Microsoft word - access to justice
PROMOTING ACCESS TO JUSTICE- ISSUES AND CHALLENGES
Munmun Singh, Fourth year student of B.A. LL.B. National Law University Delhi1
India is rightly acclaimed for achieving a flourishing constitutional order, presided over by
an inventive and activist judiciary, aided by a proficient bar, supported by the state and
cherished by the public. At the same time, the courts, and tribunals where ordinary Indians
might go for remedy and protection, are beset with massive problems of delay, cost, and
ineffectiveness. Potential users avoid the courts; in spite of a longstanding reputation for
litigiousness, existing evidence suggests that Indians avail themselves of the courts at a low
rate, and the rate appears to be falling. Still, the courts remain gridlocked. There is wide
agreement that access to justice in India reforms that would enable ordinary people
to invoke the remedies and protections of the law. The Lok Adalat, literally meaning
people's court, and as the name suggests is a forum for promoting access to justice having a
different source and character than the courts of the state. In fact, the Lok Adalat is a
creature of the state, but because of the pretension that it is not, it deserves examination
under the rubric of an alternative, non-state justice system.
Need for Access to Justice:
Justice is the foundation of any civilized society. Preamble to
the Constitution of India includes ‘Justice – social, economic and political’ as a
Constitutional goal. Article 39-A of the Constitution provides for ensuring equal access to
justice. Administration of justice involves protection of the innocent, punishment of the
guilty and satisfactory resolution of disputes. It has been rightly said that an effective
judicial system requires not only that just results be reached but that they be reached on
Steps have been constantly taken to simplify procedures and to make the working of the
system more efficient by judicial reforms and by management techniques. However, the
1 Author is available at [email protected]
task before the legal fraternity in India is gigantic, to say the least. The following figures
quoted by CJI R C Lahoti (as he was then) on Law Day, 2004, speak volumes:
Table 1: Strength of Indian Judiciary and Lawyers:
Number of advocates enrolled in the country
Table 2: Pendency of Litigation as on 30/6/2004:
Even as the Indian Judiciary, working under considerable handicaps such as inadequate
funds, budgetary allocations for law and justice not being part of the plan expenditure,
shortage of resources, shortage of staff and infrastructure, shoulders the phenomenal
burden of the volume of litigation and range of cases, the figures above reveal an acute
need for alternative mechanisms for dispute resolution.
Unfortunately, the currently available infrastructure of Courts in India is not adequate to
settle the growing litigation within reasonable time. Despite the continual efforts, a
common man may sometimes find himself entrapped in litigation for as long as a life time,
and sometimes litigation carries on even on to the next generation.
In the process, he may dry up his resources, apart from suffering harassment. Thus, there is
a chain reaction of litigation process and civil cases may even give rise to criminal cases.
Speedy disposal of cases and delivery of quality justice is an enduring agenda for all who
are concerned with administration of justice.
Access to Justice
: “Access to Justice” is a curious phrase as it implies that the system of
justice is not in fact available to all and that there are obstacles in the way. Is it true? In a
civilized society, the state guarantees that each citizen approach the permissible and
prescribed grievance redressal forum to claim his rights even if it is against the state.
However, the truth is that civil justice has been beyond the reach most of the disputants,
though they in turn are by no means beyond the reach of the criminal justice system. It is
important to remember that it is only in recent years that an assumption that access to
justice as a universal right was made and even more recently have begun to recognize it as
a fundamental right, a right which is political, economic and social as adumbrated in the
The Universal Declaration of Human Rights mandates in Article 10 that “everyone is
entitled in full equality to a fair and public hearing by an independent and impartial
tribunal, in the determination of his rights and obligations and of any criminal charge
Access to Justice therefore has two parts: (1) where a person is able to approach the Courts
but may not take his litigation right through the trail or to the appellate Court or to the
highest Court of the land; (2) where a person has not been able to approach the court at all.
The latter can be sub-divided into two parts—(a) cases where the person is aware of his
right but does not know whom to approach and which forum to approach, or is unable to
approach the Courts of law because of poverty or other reasons, and (b) cases where the
person is not aware of his rights at all. ‘Access to Justice,’ must be board- based and
people-oriented3. As it is the most basic of all human rights in any civilized world- one that
has a democratic dimensions involving remedial jurisprudence for every bona fide seeker.
However, before we begin to understand the contours of access to justice, it is essential to
address a more fundamental issue i.e. what is justice? Unless we understand what we are
attempting to ‘access,’ we may never truly appreciate how to achieve that objective.
Ø The concept of justice: Before proceeding further it is imperative that one understand the
term ‘justice.’ It is interesting to note that this expression has been used in our Constitution
only in the Preamble and in Article 142. Nowhere else in the Constitution has the term
been defined. Justice Krishna Iyer in an address to the 18th Annual Conference of the
America Judges Association identified ‘justice’ with ‘truth.’ So, in his understanding, the
quest for justice is the quest for truth, and by analogy, justice is denied when truth is
checked by a Judge’s “pet social philosophy”. The dispensation of justice entails giving
one his due. This in turn means that Courts must in every way provide relief and find legal
techniques to provide relief to one who has been deprived of what was due to him or to her.
Such a situation arises because the law as it is may fall short of the law as it ought to be.
Beneficial legislations for the upliftment of weaker sections of society therefore is not
considered a violation of Article 14 as justice does not necessarily demand the same result
for everybody- inequality of treatment is not an exception but is a rule of justice.
Ø The Contours of ‘Access to Justice’: Its briefly discussed above, that any discourse on
access to justice must inevitably touch upon the hurdles of differing nature that present
themselves in the path of the wronged seeking justice- this includes, the litigants who has
had access to the Court but has not obtained quick relief; those who have not even had the
chance to knock at the doors of the Court because of ignorance of their legal rights or
poverty; those who are aware of their case is heard – such as prisoners in need of post facto
3 Akhil Bharatiya Soshit Karamchari Sangh (railway) v. Union of India, (1981) 1 SCC 246,281.
remedy for prison excesses committed during their incarceration4. It is generally agreed
that access to justice requires three basic facilities: (a) that there must be a dependable
system of laws; (b) that there must be Courts to enforce these laws; (c) that there are well-
trained officials to manage such Courts. It is also well understood that access to justice is
not merely justice in its ordinary sense; rather, access to justice must include access to
social, economic, and political justice, as encapsulated in Part IV of our Constitution of
It would not come as a surprise that often hurdles of the simplest and most obvious nature
have had devastating results, for example, it has been found that the Court fees payable by
the litigants may at times being an impediment in achieving access to justice for indigent
litigants, if it is prohibitively high5; or that the principle of locus standee may many a time,
wrongfully prevent officious outsiders from approaching the Courts, even when such
outsiders do so solely for the cause of justice6.
Ø The Efforts of the Superior Courts in India – Ensuring Existing Rights and Creating New
Rights: To tackle such problems and more, Courts in India continuously adopt strategies
that challenge the bounds of judicial inventions as public interest litigation owe their
existence to the liberal construction which our Courts have given to the phrase ‘access to
justice.’ While, as Earl Johnson, Jr. finds American Courts consider indigents to have
“access to the Courts” on the count that they could come to the courtroom without cost,
even though they could not engage a lawyer, courts in India have sought a holistic
understanding of the concept accessibility. For the latter, access is not merely superficial
attendance in the Court; it connotes “access” both in letter and spirit. At the forefront in
facilitating access to justice has been the Supreme Court of India which has not hesitated to
“innovate new methods and devise new strategies for the purpose of providing access to
justice to large masses of people who are denied their basic human rights and to whom
freedom and liberty have no meaning.”7
Class-action suits, representative suits, and public interest litigation are some of the
techniques which have been evolved to overcome the problems of accessibility. At the
4 Sunil Batra (II) v. Delhi Administration, (1980) 3 SCC 488. 5 M/s Central Coal Fields Ltd. v. M/s Jaiswal Coal Co., 1980 (Supp.) SCC 471. 6 P.S.R. Sadhanantham v. Arunachalam, (1980) 3 SCC 141. 7 S.P. Gupta v. Union of India, 1981 (Supp.) SCC 87.
same time, the Superior Courts in India have also ventured to create new rights for the
citizens through progressive interpretations of the Constitutional provisions. For example,
most recently in Naveen Jindal v. Union of India8, the Supreme Court created a new right
by holding that every citizen of the country has the fundamental right to fly the National
Flag with dignity under Article 19 (1) of the Constitution of India. Besides this, the other
rights created are, for example, the right to travel, right to privacy, prisoners’ right to
interview, right to a fair trial, right against torture and custodial violence, right to free legal
aid, right to health care, right to safe drinking water, women’s right against sexual
harassment, right to quality life, right to family pension, right to work (though not
fundamental), and right to environmental protection.
Ubi Jus Ibi Remedium:
Is it an empty formality?
This concept a potent judicial technique for dispensing justice within the context set out
above, is to provide succor to those who have a right to relief. In other words, no one must
be denied a remedy if he or she has a right- ubi jus ibi remedium. It is said that the maxim
is of action called an ‘action on the case’ – where no precedent of a writ could be produced,
the clerks in chancery agreed to form a new one. So much so, that in Dhannalal v.
Kalawatibai,9 the Supreme Court observed: “If a man has a right, he must, have a means to
vindicate and maintain it, and a remedy if he is injured in the exercise and enjoyment of it,
and indeed, it is vain thing to imagine a right without a remedy, for want of right and want
of right and want of remedy are reciprocal.”
The principle that rights must have remedies is ancient and venerable. In Ashby v.
White,10 the Chief Justice of the King’s Bench stated: “If the plaintiff has a right, he must
of necessity have a means to vindicate and maintain it, and a remedy if he is injured in the
exercise or enjoyment of it; and indeed it is a vain thing to imagine a right without a
remedy; for… want of right and want of remedy are reciprocal… where a man has but one
remedy to come at his right, if he loses that he loses his right.”
8 (2004) 2 SCC 510. 9 (2002) 6 SCC 16, 29-30. 10 92 Eng. Rep. 126 (K.D. 1703).
The enforcement power of the remedy is the quality that converts pronouncements of ideals
into operational rights. It is this enforceability that makes something legal, rather than
moral or a natural right. In the Federalist, Alexander Hamilton stated that the definition of a
claim as a “legal” right depends upon the availability of this enforcement: “It is essential to
the idea of a law that it be attended with a sanction; or, in other words, a penalty or
punishment for disobedience. If there be no penalty annexed to disobedience, the
resolutions of commands which pretend to be laws will, in fact amount to nothing more
The remedy is thus the integral part of each right that is ultimately necessary to the
effectuation of the rule of law. For without a remedy, judicial decisions are merely advisory
opinions, hypothetical undertakings with no practical effect. Without remedies, the law
simply has no force in society. Individuals need not conform their behavior and established
The Supreme Court of India has gone further by stating the access to justice requires more
than “mere declaration of invalidity of an action or finding of custodial violence or death in
lock-up…”11 Rather, the principle of ubi jus ibi remedium mandates that those who
approach the Courts for justice should be provided a “meaningful” remedy. Thus, for
instance, access to justice may require the Court not only to prosecute the offender, but also
where necessary to provide monetry compensation to the victim of the crime. Bandhua
Mukti Morcha,12 are but a few of the instances out of countless many where the Apex
Court of this land has provided not merely relief, but relief with compassion and foresight
that would merit being called “meaningful.”
Identifying Structural and Operational Judicial Reforms
:- While the Courts have never
shun away from its duty of providing access to justice for the teeming millions of this
country, it would not be incorrect to state that the objective would be impossible to achieve
unless justice dispensation mechanism is reformed. There are two ways in which such
reform can be achieved- through changes at the structural level, and through changes at the
operational level. Changes at the structural level challenge the very frameworks itself and 11 D.K. Basu v. State of West Bengal, (1997) 1 SCC 416, 437-38. 12 Bandhua Mukti Morcha v. Union of India, AIR 1984 SC 802.
require an examination of the viability of the alternative frameworks for dispensing justice.
It might require an amendment to the constitution itself or to various statutes. On the other
hand, changes at the operational level require one to work within the framework trying to
identify various ways of improving the effectiveness of the legal system.
It must nevertheless be borne in mind that the effectiveness of the justice dispensation
machinery ultimately depends upon the way in which we conceptualize justice.
Ø Changes at the ‘Structural’ level
: a) Shift from conflict resolution to justice dispensation.
Indian Courts are attuned to resolving conflicts between the parties based on the pleadings
presented by them. The Higher Judiciary, particularly the Supreme Court, while exercising
its jurisdiction has devised several instruments for dispensing justice. Several innovative
legal approaches have been used which can serve as a catalyst for Legal Reform. This is
evident in the creation and development of the PIL jurisdiction. Similarly, attempts are to
be made to decentralize judicial activism right down to the Lowest Court in the country, as
well as to affect a paradigm shift in favor of justice dispensation. In this regard, the concept
of Lok Adalats – or, people’s Courts- is particularly relevant .Prior to the introduction to
the Legal Services Authorities Act, 1987, legal services by the states were provided under
various government orders issued in 1976 which also organized Lok Adalats. The present
form of Lok Adalats introduced under the Legal Services Authorities Act ,1987 has since
then gained considerable popularity in providing cheap and speedy justice in an atmosphere
of friendly spirit hardly resembling a conventional Court of law . It is the Lok Adalats
which go to the people to deliver justice at their door step both , by settling disputes which
are pending in Courts and also by resolving disputes which have not yet reached the stage
of litigation in Court. The basis for the dispute settlement in the Lok Adalats system is the
principle of mutual consent and voluntary acceptance of the solution with the help of
Justice for the Poor: Judicial enforcement of socio-economic rights.
Any discussion on justice for a billion people necessarily requires reference to socio-
economic rights. Unlike western societies, socio-economic rights are important for an
Indian for exercising his rights. Although the Indian Constitution does endorse these rights
in the form of Directive Principles of State Policy in Part IV of the Constitution, it does not
provide any mechanism for their enforcement. Therefore, the Indian Supreme Court has
made them partly enforceable by extending the language of Article 21 of the Constitution.
To paraphrase Justice Albert Sachs of the South African Constitutional Court, ‘the
Supreme Court of India smuggled the rights from Part IV to Part III of the Constitution of
This innovation of the Indian judiciary to enforce socio- economic rights has seen parallels
in Courts of other jurisdictions as well.
However, the question remains should India adopt a new model where the judiciary has a
more active in the enforcement of these rights? This question has provoked a profound
debate in which both side have exchanged persuasive arguments. Any strategy to resolve
this dilemma must take into account the fact that the civil and political rights without socio-
economic rights are inadequate for the poor and deprived. At the same time, due respect
must be paid to democratic deliberation and resource intensive nature of these rights. The
core rights represent the basic entitlements of every citizen, which cannot be left, to the
ordinary political processes. In respect of the other socio- economic rights, they are
dependent on the democratic prerogatives and therefore the traditional scheme of judicial
review has to be modified. This strategy will ensure that socio-economic rights are not
mere “Constitutional ropes of sand,” but are concrete Constitutional commitments.
If the judiciary skillfully implements our Constitution, it may transform the society, which
would go a long way to ensure socio- economic and human rights to the citizens of India.
The rule of law, which is the bedrock of democracy, if strictly enforced, would enable us to
bring economic progress for the nation also.
Ø Changes at the ‘Operational’ Level
: At the operational level, one is working within the
framework with the intention of fine- tuning it to achieve its objectives. At this level, we
have to look at several factors, which affect the efficiency and the effectiveness of the
All successful justice systems provide access to all citizens requiring their services, operate
with a reasonable amount of efficiency and timeliness, make decisions and resolve
conflicts in line with legal norms and widely held values, and operate in a predictable,
transparent, and effective fashion. In my view, the biggest hurdle in administering justice
for a billion people is delays. Delay in justice administration is the biggest operational
obstacle which has to be tackled on a war footing.
Intensive use of the ADR framework- privatization of dispute resolution
Alternate Dispute Resolution, to my mind, is essentially the privatization of the dispute
resolution process, whose success ultimately depends up on the Arbitration and
Conciliation act, 1996, Section 89 of the Civil Procedure Code, 1908 and the Legal
Services Authorities Act, 1987 as well as the Legal Services Authorities (Amendment) Act,
2002, which provides for an institutional framework for the resolution of disputes without
the intervention of the Courts. But there is an urgent need for tightening this dispute
resolution framework so as to reduce the burden on the Courts.
We must take the Alternate Dispute Resolution mechanism beyond the cities. The Gram
Nyayalayas as contemplated by the Law Commission should process sixty to seventy
percent of rural litigation leaving the regular courts in the districts and the sub- divisions to
devote their time to complex civil and criminal matters. With participatory, flexible
machinery available at the village level where non- adversarial, settlement- oriented
procedures are employed, the rural people will have fair, quick and in expensive system of
dispute settlement. Only revision jurisdiction on civil matters and that too on questions of
law would be left to the District Courts.
Since rent and eviction suits constitute a considerable chunk of litigation in Urban Courts,
and that they take on an average three or more years to get adjudicated in the Court at the
first instance, the Law Commission has felt that an alternative method for these disputes is
The Commission has also recommended that the provisions relating to Conciliation in the
Arbitration and Conciliation Act, 1996, should be suitably amended so as to provide for
obligatory recourse too conciliation or mediation in relation to cases pending in the Courts.
Whatever mechanism we adopt our ultimate aim must be to ensure that not more than
fifteen percent of the cases go for final adjudication. This is the trend in the legal system of
develop countries where most of the cases are resolved by alternate dispute resolution
mechanisms like conciliation, mediation, and arbitration. Pre-trial conciliation accounts for
the disposal of a large number of cases.
Tribunalisation: Creating specialized tribunals for resolving a particular variety of disputes
has become the order of the day. Tribunalisation was an experiment that was initiated in the
objective of ensuring expeditious adjudication by experts. But the experience of the last
decades clearly showed that tribunalisation cannot be a panacea for resolving judicial
arrears unless there is a supporting institutional framework to supervise the working of the
The following steps may be adopted to ensure that tribunals achieve their objective:
1. Discontinuing with the practice of establishing Appellate Tribunals:
The rationale for
establishing appellate tribunal is no longer valid due to the decision of the Supreme Court
in Chandra Kumar v. Union of India, 13 where in the Court held that the jurisdiction of the
High Court under Articles 226 and 227 forms part of the basic structure of the Constitution
and cannot be taken away by a Constitution amendment. Hence, the practice of establishing
Appellate Tribunals should be discontinued.
2. Adjudication of Constitutional Issues:
Some Tribunals can adjudicate over
Constitutional issues (except the Constitutional Validity of the Parent Act) even when
certain members of the tribunals are non-judicial members. These members are not trained
in law and thus there is an inherent anomaly in the system as it prevails today.
3. Pendency of cases at the Tribunal:
There is a huge pendency of cases in most tribunals
and this does not serve the ends of justice and defeats the very objective for which they
have been set up. The tribunals today have become another parallel structure plagued with
the same problems that prevail in the regular courts.
4. Superintendence over Tribunals:
High Courts are entrusted with the power of
superintendence over tribunals by virtue of Article 227, but in practice they do not exercise
this function. The Supreme Court in L. Chandra Kumar’s case has suggested that there
should be “an independent supervisory body to oversee the working of the tribunals.” This
recommendation should be implemented as soon as possible. It should be the duty of
tribunals this supervisory body to ensure that the tribunals are able to discharge their
functions in an efficient manner and ensure their independence.
5. Seat of Tribunals:
Many tribunals presently exercise original jurisdiction in lieu of the
Civil Courts. However, their establishment is limited only to the four metropolitan towns.
Since they replace the Civil Courts, permanent tribunals must be established throughout the
country or alternatively, if there is not sufficient work, a Circuit Bench may be established.
Criminal Justice Administration: Reform of the judiciary would be in complete without
special emphasis and reforming the criminal justice administration system since delay in a
criminal right, affects the core fundamentals right of the accused the and also of victim.
The criminal justice delivery system in India has not achieved the ideals it was meant to
achieve- of ensuring fair, inexpensive and speedy trial. Most of the fundamental principles
of criminal law, such as the right to speedy trial, the right to legal aid, the right to fair trial,
etc., have been declared to be fundamental rights by the Supreme Court through a process
of judicial interpretation starting from the Hussainara Khatoon v. State of Bihar.14
The single most important reason for arrears in the criminal Courts is the lack of sufficient
number of courts. The Law Commission has made this point succinctly clear in its 120th
Report. Unlike civil justice delivery system, lack of Courts is not an administrative
problem but a Constitutional one. Every state must be mandated by a statute to establish
requisite number of courts based on population, litigation and other relevant criteria. This
will provide the necessary imperative the right to speedy trial a reality in India. It may be 14 AIR 1979 SC 1360.
noted that this idea is not as far- fetched as it seems to be: the Constitution already provides
the exact number of representatives from each State to the Council of States, based on
The other factor for the delay is the lack of separation between the law and order
department and the investigative department of the police. Furthermore, the investigative
departments works without any proper legal advice at the investigation stage. This has
resulted in lack of professionalism, over work and resultant failure in conducting proper
investigation. Both the 154th Law Commission Report and the Fourth National Police
Commission Report recommended that the investigating agency be separated from the law
and order department of the police. This would have several advantages:
(a) It would bring the investigating police under the protection of judiciary and would
greatly reduced the possibility of political or other types of interference;
(b) Efficient investigation will reduce the possibility of unjustified and unwarranted
prosecution and consequently a large number of acquittals;
(c) It would result in speedier investigation and consequently quicker disposal of cases.
The kind of independence and efficiency that is desired of the investigating agency can be
obtained only if it is given a constitutional shape. Further, a concern similar to that of the
investigation agency has been raised with regard to the prosecution machinery. It has been
a common complaint that prosecutions are not being diligently and efficiently conducted,
especially at the lower levels. This issue has particularly come up in the context of
withdrawal of prosecution. Independent status for a Directorate of Prosecutions may be the
only way in which the independence and efficiency of the prosecution agency can be
In any event, taking a more holistic view, it must be realized that the onus to ensure the rule
of law as a pre-requisite to socio- economic progress is not one to be discharged only by
the courts through judicial innovation- it lies equally at the steps of the state end its
In prologue, permit me to make certain observations on access justice that
often escapes us. Foremost is the aspect of delay. It would not be untrue to state that
besides the misuse of laws by the lawyers and the need for amending the stringent laws;
one of the primary reasons for the accumulation of huge backlog is the non-use of even the
existing procedural laws which may prove helpful in court management. There is, of
course, no single remedy for this problem. The solution has to be multi-pronged, consistent
and applied uninterruptedly for a number of years as part of a comprehensive program me.
Secondly, emphasis should be laid again on the need for training judicial officers. In this
respect, the decision in All India Judges Association v. Union of India16, where the
Supreme Court laid emphasis on the training to be imparted to the judicial officers, is
crucial. The objective behind judicial training is to develop skills, knowledge, work culture
and attitude in a judicial officer with a view to improve the quality and quantity of the
output. Training the judicial officer and Court staff in this context gains prime importance.
As only a fraction of the litigants alone can afford reaching the appellate court, the justice
delivery to the poor and vulnerable must be improved at the trail level. Thus, the training in
Court management technique and legal and technological issues to the subordinate
judiciary carries great emphasis. Updating of legal knowledge on new laws and their
implication, including issues relating to Intellectual Property Rights, Cyber Laws, and
International Trade Law, the use of the latest technologies for better administration,
utilization of the existing infrastructure for case management and other management
practices etc. are to find in the curriculum. Training should also be made compulsory for
the judges in the Appellate Court. We must constantly remind ourselves that it is our
solemn duty to learn our trade, to discover if things are better done in other countries, and
to fight for the removal of blemishes from our own system of justice.
Thirdly, there are the issues of providing access to justice those who reside in such areas
that are not accessible even physically. It is therefore of utmost concern that strategies and
programmes be developed by the judiciary and the administration to provide them relief in
a manner that compares with those in more favored situations.
Finally, we need to deliberate on the methodologies to be adopted for encouraging justice
dispensation through the traditional forum of Panchayats. This age-old institution has found
new vigor with the introduction of the 73rd Amendment to the Constitution, and must
accordingly be considered as another pillar in the edifice that symbolizes justice.
Strengthening the institution of Panchayats and empowering people at the grass-roots level
to resolve their disputes amicably would solve many of the problems that are faced by
conventional justice dispensation machinery in its attempt to percolate to the lowest levels.
This institution is also perhaps the solution to the problem of access to justice identified
with those people living in remote regions who are cut-off from the civilized world.
We have to prepare for the future. Let there be access to all irrespective of their stature,
caste, creed, or religion. Enforce let equality as enshrined in our Constitution in the judicial
DA DECLARAÇÃO DE INCONSTITUCIONALIDADE DO ART. 273, DO CÓDIGO PENAL OU RECONHECIMENTO DA ATIPICIDADE MATERIAL DO FATO, ANTE A INEXISTÊNCIA DE RESULTADO JURÍDICO Por Bruno Haddad Galvão, Defensor Público do Estado de São Paulo O artigo 273, do Código Penal, foi introduzido pela Lei 9.677, de dois Assim como outras leis, tais como a de n.° 8072/90 e 8930/94, referida lei foi
A Brief Biodata of Prof. Mosaad Attia Abdel-Wahhab Employment: 1985-1989 : Assistant Researcher, Department of Food Technology, Food Technology and Nutrition Division, NRC. 1989-1990 : Researcher Assistant Present Department of Food Technology, Food Technology and Nutrition Division, NRC. 1990-1994 : Visiting Scientist, VAPH, Collage of Veterinary Medicine, Texas A&M Univer