Introduction: In an important verdict, the Apex Court of India in Zainul vs State of Bihar directed the legal test for Deciding person liability as per Section 149 of the Indian Penal Code (Now Section 190 of The Bharatiya Nyaya Sanhita, 2023), which explains the unlawful assembly. Justices J.B. Pardiwala and R. Mahadevan delivered the judgment, highlighting the importance of protecting individuals from Unlawful prosecution merely based on their presence at the time of
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