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EFFECT OF INTERNATIONAL CONVENTIONS ON SEXUAL OFFENCES AGAINST WOMEN IN INDIA By: THUSHAR V. SENAN & ASHIQUE MUHAMMED BIN KAMAL
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Article Details
EFFECT OF INTERNATIONAL CONVENTIONS
ON SEXUAL OFFENCES AGAINST WOMEN IN INDIA
AUTHORED By:
THUSHAR V. SENAN[1]
&
ASHIQUE MUHAMMED BIN KAMAL[2]
ABSTRACT
Historically,
women have always been at the receiving end of sexual offenses, violence, and
crime. The United Nations and the introduction of several international
covenants are said to have created a positive impact on the prevention of
offenses against women. Even though there aren’t a lot of international
conventions which are solely dealing with the rights of women and the
prevention of offenses against them, the rights of women are highlighted in if
not in many, all of the existing international covenants. Some covenants like
the CEDAW (UN Convention on Elimination of All Forms of Discrimination against
Women, 1979) are specifically aimed at preventing sexual offenses against
women. The implementation of international laws in protecting women could find
a lot of hurdles in a country like India which has numerous personal laws and
diversity. Still, India is part of almost all major human rights conventions
and has adopted many provisions into domestic laws. But how are they impacting
a country like India? Are there enough provisions adopted from the
international covenants to protect women? The fact that India is not part of
the CEDAW-OP curtails the right of women to approach the international courts
or committees. Doesn’t this restrict their right to seek remedy? Or is it that
the Indian judiciary and legal system have all aspects covered to protect women
and their rights? And most importantly, has the crime rate gone drastically
down after India became part of the treaties, and are women feeling safer and
protected now?
This paper
aims to disclose the impacts the covenants have on sexual offenses against
women in India.
INTRODUCTION
We are
still not clear on how women turned out to be the oppressed or underprivileged
category among the two genders. The assumption is the biological differences
between them which created a rift on who is the more dominant over the other.
Men, being physically superior to women might have felt superior in every other
ways too and hence the differences. This sense of being over powered helped men
to dominate all positions of power and governance and women were shunned to
their households. This was followed by acts of violence on women who were
physically inferior. This might not be accurate but this is somewhat the
picture of what has happened in history. With the development of civilizations
and societies, changes happened to the rights and protection of women. The
changes that took place through the course of history are very evident. 2000
years ago, the Roman laws guaranteed men the right to have authority over life
and death of his wife. The 18th century men had the right to
discipline his wife with a stick. But many philosophers and thinkers helped to
change these concepts. For example, in the works of Plato, it is said that
human souls are sexless which directs towards gender equality. The
enlightenment period also saw differences and improvement in the same. With the
development of society and human rights, women are guaranteed their rights to
be treated equal to men and protect them from torture and violence.
But this
paper is not aiming to find out the history of violence against women. The aim
of the paper is to figure out how the international conventions have impacted
women. The introduction of United Nations and various international covenants
have guaranteed the protection of women against violence and torture. The mere
introduction of these and ratification of the same by countries are the
theoretical aspects of ensuring protecting of women. What we need to know is
the practical aspect of this. How has these conventions and provisions helped
women feel safer or how these have helped in the graph of crime to go down, if
it has gone down.
This paper will compile information on the
violence of women and how the international covenants, especially CEDAW have
impacted them since their ratification in India.
OBJECT OF THE STUDY
The basic
objective of the study:
1.
How the ratification of International covenants have
impacted crime rate in India with special emphasis on CEDAW?
2.
To identify the discrepancies between the CEDAW and
the numerous Indian laws that provide women's rights protection and to offer
suggestions
This
analytical research has been carefully planned to enhance the reader's
comprehension of CEDAW and the current state of CEDAW article implementation in
India. It also uses data and statistics obtained from various sources to show
the differences in crime rate for the reader.
CONTENT
In our
opinion, the fact that India ratified CEDAW did not result in a decrease in
violence against women since the international agreement was not formally
implemented and enforced throughout Indian society. This paper will use
research to demonstrate the lack of advancement in women's safety. India is
part of several international covenants such as the Convention on Rights of
Child, International Convention on Civil and Political Rights, International Convention
on Economic Social and Cultural Rights, Convention on the Elimination of All
Forms of Discrimination against Women etc. The 1993 Vienna Declaration asks
for efforts to incorporate women's equal rights to human status. It emphasizes
the need to end violence against women in both public and private settings. The
Beijing conference in 1995 gave people a place to focus on some of the
important concerns that had been recognized as major roadblocks to the growth
of most women worldwide. It concentrated on topics like violence against women,
prejudice against women, etc. Article 55 and 56 of United Nations charter cast
a legal obligation on United Nations organization to promote respect for
equality and human rights. The Universal Declaration of Human Rights agreed in
1948 is one of the earliest modern covenants which talks about the right of men
and says that human rights are equal for all humans irrespective of their
gender. All people are "born free and equal in dignity and rights,"
according to the Universal Declaration of Human Rights. Hence, regardless
of gender, everyone has the right to liberty, dignity, and equal rights. Women
and girls continue to face discrimination and grave abuses of fundamental basic
rights every day and everywhere. In addition to having less or no access to
healthcare and being disregarded in terms of land or property ownership, more
women than males live in need and poverty.
Another
significant international human rights treaty, the ICCPR guarantees a number of
civil and political rights. The International Covenant on Economic, Social, and
Cultural Rights and the Universal Declaration of Human Rights are collectively
referred to as the International Bill of Human Rights. According to the ICCPR,
nations that have ratified it are required to defend and uphold fundamental
human rights, including: the right to life and human dignity; equality before
the law; freedom of speech, assembly, and association; freedom of religion and
privacy; freedom from torture, ill-treatment, and arbitrary detention; gender
equality; the right to a fair trial; right to family life and family unity; and
rights of minorities. The important things to be noted in these are that, none
of these covenants creates a distinction between men or women. None of the international
covenants guarantee any rights to men that are not guaranteed to women. But it
was necessary to guarantee the protection of the category which was facing
oppression and violence.
And hence,
CEDAW was introduced. The CEDAW was approved by the UNGA on December 18, 1979,
but it wasn't until September 3, 1981 that it became a legally binding
international agreement. Over 189 nations have ratified CEDAW and 165 have
ratified CEDAW-OP as of today (Optional Protocol). It is one of the most important international
accords that direct the work of UN Women in attaining gender equality and
empowering all women and girls is which is sometimes referred to as the
worldwide bill of rights for women. The CSW's efforts have been crucial in
exposing all the ways that women have been denied equality with men. The CEDAW
is the most important and comprehensive of the declarations and conventions
that came out of these efforts to benefit women. Different rights and freedoms
are outlined in these articles, all of which are given equal weight. Women's
rights are human rights. Women and girls are entitled to the same basic rights
since they are fellow humans, including the right to vote, a fair pay, an
education, and a life free from abuse. Unfortunately, many people over the
world are being denied their constitutionally guaranteed human rights only
because they are women and girls. Globally, not a single nation has yet
achieved gender justice. In many locations, women are risking their lives by
standing up to claim their rights.
India
ratified CEDAW in 1993. This was ratified in order to guarantee the safety and
well-being of women and their protection beyond that of what was already
guaranteed under the penal provisions and domestic laws. To implement legal
provisions in a country like India is no easy task considering the cultural,
social and economic disparities of the people. The diversity of the people
always stands in the way of many major decisions. But law needs to consider the
well-being of the citizen and that is the paramount objective of the judiciary
too.
The most
prominent crimes against women in India include:
·
Bride burnings/Dowry abuse;
·
Female foeticide/infanticide; and
·
Human trafficking/sex slaves
·
Murder
·
Sexual crimes
·
Domestic violence
·
Abduction
·
Acid attack
·
Forced child marriage etc.
Dowry
deaths are the death of a married woman who is murdered over dowry disputes
either by the husband or the relatives of the husband. The IPC prevents and
punishes a person from committing dowry death under section 304B. In 1994 there
were 4,935 dowry deaths and 25,946 cases of dowry harassment, while in 2005,
eleven years after the signing of CEDAW, that number increased to 6,787 dowry
murders and 58,319 incidents of dowry harassment.[3]
As of 2008, there were 31,950 pending cases of dowry deaths, 117 cases
withdrawn, 1,948 convicted, and 3,876 acquitted or discharged.[4]
CEDAW was ratified by India in 1993 and as the statistics shows, there is no
decline in the number of dowry deaths or dowry related harassments. The cruel
fact is that the crime rate didn’t stay still either. It is going up
constantly.
Female
foeticide is a process of aborting a foetus in the womb of a mother when the
foetus is diagnosed to be a female. Rise in female foeticide rate was one of
the major concerns at a time. From 1960s to 2010s, the male to female ration in
India was real problematic due to the increase in female foeticide. The MTP
laws were made stringent after that and the foeticide rates in general came
down. The MTP act and PNDT act regulated the gender reveal before delivery and
illegal abortions. Section 312 to 318 of the Indian penal code also contains
provisions which prevent infanticides, gender-reveal etc. according to a study
conducted in 2004, the male to female ratio had dropped to 800:1000. Studying
data proves that the female foeticide had increased by a percentage of 13 between
1991 and 2011[5]
which happens to be the time when CEDAW was ratified by India.
Taking the
recent years into account, the rate of crime against
women rose a whopping 15 per cent in one year: from 56.5 per cent in 2020 to
64.5 per cent in 2021.[6] 31.8 percent
of all cases were cruelty cases involving a spouse or one of his relatives that
were reported under section 498A of the Indian Criminal Code. An increase from
the 3,71,503 cases submitted in the same category in 2020 to a total of
4,28,278 cases in 2021. The data also reveals that, up from 56.5 percent in
2020, the crime rate per lakh women was 64.5% in 2021.
The
number of recorded occurrences of crime against women increased by 15.3% in
2021 compared to 2020, according to the National Crime Records Bureau of India.
The National Crime Records Bureau reports that although there were more than
228,650 recorded crimes against women in 2011, there were 4,28,278 reported
crimes against women in 2021, an increase of 87%.
The
steady incline in the crime rate is the same for all other related offences too
such as human trafficking, acid attacks, outraging modesty of a woman etc. In
fact, our research couldn’t exactly find any crime against woman that has
actually gone down in rate. We are not totally denying that the crime rate hasn’t dropped at all. It is true that between the
period of 2019 and 2020, there has been a drop in the crime rate of Cruelty
by husband or his relatives(1,24,934 to 1,11,549), Dowry Harassment(13,307 to
10,366), Dowry Death (7,141 to 6,966) and Domestic Violence (533 to 446). But
in 2021, these numbers started to incline again. A total of 4,28,278 cases of
crime against women were registered during 2021, showing an increase of 15.3%
over 2020. Trafficking alone showed an increase of 27.7% in 2021 in comparison
with 2020. Cruelty by husband or his Relatives (31.8%), assault on women with
purpose to outrage her modesty (20.8%), Kidnapping & Abduction of women
(17.6%), and Rape (7.4%) accounted for the majority of instances under the
IPC's definition of crimes against women. In comparison to 56.5 in 2020, the
crime rate per lakh women in the population is 64.5 in 2021. The decline in the
number of crimes in 2019 could be partially due to the pandemic too. We
couldn’t find any evidence which could show that the legal provisions impacted
in that negligible decline of crime rate.
Another
major sexual offence that Indian women face is regarding the cyber offences.
This includes cyber bullying, cyber pornography, child pornography etc. the
issue with the cyber offences is that, it is a relatively newer concept for us.
Even though the IT Act was introduced in 2000, the act turned out to be a
half-baked law as the operating area of the law stretched beyond electronic
commerce to cover cyber-attacks of non-commercial nature on individuals as
well. While commercial crimes and economic crimes were moderately managed by
this Act, it miserably failed to prevent the growth of cyber-crime against
individuals, including women[7].
According
to a research[8],
74% of participants believed that women were more vulnerable online than males.
There were 60 female participants in this research. Just 11.7% of the 60
respondents know they've had unpleasant online interactions. 85% of the
respondents to this survey on Cyber Victimization of Women and Cyber Laws in
India reported receiving harassing emails from people that included
pornographic photographs, sexual messages, etc. Just 15% of respondents know
that these emails are "trashes" and don't care about them. About 50%
of the respondents reported receiving abusive, threatening, or blackmailing
emails from their ex-husbands or ex-boyfriends. The Indian laws which are still
dormant in the case of cyber-crimes are insufficient to deal with such issues.
Coupling that with the digital divide and cyber illiteracy gives us a crystal
clear image on the number of reported and unreported cases in the cyber
section.
Under
the IPC, the forced intercourse by a man with his wife is not rape under the
provision of rape[9].
Unless it is a case of judicial separation, there is no remedy for marital rape
in Indian laws. The international covenants are also silent regarding these
matters. Offence of rape defined under section 375 of the IPC is another major
sexual offence that women encounter. Rape is evidence that all attempts to
prevent violence have failed once it has occurred. The pronouncement of
increased punishment as a response is mostly a show of dissatisfaction and
impotence. The focus should be on rehabilitation and prevention. Since violence
against women is a widespread social issue, legislation alone would not be
sufficient to address it. In India, a flurry of laws protecting women from
various types of assault was passed throughout the 1980s. The first changes made
throughout this process were to the rape legislation. It all began with a
Supreme Court decision from 1979[10]
that said that a woman's chastity and character were the grounds for accepting
or rejecting the claims of rape. Since then, great progress has been achieved
addressing rape in these laws with changes and the inclusion of various
additional provisions to the Indian Penal Code, 1860 the Code of Criminal
Justice, and the Indian Evidence Act. Judges are instructed not to allow
evidence on women's character or prior sexual behavior unless required by the
standards of a fair trial.[11]
But similar to other crimes, the rate of commission of rape hasn’t gone done
either.
This
proves beyond any doubt that the introduction or ratification of CEDAW or any
other international covenant in India has had absolutely no or less impact that
what is hoped for. The same goes for the national provisions. The absence or
insufficiency of enough provisions to protect women is evident from statistics
given above.
The constitution
of India provides that all men and women be treated equally without any
discrimination on grounds of religion, race, caste, sex or place of birth. The
same is guaranteed under the international covenants like CEDAW. But the
practical aspects prove us that there is a huge gap in implementation of the
same. It is still difficult for women to enjoy and execute their equal rights
in all areas of life, including the social, economic, and political ones.
PROBLEMS AND RECOMMENDATIONS
What
exactly are the reasons for the increase in the rate of crime against women? We
are living in a period which is most probably the most evolved, civilized and
forward thinking era of mankind. But still we cannot see women as an equal or
not cause harm to them in any manner. The reason is far beyond than what a few
provisions or conventions could fix. The reason lies in the evolution of man,
in the suppression and oppression of genders, in the way we grew into a
patriarchal society, and to a huge extend, silence and corruption.
There
is a continued low representation of women in the upper echelons of lawmaking
affirmative actions (During 2011-15, female MLAs in the State Legislative
Assemblies were 8.4% and female candidates were 7.3%, 48.5% of the Indian
population is women, but only 27.4% of women are in the workforce. Women hold
only 14.39% of seats in Lok Sabha and 8.8% women in Rajya Sabha)[12].
Affirmative action measures are necessary to increase the representation
of women in positions of power, such as the legislature reserving 33% of seats
in the Lok Sabha and all State Legislative Assemblies for women.
The
constitution protects the citizen from fundamental rights violation against the
state only. There are no provisions or remedy regarding what a person is
supposed to do when their fundamental right is violated by a private party.
This affects the women more than men. . Appropriate legislations have to
be ensured to fill the legislative vacuum regarding the absence of defense
against private party in fundamental rights violation.
The
presence of several customs that still exists throughout the country especially
in rural areas has to be dealt with and removed. Efforts should be made to
discourage prejudices and eliminate customs and practices that discriminate
against women
The
lack of suitable and high-quality crèches for the children of working women
deters them from entering the workforce. Child care facilities should be
provided at or close to the office or home to support and encourage women to
work. Notwithstanding limitations on the appointment of women as independent
directors under the 2013 Companies Act, there are very few women in executive
roles, particularly at the board level, and many posts are unfilled. This can
be tackled by filling the board's open positions for women as soon as possible.
A time limitation should be kept within which it has to be mandatory for
filling the vacant positions.
Women
are deprived of their rights without any of their faults when they are denied
the opportunity to vote and subsequently disqualified from running for office
due to their lack of educational qualifications.[13]
As per 2020, only around 66% of women are literate in India as compared to 82%
of men.[14]
Legislators need to be more considerate when establishing conditions that bar
women from running for office due to a lack of education until a certain level
of literacy among women is reached in light of the ground-level realities
surrounding women's literacy, particularly older women.
The
Supreme Court needs to work to enhance the proportion of female justices and
senior attorneys. This will help cases be decided from the women’s perspective
too. Prejudice and patriarchy are not just the subjects of the illiterate.
Notwithstanding
regulations protecting employees' rights to social security and labour welfare,
many workers continue to fall outside the scope of these rules, which primarily
apply to those employed in the organized sector. As nearly 94% of women
employees are in unorganized industries like brick kilns, construction, and
agriculture, they are not covered by these rules. It is important to secure
worker welfare and social security, pay equitable salaries to all employees,
and take legal action to incorporate the unorganized sector. Protecting rights
of women in unorganized sector would help crime rate to go down in that
particular sector.
There
are religions in our country which doesn’t provide any certain age limit for
marriage of a girl child. This can result in child marriages, which in turn
causes sexual and violent offences against girl children. Such private laws
must be amended and bought under the purview of the national legislation.
The
absence of a ‘sexual harassment complaints committee’. The introduction of a
committee which solely focuses on dealing with the sexual harassment cases
which is headed and run by women would make it easier for victims to approach a
judicial body and make claims.
Child
marriage is more common in rural than urban settings, according to NFHS-5
statistics. Early pregnancy and various health concerns, exposure to marital
abuse, and early school dropout are the outcomes of this. Only the state
parties can create a difference in this matter. They must educate people in
rural areas regarding the adverse effects of early marriage and legal
obligations to refrain from abetting or committing the same. In rural regions,
violence against women, especially community-sanctioned violence (Khap
panchayat, branding, and witch hunts), is still pervasive and mostly affects
women from SC/ST groups. State Parties must pursue severe penalties against
offenders in order to prevent the general public from carrying out similar
crimes. Women's rights education, an easily accessible justice delivery system,
including One Stop Centers (OSCs - where all the facilities are available under
one roof) should be implemented in rural areas.
Another
important problem that the victims face is corruption and bribery. The accused,
if influential and rich, delays the processes of taking action against them and
denes justice for the women. We have seen this pattern in a lot of cases
including the infamous Visakha case[15].
Here, Banwari Devi was repeatedly raped for doing her job and the court
acquitted the accused. There are several other cases where medical certificates
are not obtained, FIR is filed late, the officers accept bribes to destroy
evidences etc.
The
worrying factor in this matter is that, a lot of victims are asked to remain
silent or forgive the accused without any charges. The people who ask the
victim to remain silent turns out mostly to be her own parents or close
relatives. This silence grants the wrong doers, who are mostly men, to turn out
into recidivists. According to 65% of Indian males, women should put up with
violence in order to maintain the stability of the home and occasionally
deserve to be beaten. According to the International Men and Gender Equality
Study (IMAGES) Questionnaire, 24% of Indian males had at some time in their
life engaged in sexual violence. As many instances go unreported, it is
particularly challenging to acquire precise data on the frequency of case occurrences.
This is mostly because of the potential reporter's fear of humiliation or
embarrassment, as well as the intense pressure not to harm the family's
reputation. Law enforcement officials are more likely to take bribes from the
family of the accused for similar reasons, or possibly because they are afraid
of more serious repercussions like honor murders. The time to understand that
the life of a victim is far more superior to the honor of the family and their
good-will is far gone. It’s as if even though we live in 2023, our thoughts and
culture hasn’t graduated since the enlightenment period.
Other
ways of reducing crime rate includes Population control, Education and
employment, Gender sensitization (by parents and teachers), Law enforcement,
Legislation (which includes Change in mind set of the judiciary, Amendments in
existing legislations, Appropriate application of laws in the setting of
mental illness, New legislation is needed to
provide for granting Interim Relief), Restriction on use of alcohol, proper
treatment of Mental illness etc.
CONCLUSION
It is quite
ironic that the longest written constitution in the world has one of the
biggest crime rates against women in the world. We can blame it on a lot of
things – the population, poverty, economic and cultural differences etc. But at
the end of the day, even for the laymen, the question is - What has the
government done? What has the law done?
It is
difficult to say that the law and constitution is blind and deaf. The legal
provisions have ensured on paper all sorts of protection against violence or
torture or discrimination against men and women. It includes many acts and
amendments such as the Protection of Women from Domestic Violence Act (2005),
The Commission of Sati (prevention) Act (1987), and Indian Penal Code, The
Dowry Prohibition Act (1961) etc. along with other mechanisms such as The
National Commission for Women, Vishakha guidelines etc. But if it doesn’t aid
you practically, there is absolutely no point in having it. India does seem to
be aware that there is a problem for the women in their nation, as seen by the
acts, laws, and organizations that have been established to address the unique
issues that women in India face. These regulations just demonstrate that India
is attempting to protect women on paper from a statistical standpoint; they do
not appear to be having a beneficial impact on women's lives. It is as if we
are not trying hard enough.
The fact
that all offences that are mentioned in this paper doesn’t appear in CEDAW but
appears in the Indian legal provisions makes us wonder what the point of that
was. The findings are concerning since; despite relatively few criminal
convictions, each of the crimes discussed in this report has statistically
increased after CEDAW's adoption.
Another
important matter is that India has not ratified the optional protocol of CEDAW.
An Optional Protocol is a legal instrument that supplements an
international treaty. An international treaty known as the Optional Protocol to
the Convention on the Elimination of All Forms of Discrimination against Women
sets complaint and investigation processes for the said convention. Without a
country being part of the OP of a convention, individual parties cannot access
the international courts or committees as an appellant body. It is not
exclusive to CEDAW. India has not signed the optional protocol of almost any
major international covenants.
India's
adoption of CEDAW did not cause it to alter its cultural and religious
perspectives on the worth of the female population. In actuality, little seems
to have changed since CEDAW was ratified. The figures demonstrate the truth. As
CEDAW has obviously done little to assist Indian women, India needs a more
effective political system in order to prevent gender-based violence.
REFERENCES
·
National
Crime Records Bureau: Ministry of Home Affairs, 2005
·
National
Crime Records Bureau: Ministry of Home Affairs, 2008
·
Ramaiah,
G. J., Cahandrasekarayya, T., & Murthy, P. V. (2011). Child sex ratio in
India: Trends, issues and concerns. AsiaPacific Journal of Social Sciences,
3(1), 183-198. Retrieved from http://www. socialsciences-ejournal.org/5.10.
Chan drasekharayya.pdf
·
National Crime Records Bureau: Ministry of
Home Affairs, 2022
·
Bobbie Khanna, CEDAW and the Impact on
Violence against Women in India, UW Bothell Policy Journal, 2013
·
Women’s Rights in India: An Analytical Study
the United Nations Convention on the Elimination of All Forms of Discrimination
against Women (CEDAW) The Indian Constitution, Legislations, Schemes, Policies
& Judgements of and 2021. NHRC, India.
·
Global Gender Gap Report, 2020 by World
Economic Forum
·
International Men and Gender Equality Study
(IMAGES) Questionnaire
·
Debarati Halder and K.Jaishankar, Cyber
Victimization of Women and Cyber Laws in India, Cyber-crime and the
Victimization of women: Laws, rights and regulations
·
Vina Majumdar, Political Ideology of the
Women’s Movement’s Engagement with Law, 16, available at
http://www.cwds.ac.in/wp-content/uploads/2016/09/PoliticalIdeology.pdf
[1] Affiliated with the School of
Legal Studies, CUSAT. The author can be reached at
[2] Affiliated with the School of
Legal Studies, CUSAT. The author can be reached at ashiquethoppil@gmail.com
[5] Ramaiah, G. J., Cahandrasekarayya,
T., & Murthy, P. V. (2011). Child sex ratio in India: Trends, issues and
concerns. AsiaPacific Journal of Social Sciences, 3(1), 183-198. Retrieved from
http://www. socialsciences-ejournal.org/5.10. Chan drasekharayya.pdf
[7] Debarati Halder and K.Jaishankar,
Cyber Victimization of Women and Cyber Laws in India, Cyber-crime and the
Victimization of women: Laws, rights and regulations
[10] Tuka Ram v. State of Maharastra , AIR 1979 SC 185.
[11] Vina
Majumdar, Political Ideology of the Women’s Movement’s Engagement with Law, 16,
available at http://www.cwds.ac.in/wp-content/uploads/2016/09/PoliticalIdeology.pdf
Article Information
EFFECT OF INTERNATIONAL CONVENTIONS ON SEXUAL OFFENCES AGAINST WOMEN IN INDIA By: THUSHAR V. SENAN & ASHIQUE MUHAMMED BIN KAMAL
Authors: THUSHAR V. SENAN, ASHIQUE MUHAMMED BIN KAMAL
- Journal IJLRA
- ISSN 2582-6433
- Published 2023/05/31
- Volume 2
- Issue 7
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International Journal for Legal Research and Analysis
- Abbreviation IJLRA
- ISSN 2582-6433
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