IMPORTANCE OF LEGAL SCHOLARS IN DEVELOPMENT OF LAW

BACHELOR OF LAWS (B.A., LL.B.)

Submitted by
NAME – NISHCHAY SHARMA
PROGRAM – BACHELOR OF LAWS (B.A. LL.B.)
SEMESTER – IV
SECTION – A
SCHOLAR NO. – 11110102392

Submitted to

MS. ANSHI JOSHI

ASSISTANT PROFESSOR OF LAW

DEPARTMENT OF LAW, PRESTIGE INSTITUTE OF MANAGEMENT AND

RESEARCH, INDORE
 Table of Contents

1. CHAPTER 1 – LEGAL SCHOLARS________________________________________III

1.1. WHAT IS MEANT BY LEGAL SCHOLARS ?___________________________________III

1.2. INFLUENCE OF LEGAL SCHOLARS_________________________________________III

2. CHAPTER 2 - ROLE OF LEGAL SCHOLARS IN DEVELOPMENT OF

NATURAL LAW_____________________________________________________________V

2.1. WHAT IS NATURAL LAW ?_______________________________________________V

2.2. HERACLITUS (530-470 BCE)_____________________________________________V

2.3. SOCRATES (470-399 BCE)______________________________________________VI

2.4. ARISTOTLE (384 – 322 BCE)____________________________________________VI

2.5. SAINT THOMAS AQUINAS (1225-1274)____________________________________VII

2.6. NATURAL LAW AND INDIAN LEGAL SYSTEM_______________________________VII

3. CHAPTER 3 - ANALYTICAL SCHOOL OF THOUGHT: MAJOR LEGAL

SCHOLARS_________________________________________________________________X

3.1. WHAT IS ANALYTICAL SCHOOL OF THOUGHT ?______________________________X

3.2. JEREMY BENTHAM (1748-1832)___________________________________________X

3.3. JOHN AUSTIN (1790-1859)______________________________________________XI

3.4. H.L.A. HART (1907-1992)______________________________________________XII

4. CHAPTER 4 - HISTORICAL SCHOOL OF THOUGHT_______________________XIII

4.1. WHAT IS HISTORICAL SCHOOL OF LAW ?__________________________________XIII

4.2. SAVIGNY (1779-1861)_________________________________________________XIII

 4.3. HENRY MAINE (1822-1888)____________________________________________XIII

5. CHAPTER 5 - SOCIOLOGICAL SCHOOL OF LAW__________________________XV

5.1. WHAT IS SOCIOLOGICAL SCHOOL OF LAW ?________________________________XV

5.2. MONTESQUIEU (1689-1755)_____________________________________________XV

5.3. ROSCOE POUND______________________________________________________XV

6. CHAPTER 6 – CONCLUSION___________________________________________XVI

7. BIBLIOGRAPHY______________________________________________________XVII
 1. CHAPTER 1 – LEGAL SCHOLARS

1.1. WHAT IS MEANT BY LEGAL SCHOLARS ?

The origin of the word “legal” can be found in the Latin term “legalis” which is again derived
from the Latin word “lex” which means “law”.1 Therefore, the term “legal” means connected
with or allowed by the law.2The dictionary meaning of “scholar” is a person with great
knowledge about particular subject or subjects. 3 However Seyda Deligonul in his article “The
Meaning of a Scholar” provided an in-depth and distinguished meaning of who is a scholar,
according to him, a scholar is a person who thinks deeply, explores different ideas, and stays
open to uncertainty and new possibilities. Instead of just collecting facts, a scholar analyzes,
questions, and learns about the subject.4
By understanding the meaning of both the word, the meaning of legal scholar or who is called
a legal scholar becomes very clear and easy to understand. Legal scholars are the individuals
who study and analyze the laws, legal systems and legal principles.5

1.2. INFLUENCE OF LEGAL SCHOLARS

The legal scholars have a great part in development of law as well as in the interpretation of
legal principles, their contentions help in understanding deeper meaning and purpose of laws
and principles which helps in better administration of justice and application of law. This is
the reason that the arguments and writings of legal scholars are still discussed and have
relevancy even today. In a recent study, data was collected from more than 3 million judicial
decisions in United States and Germany to know how frequently legal scholars are cited in
the judicial decisions by the judges. The study found that out of all the judicial decisions that
were analyzed, there were 43,839 citations to legal scholars. 6 The study also found that legal

1
Emilio Abiusi, A Brief Etymology of Law, 13 INTERNATIONAL JOURNAL OF
LANGUAGE & LAW 1, 3 (2024).
2
CAMBRIDGE DICTIONARY, https://dictionary.cambridge.org/dictionary/english/legal (last visited Mar. 28, 2025).
3
CAMBRIDGE DICTIONARY, https://dictionary.cambridge.org/dictionary/english/scholar (last visited Mar. 28,
2025).
4
Seyda Z. Deligonul, The Meaning of a Scholar, 19 MICHIGAN STATE UNIVERSITY CONTRIBUTIONS TO
INTERNATIONAL BUSINESS AND INNOVATION 227, 227 (2015).
5
CAMBRIDGE DICTIONARY, https://dictionary.cambridge.org/example/english/legal-scholar (last visited Mar. 29,
2025).
6
Nora Stappert, A New Influence of Legal Scholars? The Use of Academic Writings at International Criminal
Courts and Tribunals,31 LEIDEN JOURNAL OF INTERNATIONAL LAW 963, 965-974 (2018).
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scholarship has more influence in the courts of Germany than in American courts, where the
decisions are majorly based on precedents and reasoning. Courts in both the countries, when
the need arises, refers to highly influential legal scholars which shows the importance of the
legal scholars in interpretation, administration and development of law.7

7
Supra note 6.
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 2. CHAPTER 2 - ROLE OF LEGAL SCHOLARS IN DEVELOPMENT OF NATURAL LAW

2.1. WHAT IS NATURAL LAW ?

Natural Law has been defined by different scholars. Huges and Dias have described natural
law as a law which operates independently of any convention, legislation or other
institutional devices and is inherent in human nature.8 Cohen has defined natural law as not a
body of actual laws but as a perspective, according to him natural law isn’t about the laws
enacted by government or the interpreted law enforced by the courts, instead it is a way of
looking at things. 9 It includes the ideas like liberty, equality, morality, ethics, reason, good
conduct and etc.10
In jurisprudence, natural law refers to certain rules and principles that are believed to come
from a higher source i.e. not from any government or political power. Some thinkers say
these rules come from God, others say they come from nature, and some believe they come
from human reason. The common factor in all of the scholars is that they believe that
morality forms the most important part of natural law. Blackstone even said “Since God and
natural law coexist, the natural law is supreme above all other laws, and no law created by
humans can be enforceable if it conflicts with the rule of nature.”11

2.2. HERACLITUS (530-470 BCE)

Although Aristotle is considered as the founding father of Natural Law but the basis for
natural law was laid by Heraclitus.12 Heraclitus gave three essential characteristic features of
law of nature, which are:

 Destiny

 Order, and

 Reason

8
Dr. N.V. Paranjape, Studies in Jurisprudence and Legal Theory 139 (Central Law Agency 2015).
9
PHILIP SHUCHMAN, READINGS IN JURISPRUDENCE AND LEGAL PHILOSOPHY 660 (Little, Brown and Company
1979).
10
Id.
11
Ruchika Chaurasia And Tanya Sharma, Critical Analysis of Natural Law Theory and its Contribution to the
Justice System, 6 INTERNATIONAL JOURNAL OF LAW MANAGEMENT & HUMANITIES 2892, 2892 (2023).
12
Dr. V.D. Mahajan, Jurisprudence and Legal Theory 596 (
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According to him reason is the main part of natural law.

At the time of Heraclitus there was instability in Greece and it was felt that laws were mostly
made to benefit people in power, while ordinary people were always struggling.So it resulted
in the idea that there should be some fixed principles that could apply to everyone and these
principles, based on morality and fairness, would help bring peace and stability. That’s how
the idea of natural law began to grow.13

2.3. SOCRATES (470-399 BCE)

According to Socrates, there is a natural law just like a natural physical law. Man possesses
insight that allows him to see the goodness and badness of things and to understand the
eternal moral principles. Socrates explained that this insight through which a person see good
and bad things and appreciates moral values forms the basis for judging the law. 14 However
he never said that a law which is not in conformity to moral law should not be followed.

2.4. ARISTOTLE (384 – 322 BCE)

Aristotle widened the meaning and scope natural law and provided a more logical
interpretation of the natural law. He explained two ways by which man is a part of nature.
Firstly, he is a creation of God and secondly, he has the ability to reason which enables a man
to articulate his actions.15 He differentiated natural justice and legal justice. He considers that
natural justice is universal and based on human nature and reason, and legal justice, which is
created by human laws and may vary between societies. Aristotle argued that true laws must
align with natural justice to be considered morally right.16
Aristotle also defined natural law as ‘reason unaffected by desires’. By this he meant that
laws should be made and applied based on rational principles, not on the basis of personal
preferences or desire.17

13
Supra note 8 at 141.
14
Dr. Avatar Singh and Dr. Harpreet Kaur, Introduction to Jurisprudence 63 (LexisNexis 2013).
15
Supra note 8 at 142.
16
Stephen E. Gottlieb, Brian H. Bix, Timothy D. Lytton and Robin L. West, Jurisprudence Cases and Materials:
An Introduction to the Philosophy of Law and Its Applications 311 (Stevens and Sons Limited 1958).
17
George Duke, Aristotle and Natural Law, 82 THE REVIEW OF POLITICS 1, 5 (2020).
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 2.5. SAINT THOMAS AQUINAS (1225-1274)

Saint Thomas Aquinas is considered to have significant role in development of natural law.
He divided law into four types:
 Eternal Law: The God’s plan, immutable to changes.
 Natural Law: A part of eternal law that human beings can understand through reason.
 Divine Law: A branch of eternal law, refers to the moral laws revealed in sacred
texts, and interpreted by the Church.
 Human Law: Laws made by humans.

Aquinas considered human laws as the most unjust laws. He believed that the purpose of the
state was to provide basic needs to its people and ensure their safety and well-being.
Therefore, any law made by the state should be consistent to the natural law and any human
law which is not in conformity to the natural law will be unjust law. He gave the phrase “Lex
iniusta non est lex” which means that law which is unjust is not a law and therefore it should
not be followed.18
In summary, according to Aquinas, true law comes from God and can be known through
human reason. He believed that laws should promote the common good and reflect moral
principles.

2.6. NATURAL LAW AND INDIAN LEGAL SYSTEM

The Indian legal system is deeply rooted in the principles of equity, justice, good conscience,
and natural justice. The concept of ‘Dharma’ in Indian culture represented the idea of natural
law. Dharma was seen as a moral code guiding individuals on how to live a righteous and
orderly life.19 Many laws and principles which exist today reflects the idea of Natural Law
School, specially the fundamental rights in Indian Constitution Right to equality, right to
freedom and right to life reflects the idea of natural laws. The Universal Declaration Of
Human Rights of UN, adopted in 1948, signed by 193 countries is a perfect example of
recognizing natural law principles, though it is not binding but it aims to provide rights to all
human beings.
18
Srirupa Choudhury, A Study Of One Of The Most Fascinating And Ancient Theories Of Jurisprudence: The
Natural Law Theory By Thomas Aquinas, 6 INDIAN POLITICS & LAW REVIEW JOURNAL 1, 6 (2021).
19
Swastik Kumar, Concept of Law and Dharma in Indian Jurisprudence, 11 International Journal For Research
in Applied Science & Engineering Technology 76, 76 (2023).
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In India judges also played an important role in discussing natural law ideals in constitutional
interpretation:

2.6.1. The Kesavananda Case20

It is one of the best example to understand the judiciary’s attempt to give importance to
natural law principles. In this case the court said that some principles in the constitution are
essential and no one can take them away from the people, not even the parliament, which
aligns with the Natural law school.

2.6.2. The Kraipak Case21

In this landmark case of the SC of India highlighted one of the core principles of natural
justice, the legal maxim “nemo debet esse judex in propria causa,” which means “no one
should be a judge in their own case.” The Court emphasized that the purpose of natural
justice is to ensure fairness and prevent any miscarriage of justice. These principles are not
meant to replace existing laws but rather to enhance and support them. The Court also noted
that the scope of natural justice has been broadened over time to keep up with the needs of a
modern and evolving society.

2.6.3. The Sangram Singh Case

In the famous case of Sangram Singh Vs. Election Tribunal, Kotah and Ors. 22, the SC of India
held that India’s procedural laws are deeply rooted in the principles of natural justice. One of
the key aspects is that no person should be judged guilty without being given a fair chance to
be heard.
Looking at this and other similar cases, it’s clear that natural justice has been given
significant importance in the Indian judicial system. Today, all decision-making bodies,
including those handling administrative matters, are required to follow these principles to
ensure fairness and justice.

20
Kesavananda Bharati v. State of Kerala, AIR 1973 SC 1461.
21
A.K. Kraipak and Ors. vs. Union of India and Ors., MANU/SC/0427/1969.
22
Sangram Singh vs. Election Tribunal, Kotah and Ors., MANU/SC/0044/1955.
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 3. CHAPTER 3 - ANALYTICAL SCHOOL OF THOUGHT: MAJOR LEGAL SCHOLARS

3.1. WHAT IS ANALYTICAL SCHOOL OF THOUGHT ?

The exponents of natural law school believed that law should not be against morality but
many legal scholars were against this idea as they considered it as very unclear and uncertain
definition. The Analytical School of Law focuses on the law “as it is”, not how it should be.
This means that unlike natural law school, it studies law in its actual form, without mixing it
with morality, religion, or ethics.23 It is also known as imperative school and positive school.
24

3.2. JEREMY BENTHAM (1748-1832)

Jeremy Bentham was a key figure of the Analytical School of Law, he is considered to be the
founder of positivism in modern sense. Bentham is considered as a critic of natural law, he
called it ‘nothing but a phrase’. He even called the Blackstonian natural rights as ‘non-sense
upon stilts’. He divided law into two types:
 Expository Law – what the law actually is, without judging whether it’s good or bad.
 Censorial Law – what the law should be, focusing on how to improve it.

Bentham was also known for the Utilitarian Theory, which focuses on maximizing happiness
and reducing pain in society. He believed that laws should promote greatest happiness to
highest number of people. He supported a laissez-faire state, meaning the government should
interfere as little as possible, letting people enjoy freedom and make their own choices. He
believed that when people have freedom and happiness, society improves as a whole. 25 He
described happiness using factors like:
 Intensity
 Duration
 Certainty
 Nearness

23
Supra note 8 at 22.
24
Supra note 14 at 14
25
Aditi Pandey and Alliance University, Analytical School And Its Relevance In The Modern World, 3 INDIAN
JOURNAL OF INTEGRATED RESEARCH IN LAW 1, 3 (2023).
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  Fecundity
 Purity
 Extent

Bentham’s thoughts regarding the laws were more focused on the happiness of the people, he
neglected the idea of individual rights and that happiness of majority could also harm the
minorities and lead to their suppression, which is unjust. Also some restrictions are necessary
for protecting people and maintaining balance. Bentham also strongly opposed judge-made
law and supported the Imperative Theory, where law is a command of the sovereign and must
be followed. However, in present time judges do play an important role in law-making,
especially when the legislature is unable to address urgent or complex issues. The case of
Vishaka & Ors vs. State Of Rajasthan & Ors' 26, is a perfect example of it where the judge
made recommendations and a law aimed at preventing sexual harassment of women in the
workplace. This shows how judicial powers have evolved beyond Bentham’s view.

3.3. JOHN AUSTIN (1790-1859)

John Austin is considered as the father of the Analytical School. His most important
contribution is the Command Theory of Law, which he explained in his book “The Province
of Jurisprudence Determined”. He defined law as “A rule laid down for the guidance of an
intelligent being by another intelligent being with authority over him.”
In simple words, he believed that law is a command given by a sovereign, backed by
sanction. People follow these commands not because they’re moral or ethical, but because
they fear consequences. He divided law into two types:

 Law improperly so called – These are general moral rules like natural law or divine
law, which apply broadly but are vague and not legally enforceable. He did not
consider these as real laws.

 Law properly so called – These are clear, man-made laws created by a sovereign,
meant for specific people or groups, and legally enforceable. This includes divine law
and positive law. He considered these as real laws.

26
Vishaka & Ors v. State Of Rajasthan & Ors., AIR 1997 SC 3011.
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Bentham was more focused on happiness of the people but Austin was very clear in his
statements, according to him laws are laws as it is, it has nothing to do with goodness,
badness, happiness or morality and it should be separated in study of law. Any command of
the sovereign that is backed by a sanction, whether moral or immoral is a law and should be
followed by all.

3.4. H.L.A. HART (1907-1992)

Herbert Lionel Adolphus Hart was a British legal philosopher, he criticized Austin’s
command theory and based on the relationship between law and society he introduced his
own legal theory. According to him a legal system has two types of rules:
 Primary Rules: These are duty imposing rules, they tell the people what they should
and should not do.
 Secondary Rules: These are power-conferring rules, used by lawmakers, judges, and
officials to create, change, or interpret primary rules.
Hart believed that for proper functioning of a legal system, both the types of rules are
required.

In the times when Bentham and Austin’s concept of law, which ignored the idea of morality
in laws, was gaining popularity Hart also gave importance to morality though not directly.
According to him it is essential to have certain element of natural law in law and morality as
a logical necessity. Hart’s positive law implies that law and morality are supplementary and
complementary to each other.

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 4. CHAPTER 4 - HISTORICAL SCHOOL OF THOUGHT

4.1. WHAT IS HISTORICAL SCHOOL OF LAW ?

The Historical School is the thought that believes that the law is not created by the will of a
ruler or legislature, but it develops gradually over time through the customs, traditions,
culture, and practices of people. They believe that law is a product of history and it grows
with society like language and culture do. It considers customs and practices as the main
source of law.27

4.2. SAVIGNY (1779-1861)

Friedrich Karl Von Savigny is considered as the propounder of historical school. He

explained that law is not made but it grows i.e. law is a evolutionary process. This concept of
evolution was given by Savigny even before Darwin’s theory of evolution. He believed that
to truly understand law, we must see it as something deeply rooted in the history, culture, and
collective spirit of the people and he regarded this common will or spirit of the people as
Volksgeist. The word comes from two German terms, “Volks” meaning people and “Geist”
meaning spirit or common will. Therefore, Volksgeist refers to general and common
perception of the people or the spirit of the people. According to Savigny, laws aren’t just
made but they evolve naturally over time along with society like language.28

He argued that each nation’s legal system should reflect its own people’s traditions, customs,
and beliefs. Just as local languages may not make sense in foreign lands, local laws shouldn't
be applied universally either. He believed that a well-developed legal system should grow
from society’s long-standing customs and values.

4.3. HENRY MAINE (1822-1888)

He is one of the major legal scholar of historical school, he studied the legal systems of
various cultures, including India, and his research added depth and structure to the Historical
27
Supra note 14 at 24.
28
Shraddha Pandit, Historical School of Jurisprudence: An Intriguing Province, 6 INTERNATIONAL JOURNAL OF
LAW MANAGEMENT & HUMANITIES 712, 716 (2023).
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School. He proposed that development of law has four main stages:
 First Stage: King used to make laws, who was considered to be acting on God’s
behalf and therefore the laws made were divine laws.
 Second stage: The power of kings declined, and small groups like military rulers or
elites started gaining power and later the laws made by these small groups started
turning into customs.
 Third Stage: The original lawmakers lost the power, priests and minorities started to
handle the administration of the law and its understanding.
 Fourth Stage: It is the stage where the existing laws at that time were codified.

Unlike Savigny, who focused mainly on how customs shaped law and dismissed legislation,
Maine also acknowledged the value of legislation, legal fictions, and equity.29

29
Supra note 28 at 718.
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 5. CHAPTER 5 - SOCIOLOGICAL SCHOOL OF LAW

5.1. WHAT IS SOCIOLOGICAL SCHOOL OF LAW ?

The Sociological School of law considers law as a tool to regulate society and improve the
lives of people. This school doesn’t just focus on rules or customs but tries to understand how
law affects human behavior and social needs. According to this school laws should be made
for the benefit of the people. It believes that social welfare and justice should be the goal
behind making the laws.30

5.2. MONTESQUIEU (1689-1755)

French philosopher Montesquieu one of the major legal scholars to discusss the idea of
sociological school of law and his works provided base for other future legal scholars. He
believed that the social state of society had some influence on the legal system. He also
realised the importance of using history to understand how society is organized and
emphasized the importance of knowing and understand a society’s history before creating its
laws. Montesquieu believed that laws should reflect the society’s values, culture, and political
structure. He also said that laws should adapt to the needs and traditions of the people.31

5.3. ROSCOE POUND

Roscoe Pound, an American jurist, was a leading legal scholar in the sociological school of
law. He carried forward the view of Montesquieu and expanded the theory and made it
structured. He explained that laws are not just rules or regulations but it is a social tool which
reflects the values, needs and goals of society. He was of the view that legal systems should
not just follow the legal theories but their aim should be to serve the needs of the society.32
In summary, Roscoe Pound shifted the focus of law from theory to people and society. His
vision made law more human-centered, encouraging lawyers and judges to work not just with
rules but with empathy, understanding, and social responsibility.

30
Jyaditya Dogra, Understanding the Sociological School of Jurisprudence: Exploring the Intersection of Law
and Society, 4 NYAAYSHASTRA LAW REVIEW 1, 2 (2023).
31
Id at 6.
32
Id.
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 6. CHAPTER 6 – CONCLUSION

The Legal scholars have played an important role in shaping how we understand, apply, and
even question the law. Whether it is the idea of laws based on morality of natural law thinkers
like Aristotle and Aquinas, the practical reasoning of analytical scholars like Bentham and
Austin, the cultural insights of historical thinkers like Savigny, or the socially driven ideas of
the sociological school, they all have contributed in their own ways to building better legal
systems. Even today, their writings and interpretations help us see law not just as rules, but
provides different perspective to see it and understand its purpose, applicability and
consequences in depth.
The law theories developed by legal scholars also influences the judges in their interpretation
for example a judge highly influenced and agrees with the scholars belonging to analytical
school, will tend to apply the laws strictly as they are made but a judge who is inclined
towards natural law school will have a different interpretation towards the laws. For example
in Vishakha case the judges showed judicial activism and showed how courts can use natural
justice and universal moral principles to fill legal gaps and provide true justice. The case of
The Collector and Ors. Vs. Mutu Ramalinga Sathupathy and Ors. 33 reflects the idea of
historical and sociological school where the importance to customs was given and considered
them as a valid source of law. After that in another case of Rao Kishore Singh 34, it was held
that if there are new legal or social development than the customs contradicting with it will
not be valid. Through the critical analysis of Legal scholars their theoretical frameworks, and
scholarly writings also guide the lawmakers and also has high influence on judicial thinking
and decisions. Their work bridges the gap between the legal principles and their practical As
seen in landmark judgments and legislative reforms, the insights of legal scholars continue to
serve as a foundation for progressive legal development and the pursuit of justice in society.
The judgements and reasoning of judges in several case laws still reflect the ideas of legal
scholars. In conclusion, legal scholars give depth to the law. They help us not only follow it,
but also understand why it exists and how it can improve.

33
The Collector and Ors. vs. Mutu Ramalinga Sathupathy and Ors., MANU/WB/0038/1868.
34
Rao Kishore Singh vs. Gahenabai and Ors., MANU/PR/0098/1919.
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 7. BIBLIOGRAPHY

Books
1. Dr. N.V. Paranjape’s “Studies in Jurisprudence and Legal Theory”.
2. Dr. V.D. Mahajan’s “Jurisprudence and Legal Theory”.
3. Dr. Avatar Singh and Harpreet Kaur’s “Introduction to Jurisprudence”.

Websites
1. https://thelawbrigade.com/wp-content/uploads/2021/01/Srirupa-Choudhury-IPLRJ.pdf
2.https://ijirl.com/wp-content/uploads/2023/04/ANALYTICAL-SCHOOL-AND-ITS-
RELEVANCE-IN-THE-MODERN-WORLD.pdf
3. https://www.ijlmh.com/wp-content/uploads/Historical-School-of-Jurisprudence.pdf
4. https://core.ac.uk/download/581012782.pdf.
5.https://www.scconline.com/blog/post/2023/07/24/a-contemporary-analysis-of-the-
confluence-of-natural-law-and-natural-rights/
6. https://www.manupatra.com/roundup/323/Articles/due%20process%20of%20law.pdf
7.https://ijlmh.com/wp-content/uploads/Critical-Analysis-of-Natural-Law-Theory-and-its-
Contribution-to-the-Justice-System.pdf
8.https://ijirl.com/wp-content/uploads/2023/04/analytical-school-and-its-relevance-in-the-
modern-world.pdf
9. https://www.ijraset.com/best-journal/concept-of-law-and-dharma-in-indian-jurisprudence
10. https://smrj.nemsu.edu.ph/index.php/SMRJ/article/download/45/43
11. https://www.languageandlaw.eu/jll/article/view/156

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