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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