This section contains the nature of the case and procedural background.

Subramaniam (D) was wounded by security forces. They searched him and discovered 20 rounds of ammunition on him. He was tried on a charge of being in possession of ammunition without lawful authority. His defense was that he had been captured by terrorists and was acting under duress. At trial, D attempted to present evidence of certain things the terrorists had said to him. The trial judge ruled the statements inadmissible. D was convicted and appealed.

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