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CRITICAL ANALYSIS OF NEED FOR GENDER NEUTRAL LAWS IN INDIA
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CRITICAL
ANALYSIS OF NEED FOR GENDER NEUTRAL LAWS IN INDIA
AUTHORED BY - HIMANSHU KUMAR
& DR. ANNIRUDH VASHISHTHA
CHAPTER- 1
INTRODUCTION
1.1. OVERVIEW
The Indian
Penal Code 1860 was drafted
in the colonial era with a view to penalise
certain conducts or activities which were both socially
and morally wrong and illegal and hence were included in the term 'offence'. Although,
most of the provisions under the Code punish
both men and women for an offence committed by them, there are certain offences which are deemed and
presumed to be committed by a man upon a woman.
Considering the time when the penal code was drafted,
it seems justifiable to presume that certain offences
can be committed by only men upon
women. However, taking into account that the code is now more than 150 years old and the society has drastically changed
over the period
especially in the last 2-3 decades. Hence,
a change in the law of the land and a change
in the mindset of the society is the need of the hour.
However, the society
has always expected
masculinity from men and the society's definition of being a 'man'
has in many cases curbed the reporting
of offences against men especially sexual offences. Social stigmas
and societal expectations more often than not results
in many of the offences
being not reported
and 'compromise' being made between the accused and the victim, victim
being a man or a woman. Through
various judgments recently, the Supreme Court has tried to make the definition of offences under the umbrella
of gender- neutrality.
However, the reach and interpretation of judgments of the courts has always been limited by lack of education
among the masses.
The Indian law denies to acknowledge that men can be causalities of sexual brutality.
Noticeable instance of this is The Indian
Penal Code. Section
354 of the Penal Code which deals with assault or criminal force to
outrage modesty, though
include men and women both as perpetrators, only provides woman as a victim and entirely
denies men or the transgender equal rights. "The IPC
Sections 354A, 354B, 354C and 354D, dealing
with sexual harassment, disrobing, stalking and voyeurism,
explicitly refer to men as the perpetrators of these crimes and women as victims".
Also, Section 366 dealing with kidnapping, abduction, etc. of a woman
to compel her marriage against her will is only gender specific and fails to acknowledge that even men can be kidnapped or abducted or compelled to marry against
their wish wherein
perpetrator could be a
man or a woman or both. The only remedy available to a man under such a situation
would be nullification of marriage through
a civil court and no criminal remedy is available
to him.
Sections 366A and 366B which were legislated with the intention to curb illegal procuration or importation of minors, either
within India or from foreign, the said sections fails
to take into account procuration and importation of minor boys.
Similarly, Section 375, IPC, defines
rape and legal provisions against
it and Section 376 containing its punishment thereof,
has no mention of rapes
against men. Not only an offence against a person's body to whom the perpetrator may be known or not, the Penal Code also contains
such discrimination under Chapters XX and XXA related to offences relating to marriage. Section
493 which deals with cohabitation deceitfully caused by a man
to the any woman who is not lawfully
married to him, under a belief that she is lawfully married to him or have sexual intercourse with him under that belief.
However, the section does
not deal with a situation where such an offence is committed by a woman towards a man. Section 498 which deal with enticing or taking away or detaining a
married woman with criminal intent is
although gender-neutral with regards to the perpetrator but considers
only women as victims and does not include men as victims.
It fails to acknowledge that in any case a woman can induce or entice or take away a man with criminal
intent to have illicit intercourse with her or any other person. Similarly, Section 498-A contained in Chapter XX- A which was
inserted in the Indian Penal Code through
amendment of 1983, provides that if 'husband'
or 'relative of the husband'
subjects a woman to cruelty
shall be punished
as per the punishment prescribed.
The said section
acknowledges the perpetrator or accused could be any person be it male or female,
of the family of the husband, however,
the victim of such an offence can only committed against the wife or the woman being wife of a person.
At the very outset of this dissertation, the Author would like to clarify and declare that the intention
of the Author is not undermine the experiences
of women subjected to rape and other sexual offences and discrimination and the Author is also aware of the fact that many of such offences
are not even reported to police or other public law enforcement authorities due to societal
pressures and interference of family members
due to common notion of "what will the society
think" largely prevalent
in India. However,
as society matures,
we must develop
empathy for all alike, be it man, woman or recently
legally recognised third gender and this includes male and transgender assault
and harassment victims.
While the actuality that men can be sexually
abused may delight
a few, or appear to be
inconsequential to the majority ,this detachment towards sexual violence against men is a noticeable example of
how genuine this issue is.
Unfortunately, absence of legal provisions and
social acknowledgment of men being raped by men or women, or men being forced to bear any type of sexual violence,
is a reinforcement of the orthodox and patriarchal gender stereotypes.
Popular culture doesn't burden from portraying a men less 'manly' or 'masculine' image of a male who refuses to simply accept
female sexual advances.
The concept of 'consent' from a man's side is sometimes
considered, and is assumed to be a positive 'given'. A man being compelled into sexual activities is frequently depicted
as a positive encounter for them, asserting their 'masculinity'.
Along these lines, most men wouldn't
have the option to perceive
an action as abusive or without consent.
A majority of the Indian society is disinclined to even the thought of homosexuality, including its acceptance
in lifestyle.
CHAPTER – 2
CURRENT ENTITIES
WITHIN INDIAN LAWS
Sexual
offenses against women are among the most horrifying crimes against
human decency and conscience, and they are heavily penalized in every nation. Even though
women are susceptible to all kinds of crimes, some crimes, like rape, molestation, sexual harassment,
and immoral trafficking, are unique to women. Of them, rape is arguably the most harmful and a grave violation of
women's dignity.
The intentional use of sexual approaches as a tool to assert dominance over another person and to cause them pain or shame is known as sexual harassment. Any act—physical or psychological—that targets
a person's sexuality
or is performed through sexual methods is considered sexual harassment. Sexual assault has been really harsh.
The penal laws in India, primarily the Indian Penal Code of 1860, provides for such acts and their
respective punishments which are not only considered to be committed
against a particular individual, but are considered to be committed against the entire
society and hence such
acts must be punished accordingly. The penal code contains such offences
under various chapters
which might be against an individual, a group or class of individual, property or State, etc.
However, the discussion in this Dissertation will be restricted to the relevant
Chapters and provisions. The penal laws in India though recognises and punishes certain
acts committed on a woman in various
situations under Chapter
XVI of the Penal Code. The said Chapter can be classified as following:-
2.1.
Offences involving
Criminal Force and Assault
Under
Chapter XVI the offences involving criminal force and assault are specifically provided
under sections 354, 354-A, 354-B,
354-C and 354-D. For convenience, the sections are reproduced below:-
354. Assault
or criminal violence
against a woman intended to shock her modesty. - Whoever attacks
a woman or uses criminal
force against her, intending
to outrage or knowing that he can outrage her
modesty, [is punished
by imprisonment for each category
which will not be less than one year but which can
extend up to five years and must; shall also be fined ].
(354-A. Sexual harassment and punishment for sexual harassment-
(1) ) A person who commits any of the following
acts –
(i)
physical contact
and advances involving
unwanted and explicit
sexual overtures or
(?i) a demand or requesting
for sexual favors
(iii)
showing pornography against the will of a woman or
(iv)
making sexually
coloured remarks
(2)
Any man who has an offense referred to in subsection (1)(i) or (ii) or (i) shall be punished with rigorous imprisonment which may extend to three years or with fine or with both.
(3)
A man who commits
an offense referred
to in clause (iv) of subsection
(1) (iv) shall be punished with imprisonment which may extend to may extend to one year, or with fine, or with both.
354-B. Assaulting a woman or using criminal
force with intent to disrobe
- Any man who attacks
a woman or uses criminal
force against her or instigates such an act with the intention of undressing or exposing her, shall be punished by imprisonment. a term which must be at least three years but may extend up to seven years and shall also be punished with a fine.
354-C. Voyeurism - Any man who looks at or photographs a woman in private life in circumstances in which he would ordinarily expect that he would not be observed
by the criminal or by any other
person at the order of the
criminal, or who distributes such a photograph. sentenced to prison on first conviction for a term of office
which must not be less than one year
but which may extend up to three years and shall also be punished
with a fine and on a second or subsequent conviction with imprisonment for a term which must not be less
than three years but which may extend
up to seven years and also with a fine.
354-D. Stalking-
(1)Any man who follows a woman and contacts her or attempts to contact
her to repeatedly promote personal
contact despite her apparent indifference
(2)? monitors a woman's use of the Internet, e-mail or other electronic communications, commits the crime of stalking Provided that such behavior
does not constitute stalking, if the man engaged in it shows that-
1.
it was done for the prevention or detection of crimes, and the State
believed in the prevention and detection of crimes for the
accused; or
2.
It is made under any law or to comply with a condition
or requirement imposed by any person under any law; or
3.
in the given circumstances, such behavior was reasonable and justified.
2.
A person
convicted of the crime of stalking must be punished
with imprisonment for up to three years, and will also be punished with fine; and shall be punished by imprisonment on a second
or subsequent conviction of either description for a term which may extend to five years, and shall also be liable to fine On the other hand, the Penal Code in India does not contain any provision
for protection or punishment of any
form of harassment, be it sexual or otherwise, towards men or transgender. On perusal of Sec. 354 as above
stated, the essential ingredients of section 354 can be culled out as:-
1.
That the assault must be on a woman;
2.
That the accused must have used criminal force on her;
3.
That the criminal force must have been used on the woman intending thereby to outrage
her modesty.
It is clear from above that the offence under section 354 can be committed
only when an assault or criminal force is asserted
to a woman with the intent to
outrage her modesty. Under this section,
a perpetrator could be any person, i.e., a man or even a woman as the section uses the term 'whoever' rather
than 'a man who assaults
of uses criminal force..' and therefore, anyone who commits
the offence under the said section is liable to be punished
as per the punishment provided.
However, it is to be noted that the offence
under section 354 can be committed
only against a woman and the Penal Code makes no reference or provides
any situation or prescribes punishment in a case where any
assault or criminal force is used, either by a
man or a woman towards another man or transgender with the intent of outraging
his modesty.
Whereas, on perusal
of Section 354-A
following acts constitutes the offence of Sexual
Harassment as provided in the Act-
(i)
Physical contact
and advances involving
unwelcome and explicit
sexual overtures; or
(ii)
A demand
or request for sexual favours; or
(iii)
Showing pornography against the will of a woman; or
(iv)
Making sexually
coloured remarks.
Under
Section 354-B, an assault or use of criminal force to any woman or abetment
of such act with the intention of disrobing or such compulsion constitutes an offence
under the said section.
Under Section 354-C, watching or capturing the image of a woman engaged in a private
act where she would usually
expect privacy or any act not of a kind ordinarily done in public;
or dissemination or circulation of such image
either by the perpetrator or any other person on his behalf is an offence.
Under Section 354-D, following acts constitutes the offence of Stalking
as provided in the Act-
(i)
Following
a woman and contact, or attempts to contact such woman to foster personal interaction repeatedly despite a clear indication of disinterest by such woman; or
(ii)
Monitoring the use by a woman of the internet, email
or any other form of electronic communication.
However, following
exceptions are provided
in the section itself. The following acts do not constitute the offence of stalking as provided in the abovementioned section –
1.
It was pursued for the purpose
of preventing or detecting crime and the man accused of stalking had
been entrusted with the
responsibility of prevention and detection of crime by the State; or
2.
It was pursued under any law or to comply with any condition
or requirement imposed
by any person under any law; or
3.
In
the particular circumstances such conduct was reasonable and justified.
2.2.
Sexual offences
The
most grievous sexual offences against women, that is, of rape and its other aggravated forms are given under the head "Of
Sexual Offences" in Chapter XVI under sections
375 to 376-E. These sections
have been amended
from time to time to include the variety of acts through which these offences are
committed in today's ever changing dynamic
society, enhancing its scope and ambit and the ambit was recently
broadened vide amendment
of 2018.
The said sections provides as follows:-
375. Rape —A man is said to commit "rape" if he—
(a)
penetrates his penis, to any extent,
into the vagina,
mouth, urethra or anus of a woman or makes her to do so with him or any other person; or
b)
inserts,
to any extent, any object or a part of the body, not being the penis, into the vagina,
the urethra or anus of a
women or makes her to do so with him
or any other person ;or
c)
manipulates any part of the body ofa woman so as to
cause peneration into the vagina, urethra, anus or any part of body of such woman or makes her to do
so with him or any other person; or
(d) applies his mouth to the vagina,
anus, urethra of a woman or makes her to do so with him or any other person.
The definition of rape as provided under Section 375 and its punishment thereof
under Section 376 is self explanatory and therefore
all the ingredients need not be explained individually. Such vast ambit of a penal provision is very much appreciable since it enables
to cover and punish an offence both in present
and in future and harshest
punishment should be implicated upon the perpetrator because an offence
like rape is not only against the body but also affects the soul of the victim. However,
the section only suffers from one infirmity, i.e., the offence
of rape can only be committed by a man against a woman. It squarely excludes
a situation where a man could be a victim
of forced sexual
act by a woman. It also excludes
the situation where a transgender is involved either
as a perpetrator or as a victim. As of now, both of these
situations are covered under Sec. 377, i.e., unnatural offences.
In India, various
studies have documented the sexual and physical violence
against transgender persons.
The last concrete step towards
making rape a gender neutral
crime was by the Justice
Verma Committee in 2013. "However, even The Verma Committee proposed
that the perpetrator in rape be recognised in law as 'male'", writes Albeena
Shakeel in EPW, "and the victim be "persons" (including females, males, transgenders). This was an acceptable
proposal in law. However, the government's 'Criminal Law (Amendment) Ordinance, 2013' is distinguished by its thrust on viewing women as potential rapists.
It is time we stop trivializing sexual abuse against
men. We need to start reflecting on the stereotypes that have led to a benighted approach towards sexual violence against
half the population of our country.
The Indian law is based on the belief that a victim of rape can only be a woman. This arises from the assumption
that rape is an act of sex alone to satisfy the sexual desire of the perpetrator. The argument against complete gender neutrality is
that it is "physically" impossible
for women to rape men. As Brownmiller argued in Against Our Will that only men can coerce women into having sex. Rape's critical
function is nothing
more or less than a conscious process
of intimidation by which all
men keep all women in a state of fear. ' This
argument presumes that men are stronger, therefore they can commit rape and women cannot commit rape because
it is physically and biologically impossible for a woman to commit rape.
In the Criminal Law (Amendment) Ordinance, 2013, the crimes of rape and sexual harassment were gender neutral.
The term "rape" was removed entirely and was substituted with "sexual
assault". However, strong objections were raised by women's groups
and the Act ended up making the offences of rape and sexual harassment gender specific. Women can no longer rape or even sexually harass
men. Thus only male-on-female
rape is acknowledged and clearly defined under law in India.
eath or resulting in persistent vegetative state of victim- Whoever,
commits an offence
punishable under sub-section (1) or sub-section
(2)
of
section 376 and in the course of such commission inflicts an injury which causes
the death of the woman
or causes the woman to be in a persistent vegetative state, shall be punished
with rigorous imprisonment for a term which shall not
be less than twenty years, but which may extend to imprisonment for life, which shall mean imprisonment
for the remainder of that person's natural life, or with death.
376AB. Punishment for rape on woman under twelve years of age.- Whoever,
commits rape on a woman under twelve years of age shall be
punished with rigorous imprisonment for a term which shall not be less than twenty
years, but which
may extend to imprisonment for life,
which shall mean imprisonment for the remainder of that person's natural life, and with fine or with death
Provided that such fine shall be just and reasonable to meet the medical expenses
and rehabilitation of the victim
Provided further that any fine imposed under this section shall be paid to the victim.
376B. Sexual intercourse by husband upon his wife during separation.
—Whoever
has sexual intercourse with his own wife, who is living separately, whether under a decree of separation or otherwise,
without her consent, shall be
punished with imprisonment of either description for a term which shall not be less than two years but which may extend
to seven years, and shall also be liable to fine.
Explanation.—In this section,
"sexual intercourse" shall mean any of the acts mentioned
in clauses (a) to (d) of section 375.
376C. Sexual intercourse by a person
in authority.—Whoever, being
—
(a)
in a position of authority or in a fiduciary relationship; or
(b)
a public servant; or
(c)
superintendent
or manager of a jail, remand home or other place of custody established by or under any law for the time being in force, or a women's or children's institution; or
(d)
on
the management of a hospital or being on the staff of a hospital, abuses such position or fiduciary
relationship to induce or seduce any woman either
in his custody or under his charge
or present in the premises to have sexual intercourse with
him, such sexual intercourse not
amounting to the offence of rape, shall be punished with rigorous imprisonment of either description for a
term which shall not be less than
five years, but which may extend to ten years, and shall also be liable to fine.
376D. Gang rape.-Where a woman is raped by one or more persons constituting a group or acting in
furtherance of a common intention, each of those persons
shall be deemed
to have committed the offence of rape and shall be punished with
rigorous imprisonment for a term which shall not be less than twenty years, but which may extend
to life which shall mean
imprisonment for the remainder of that person's natural life, and with fine:
Provided that such fine shall be just and reasonable to meet the medical expenses
and rehabilitation of the victim:
Provided further that any fine imposed under this section shall be paid to the victim.
Sections 376A, 376B, 376C and 376D were inserted in the Indian
Penal Code through Amendment in the year 198324 after the a highly criticised judgment of Supreme
Court in 1979 which is commonly known as Mathura
Rape Case'S in which two police officers
were acquitted of allegation
of rape as the court observed that the victim
raised no alarm; and also that there were no visible marks of injury on her body thereby suggesting no struggle
and therefore no rape. Out of the
above stated four sections, Section 376A and 376D are considered aggravated forms of rape as these offences
have the excessive element of force
or assault as compared to offence of rape under Section 376 alone, which is evident from reading the plain language
of the sections. On the other hand, the offence under Section 376B and
376C particularly involves the
element of 'trust' between the perpetrator and
the victim. For example, under Section 376B the relation between the man and the woman is of husband
and wife living
separately and under Section 376C the man is in a position
of authority as specified in the four clauses of the said section.
Also, Section 376AB was introduced recently through the amendment in the year 20182 to protect the sexual
exploitation of a woman under the age of 12 years. It is to be noted here that as per the POCSO Act and the JJ Act, which are primarily
Gender Neutral Legislations, any person below the age of 18 years is to be considered as a child, therefore through
that interpretation this section provides
protection against sexual
exploitation of a girl child and does not include
within its ambit the sexual
exploitation of a boy under the age of 12 years, which would ultimately
fall under the POCSO Act.
376DA. Punishment for gang rape on woman under sixteen
years of age - Where a woman under sixteen years
of age is raped by one or more persons
constituting a group or acting in furtherance of a common intention, each of those persons shall be deemed to have committed the offence of rape and shall be punished with imprisonment for life, which shall mean imprisonment for the remainder of that person's natural life, and with fine:
Provided that such fine shall be just and reasonable to meet the medical expenses
and rehabilitation of the victim
Provided further that any fine imposed under this section shall be paid to the victim.
CHAPTER – 3 INTERNATIONAL PERSPECTIVE
Laws in Other Countries
In
many countries other than India, gender neutral laws have already been enacted, mostly
with respect of offences like rape. As much as
63 countries in the world have gender-neutral rape laws namely United Kingdom,
United States of America, Republic
of Ireland, Philippines, etc. to name a few.
1. United States of America
The FBI's Uniform Crime Report in 2013 redefined
rape as: "The
penetration, no matter how slight, of the vagina or anus with any body part or object, or oral penetration by a
sex organ of another person, without the consent of the victim."16 The prior definition had not changed
since 1927 and gained the attention of sexual assault
awareness groups because it had alienated the victims who did not fit the definition - "the carnal knowledge of a female,
forcibly and against her will". The former
definition of "forcible rape" focused on vaginal penetration, but the newer definition includes forcible
anal or oral penetration. The old definition, "the
carnal knowledge of a female, forcibly and against her
will", did not include forcible oral or
anal penetration, the rape of women with other objects,
or the rape of a man. This new definition encourages
male rape victims to seek the help they need and also includes
sexual assaults that previously were not covered
by the definition of rape. The basis for changing
this definition lies in the
statistics provided by governmental institutions such as the U.S. Department of Justice and the CDC. A study done
by the CDC found the following statistics
:-
Intimate Partner Violence
•
About 1 in 3 men experienced contact sexual violence,
physical violence, and/or stalking by an intimate
partner during their lifetime.
•
Nearly
56% of men who were victims of contact sexual violence, physical violence, and/or stalking by an intimate
partner first experienced these or other
forms of violence
by that partner
before age 25.
Sexual Violence
•
Nearly 1 in 4 men in the U.S. experienced some form of contact sexual
violence in their lifetime.
•
About 1 in 14 men in the U.S. were made to penetrate someone during their lifetime.
•
More than 1 in 38 men in the U.S. experienced completed or attempted rape victimization in their lifetime.
•
Among male victims of completed or attempted rape, about 71% first experienced such victimization prior to age 25.
2. Philippines
Prior
to the 1997 amendment of Revised Penal Code of 1930, male victims of rape were not acknowledged
under Philippine law. Article 266-A
of the law defines rape by "an act of sexual assault" by any person
either by "inserting his penis into another person's
mouth or anal orifice" or inserting "any instrument or object,
into the genital
or anal orifice of another person". The 1997 amendment
allowed the legal recognition of rape of males, both by other males and by females.
3. Republic of China
Until November
1, 2015, sexual offences against
males above the age of 14 could not be prosecuted unless they
also included a physical assault, in
which case only the physical component was punishable. However, a revision
of Article 237 of the Criminal Law of China
which criminalises "forcible indecency," made that section of
the law gender-neutral. Offences that
constitute rape of males may be tried under
this article, with offenders facing a maximum of five years in prison.
CHAPTER - 4
MISUSE OF WOMEN CENTRIC
LAWS AND ITS REMEDIES
"Women commit
crime for the same reasons
that men do. Crime has no gender, and neither should our laws."
The Indian Penal code, in its basic form, is the main criminal code of India, which lists all the cases and punishments that a person committing
any crimes is liable to be charged with, and covers any Indian citizen or a person of Indian origin.
It is a fact that the law all around the globe is misused by the people, either
by the reason of poor drafting or by the reason of loopholes in the
law which render a person to mold the law according to his or her personal
needs and get away with it without
any repercussions or punishment by the law. It is often seen that penal laws are misused by a person to settle personal scores with another
or to take revenge. Considering this, the Chapter
is divided into 2 parts, i.e., the misuse of the existing provisions of the law
which were primarily meant for protection of women from an offence
and what are the available
remedies in the law in case a false case is filed by a person to harass another.
It is not just about crimes against men in the form of rape, violence or assassination. The worst is the false accusations of crimes against
these innocent men by women. In the Indian legal system, a woman can accuse a man of rape, domestic
violence or dowry harassment if there is little evidence
and he can be caught.
in captivity Today,
tens of thousands of innocent
Indian men are rotting in jail for crimes they
did not commit thanks to fabricated claims by women. India's harsh laws are being abused left, right and center, and women are imprisoning men on false
charges. From posing
as personal agents
to extorting money, women are blatantly
manipulating Indian laws. From
sour relationships to broken marriage vows, all the reasons are enough
to falsely accuse
men and put them behind
bars. Girls who stay late in premarital affairs accuse their boyfriends of rape, regardless of the boys' reputation. , future, career and life.
CHAPTER - 5 CONCLUSIONS
One of the most important
manifestations of inequality worldwide is GENDER EQUALITY. When the very strong feminist
movement that began in the middle of the 20th century sheds light on the great inequality and cruelty that women suffer every day. , the law had to be changed so that women
could be equal
to men. The legislation we started with was quite,
perhaps completely legal at the time, but the dawn of today has put men in such a naive position
that they fall prey to so-called "women's empowerment" legislation. Much less has been said about how we have become a prison state, passing almost every draconian law imaginable to curb crimes
against women and allowing ordinary
citizens to be arbitrarily arrested
and imprisoned in deplorable conditions. This decade proved that. the need for a gender-
neutral society. The Oxford Dictionary describes a gender-neutral adjective as suitable, proper or common
to the male and female
genders. or gender,
and emphasizes the equal treatment
of men and women under the law without discrimination. We see a society where
equality is realized
in its true sense, not at the expense of any gender. Through this research, an attempt has been made to highlight
the history of our existing
law and what changes are required in it because
of the ever changing dynamic society and mindset of the people.
Though, no doubt that certain laws are necessary for protection of women, it cannot be denied that due to a drastic
change in our society and the diversification of societal and sociological aspect
of the people, certain laws which were earlier only applicable to one part of the society has broken its barriers and is now applicable to each and every individual without any prejudice
to their sexuality. It has been observed by Perera that gender neutral
law is not anti- women
in nature.
Article Information
CRITICAL ANALYSIS OF NEED FOR GENDER NEUTRAL LAWS IN INDIA
Authors: HIMANSHU KUMAR, DR. ANNIRUDH VASHISHTHA
- Journal IJLRA
- ISSN 2582-6433
- Published 2024/05/02
- Issue 7
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International Journal for Legal Research and Analysis
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