1. Explain each incriminating evidence specifically and clearly.

2. Ensure that your narrative in S.313 is consistent with your defence in the case (as discernible from bail applications, cross examination of PWs, discharge application, etc).

3. Traditional/generic responses such as “This is false case” or “This is a matter of record. I am innocent.” simply don’t work!

4. Help the Court frame better questions. Specific questions and specific answers.

5. Take this as an opportunity to help the Court understand the case better & lay out your narrative/story. Humanise your client. Make the Court see the person & humanity in her and not just “Accused No. XXX”. (A number on the file!).