member will have impact. Further, the court depended on the constitutional Bench s decision in Election Commission of India vs. Saka Venkata Rao 40, wherein it was held that there has to be same set of disqualification for election as well as continuing as a member. Hence, parliament does not have power to make different laws for a person to be disqualified for being picked as a member and for a person to be disqualified to proceed as member as it made by making section 8(4) of the Act. For aforementioned two reasons the Hon ble Supreme Court held that parliament has surpassed its power given by the constitution instituting sub-section 4 of section 8 of the Act and in like manner it is ultra vires the constitution. In any case, the Hon ble court further held that this judgment of the court will be prospective in nature. Sitting people s who have as of now been convicted under section 8(1),(2)and (3) of the Act and have filed appeals or revisions in higher courts before the pronouncement of this judgment, would not come under the purview of this declaration since it will be against the principles of natural justice. Recently on 10th March 2014 Supreme Court gave another decision on a PIL recorded by Public Interest Foundation 38 Id at Lily Thomas vs. Union of India, MANU, SC, 0687, para 6 40 Election Commission of India vs. Saka Venkata Rao, AIR 1953 SC

11 instructing the subordinate courts to discard the cases U/s 8(1)(2)(3) inside one year from the date of charge sheet filed by the investigating agency. If any case requires more than this period, subordinate court must bring the matter before concerned High Court. Also, in the event that it feels the cause is reasonable, it might give a suitable time to declare the judgment of the case. Thus, it is understood that judiciary is attempting its best to check the criminalization in Indian politics. VI. CONCLUDING OBSERVATIONS The entry of crooks in election politics must be stopped at any cost. if it is not checked it, will erode the system completely. The deficiency of capable persons in politics may crumple the nation internally and externally. Various commissions and panels, for example, the Law Commission of India, Election Commission, and Vohra Committee and so forth have analyzed the issue of criminalization of politics however the threat is expanding day by day. The parliament has taken endeavours by amending the laws, for example, IPC and the RP Act but the exercise has proved futile. The Supreme Court of India has likewise attempted to check the evil but the problem remains unabated. The Court has in unequivocal terms needs to avert criminalization of politics. It says, lawbreakers cannot become lawmakers. Actually the roots of the problem lie in the political system of the country. There is absence of political will to combat the problem. The political parties also do not believe in higher moral standards. All the political parties should unitedly make efforts to prevent criminalization of politics. Election commission need to assert itself. If and when the Election Commission would assert itself and take a firm stand that those persons against whom corruption and criminal charges have been admitted in the court cannot contest elections, parliament certainly cannot ignore such view 41. The IPC and the RP Act both should be properly amended 42 as well as criminal procedure code 43. Appointment of public prosecutors, Additional public prosecutors for court 41 N.S. Venkatarman, Does Election Commission Commission Have Powers to Bar Persons Facing Corruption Charges From Contesting, Sulekha (last seen on 3/6/) 42 Representation of People (Amendment) Bill, 2013 A Bill to check criminalisation of politics. It removes the exemption given to sitting MPs, MLAs and MLCs who have been convicted of criminal offences. It also disqualifies them from their membership of the Legislature(draft bill). ( last seen on 2/6/) 67

12 matters should be free and fair. RP Act should be used smartly so that even suspect can be stopped from contesting election. The candidate should be asked to give detailed information regarding all civil and criminal matters against him on affidavit. And, if the information indicates criminal case, he should be disqualified irrespective of the fact that he was not prosecuted and/or punished by a court of law. There should be special courts for solving the cases of criminalization of politics 44.the High Court or Supreme Court judges should be given power to transfer the cases related to disqualification of candidates from one fast track court to another. People can use NOTA to prevent tainted politicians from entering in politics 45. It will help to maintain sacredness and purity of elections. Bibliography Cases Referred Sasangouda V SB Amarbhed Kanhiyalal Omar vs R.K. Trivedi & Ors Union of India Vs Association for Democratic Reforms and another TN Seshan v Union of India and Ors Common Cause v Union Of India Sarat Chandra V Khagendra Nath B.R. Kapur V State of T.N..K. Prabhakaran V P. Jayarajah Vidyacharan Shukla V Purushottam Lal Mannilal V Parmailal 43 The Code of Criminal Procedure (Amendment) Bill, 2013 (A Bill to improve accountability in the appointment of public prosecutors so as to enable them to function independent of the executive and other external influences)(draft bill) Procedure-Amendment-Bill-2013.pdf (last seen on 2/6/ 2106) 44 Fast Track Courts for Elected Representatives Bill, 2013 (A Bill to establish special Fast Track courts for the trial of cases involving criminal charges against elected representatives)(draft bill) ( last seen on 3/6) 45 (last seen on 7/6/) 68

13 Lily Thomas vs. Union of India Election Commission of India vs. Saka Venkata Rao Journals S.N. Sharma, Booth Capturing: Judicial Response Journal of the Indian Law Institute B.P.C. Bose & MVS Koteswara Rao, Criminalisation of Politics: Need for Fundamental Reform The Indian Journal of Political Science R.Y.S. Peri Shastry, Elections: A Code of Conduct for Contestants Journal press india Larrdis, the First Report of the Ethics Committee of Rajya Sabha Jcps S.N. Sharma, Booth Capturing: Judicial Response Jjli Minch Mallikarjun I, Criminalization of Politics and Indian Administration Spectrum A Journal of Multidisciplinary Research GRS Rao, Electoral Reforms: Touchstone of the Basic Process of Power, Politics India Statutes Indian penal code 1860 Representation of people Act 1951 Books Dr. Mrs Kiran Jain & P.C. Jain, Chawla s Elections: Law & Practice Gehlot, N.S, Hawala Revolution in Indian Politics, Websites