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LANDMARK CASE

Nandini Satpathy v. P.L. Dani

(1978) 2 SCC 424 · Supreme Court of India · Criminal procedure

At a glance

  • Citation: (1978) 2 SCC 424
  • Court: Supreme Court of India
  • Area of law: Criminal procedure
  • In one line: Yes. Article 20(3) applies at the investigation stage, and the person may have a lawyer present.

1 Facts

A former chief minister was questioned by police and refused to answer certain questions.

2 Issue

Does the right against self incrimination apply during police interrogation?

3 What the court decided

Yes. Article 20(3) applies at the investigation stage, and the person may have a lawyer present.

4 Why it matters

It extended protection against compelled testimony.

5 Think about it

What counts as compulsion during questioning?

6 Analyse it yourself

Read the full judgment from an official source or a law database, then brief it in seven steps: facts, issues, arguments, decision, ratio, obiter and significance. Always check the citation before you rely on it.

How to analyse a judgmentHow to cite this caseTrial Advocacy

7 More cases on Criminal procedure

  • Arnab Manoranjan Goswami v. Union of India (2020) 14 SCC 12
  • Arnesh Kumar v. State of Bihar (2014) 8 SCC 273
  • D.K. Basu v. State of West Bengal (1997) 1 SCC 416
  • Gian Singh v. State of Punjab (2012) 10 SCC 303
  • Gideon v. Wainwright 372 U.S. 335 (1963)
  • Gurbaksh Singh Sibbia v. State of Punjab (1980) 2 SCC 565

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