Women Victims and Eradication of Secondary Victimization
–An Urgent need.
N. Amareswari. R.S. SPMVV, Tirupathi
[email protected], ph.8985664741.
Law is a Bottomless Pit, it is a cormorant, A Harpy that Devours Everything
Mans Strength is Woman, Mans Weakness is also a Woman and a Basic Source to every life and liberty of a man and woman without whom mans root causes will be wiped out completely and absolutely is a Woman. But depicting woman as a weaker sex is a serious crime, a perfect illogical issue and evil to be curbed immediately. The Supreme Source (Other than any Political or worldly authority) Creates man and woman equally and there are no deviations like Gender inequality as per the Devine laws. The Law of God ensured Equal and inalienable rights to all Human Beings without any discrimination either regard to religion, race region, caste sex or gender or any of them. As the Natural Law and its theories reflect a perpetual quest for absolute justice, the term justice has defined in the Preamble of the Supreme Law of India to ensure Social Justice, Political and Economic justice to all its citizens and persons without any discrimination. Honour killings are the result of the Caste System, different forms of domestic violence are the result of gender discrimination, and inefficient improper administration is the result of the violation of principles of natural justice. 72 years of Indian Independence crystal clearly showing the increased crime rate against women, rapes and hounour killings became the plight of woman victim more pitiable. Therefore, the victim women are taking recourse to the ‘easy way’ of escaping it all by putting an end to their lives[i]. Women Empowerment alone can establish Progressive Societies and establishment of egalitarian social order. Women Reservation Bill in addition to curb secondary victimization, it also makes the country as a Developed Country, is the main objective of this paper.
A law in its Majestic Egalitarianism forbids the rich as well as the poor to sleep under the bridges, to beg in the streets and to steel bread. Egalitarianism is a political doctrine that holds that all people should be treated as equals from Birth to Death. Egalitarianism is A Belief in human equality esp. with respect to social, political and economic rights and privileges and advocates the removal of inequality among people and of discrimination on the grounds of religion, race, GENDER or SEXUAL etc. The Democratic Doctrines that ALL PEOPLE ARE EQUAL AND DESERVE EQUAL RIGHTS AND OPPORTUNITIES is confronted with different religion, race, caste, SEX, place of birth and some other corrupted acts like Blunder violation of Basic Principles of Natural Justice, poverty, unemployment and the like, from which the women victim is subjected to First Form of Victimization at the Homes and Secondary form of victimization before the courts of law from the conjugal homes. If the crime rate against the lower strata of the community based on caste or religion or region is Genus, the increased crimes rate against women, girl child is Species. Total Substantive Laws holding the Democratic Principles and Democratic Way of Administration, with Liberty, Equality, Fraternity, Equity Principles so on Confronted and fully Confined with Procedural Delayed Justice and Denied Justice procedures and Accused Oriented Legal System Principles. In the crisis of Indian democracy, India has failed to nurture individual and collective capabilities. There has been far too little effort in public policy to create spaces where citizens interact freely and peacefully Jawaharlal Nehru, had seen Indian independence as an opportunity to build a “prosperous, democratic and progressive nation and to create social, economic and political institutions which will ensure justice and fullness of life to every man and woman”. B.R. Ambedkar, with legal acumen and a practical bent of mind, had defined democracy as a means to bring about a significant change in the living conditions of the depressed without resorting to bloodshed. These ambitious programmes and the hard work they would have entailed fell by the wayside in the practices of India’s political class and in the discourse of its intellectuals.
The Procedural Laws Specifically Stressed for the Protection and Rights of Accused by completely ignoring the Victim’s Single Right. Though the Victim, Victim Compensation schemes and laws inserted through criminal procedural code Amendment Act[ii] recently in 2009 the time taking for the immediate monetary relief even to the acid poured victims, the time taking for immediate relief is taking more than one year to take immediate relief for emergency treatment and all. As there is no focus on victim protection law even after 72 years of Indian Independence women’s plight is completely deteriorated. The Substances ie the real laws became like Paper Fleets, where as Procedural laws blurs with Delayed justice and other infrastructural lacunas furthered Equality against women became as a Legal Fiction, ultimately the effects of all these fall only on women and children esp girl child.
Article 14 of Supreme Law of India runs as follows; The State shall not deny to any person equality before the law or the equal protection of the laws within the territory of India[iii]. The 2 concepts involved in this Article 14 ‘equality before law’ and ‘equal protection of laws’ forbids class legislation and allows reasonable classification for the purpose of achieving specific ends[iv].
Article 15 of the Basic Law States about Prohibition of discrimination on grounds of Religion, Race, Caste, Sex or Place of Birth. No Citizen shall on grounds only of religion, race, caste, sex, place of birth or any of them be subject to any disability, liability, restriction or condition with regard to access to shops, public restaurants, hotels and places of public entertainment, or the use of wells, tanks, bathing Ghats, roads and places of public resort maintained wholly or partly out of State funds or dedicated to the use of general public. These prohibitions against discrimination, however, would not preclude the State from –
- Making special provision for women and children; the legal sphere commands not only the equality, but also special provisions and special considerations for the upliftment of women and children was ensured.
Indian reality is a paradox, India is remarkably unique, in the scene that it faces a dichotomy in nearly aspects of its vibrant democracy. Half of the humanity of women has had no opportunity so far to participate effectively in the Promotion of peace and in establishment of egalitarian society for all. It is the high time that women should be entrusted with this task as the ruling leaders[v]. One sided intelligence of men has planned for exploitation of humanity especially women and the destruction of the whole world. Being given the labels of Weaker Sex women subjected to the tyranny of the male and given a subordinate Place in the society But Women are the Harbinger of Peace, she is the Creator and Restorer of Peace[vi] Suppression Oppression or Violence against women is Derogatory to the Basic Structure of the Indian Constitution.
Violence against women including Domestic Violence which is taking in the form threats, Verbal abuse, battering, rape and murders of wives with suspicious and intoxicated behaviour or Dowry deaths and Hounour killings of even their own daughters, esp. the offences which are occurring within the 4 walls of the house it is too difficult to produce any proof and evidence coming to the family matters though there is a general presumption that whenever the victim stands before the court of law be presumed as a victim with immediate assistance became just like a paper fleet.
Even after exceeding 7decades of independence the Indian Parliament Contained Only 15%, of its women representatives, in the year 1951 it is 4.5%, in 1957 it is 4.45%, in 1962 it is 6.28, in 1967 it is 5.58%, in 1971 it is 5.41%, in 1977 it is 3.51, gradually it was increased to 12.15 in the Lok Shabha Elections in 2014. The Reservation for Women Contains very less for reasons unknown may be the Patriarchy paradoxical camouflage customs or traditions. The Dignified Life of Women Subjected to the tyranny of Patriarchy norms and male dominated chauvinistic camouflage statements.
Respect for Human Rights is the Basic Principle of Democracy. The women’s emancipation movement saw the light of the day in the 18 century with the laying of solid foundation of the democracy in the west. The birth of many women’s National and International Associations in well developed and developing countries bears testimony to her disillusion and active inspiration to her disillusion and active inspiration to get her due from their stingy and stinted masters. The Convention on the Elimination of All forms of Discrimination against Women, 1979 Universal Declaration of Human Rights 1945 and other international conventions, laid number of Human rights to abolish Gender violence. Women in India suffer from a variety of social and economic disabilities which prevent them from exercising their human rights and freedom in society. Child Marriage, especially of the female infant was common; widow marriage was prohibited. Even if she succeeded in escaping from the funeral pyre of her deceased husband where she was expected to be burnt alive, a divorce was generally looked down upon and her remarriage was socially disapproved. During the last few decades, a number of legislations have been passed with a view to ensuing equality of social, legal and economic Status and Opportunities for women. In practice, however, it seems that it has eluded women[vii].
At National Level The Dowry Prohibition Act,1961, the Sati Prevention Act, 1987, the Widow Re- marriages Act, the indecent representation prohibition act 1986, medical termination of pregnancy act 1971 and number of provisions under Cr.pc IPC provisions, Special enactment like Domestic Violence Act, women organizations, Women and child Welfare Committees at Each District level, Mahila Police Stations and Mahila Courts, but all these plenty of protective provisions and measures are not in a position to save the life of women victim mean, Indian Democracy had Collectively failed somewhere or altogether in ensuring equity and egalitarianism in society. The Supreme Law of India the Constitution States All are Equal Before Law, All have Equal right and obligations, Equal pay for Equal Work, Social Economic and Political Justice and Fraternity Principles among all individuals equally. We have to accord with the truth that the woman’s political and conjugal freedom alone can lift of its evils like rapes, kidnaps, eve teasing, dowry deaths, cruelty to women, wife beating molestations gang rapes custody rapes at police stations (Law maker is the Law Breaker here where in drastic and stringent reforms is the need of the hour for their removal from services). Domestic Violence within the 4 walls of the house, has peculiar forms wherein victim is again victimized Secondarily.
The National Commission For Women Was Constituted by the National Commission for women Act 1990 Act with an objective of women emancipation.
Judicial Approach in the Protection of Women.
Supreme Court Judgments that made India a better place for women. Women have always been considered as the weaker sections of the society as the victims. They have been shown merely as characters in men’s world. These judgments reflect the women’s strength, each of these judgments should be viewed as the tryst of a women to reassert her strength to redefine the patriarchal laws. Recently the SC abolished the norm of Talaq and legalized the Adultery where there is a free will between married woman and man, & almost all offences became Gender Neutral.
- Bodhisattwa Gautam (Vs.) Subha Chakravarty. AIR 1996 SC 1922, 1926:(1996) 1SCC 490.
Recognizing that women in India need to be liberated from unjust social political and economic suppression, the Supreme Court has declared that rape is a heinous crime against the women and amounts to violated of the Fundamental Rights guaranteed to a women under Article 21. The court has gone further and recognized the Right of a rape victim to claim compensation to from the offender for violation of constitution right to live with human dignity which is guaranteed to her by Article 21. The court held in this case “Rape” as an offence which is violative of the Fundamental Rights of a person guaranteed under Article 21 of the constitution
- Vishaka and others (vs) Rajasthan and others (1997) 6 SCC 241
Aszia modi says in her book, ten judgments that changed India “Judicial Activism reached its pinnacle in Vishaka (Vs.) State of Rajasthan. For the protection of women against Sexual Harassment at the working place, the bench comprising of Chief Justice Verma, Justice Sujatha Manohar, and Justice B.N kirpal issued guidelines to prevent Sexual Harassment against women in workplace. This verdict was superseded by the Sexual Harassment of women at workplace (prevention, prohibition & redressal) Act 2013. The Supreme Court has emphasized that it is the duty of the executive to fill the vacuum by Executive orders because it field is conterminous with that of the legislature and where there is inaction even by the executive, whatever the reason, the judiciary must step in, in exercise of its constitutional obligations under the aforesaid provisions to provide a solution till such time as the legislature acts to perform its role by enacting proper legislation to cover the field[viii].
“The claim in public law for compensation for unconstitutional deprivation of Fundamental Right to life and liberty, the protection of which is guaranteed under the constitution, is claim based on strict liability in addition to the claim in private law for damages for tortuous acts of public servants”
The court has emphasized that public law proceedings are a different purpose than the private law proceedings. The purpose of the former. “is not only to civilize public power but shall also to ensure the citizens they live under a legal system wherein their Rights and interests shall be protected and preserved”. On the other hand civil action for damages is a long drawn and a cumbersome judicial process
- People’s Union for Democratic Rights (Vs.) Union of India (1982) 3 SCC 235AIR 1982 SC 1473. 1490-91
Appropriate directions may also be given where a Fundamental Right such as the right one under Articles 17, 23 & 24 available against the private persons is violated (346 P).
- Revathi (Vs.) Union of India AIR 1988 SC 835: (1988) to SCC 72
The operation of Article 15(3) can be illustrated by the following few cases.
- Under Section 497 Indian Penal Code the offence of adultery can be committed by a male and not by a female. Who cannot even be punished as an abettor. As this provision makes a special provision for women, it is saved by Article 15(3). The Supreme Court was observed
- “Sex is sound a classification and although their can be no discrimination in general on that ground the Constitution itself provides for special provision in the case of women and children by clause(3) of Article 15. Article 14 & 15 thus read together validated last sentence of section 497, I.P.C, which prohibits the women from being punished as an abettor of the offence of adultery.”
- B.Muthamma(Vs.) Union of India, AIR 1979 SC1868 (1979) 4 SCC 260
A service rule requiring a female employee to obtain written permission of the Government, before solemnization of her marriage and denial of her right to be appointed on the ground that she was a married women are discriminatory. The Supreme Court has said -“We do not mean to universalize or dogmatize that men and women are equal in all occupations and all situations and do not exclude the need to pragmatise where the requirements of particular employment, the sensitivities of sex or the peculiarities of social sectors or the handicaps of either sex may compel selectivity. But save where the differentiation is demonstrable, the rule of equality must govern”.
- Chairman Railway Board (Vs.) Chandrimadas AIR 2000 SC 988: (2000) 2 SCC 465
Under Article 226 compensation has been awarded to a Bengla Deshi lady who was gang raped by railway employees at the Scaldah Station. “The applicability of the Universal Declaration of Human Rights and principles there of may have to be read, if need be, in to the domestic jurisprudence”. The benefit of equality before law and equal protection of law accrues to every person in India whether a citizen or not. As the Supreme Court has observed on this point:
“We are a country governed by rule of law. Our Constitution confers certain rights on every Human Being and certain other rights on citizens. Every person is entitle to equality before the law and the equal protection of the laws
- Vaddeboyina Tulasamma (vs) Vaddeboyina Shesha Reddy 1977 SCR (3) 261
The Supreme Court in this case highlighted the Hindu females Right to maintenance as a tangible Right against property which flows from spiritual relationship between the husband and wife. The bench comprising of Justice P.N.Bhagawathi, Justice A.C Gupta and Justice S.M Fazal Ali held that Section 14(1) of the Hindu Succession Act 1956 must be liberally construed in favour of the females so as to advance the object of the Act. This Section make female Hindu a full owner of the property instead of a limited owner.
- Marry Roy etc (vs) State of Kerala and others AIR 1986 SC 1011
Supreme Court in this case held that Christian women are entitled to have an equal share in their fathers property. This path breaking judgment sent shock waves throughout the country. Till then Christian women in kerala governed by the provisions under 1916 tranvencore- kochi Christian succession Act. Under this Act a Christian daughter can inherit only 1/4th of the share of the sons in her father’s property. The bench comprising of Chief Justice P.N. Bhagawathi, and Justice R.S. Patak, gave a liberal interpretation that benefited Christian women in kerala and brought them within the ambit of Indian Succession Act 1921, better still, the ruling granted equal Rights to Christian women with retrospective effect.
- Masilamani Mudaliar (Vs.) Idol of Sri Swamynathaswamy Thirukoil(1996) 8 SCC 525: AIR 1996 SC 1697
Section 14, Hindu Succession Act, 1956 converting the women’s limited ownership of property into full owner ship has been found in pursuance of Article 15(3)
- Raghubansan Saudagar Singh (Vs.) State of Punjab, AIR 1972 P&Hon’ble 117
A Government order making women in eligible for the post of a warden in men’s jail was upheld as the position of women would become awkward and hazardous while ensuring and maintaining the discipline over habitual offenders. (This decision does not fit well with the language and intent of Article 15(3).
The language of clause (3) is in absolute terms and does not appear to restrict in any way the nature of ambit of special provisions which the state may make for women or children or both. The Supreme Court has held that the special provision referred to in clause(3) need not be restricted to measures which are beneficial in the strict sense. However special provision for women means “that no less favourable treatment is to be given women on gender based criterion which would favour the opposite sex and women will not be deliberately selected for less favourable treatment because of their sex”
- Sareetha (Vs) Venkata Subbaiah, AIR 1983 A.P. 356
Sec 9 providing for the relief of Restitution of conjugal rights is unconstitutional as it offends against Article. 21 of the constitution (Right to liberty which includes right to privacy) and Article.14 of the constitution (Right to equality).
- Delhi Domestic Working women’s Forum (vs) Union of India 1995 SCJ (1) 94
National Commission for Women Act 1990, Sec 10 w.e.f. 31-1-92 as per Notification No S.O. 99 (E) dt. 31-1-92 Functions of the Act – Third respondent to evolve such scheme as to wipe out the tears of the unfortunate victims of rape- Such Scheme to be prepared within 6 months – Thereupon Union of India would examine the same and to take necessary steps for the implementation of the scheme at the earliest- Rape Victim.
Supreme Court in Number of Cases In Githa Hariharan (Vs.) Reserve Bank of India, AIR 1999 SC 1449, 2 SCC 228. Interpreted Sec 6(a) Hindu Minority and Guardianship Act, 1956, as well as 19(b) of Guardians and wards Act, to mean that when the father is not in actual charge of the affairs of the minor either because of his indifference, or because of an agreement (oral or written) between him and the minor’s mother, and the minor is in the exclusive care and custody of the mother or the father for any other reason is unable to take care of the minor because of his physical or mental incapacity, the mother can act as the natural guardian of the minor and all her actions would be valid even during the life time of the father, who would be deemed to be ‘absent’ for the purpose of Sec, 6(a) of the HMG Act and S. 19(b) of the GW Act.
A stream of judicial thoughts in Maneka Gandhi Case, AIR 1978 SC 597. Writ petn. No 231 A Stream of judicial thoughts by Seven Judge Bench included number of other rights under the Right to personal liberty, Learned Judge Stressed the relationship of Rights to travel to the Right to know, Right to converse with others, Right to consult with them, to observe social physical political and other Phenomenon’s[ix] abroad as well as at home gives meaning and substance to freedom of expression and press. A woman who is major has the right to go anywhere and live with anyone who likes without getting married. “This may be regarded immoral by society but it is not illegal. There is a difference between Law and morality”.
Supreme Court agreed with the premise that ‘gender equality’ is one of the basic Basic Principles of the Constitution. If the word ‘after’ in Section 6(a) were to be interpreted to mean that the mother was disqualified to act as the guardian of the minor during the father’s lifetime, and that she could act as such only after his death, then the same would definitely run counter to the basic requirement of Constitutional mandate as it would lead to differentiation between male and female. But the provision in question could be so interpreted as to make it compatible with Article 14. Accordingly, the court interpreted Section 6 so as to mean that the mother could act as the natural guardian of the minor during the father’s life time. If the father was not in actual charge of the affairs of the minor. Similar interpretation was given to Section 19(b) of the Guardians and wards Act 1980.
12.Refence may also be made to Sarala Mudgla and Lilly thomos.
The Supreme Court has used the directive principles contained in Article 39(a) and 39(d) and 39(e) to confer economic empowerment on women.
- Danial Latify (Vs.) Union of India AIR 2001 Sc 3958:(2001) 7 SCC 740.
The validity of the Muslim women (protection of Rights and Divorce) Act, 1986, was challenged on the ground that the Act, when compared with S.125, Cr P.C., is discriminatory against muslim divorce women. But the Supreme Court negative the contention. The court has ruled that the purpose of both laws is the same viz., to meet a situation where a divorced women is likely to be led into destitution and vagrancy.
Suggestions and Conclusion for the attainment of Egalitarian Society:
- Equality, Welfare, Protection with all basic human rights throughout the life and finally Egalitarian Social order can be achieved only with the Women Empowerment. As per Article. 15(3) Women entitled for Every protection including with favorable and positive discriminatory laws. A Long Pending Women Reservation Bill has to be passed with complete assent at the Parliament not with 33% reservations but with More than 50% as per Article. 15(3) of the Fundamental Law of the Land to emancipate women from oppressive scale of social values and to ensure greater value to the creator and restorer of Peace in the society. . Women need equal political status, Legal, Social and Economic Status at every walk of her in each and every Government departments. At present 15% Women Representation be increased to 50% with Equity and Equality and Just Principles. The Basic Structural Principles of the Indian Constitution i.e. Liberty Equality, Fraternity, Justice, Which are meant for achievement of Democratic norms and Socialistic Law and order will be ensured only with the women who is the Creator and Restorer of Peace in the World. Sustainable development of the country Possible with Collective Outlook from Women Organizations with support of the Governement to attain equality at every walk of life is an urgent need.
- Gender Sensitization Programmes has to be conducted at Local, District, State and National levels for the Emancipation of women from all traditional disabilities and from oppressive scale of social values. It is necessary to see that in all matters of health and education… that the both Girl and Boy are treated alike and free and compulsory education up to 14 years by creating awareness about all their Rights esp. regard to their Legal rights. A beginning is thus made in very home in early childhood of men and women, unless resisting violence is not possible, the attitude of women should also be changed by enlightening about their Rights and Duties by keeping aside all male dominated camouflage statements. Drastic awareness about their rights and duties to perform all duties which is the essence of law and to seek assistance from court of for implementation of Every Legal Right.
- The essence of Law is Performance of Primary and Secondary Duties: Duty Violation may occur in So many form, by intoxicated State of mind of a husband against his wife, or Personal, Official, Pecuniary Biases at the Office Levels so on where in the first case the life itself is kept in endangered position and in Second case brutal inhuman & official white collar crime or Official Law breaking system continuing from eras, and centuries. The misuse of power leading to Complete disorder, uproars in the society. Stringent Laws with rigorous imprisonment and Permanent Removal from the Positions to such Persons (Law maker should not be the law breaker) may ensure the Decent Administration Ultimately We may Join in the Progressive Lines of Progressed Nations.
- The value based education system in addition to sociological scientific and technical education, Every Child must be imparted with moral and ethical values. Free and Compulsory education is must for each and every child by completely banishing the child labour system, creating a right foundation which built bright future to Every child. Truth Beauty and honesty values be laid as the basis for each and every child. Heinous Crimes like sexual assaults against even at infancy age, foeticide, infanticide, and all issues which are facing by women and girl from the women to tomb, its Causes and Drastic Effects on the Happiness of the family has to be regarded and set right only through value based education system. The Substantive qualitative change, Possible only with Values and Value based education System. Objective Oriented Educational System has to be inculcated from Primary level to PG Level, the ultimate object be the Peace Progress and maintenance of law and order for egalitarian society.
- A complete banishment on belt shops by the govt. solves more than half of the women issues which is the main cause for the breakdown of the families. Committing rapes in drunken State, killing of wife, or their own children and Parents for properties in the drunken State, different forms of Domestic Violence in drunken State all these leading to the single parenting atmosphere which depriving the child to live in a proper family environment, which ultimately leading to the delinquency among children and creating some other new problems. Belt shops are not good for the healthy society, it is the binding duty upon the govt to prepare plans schemes and steps for welfare of the society. A Right to lead healthy life is basic right be sustained immediately.
- Avoid Secondary victimization of women and children- a women or child subject to assault, sexual or otherwise, may face more humiliation during interrogation or trial, rather than at the time of offence. It is perhaps due lack of sensitivity on such issues among the investigating agencies that often leaves the victims embarrassed. At a workshop on ‘ Crime against women and Children’ organized by police and judicial department at SPMVV Campus the judge advised the investigating agencies to observe restraint and exhibit sensitivity towards cases involving women and children as the humiliations caused during the interrogation is much more, and amounts to secondary victimization of the victim. Tukaram and another (Vs.) State of Maharashtra. AIR 1979 SC 185[x].
- Like some of special enactments, a special form of victim compensation laws should be make which is already existed in some developed countries. Instead of spending Crores of amount on the war and warfare, should be converted to the free and compulsory education to all and the also the amount which is spending on the accused and convicted should be transferred to the innocent victims of the same case. The culprits and convicted must possess only the duties ie duties to serve the victim in their hands.
- Preventive measures have to be taken than the curative steps. Already existing Stringent laws like Nirbhaya enactment, immediate reliefs under some other enactments have to be implemented immediately and the transparency and accountability on the part of all administrative authorities for immediate action with an objective of eradication of secondary victimization esp. to abolish crimes against women and children, the Objectives intended to achieve by the enactment to maintain equilibrium has to be accurately carefully implemented by the law enforcing machinery. The end of law is to ensure peace and order in the society and to see justice should reach to all, has to be implemented by the State effectively.
- Victim Oriented System, Effective Victim Protection laws with Effective Mechanism for immediate relief without any technical procedural delays with establishment of Specific Compensatory Boards be created.
- The extraneous considerations like Customs Usages Practices which furthering suppression of women has to be effectively eradicated. The idea of justice e Political Justice social justice and economic justice in the cultural domain has to be ensured equitably. Justice is not a cloistered virtue, she must be allowed to suffer the scrutiny and respectful even though outspoken comments of ordinary men. A quest for Accountability at every level and at every department is sine qua non for peaceful and better administration. Equal status to the women and the girl child at homes, at schools, at working places, and all other places, protecting and enforcing all Human Rights against half of the world will establish PEACEFUL, PROGRESSIVE AND EGALITARIAN WORLD. Women Empowerment alone Can Set right the Corrupted or Disordered Society into Egalitarian Society, where in Every body is Equal without any kind of discriminations. Even in the digitalized era I hope from despire women and girl children be protected from Patriarchy norms by ensuring Even Life and Liberty, which are inalienable and which is the heart and soul of the supreme law of our Indian Constitution.
[i] CRIMES AGAISNTY WOMEN – By. J.P. ATRAY. Introductory Part.
[ii] Inserted by Cr.P.C(Amndt.) Act, 2008 (Act No. 5 of 2009) w.e.f. 31-12-2009, vide not, No. S.O. 3313(E), dt. 30-12-2009.
[iii] Indian Constitutional Law – Prof.M.P.Jain 5th edition 2008. P.856.
[iv] Ibid – Page – 857
[v] Mr. A.B.Patel in his Paper “Women’s Leadership in Peace Education” P.2. of “ Women Education and Peace” By Dr.Suryanath Prasad, Dr. Smt. Suman Sukla.
[vi] Ibid – Page 12
[vii] Women’s Rights : Myth and Reality – SACHCHIDANANDA , RAMESH P. SINHA.. p. 28
[viii] INDIAN CONSTITUTIONAL LAW – M.P. Jain. Fifth Edition P 265
[ix] AIR 1978. Page 642.
[x] CRIMINAL LAW By P.S. ATCHUTHRN PILLAI. Page.491.