Assignment

On
Stages and commission of crime
Submitted To: Submitted By:
Name: -Dr. Farhana Name-Asha

Course- LL.M. (Ist Semester)

Subject- General principles

of criminal law
SYNOPSIS:

 Introduction

 History

 Definition of Crime

 Intention to Commit a Crime

 Preparation

 Attempt

 Difference between Preparation and Attempt

 Accomplishment

 Inchoate crimes

 Bibliography
INTRODUCTION

Criminal law is a body of rules and statutes that defines conduct prohibited by the state because
it threatens and harms public safety and welfare and that establishes punishment to be imposed
for the commission of such acts. Criminal law differs from civil law, whose emphasis is more
on dispute resolution than in punishment. The term criminal law generally refers to substantive
criminal laws. Substantive criminal laws define crimes and prescribe punishments. In contrast,
Criminal Procedure describes the process through which the criminal laws are enforced. For
example, the law prohibiting murder is a substantive criminal law. The manner in which state
enforces this substantive law—through the gathering of evidence and prosecution—is
generally considered a procedural matter. Human Being- The first element requires that the
wrongful act must be committed by a human being. In ancient times, when criminal law was
largely dominated by the idea of retribution, punishments were inflicted on animals also for
the injury caused by them, for example, a pig was burnt in Paris for having devoured a child, a
horse was killed for having kicked a man. But now, if an animal causes an injury, we hold not
the animal liable but its owner liable for such injury.

There are the four stages in commission of the crime.

· Intention

· Preparation

· Implementation

· Accomplishment

HISTORY

The first civilizations generally did not distinguish between civil law and criminal law. The
first written codes of law were designed by the Sumerians around 2100- 2050 BC. Another
important early code was the Code Hammurabi, which formed the core of Babylonian law.
These early legal codes did not separate penal and civil laws. Of the early criminal laws of
Ancient Greece only fragments survive, e.g., those of Solon and Draco. After the revival of
Roman law in the 12th century, sixth-century Roman classifications and jurisprudence
provided the foundations of the distinction between criminal and civil law in European law
from then until the present time. The first signs of the modern distinction between crimes and
civil matters emerged during the Norman invasion of England. The special notion of criminal
penalty, at least concerning Europe, arose in Spanish Late Scholasticism, when the theological
notion of God's penalty (poena aeterna) that was inflicted solely for a guilty mind, became
transfused into canon law first and, finally, to secular criminal law. The development of the
state dispensing justice in a court clearly emerged in the eighteenth century when European
countries began maintaining police services. From this point, criminal law had formalized the
mechanisms for enforcement, which allowed for its development as a discernible entity.

DEFINITION OF CRIME

The concept of crime involves the idea of a public as opposed to a private wrong with the
consequent intervention between the criminal and injured party by an agency representing the
community as whole. Crime is thus the international commission of an act deemed socially
harmful; or dangerous and the reason for making any given act a crime is the public injury that
would result from its frequent participation. The society therefore takes steps for its
presentation by prescribing specific punishments for each crime.

1. The word ‘crime’ is of origin ‘Crimean’ which means ‘charge’ or ‘offence’ Crime is a
social fact.

2. The Waverly Encyclopedia defines it as, “An act forbidden by law and for performing
which the perpetrator is liable to punishment”.

3. James Anthony Froude (1818-94) wrote, “Crime is not punished as offence against God,
but as prejudicial to society”.

4. Sir John Hare (1844 - 1921) Explains, “Crimes sometimes shock us too much: Vices always
too little”.

5. Dr. Gillian J.L. points out, “More important is the feeling of danger to ourselves and our
property than the criminal–induces”. (Gillian, J.L Criminology and penology (1945)

6. Mr. Justin Millar contends that the crime is the commission or omission of act which the
law forbids or commands under pain of punishment to be imposed by the State.
7. Watermark Says that customs and laws are based on moral ideas and that ‘crimes’ are such
modes of behavior as are regarded by society as crimes.

8. According to Adler, ‘Crime’ is merely, “an instance of behavior prohibited by criminal

law”. 9. According to the Italian school of criminologists, crime is abnormal in so for as it is
atavistic or pathological in its nature.

INTENTION TO COMMIT A CRIME

According to Sir Stephen “A crime is an act or an omission in respect of which legal

punishment may be inflicted on the person who is in default either by acting or omitting to act”.
So, crime is nothing but an Act which is forbidden by law and is against the moral sentiments
of the society.

One of the principles of Criminal law says that an act cannot be considered as a crime when
the mind of the person who has done the said act is innocent and not guilty. The fundamental
principle of penal liability is based on a Latin maxim “Actus non facet reum nisi mens sit rea”
which means “The Act and the Intent must concur to constitute a crime”. In simple words, it
means an act done by a person will not be considered as a crime unless it is done with a guilty
mind. For example, Jack picks up his watch from the locker room at Tennis club and goes back
home. Later, he realizes that it is not his watch but even then, he retains it in his possession as
this watch is better looking and more expensive than the watch he had earlier. As Jack wanted
to retain the watch with himself thereby dispossessing the true owner of the same so there is
both a guilty act and a guilty mind and that’s when it’s considered to be an offence.

Intention is the first stage in the commission of an offence and known as mental stage. Intention
is the direction of conduct towards the object chosen upon considering the motives which
suggest the choice. But the law does not take notice of an intention, mere intention to commit
an offence not followed by any act, cannot constitute an offence. The obvious reason for not
prosecuting the accused at this stage is that it is very difficult for the prosecution to prove the
guilty mind of the person.

Intention is a term, which is very difficult to define. It is not defined in the Penal Code. It is a
common term known to everybody, but at the same time, it defies a precise definition. It can
be variously said to mean the object, purposes, the ultimate aim or design behind doing an act.
Intention is the conscious exercise of the mental faculties of a person to do an act, for the
purpose of accomplishment or satisfying a purpose 1.Intention, therefore, is usually used in
relation to the consequences of an act, and not in relation to the act itself. A person clearly
intends a consequence if he wants hat consequences to follow from his action. 2

The idea of ‘intention’ in law is not always expressed by words ‘intention’, ‘intentionally’ or
‘with intent to’. It is expressed also by words such as ‘voluntarily’, ‘willfully’, ‘deliberately
intention’, ‘with the purpose of’, or ‘knowingly’. All these varied expressions find place in the
various sections of the IPC.

Eg: Waging a War against the Government is punishable. In this case, mere intention to commit
is punishable. Similarly, mere assembly of persons to commit a dacoity is punishable even
though there is no preparation to it.

One of the most important ingredients of a crime is Mens rea i.e., an intention to do a wrongful
act knowing the evil consequences of the same. The element of Mens rea is indicated by use
of words such as intention, malice, fraudulent, recklessness etc. There must be a mind at fault
before commission of an offence. Mens rea includes both the intention to do an act as well as
abstaining from doing an act which is required to be done. Mere intention to do a wrongful act
is itself prohibited by law. An accused will be held guilty if it’s proved that he had an intention
to commit the crime but the burden of proof lies on the opposite party and there should be
sufficient justification to conclude that intention existed. The court in Ramachandra Gujar’s
case held that intention can be only inferred from the conduct of a person and the probable
effect of such a conduct must be taken into account as well.
In State of Maharashtra vs M.H. George3, the Supreme Court held that criminal intention is a
psychological fact which needs to be proved even with regards to offences under special acts
unless it’s specifically ruled out or ruled out by necessary implication.
In Hari Mohan Mandal vs. State of Jharkhand4 , Hon’ble Supreme Court held that it is not
essential that bodily injury capable of causing death should have been inflicted. Intention to
kill or knowledge that death will be caused is a question of fact which will be subject matter of
trial.

1
Bhagwani Appaji v. Kedari Kashinath (1900) ILR 25 Bom 202; Jai Prakash v Delhi Administration (1991) 2 SCC
32, 1991 (1) scale 114.
2
Ram Kumar v State AIR 1970 Raj 60; Sorabjeet Singh v State of Uttar Pradesh (1984) SCC (Cri) 151, AIR 1983
SC 529
3
1965 AIR 722, 1965 SCR (1) 123
4
2004 AIR SC
In State vs. Salauddin @ Raja & Anr., the court held that Intention or knowledge is an essential
ingredient for an offence under Section 307 IPC.

PREPARATION
Preparation is the second stage in the commission of a crime. It means to arrange the necessary
measures for the commission of the intended criminal act. Intention alone or the intention
followed by a preparation is not enough to constitute the crime. Preparation has not been made
punishable because in most of the cases the prosecution has failed to prove that the preparations
in the question were made for the commission of the particular crime.

If A purchases a pistol and keeps the same in his pocket duly loaded in order to kill his bitter
enemy B, but does nothing more. A has not committed any offence as still he is at the stage of
preparation and it will be impossible for the prosecution to prove that A was carrying the loaded
pistol only for the purpose of killing B.

Preparation When Punishable

Generally, preparation to commit any offence is not punishable but in some exceptional cases
preparation is punishable, following are some examples of such exceptional circumstances-

a) Preparation to wage war against the Government - Section 122, IPC 1860;

b) Preparation to commit depredation on territories of a power at peace with Government of

India- Section 126, IPC 1860;

c) Preparation to commit dacoity- Section 399, IPC 1860;

d) Preparation for counterfeiting of coins or Government stamps- Sections 233-235, S. 255

and S. 257;

e) Possessing counterfeit coins, false weight or measurement and forged documents. Mere
possession of these is a crime and no possessor can plead that he is still at the stage of
preparation- Sections 242, 243, 259, 266 and 474.

ATTEMPT
A person is guilty of an attempt to commit a crime when such person, with the intention to
actually commit the crime, does an act which is a substantial step toward the commission of
the crime, but not the actual commission of the crime. Therefore, an attempt to commit a crime
consists of two elements:
(1) an intent to engage in crime; and

(2) a conduct constituting a substantial step towards commission of the crime.

A statute may forbid an attempt to commit a specified crime. An attempt to commit a crime,
when punishable, is an offense that is separate and distinct from the crime that was
attempted. To qualify as a substantial step, something more than mere preparation should be
done. Preparation alone, or a mere statement of the person’s intent to commit a crime, is not
sufficient to constitute an attempt. However, the step should be lesser than the actual
commission of the crime. To establish attempt, the alleged conduct must support the person’s
criminal intention to commit the crime. The person must have engaged in some activity that is
a substantial portion of the crime. An attempt must be an action on the part of the person that
comes very close to the accomplishment of the desired results. A person who fails to commit
the attempted crime is also regarded to have attempted to commit the crime.

Intent is an important element when determining whether an attempt to commit a crime has
occurred. The person making the attempt should have the intention to complete the acts that
constitutes the crime. It is the intent to commit the crime, not the possibility of success that
determines whether the person’s act or omission constitutes the crime of attempt. A person
can be convicted for an attempt to commit a crime only when such person has a direct and
specific intent. Therefore, acts done as a result of negligence or recklessness cannot be
considered as an attempt to commit the crime as there is no intention to commit the crime.

It is also known as the 'Preliminary Crime'.

Section XXIII of the IPC, 1860 deals with 'of Attempt to Commit Offences' and provides the
punishment for attempt.

Essentials of Attempt

1. Guilty intention to commit an offence

2. Some act done towards committing the offence

3. The act must fall short of the completed offence

Attempt is the direct movement towards the commission of a crime after the preparation is
made. According to English law, a person may be guilty of an attempt to commit an offence if
he does an act which is more than merely preparatory to the commission of the offence; and a
person will be guilty of attempting to commit an offence even though the facts are such that
the commission of the offence is impossible.

Attempt Under the Indian Penal Code, 1860 The Indian Penal Code has dealt with attempt in
the following four different ways- Completed offences and attempts have been dealt with in
the same section and same punishment is prescribed for both. Such provisions are contained in
Sections 121, 124, 124-A, 125, 130, 131, 152, 153-A, 161, 162, 163, 165, 196, 198, 200, 213,
240, 241, 251, 385, 387, 389, 391, 394, 395, 397, 459 and 460.

Secondly, attempts to commit offences and commission of specific offences have been dealt
with separately and separate punishments have been provided for attempt to commit such
offences from those of the offences committed. Examples are- murder is punished under
section 302 and attempt to murder to murder under section 307; culpable homicide is punished
under section 304 and attempt to commit culpable homicide under section 308; Robbery is
punished under section 392 and attempt to commit robbery under section 393.

Thirdly, attempt to commit suicide is punished under section 309;

Fourthly, all other cases [where no specific provisions regarding attempt are made] are
covered under section 511 which provides that the accused shall be punished with one-half of
the longest term of imprisonment provided for the offence or with prescribed fine or with both.

FIVE TESTS LAID DOWN BY COURTS

Thus, it is simple to say that an attempt to commit offences begins where preparation to commit
it ends, but it is difficult to find out where one ends and the other begins. To solve this riddle
various tests have been laid down by the courts. These are as follows.

 The Proximity test,

 The Locus Poenitentiae test,
 The Impossibility test,
 The Social Danger test, and
 The Equivocal test

1) THE PROXIMITY TEST- Proximity cause as explains is the casual factor which is closes,
not necessarily in time or space, but in efficacy to some harmful consequences, in other words,
it must be sufficiently near the accomplishment of the substantive offence.
In Sudhir kumar Mukherjee5 case and Abyanand Mishra6 case, the supreme court explained
the offence of attempt with help of the proximity test, saying that

“A person commits the offence of attempt to commit a particular offence” when-

a) He intends to commit that particular offence, and

b) He having made preparation with the intention to commit the offence does an act towards
its commission, such an act need not to be the penultimate act towards the commission of that
offence but must be an act during the course of committing that offence.

2) THE LOCUS POENITENTIAE TEST –The Latin expression speaks about time for
repentance. In locus Poenitentiae the word Locus means a place a word frequently used to
denote the place in or at which some material act or even such as crime, delict or breach of
contract took place. Locus poenitentiae means the opportunity to withdraw from a bargain
before it has become fully constituted and become binding.

In simple language an act will amount to a mere preparation if a man on his own accord, before
the criminal act is carried out, gives it up. It is, thus possible that he might of its own accord,
or because of the fear of unpleasant consequences that might follow, desist from the completed
attempt. If this happens, he does not go beyond the limits of preparation and does not enter the
arena of attempt. He is thus at the stage of preparation which can’t be punished.

Malkiat Singh Case7 explain this second test, in this case, a truck carrying a paddy was stopped
at Samalkha barrier a place 32 miles away from Delhi. Evidently, there was no export of paddy
within the meaning of para 2(a) of the Punjab paddy (Export control) order, 1959, the court
decided that there was no attempt to commit the offence export. It was merely a preparation.
Distinguishing between attempt and preparation supreme court observe that the test of
distinction between two is whether the overt acts already done are such that if the offender
changes his mind and does not proceed further in its progress, the acts already done would be
completely harmless. In the present case, it is quite possible that the appellants may have been
warned that they had no license to carry the paddy and they may have changed their mind at

5
(1974) 3 SCC 357
6
AIR 1961 SC 1698
7
Malkiat Singh v State of Punjab (1969) 1 scc 157
any place between Samalkha barrier and Delhi – Punjab boundary and not have proceeded
further in their journey.

3) IMPOSSIBILITY TEST- In Queen Express v. Mangesh Jivaji, the Bombay High court
held that within the meaning of section 511 of IPC (21), an attempt is possible, even when the
offence attempted cannot be committed.

In Asagarali Pradhaniu v. Emperor 8 , what the appellant did was not an “act done towards
the commission of offence” and therefore, he could not be convicted. But in a Malaysian case
the accused was liable for an attempt to cause abortion when the women were not pregnant.
Even the appeal court held the accused liable because the circumstances in this case seemed to
be exactly covered by the illustration to section 511 IPC.

The act itself is impossible of performance and yet it constitutes an offence of attempt to
commit crime. This was precisely the position in English law before Houghton v Smith case.

In R v. Shivpuri9 it has been held that if the mental element has proceeded to commit the act
but failed his responsibility for attempt would be evaluated in the light of facts as he thought
them to be (putative facts).

4) THE SOCIAL DANGER TEST – In order to distinguished and differentiate an act from
an act of preparation the following factors are contributed.

a) The seriousness of the crime attempted

b) The apprehension of the social danger involved.

In this test the accused’s conduct is no examined only partially but the consequences of the
circumstances and the fullness of the facts are taken into consideration. For example, X
administers some pills to a pregnant woman in order to procure abortion. However, since the
pills are innocuous, they do not produce the result. In spite of this X would be held liable for
an attempt from the view point of the social danger test, as his act would cause as alarm to
society causing social repercussions.

5) THE EQUIVOCALITY TEST – It is a situation wherein there are two opinions about the
crime here, as decided by the Madras High Court, an attempt is an act of such a nature that it

8
(1934) ILR 61, 64
9
(1987) 1 AC 1 (HL)
speaks for itself or that it is in itself evidence of the criminal intent with which it is done. A
criminal attempt bears criminal intent upon its face. In other words, if what is done indicate
unequivocally and beyond reasonable doubt the intention to commit the offence it is an attempt
or else it is a mere preparation.

Difference between Preparation and Attempt

Attempt to commit crime is punishable, whereas preparation is not as discussed above. This is
because preparation would generally be a harmless act, example attempt to commit murder
creates a disturbance in the society and the sense of insecurity in an individual, while
preparation may not create alarm in society. According to Indian penal code an “attempt” is a
continuous proceeding which at one stage assumes criminal character.

In Sudhir Kumar Mukherjee v State of West Bengal10, Supreme court held that, attempt to
commit an offence begins when the preparation is complete and the culprit commences to do
something with the intention of committing the offence and which is a step forward toward the
commission of the offence.

In Abhyanand Mishra v. State of Bihar11Supreme Court held that the movement culprit
commences to do an act with the necessary intention, he commences his attempt to commit an
offence. Such an act need not be the penultimate act towards the commission of that offence
but must be an act during the course of committing that offence.

ACCOMPLISHMENT
The last stage in the commission of an offence is its accomplishment or completion. If the
accused succeeds in his attempt to commit the crime, he will be guilty of the complete offence
and if his attempt is unsuccessful, he will be guilty of an attempt only. For example, A fires at
B with the intention to kill him, if B dies, A will be guilty for committing the offence of murder
and if B is only injured, it will be a case of attempt to murder. The last stage in the commission
of an offence is its accomplishment or completion. If the accused succeeds in his attempt to
commit the crime, he will be guilty of the complete offence and if his attempt is unsuccessful,
he will be guilty of an attempt only. For example, A fires at B with the intention to kill him, if
B dies, A will be guilty for committing the offence of murder and if B is only injured, it will
be a case of attempt to murder. Security and stability are basic human needs, no less important

10
(1974) 3 SCC 357
11
AIR 1961 SC 1698
than food and clothing. Without security and stability, a human being is not able to properly
conduct his daily life, let alone come up with new ideas or contribute to the development of a
high level of civilization. Man has been conscious of the need for security since the beginning
of his life on Earth, and he has continuously expressed his awareness of this need in many
ways. With the formation and evolution of human society, he has expressed this and other
needs through the establishment of a state and the formation of laws. This was accomplished
in order to ensure general security, settle disputes and conflicts that threaten society, and
oppose external threats to its security posed by other nations. The development of these man-
made laws did not come to completion except in the last few centuries as the result of a long
process of trial and error. By contrast, the Law of Islam was sent down to Muhammad, may
the mercy and blessings of God be upon him, in its complete form as part of His final message
to humanity. Islamic Law pays the most careful attention to this matter and provides a complete
legal system. It takes into consideration the changing circumstances of society as well as the
constancy and permanence of human nature. Consequently, it contains comprehensive
principles and general rules suitable for dealing with all the problems and circumstances that
life may bring in any time or place. Likewise, it has set down immutable punishments for
certain crimes that are not affected by changing conditions and circumstances. In this way,
Islamic Law combines between stability, flexibility, and firmness.

INCHOATE CRIMES

An inchoate crime is one that is "committed by doing an act with the purpose of effecting some
other offence" (G. Williams, Textbook of Criminal Law).

Smith and Hogan define “inchoate” as “just begun, incipient, in an initial or early stage.”

Inchoate or incomplete offences are offences where for one reason or another the perpetrator(s)
failed to commit the substantive offence.

It may be that the perpetrator(s) were interrupted or frustrated in their efforts to commit the
offence by the police or because the plan failed due to impossibility. For example the plan fails
because the means adopted are inadequate (e.g. intends to poison a victim but the amount
administered is harmless, or makes a false statement that does not deceive the intended victim)
or, the pickpocket who puts his hand in a person's pocket only to find it empty; or the burglar
who is disturbed by the police when he is in the process of trying to break open the window;
or the safebreaker who finds when he gets to the safe, it is too difficult for him and he cannot
open it.

An inchoate offence requires that the defendant had the specific intent that the underlying
offence would be committed; and

 Incited another to commit the offence; or

 Agreed (conspired) with another to commit the offence; or
 Attempted to commit the offence

Further, inchoate offences are committed when the defendant takes certain steps towards the
commission of a crime.

Unlike liability for secondary participation in a crime, it is unnecessary that the main offence
be committed.

There are three main inchoate offences –

1.incitement,

2. conspiracy and

3. attempt

The case of R v Curr [1968] 2 QB 944 makes the foregoing point. In that case the defendant
ran a loan business whereby he would lend money to women with children in return for their
handing over their signed family allowance books. He would then use other women to cash the
family allowance vouchers. He was convicted of inciting the commission of offences under
s9(b) of the Family Allowance Act 1945, which made it an offence for any person to receive
any sum by way of family allowance knowing it was not properly payable.

He appealed successfully to the Court of Appeal, where it was held that the trial judge had
erred in not directing the jury to consider whether these women, who were being incited to use
the signed allowance books to collect money on behalf of the defendant, had actually known
that what they were being asked to do was unlawful. It would have been more appropriate to
have charged the defendant as the principal offender relying on the doctrine of innocent agency.
R v Tosti and White [1997] Crim LR 746

The defendants had been seen by the owners of a farm, just before midnight, walking to the
door of a barn, and examining the padlock. They saw that they were being watched, took fright
and ran off. A car was parked in a nearby lay-by, and between the car and the barn, hidden in
a hedge, was some oxygen cutting equipment. There was sufficient evidence to connect T with
the equipment. The defendants were convicted of attempted burglary. The defendants appealed
against conviction on the ground that there was no evidence upon which the jury could have
found that an attempted burglary had been committed.

It was held by the Court of Appeal, dismissing the appeal, that the short question was whether
it could be said that the defendants, in providing themselves with oxygen cutting equipment,
driving to the scene, concealing the equipment in a hedge, approaching the door of the barn
and bending down to examine how best to go about the job of breaking into the barn, had
committed acts which were more than merely preparatory, and which amounted to acts done
in the commission of the offence. The question was essentially one of degree. It had been said
in Geddes (1996) that the test was to ask whether the evidence if accepted could show that the
defendant had done an act which showed that he had actually tried to commit the offence, or
whether he had only got ready or put himself in a position or equipped himself to do so.
Applying that guidance to the facts of the present case, the facts proved in evidence were
sufficient for the judge to leave to the jury.

R v Gibson [1991] 1 All ER 439

The defendants exhibited at an exhibition in a commercial art gallery, a model's head to which
were attached earrings made out of freeze-dried human fetuses. The exhibit was entitled
'Human Earrings'. The gallery was open to, and was visited by, members of the public. The
defendants were charged with, and convicted of, outraging public decency contrary to common
law.

JUSTIFICATION FOR INCHOATE OFFENCES

Some of the justifications for having inchoate offences as a category of offences include:

(i) By virtue of the fact that inchoate offences seek to punish those who attempt to
perform or promote a criminal act, they may have some preventative capacity. If
 one knows that the act of inciting, conspiring and/or attempt represents a crime itself
punishable under law this may work as a deterrent.

(ii) If harm may arise from someone's actions, it is right for them to be held criminally
liable - the fact that actual harm is missing should not preclude legal sanctions for
malevolent behavior.

(iii) Society's need to control dangerous people and thereby protect the interests of the
innocent from violation justifies inchoate offences. By suggesting, agreeing to
commit or trying to commit a crime a Defendant has demonstrated his willingness
that the crime should be committed. This in itself justifies a finding of culpability
- it doesn’t matter that the completed crime is never committed. This justification
is particularly satisfactory as it relates to attempts. So that if D tries to shoot V with
intent but fails then he is a dangerous, morally reprehensible person and should be
so punished notwithstanding that he was not able to achieve his desired result.

(iv) Prevention is better than cure.

BIBLIOGRAPHY: -

Books required –

 PSA Pillai, CRIMINAL LAW, 13TH EDITION

Online database-

 https://www.lawnotes.in/Four_stages_of_committing_a_crime
 http://www.legalservicesindia.com/article/article/the-elements-and-stages-of-a-crime-
1228-1.html
 http://www.legalservicesindia.com/article/article/the-elements-and-stages-of-a-crime-
1228-1.html
 https://www.coursehero.com/file/12551023/stages-of-crime-2/
 http://www.scconline.com/
 http://www.manupatrafast.com/