Research Scholar, Department of Law, University of Lucknow, Lucknow (U.P.),

Drug addiction has penetrated in almost all segments of the society to such an extent that it is eating into the vitals of the nation. Over about the last three decades, the use of illegal drugs has spread at on unprecedented rate and reached every part of the globe, creating devastating problems in practically most of the nations, arising out of drug abuse. The world community has over these years demonstrated serious concern over the problem for the insidious long term effect of chronic drug use and its impact on the user, the family, the community and the society. All nations, including India have viewed drug abuse as a threat to the survival of human beings.

Drug related crimes are equally conscience stirring and have made people much over it. In this paper an attempt has been made to analyze the roots of this menace that how and when drugs started running in the bloods of Indians. It is explored that various efforts taken by India to curb this problem is merely a formality. If this issue would have been considered seriously then this dragon could be snubbed in its very inception. Drug is Death: Say no to Drugs are some slogans visible on billboards and newspapers that are proofs of the social awareness drug abuse has attracted.


Drug use is a potentially important determinant of criminal activity, although the extent of the relationship between drugs and crime has not been identified clearly. Despite strong evidence that drug use and criminal activity are positively correlated, the casual impact of drug use on crime has not been conclusively established.[1] The link between juvenile crimi­nal offending and adolescent substance use and substance use disorders is strong and well established. National data for primarily publicly funded substance abuse treatment pro-grams show that the criminal justice system accounted for 55 percent of male admissions and 39 percent of female admissions to these programs. Juvenile offenders who continue to use drugs are also more likely to continue their offending careers.[2] This “drug-crime” cycle likely reflects both the mutual causal influences between drug use and crime and the fact that substance use and offending share common risk factors. Drug treatment thus may be one way to reduce recidivism.[3]

Substance use among juvenile offenders is linked with other health risk behaviors. In one sample of detained youth with substance use disorders, 63 percent engaged in five or more sexual risk behaviors, producing height­ened vulnerability to HIV and other sexually transmitted diseases. Substance use is also associated with violence and accidents and, among pregnant women, with harm to fetal development.[4] Among adolescents in the general population, substance users, par­ticularly heavy substance users, tend to have less positive educational, occupational, and psychological outcomes.

Drug use and Delinquency

An association between drug use and delinquency has been established and this connection can take a number of forms. Crime may be an instrument of drug trade. Drug users can also commit crime to pay for their habits. One study conducted in Miami found that 573 narcotics users annually committed 200,000 crimes to obtain cash. Drug users may be more willing to take risks because their inhibitions are lowered by substance abuse. Cities with high rate of cocaine abuse are also more likely to experience higher levels of armed robbery. It is possible that crack and cocaine users are more willing to engage in a risky armed robbery to get immediate cash than a burglary, which requires more planning and effort.[5]

The relationship between alcohol and drug abuse and delinquency has been substantiated by a number of studies. Some have found that youths who abuse alcohol are more likely to engage in violence.

The National Institute of Justice’s Arrestee Drug Abuse Monitoring (ADAM) program tracked trends in drug use among arrestees in urban areas.[6] The most recent report 2002 found that among juvenile detainees almost 60% of juvenile males and 30% of females tested positively marijuana, the most commonly used drug, and its prevalence was ten and six times higher than cocaine use for juvenile males and females, respectively. Today, there is no part in the world which is free from drug abuse. India too has a long history of drug abuse. It is surrounded on both sides by routes of illicit transport, namely, Golden triangle (Burma-Thailand-Laos) and Golden crescent (Iran-Afghanistan-Pakistan) and is thus severely affected. As a result of which there is wide availability of opium and cannabis in India.[7]

Research has also shown that drug use and crime has positive link with each other and thus problem of drug use is not related just to individual but is concerned to entire community and family. The incidence of drug abuse among children and adolescents is higher than the general population. This is notably because youth is a time for experimentation and identity forming. In developed countries drug abuse among youth is generally associated with particular youth subcultures and lifestyles. This causes an acceptance by members of the subcultures of drugs and their use. In Asia figures of drug abuse are hard to find but after cannabis, Amphetamine-type Stimulants (ATS) are the most commonly uses amongst children and youth. There have been various studies carried out in the region regarding drug abuse. A 1996 study of eight cities in seven provinces of China showed that over a half of heroin abusers are below 25 years of age. A school survey conducted in 1999 among students aged 12 to 21 years, in Vientiane, reported 4.8 per cent lifetime abuse for ATS.

In India an NGO survey revealed that 63.6 % of patients coming in for treatment were introduced to drugs at a young age below 15 years. According to another report 13.1% of the people involved in drug and substance abuse in India, are below 20 years. Heroin, Opium, Alcohol, Cannabis and Propoxyphene is the five most common drugs being abused by children in India. A survey shows that of all alcohol, cannabis and opium users 21%, 3% and 0.1% are below the age of eighteen. An emerging trend about child drug abusers is the use of a cocktail of drugs through injection, and often sharing the same needle, which increases their risk of HIV infection. Overall 0.4% and 4.6% of total treatment seekers in various states were children. The use of certain drugs such as whitener, alcohol, tobacco, hard and soft drugs is especially wide spread among street children, working children and trafficked children but there is currently a lack of reliable data on drug abuse amongst children.

In 2008, CHILDLINE India Foundation published a study on substance abuse amongst children in Manipur. The study found a wide spread prevalence and acceptance of drug use from heroin to the most common Spasmo Proxyvon. The high use of intravenous drugs is accompanied by sharing of needles and hence a high prevalence of HIV/AIDS.[8]

The problem in India is there are no sensitization programmes about drug abuse in schools or for children out of school. India does not have a substance abuse policy. There is also a high incidence of charging children under the Narcotic Drugs and Psychotropic Substances (NDPS) Act, 1985. Children who at times done have access to high quality drugs will use volatile substances easily found in corner stores such as cough syrups, pain relief ointments, glue, paint, gasoline and cleaning fluids. There are very few to no health centers that deal with child substance abuse problems, especially in the rural areas. The use of tobacco is another major concern amongst children. In India 20 million children a year and nearly 55,000 children a day are drawn into a tobacco addiction. The number is shocking when compared to the 3000 a day new child smokers in the US.[9]

Children affected by substance abuse are considered as children in need of care and protection under the Juvenile Justice Act, 2000.[10]

  • Understanding causes of juveniles turning towards drug abuse

There are numerous causes of teenage drug abuse, each of which can contribute to a life-long habit of consuming drugs, alcohol and cigarettes.

  1. Lack of Supervision

Children and teenagers who are left alone for long periods of time or who are allowed to come and go as they please will have more opportunities for exposure to drugs.

  1. Availability

Availability is also an issue when it comes to retailers. If retailers sell alcohol and cigarettes to minors, they are contributing to the problem.

  1. Lack of Communication

Many of the causes of teen drug abuse can be eliminated simply by talking. Some teens may abuse drugs because they think their parents don’t care. Communication solves this problem.

  1. Stereotyping

One of the most grievous causes of teenage drug abuse is stereotyping, which is linked to parental supervision and communication. Many parents assume that their children are not at risk for drug or alcohol abuse and that they therefore shouldn’t worry. In reality, there is no specific type of teenager who might abuse drugs.

  1. Running with wrong crowd

Children who are involved with wrongdoers or drug abusers also often fall into bad habits.


  1. Lack of spiritual grounding

Lack of spiritual belief and rarely attending religious services are linked to higher risk for substance abuse and delinquency.[11]

Dangerous effects of drug use in Juveniles

  • Drugs of any kind decreases teens’ ability to pay attention.
  • The younger a person is when they begin using drugs the more likely they are to develop a substance-abuse problem and the more likely they are to relapse into drug abuse when trying to quit.
  • Juveniles who use drugs are more likely to have unprotected sex, sex with a stranger, as well as to engage in sexual activity at all. This, in turn, puts them at risk for pregnancy, rape commission or victimization, and for sexually transmitted diseases.
  • Substance use can cause or mask other emotional problems, like anxiety, depression, mood swings, or hallucinations (for example, hearing or seeing things). Either of those illnesses can result in death by suicide or homicide.
  • Depending on how the body takes in and processes each kind of drug, substances of abuse can affect virtually every one of the body’s systems. Examples of this include permanent brain damage associated with inhalants, heart attack or stroke from stimulants, halted breathing from sedatives. Any of these problems can result in death.[12]
  • Mental health problems such as depression, developmental lags, apathy, withdrawal, and other psychosocial dysfunctions frequently are linked to substance abuse among adolescents.
  • Drugs directly affect the brain, and our brains control almost everything we do. Your actions will therefore affect relationships, family, peers and the school life.[13]
  • Substance-abusing youth may be alienated from and stigmatized by their peers. These young people also often disengage from school and community activities, thus depriving their peers and communities of positive contributions they might otherwise have made.
  • Depression, developmental lag, apathy, withdrawal, and other psychosocial disorders are frequently linked to substance abuse among adolescents. Users are at higher risk than nonusers for mental health problems, including suicidal thoughts, attempted suicide, completed suicide, depression, conduct problems, and personality disorders.


  •  Substance abuse and Juvenile crimes

Consistent and substantial evidence exists that supports the relationship between substance abuse and criminal behaviors in youth. Substance abuse produces antisocial behavior in youth. Severe substance abuse is associated with increased rates of offending and more serious offenses.

The term ‘children in conflict with the law’ refers any person below the age of 18 who has come in contact with the justice system as a result of committing a crime or being suspected of committing a crime. Most children in conflict with the law have committed petty crimes such as vagrancy, truancy, begging or alcohol use. Some have committed more serious offenses. Some children are coerced into crime by adults who use them as they know they cannot be tried as adults. Often prejudice, stereotyping and discrimination brings children into conflict with law without a crime being committed. More than 1 million children worldwide are detained by law officials. In institutions children are often died access to medical care and education which are part of their rights. In 2002, 136,000 children in the Central and Eastern Europe and the Commonwealth of Independent States were found guilty of criminal offenses, compared to 117,000 in 1990. Russia accounted for 65% of these cases.

In India the number of cases of juvenile delinquents has increased from 17,203 in 1994 to 30,943 in 2004. The crimes committed by juveniles have also seen an increase in the same period from 8,561 to 19,229. Some of the increase can be attributed to the definition of juveniles being changed to include ages 16-18, but none the less more and more children are coming into conflict with law in the 16-18 age group.

A major area of concern is the rise of juvenile crimes in the overall crimes committed in the country. In 1994 juvenile crimes amounted to 0.5% of all crimes committed. In 2004 that number has doubled to 1%. The Juvenile Justice system has gives rise to many child rights concerns as children are often denied bail for petty crimes, the responsible stakeholders do not carry out proper social investigations, the conditions in the homes is often unsafe and inhumane, and juvenile justice boards are not child friendly and functions like an adult court.

According to HAQ: Centre for child rights there has been a 7.9% increase in crimes committed by children between 2003 and 2004. In 2005 there was an 11.3% increase in crimes by children. There has been an increase especially in certain kinds of crimes which is a grave concern such as rape (by 11.9%), death due to negligence (150.8%), robbery (39.6%), attempt to murder (30.7%), preparation and assembly for dacoit activities (27.6%), auto theft (18.6%) and murder (15.9%) is a matter of concern. Surprising is the increase in number of cases of girls being charged with rape. As most crimes are committed by juveniles from poor families they should also fall under the children in need of care and protection category and should be treated as such. The main legislation that deals with juveniles is the Juvenile Justice Act, 2000.[14]

Aggression among today’s youth, coupled with the desire to turn fantasy into reality, may be one of the reasons for such heinous crimes. But the marginalization due to lower socio-economic conditions within the society makes it a deadlier combination, say psychiatrists. Psychiatrist Dr Harish Shetty said that the juvenile mind finds this social chaos as conducive to have a go for their own carnal satisfaction. “Poverty, impulsivity and marginalization are factors that facilitate such crimes. Most of these youths do not believe this is a crime but just fun. The magnitude of the crime is not understood and the anonymity helps the child to have fun.”[15]

Figures on juvenile crimes by the National Crime Records Bureau (NCRB) reveal that from 2002 to 2012, there has been a 143 per cent increase in the number of rapes by juveniles. In the same period, figures of murders committed by minors went up by 87 per cent while there has been a whopping 500 per cent increase in the number of kidnappings of women and girls by minors. However, as shocking as these statistics may be, it is important to remember that over the last five years (2007-2012 ) heinous crimes like rape and murder add up to just about eight per cent of total spectrum of crimes by minors. 72 per cent of the cases against minors between 2007 and 2012 were for theft, burglary and causing hurt.[16]

  • Balancing the Juvenile Act

“Young offenders above a certain age who commit violent crimes should be prosecuted as adults”.

On August 31, 2013, the Juvenile Justice Board (JJB) ordered that the boy who raped Nirbhaya (Delhi Gang Rape Case) brutalized her with an iron rod, pulled out her intestines and then cleaned up the bus and made tea would go virtually free by sentencing him to only 28 months in a remand home as eight months of the total 36 months’ sentence had already been served. This order is subject to review by the JJB based on the behavior of the juvenile and the police are required to expunge this crime from his record in order to ensure complete rehabilitation. Despite the unprecedented street protests following the Nirbhaya rape, there has been little substantive debate on the adequacy of the Juvenile Justice Act to deal with such heinous crimes.

The JJA creates a juvenile justice system in which persons up to the age of 18 who commit an offence punishable under any law are not subject to imprisonment in the adult justice system but instead will be subject to advice/admonition, counseling, community service, payment of a fine or, at the most, be sent to a remand home for three years. However, the interest in protection of juveniles has to be balanced with the interest of protecting particularly vulnerable members of society from violent crimes committed by persons under 18 years of age and amending the law when societal conditions radically change over time. As per the reports of the National Crime Records Bureau (NCRB) entitled “Crime in India 2011” and “Crime in India 2012,” the percentage of crimes committed by juveniles as compared to total crimes has not significantly increased from 2001-2012. According to the NCRB statistics, India is not in the throes of a general crime wave by juveniles. However, the NCRB statistics relating to violent crimes by juveniles against women are very troubling. “Crime in India 2011” suggests the number of rapes committed by juveniles has more than doubled over the past decade from 399 rapes in 2001 to 858 rapes in 2010. “Crime in India 2012” records that the total number of rapes committed by juveniles more than doubled from 485 in 2002 to 1149 in 2011.

As the data suggests, between 2011 and 2012 alone, there was a massive increase in instances of rape by juveniles by nearly 300, which is almost as much as the increase in such cases over the entire previous decade. Particularly in view of the significant increase in rapes committed by juveniles since the JJ Act was passed, India should consider amendment of the Act to transfer certain violent crimes such as murder and rape committed by juveniles above a particular age to the adult criminal system.[17]

“There is a need to revisit the Juvenile Justice Act”– said by Kiran Bedi. For heinous crimes like rape it should be left to the judge to decide whether the act committed is committed by a child or not” she points out. Others like Lawyer and Activist Flavia Agnes disagree. Ms Flavia says that juvenile crime is a reflection of a break down in our society. The onus is on society to rehabilitate the child. Thus the debate has been sparked off after heinous incidence of Delhi whether the JJ Act should get amended or the issue for rehabilitation of juvenile be given more importance?

  • Preventing Drug Abuse in Juveniles- A Comprehensive Approach

Preventing or delaying use of psychoactive drugs, alcohol, and tobacco among adolescents is a critical, national public health goal. The simplest and most cost-effective way to lower the human and societal costs of drug abuse is to prevent it in the first place. Prevention is most promising when it is directed at impressionable youngsters. Adolescents are most susceptible to the allure of illicit drugs. Delaying or preventing the first use of illegal drugs, alcohol, and tobacco is essential. Treatment for substance abuse is critical for many around the world. Often a formal intervention is necessary to convince the substance abuser to submit to any form of treatment. Behavioral interventions and medications exist that have helped many people reduce, or discontinue, their substance abuse. Some of the following preventing techniques and treatment to stop drug abuse in juveniles could prove to be helpful-

In children and adolescents, cognitive behavioral therapy (CBT) and family therapy currently have the most research evidence for the treatment of substance abuse problems. Rather than be reactive, prevention programs should be proactive and reach each rising cohort. The following are some measures to control substance abuse among juveniles-

  • Central role of parents-

While all parents are critical influencers of children, parents of children aged eight to twelve are especially influential. Children in this age group normally condemn drug use. Thus parents should guide and mentor their children against harmful effects of drug abuse and it`s also the duty of parents to keep themselves away from any kind of addiction such as, smoking, drinking, taking drugs and others because they ultimately are the role models for their children.

  • National Youth Anti-Drug Media Campaign-

The media have come to play an increasingly important role in public health campaigns due to their wide reach and ability to influence behavior. Media campaigns have been used to prevent or reduce consumption of illegal drugs and smoking along with risky behavior like driving under the influence of alcohol or without seat belts. The anti-drug campaign will be truly successful only if media efforts are coordinated with initiatives that reinforce one another in homes, schools, and communities.

  • Safe and Drug-Free Schools and Communities-

Coordinators will be responsible for identifying promising drug and violence prevention programs and strategies; assisting schools in adopting the most successful strategies; developing, conducting and analyzing assessments of school drug and crime problems; working with community resources to ensure collaboration; and providing feedback to educational agencies on programs and activities that have proven to be successful in reducing drug use and violent behavior.

  • Youth Awareness program for Education-

In this modern world today there are still many people who cannot recognize the importance of education. There should be awareness program among youths for education and should be given friendly atmosphere in the schools.[18]

  • Reducing the drug availability-

Availability of dangerous drugs is needed to be curtailed so that fewer people get access to it. Drug mafia is needed to be targeted so that the existing drug addicts can be cured other can be saved from getting involved in drugs usage.

  • To have efficient law enforcement machinery which can comprehensively with international cooperation, with all aspects of crime related to narcotics and other dangerous drugs e.g., import. export, production, possession, transport, distribution and sale Stringent penalties for trafficking in narcotics and psychotropic substances.
  • Protect the juveniles and adolescents in particular and public in general against drug addiction
  •  Compulsory treatment of addicts,[19] stressing on the role of the social worker, states “changing social net work” and encouraging community involvement are proven methods of helping people suffering from drug or alcohol related problems.

The recent preceding half of the twentieth century has been witnessing a marked increase in drugs abuse, as a global phenomenon. Unfortunately the target of the drugs traffickers has been the human siblings- the children and the young adult {adolescents), who are tomorrow’s future. The Opium Act1857 and 1878 were concerned with legislation pertaining to cultivation of Poppy, manufacture of opium and regulation of possession, transport, interstate export and import including sale of opium. It may be noted the dangers of drug abuse was well contemplated as early as 1857. In sequel to Geneva Convention 1924, India being a signatory enacted Dangerous Drug Act 1930. It was to centralize and consolidate in the Union Government, the control over certain operations affecting the dangerous drugs and to provide stringent and uniform penal sanctions for such unlawful actions.

The NDPS Act 1985 and the Amending Act, the NDPS (Amendment) Act, 1988 and the prevention of Illicit Traffic in Narcotics Drugs an Psychotropic Substances Act 1988 {5.9.1988}were enacted, with alias the best thought that has been given by the welt meaning experts from criminal justice administration. The average age of the drug addicts is only 23 (twenty three) years of age. The frightening picture of a whole nation racing towards oblivion in the hands of drug abusers, has led one of the leading doctors to suggest ‘that man has come to self destructive phase in evolution.”  Bedi (1989)[20] writes in India, the statistics of juvenile and youthful offenders ‘ apprehended’ over the past ten years revealed, that more than 70 percent of the juveniles apprehended belong to 16-21 years of age group.


The thrust of this paper is prevention of drug abuse by children and adolescents. The legal and criminal justice administration are only some means to prevent drug abuse, unless a holistic approach designed on the basis of identifies social indicators in children inclination, involvement in drug abuse is chalked out, loading on any single agency to combat the global drug abuse problem, will be only a futile exercise.  The involvement of family, the teacher, the social worker, the community worker, the police, the psychologist, the doctor, the correctional, the rehabilitation, the health care programmes, work combinedly and coherently, there will always exists a gap for drug flow and drug abuse will persist. There is a need for developing the whole spectrum of drug flow chart clear and transparent, so that “the area, the person, concerned will remain vigilant. The strategy  planned need to be reviewed from time to time, the social time, and energy put into the service need by audited, so that effective budget of the social system and pragmatic co-ordination can be achieved. The holistic monitoring scheme can be simultaneously used by the concerned agency be it police, teacher, parent, social worker, doctor, psychologist, or case analyst. On the basis of this strategy, the global drugs abuse by children and young adult person may be put to a grinding halt though there may be some objections to such scheme in the name of invasion and interference of privacy, the concept can be so programmed and designed assuring least interference into the privacy and freedoms guaranteed by the Human Rights Charters.[21]


Books and Journals:-

  • Bedi, “Juvenile Delinquency: Causes and control”, Social Defense, 1989
  • Bhavani Prasad Panda , Rights of Child, Juvenile Delinquency and Administration of Justice, 1996
  • CIF, 2008, Lost in the haze: A study on substance abuse among children, Mumbai
  • Curtis Vander Waal and others, “Breaking the Juvenile Drug-Crime Cycle: A Guide for Practitioners and Policy-Makers,”S. Department of Justice, Office of Justice Programs, National Institute of Justice, 2001
  • Dennis Young, Richard Dembo, and Craig Henderson, “A National Survey of Substance Abuse Treatment for Juvenile Offenders,” Journal of Substance Abuse Treatment 32 (2007): 255–66
  • HP Kumar, The drug menace in India: A growing challenge, Health Millions 1997

·         J.S. Goel, “Drugs and Abuse” Social Defense, 1989

  • Larry J. Siegel and Brandon C. Welsh, Juvenile Delinquency: Theory, Practice and Law
  • Muhammad Ali Shuja, Essay on “Youth crimes: causes and remedies”, MPRA Paper No. 17223, posted 11 September 2009
  • National Institute on Alcohol Abuse and Alcoholism, “Underage Drinking: A Major Public Health Chal­lenge,” Alcohol Alert 59 (2003).

Newspaper and Articles:-

  • Fox Butterfield, Justice department ends testing of criminals for drug use, New York Times, 28 January, 2004
  • Heinous crimes by minor on the rise, shows NCRB data, September 6, 2013,
  •, Juveniles turning to crime a worrying sign: psychiatrists, September 5, 2013.
  • The Hindu, Aparna Vishwanathan, Balancing the Juvenile Act, September 9, 2013

Web Sources:-

[1] H. Naci Mocan and Erdal Tekin, Drugs and juvenile crime: Evidence from a panel of siblings and twins, , (last updated Aug 6, 2015)

[2] Dennis Young, Richard Dembo, and Craig Henderson, A National Survey of Substance Abuse Treatment for Juvenile Offenders, Journal of Substance Abuse Treatment , 255–66 (2007)

[3] Curtis Vander Waal and others, Breaking the Juvenile Drug-Crime Cycle: A Guide for Practitioners and Policy-Makers, U.S. Department of Justice, Office of Justice Programs, National Institute of Justice (May, 2001)

[4] National Institute on Alcohol Abuse and Alcoholism, Underage Drinking: A Major Public Health Chal­lenge, Alcohol Alert 59 (2003).

[5] Larry J. Siegel and Brandon C. Welsh, Juvenile Delinquency: Theory, Practice and Law

[6] Fox Butterfield, Justice department ends testing of criminals for drug use, N.Y. Times,  Jan 28, 2004

[7] HP Kumar, The drug menace in India: A growing challenge, Health Millions , 2-3, (1997)

[8] CIF, Lost in the haze: A study on substance abuse among children, Mumbai (2008)

[9] Ministry of women and child development Report, Working group on development of children for the eleventh five year plan (2007-2012),

[10]  Child protection and Child rights, (last updated Aug 6, 2015)

[11]The National Centre on Addiction and Substance abuse at Columbia University, Criminal neglect: substance abuse, juvenile justice and the children left behind,7 October, 2004 (last updated Aug 6, 2015)

[12] Teen drug abuse, (last updated Aug 6, 2015)

[13] The consequences of drug abuse, (last updated Aug 6, 2015)

[14] Child protection and child rights, (last updated Aug 6, 2015)

[15] Juveniles turning to crime a worrying sign: psychiatrists, Sept 5, 2013, (last updated Aug 6, 2015)

[16] Heinous crimes by minor on the rise, shows NCRB data, September 6, 2013, (last updated Aug 6, 2015)

[17] Aparna Vishwanathan, Balancing the Juvenile Act, The Hindu, September 9, 2013

[18] Muhammad Ali Shuja, Essay on Youth crimes: causes and remedies, MPRA Paper No. 17223, September 11, 2009

[19] J.S. Goel, Drugs and Abuse, Social Defense, 9-14 (1989)

[20] Bedi, Juvenile Delinquency:  Causes and control, Social Defense, 16 (1989)

[21] Bhavani Prasad Panda , Rights of Child:Juvenile Delinquency and Administration of Justice, 31-41 (1996)