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RESEARCH PAPER TITLE: FROM INK TO IDENTITY: REWRITING THE NARRATIVE OF LGBTQ+ COMMUNITY IN INDIAN LITERATURE

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ASHPINDER KAUR
Journal IJLRA
ISSN 2582-6433
Published 2024/02/10
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RESEARCH PAPER TITLE: FROM INK TO IDENTITY: REWRITING THE NARRATIVE OF LGBTQ+ COMMUNITY IN INDIAN LITERATURE
 
AUTHORED BY - ASHPINDER KAUR
 
 
ABSTRACT
Human Rights are the inherent rights given to all individuals without any discrimination. The UN Declaration of Human Rights 1948 expressly declares that there should be no discrimination on the basis of sex, nationality, ethnicity, language, religion, or any other status. But in contemporary times, where individuals are fighting for their political, economic, social, and cultural rights, the LGBTQ+ community is deprived of its fundamental rights of being a human on the basis of sex.  Many discussions claim their existence to be unnatural, but the same can be found in Indian Literature. Indian Literature in Sanskrit, Hindi, Urdu, and other regional languages celebrates same-sex love. In the 1940s, Ismat Chugthai's short story ‘Lihaaf’ tried to make a bold move by turning down all the preconceived notions as she wrote about a liaison between two women. In Medieval India, Amir Khusrau’s love for Nizamuddin Auliya is perfectly presented in his writings. Then there is a story of the fascination of Shiva for Mohini (Vishnu’s changed form) mentioned in Bhagwat Purana.  The book “The Man who was a Woman and Other Queer Tales from Hindu Lore “was written by Devdutt Patnaik, an Indian mythology scholar. The autobiographical account of Suryakant Tripathi Nirala titled ‘Kulli Bhatt’ entertains the bisexual character. The experience of being a transwoman and the issues concerning transmen, which are mostly ignored, was narrated by A. Revathi in the autobiography.  Manju Kapoor’s ‘A Married Woman’ discusses the quest of a woman for an extramarital affair with another woman. As it is rightly quoted in Mahabharata, the lamp of history destroys the darkness of ignorance. Thus, Indian Literature openly examines the existence of this community, treats their sexual orientation as normal, and throws light on their struggle for basic Human Rights.
 
Keywords: Human Rights, UN Declaration of Human Rights 1948, Discrimination, LGBTQ+ community, Fundamental rights, Indian Literature.
 
 
Introduction:
The evolution of human rights is a fascinating journey that spans centuries and reflects the collective efforts of individuals, communities, and nations to recognize and protect the inherent dignity and worth of every human being. While the concept of human rights has deep historical roots, its modern form emerged in the aftermath of World War II with the adoption of the Universal Declaration of Human Rights (UDHR)[1] by the United Nations General Assembly.  The UDHR, a landmark document, proclaimed fundamental human rights that should be universally protected, such as the right to life, liberty, and security of person, freedom of thought, conscience, and religion, and the right to education, among others. It represented a response to the atrocities committed during the war and sought to establish a global commitment to safeguarding human dignity. Since adopting the UDHR, human rights have evolved through international conventions, regional agreements, and domestic legislation. The International Covenant on Civil and Political Rights (ICCPR) and the International Covenant on Economic, Social, and Cultural Rights (ICESCR), adopted in 1966, further elaborated on the rights enshrined in the UDHR. These covenants formed the foundation for the international human rights framework and established legally binding obligations on states. Over time, additional human rights instruments and treaties have been developed to address specific issues, such as the rights of women, children, indigenous peoples, and refugees. Regional human rights systems, like the European Convention on Human Rights[2] and the Inter-American Commission on Human Rights[3], have also been crucial in promoting and protecting human rights within their respective jurisdictions. The evolution of human rights has been challenging. Conflicting interpretations, cultural relativism, and the struggle for enforcement and accountability have presented ongoing obstacles. Nonetheless, there have been significant advancements in recognizing and realizing human rights globally. Human rights discourse has expanded to encompass issues such as environmental rights, the rights of sexual and gender minorities, and the intersectionality of multiple forms of discrimination. Furthermore, grassroots movements and advocacy campaigns have been instrumental in driving progress. Civil rights movements, women's rights movements, and social justice movements worldwide have challenged oppressive systems, pushed for legal reforms, and raised awareness about human rights violations. The evolution of human rights reflects humanity's collective commitment to create a more just and equitable world.
The Link Between Human Rights and LGBTQ+ Rights:
The link between human rights and LGBTQ+ rights is grounded in the principle of equality and non-discrimination. Human rights are universal, inherent to all individuals, and are not dependent on one's sexual orientation, gender identity, or expression. LGBTQ+ rights are an integral part of human rights, as they focus on protecting the dignity, equality, and freedom of LGBTQ+ individuals.  Human rights prohibit discrimination on various grounds, including sexual orientation, gender identity, and expression. LGBTQ+ individuals have the right to be free from discrimination in all areas of life, including employment, education, housing, healthcare, and public services. Upholding the principle of non-discrimination ensures equal treatment. LGBTQ+ individuals have the same inherent rights to life, liberty, and security as any other person. Protecting LGBTQ+ individuals from violence, harassment, and persecution is essential to uphold their fundamental rights.  Human rights recognize the right to privacy and the right to form a family. LGBTQ+ individuals can express their sexual orientation, gender identity, and relationships without fear of discrimination or interference from the state or society.  It is essential to recognize that the struggle for LGBTQ+ rights is ongoing in many parts of the world, as social stigma, discrimination, and legal barriers persist.  Human rights frameworks provide a solid foundation to address these issues and ensure that the rights and dignity of LGBTQ+ individuals are respected, protected, and fulfilled.
 
Recent developments in LGBTQ+ Rights in India:
In recent years, significant developments have occurred regarding the link between human rights and the LGBTQ+ community in India.  In the case of Navtej Singh Johar v. Union of India[4], the Supreme Court of India in 2018 struck down Section 377[5] of the IPC, effectively decriminalizing consensual same-sex relationships. This ruling was a significant step towards recognizing the rights of LGBTQ+ individuals and upholding their right to privacy, dignity, and non-discrimination.
The Supreme Court in 2014[6] recognized transgender people as a "third gender" and affirmed their right to self-identify their gender. This judgment acknowledged the discrimination faced by the transgender community and called for affirmative action to protect their rights in education, employment, and healthcare.  The Transgender Persons (Protection of Rights) Act, 2019 was enacted to safeguard the rights and welfare of transgender individuals. The law prohibits discrimination against transgender people in various areas, including employment, education, healthcare, and access to public facilities. It also provides for establishing welfare boards and mechanisms for addressing grievances.  In 2020, the Delhi High Court, in a case, [7]recognized the right of same-sex couples to adopt children. The court held that denying adoption rights to same-sex couples solely based on their sexual orientation violated their fundamental rights and the child's best interests. The LGBTQ+ community and allies in India have actively raised awareness, advocated for their rights, and challenged societal prejudices. Pride parades and events are organized in various cities nationwide, creating spaces for visibility, acceptance, and solidarity.
While progress has been made, challenges persist. Discrimination, social stigma, and violence against the LGBTQ+ community continue to be issues that need to be addressed. There is a need for comprehensive legislation to protect LGBTQ+ individuals from all forms of discrimination, including in areas like employment, housing, and healthcare. The link between human rights and the LGBTQ+ community in India exemplifies the ongoing struggle for equal rights and inclusivity. It highlights the importance of legal reforms, social acceptance, and advocacy efforts to ensure that every individual, regardless of their sexual orientation or gender identity, enjoys the same rights and protections as others in society.
 
The Link Between Human Rights and Indian Literature:
Indian literature has a rich tradition that spans centuries and reflects various aspects of society, including attitudes toward gender and sexuality. While LGBTQ+ rights as a modern concept may not have been explicitly discussed in ancient Indian literature, there are references and depictions of same-sex relationships that provide glimpses into diverse sexualities and gender identities in Indian history. One of the earliest mentions of same-sex relationships can be found in the Mahabharata, an epic Sanskrit poem believed to have been composed between 400 BCE and 400 CE. In the Mahabharata, the character Shikhandi is portrayed as transgender. Born as a female, Shikhandi identifies and lives as a man, playing a crucial role in the epic's narrative. In more recent centuries, Indian literature has addressed LGBTQ themes more explicitly. For instance, in the 20th century, works by authors such as Ismat Chughtai and Kamala Das touched on lesbian experiences and desires. Ismat Chughtai's story "Lihaaf" (The Quilt) and Kamala Das's autobiography "My Story" are notable examples. However, it is essential to note that societal attitudes toward LGBTQ individuals in India have varied, and the literature reflects this diversity. While some works highlight inclusivity and acceptance, others may depict discrimination and stigma. Overall, Indian literature, across various periods, contains glimpses of LGBTQ identities and relationships. It provides insights into the complexity and diversity of gender and sexual identities in Indian history, even if the explicit concept of LGBTQ rights is not always addressed.
 
Instances from Indian Literature:
Shiva’s love for Mohini: Bhagwat Purana
In the Bhagavata Purana, one of the fascinating stories revolves around the enchanting form of Lord Vishnu, known as Mohini, and the profound fascination that Lord Shiva developed for her. This captivating tale showcases the divine play and interplay between two prominent deities of Hindu mythology[8]. The story begins when the demons and gods join forces to churn the cosmic ocean in search of the nectar of immortality. Several celestial beings and treasures emerge from the sea during the churning process. Among them is Mohini, the mesmerizing female incarnation of Lord Vishnu. Mohini possesses unparalleled beauty, grace, and charm. He falls deeply in love with her and desires her presence. This intense fascination consumes him, causing him to lose awareness of his surroundings and become absorbed in Mohini's enchanting presence. However, Mohini is an avatar of Lord Vishnu, and her purpose is to fulfill a specific role in the cosmic drama. Understanding Shiva's infatuation, Mohini uses her charm and divine grace to entice and distract him, ensuring that the gods' plan to distribute the nectar goes smoothly without any interruptions. Lord Shiva, entranced by Mohini, offers himself entirely to her, disregarding his usual composure and divine responsibilities. Their interactions symbolize the eternal dance between the masculine and feminine energies in the universe. Eventually, the purpose of Mohini's appearance is fulfilled, and she vanishes from Lord Shiva's sight. Shiva realizes that her illusionary form momentarily swayed him and regains his divine awareness. Although deeply affected by the encounter, he returns to his role as the supreme ascetic and guardian of the universe. The story of Shiva's fascination for Mohini serves as a reminder of the allure and playfulness of divine beings. It illustrates that even the most powerful deities are susceptible to the captivating charm of divine manifestations. Moreover, the story conveys that the holy is beyond conventional gender roles and can manifest in various forms, blurring the boundaries between masculine and feminine energies. It highlights the complex relationships, dynamics, and interplay between deities within the Hindu pantheon, inviting devotees to contemplate the mysteries of the divine realm.
 
The story of Shiva's fascination for Mohini from the Bhagavata Purana can be examined from an LGBTQ+ perspective, exploring themes of gender fluidity and the blurring of binary identities. It offers an opportunity to view divine manifestations and love beyond traditional gender roles. The narrative challenges rigid gender binaries and demonstrates the fluidity and expansiveness of divine expression. Shiva's attraction to Mohini can be seen as an exploration of the diverse range of human desires and orientations. It breaks away from the societal expectations of heterosexual relationships, allowing for a more inclusive understanding of love and attraction. The story also invites contemplation on the spectrum of gender identities. The story encourages the celebration of all forms of love and recognizes the divine presence within diverse gender identities and orientations. It affirms the notion that love is a universal force that transcends boundaries, norms, and expectations.
 
Amir Khusro's Love for Nizamuddin Auliya:
Amir Khusro, a renowned Sufi poet and musician of the 13th century, is known for his deep love and devotion to his spiritual master, Hazrat Nizamuddin Auliya. Their bond, often referred to as a mystical love affair, is a testament to the profound spiritual connection and the transformative power of love within the Sufi tradition.
 
Amir Khusro's love for Nizamuddin Auliya is beautifully expressed through his poetry, ghazals, and qawwalis. He composed numerous verses that immortalized their relationship, describing Nizamuddin Auliya as the beloved, the guide, and the embodiment of divine love. These poetic expressions served as a medium for Khusro to convey his deep reverence, devotion, and longing for his spiritual master. Khusro's love for Nizamuddin Auliya went beyond the realms of a teacher-disciple relationship. It was a profound spiritual connection, where Khusro saw his master as the source of divine love and guidance. The relationship between Khusro and Nizamuddin Auliya was marked by intense emotions, with Khusro often expressing his longing and yearning for his master's presence. Khusro's poetry reflects his emotional vulnerability and the depth of his love, as he often described himself as a moth drawn to the flame of  Nizamuddin Auliya's divine presence. Khusro's love for Nizamuddin Auliya extended beyond the spiritual realm and encompassed genuine affection and companionship. He would often engage in musical performances and qawwali sessions in the presence of his master, using music as a medium to express his love and devotion. These musical expressions became an integral part of their spiritual practice and served as a means of connecting with the divine. Amir Khusro's poetic expressions of love for Nizamuddin Auliya continue to resonate with audiences today, inspiring generations of seekers and lovers of divine wisdom. Their love account serves as a testament to the transformative power of love and the profound connection between a spiritual master and a devoted disciple within the Sufi tradition. It is crucial to approach historical relationships and figures with sensitivity and respect for the context of their time. While Amir Khusro's love and devotion for Nizamuddin Auliya is well-documented, it is crucial to understand it within the cultural and religious framework of the 13th century rather than imposing modern LGBTQ+ perspectives onto their relationship. In the context of Sufism, the love between a disciple and a spiritual master is often described in metaphoric and symbolic terms. It is seen as a transcendent love that surpasses human boundaries and focuses on the seeker's connection with the divine. This spiritual love is not limited to romantic or sexual aspects but encompasses a broader sense of devotion and longing. That being said, it is worth acknowledging that Sufi poetry and literature, including Khusro's works, often employ expressions of love and longing that can resonate with diverse emotional experiences. These expressions can be interpreted and appreciated by individuals from various perspectives, including LGBTQ+ individuals, to connect with the themes of love, spirituality, and personal transformation. It is essential to recognize and honor the existence of LGBTQ+ individuals throughout history and within various cultural and religious traditions. While there may not be explicit evidence of same-sex relationships between Khusro and Nizamuddin Auliya, it is essential to acknowledge and celebrate the diversity of human experiences and relationships, including those within the LGBTQ+ community.
 
Ismat Chughtai’s short story ‘Lihaaf’:
This short story was published in 1942 in an Urdu journal named Adab-i-Litaf. The story dwells on the groundbreaking concept of love between same-sex and the gender expectations from the characters[9]. Some scholars believe it to be a feminist work as it challenges the notions of a society in which there is no freedom to express sexuality as one desires.
 
The story revolves around the characters of ‘Begum Jan’(a wealthy woman) and her oil massager ‘Rabbu’( a young maid). A newlywed girl of 9 years old, she was married to a man who was triple in age than hers, unable to fulfill her marital needs and trying to find the same outside the household. Attracted by Rubby, the story dwells on the same-sex love between these two women; their love is signified by the quilt (Lihaaf).
 
From an LGBTQ+ lens, "Lihaaf" portrays same-sex desire and the complexities of navigating such desires within a society that strictly adheres to gender norms and expectations. Begum Jaan's unfulfilled desires and the clandestine nature of her relationship with Rabbu reflect the struggles faced by individuals whose sexuality does not conform to societal norms. The story also touches upon the rigid gender roles imposed on women in a patriarchal society. Begum Jaan is expected to fulfill her duties as a wife and maintain her husband's reputation, but these societal expectations stifle her desires and passions. Her attraction to Rabbu represents a rebellion against these prescribed roles and the constraints imposed upon her.
 
Chughtai's "Lihaaf" serves as a commentary on the limited options available to women to express their sexuality and desires openly. The story suggests that in a conservative society, alternative forms of intimacy and desire may find expression in hidden or coded ways, offering a glimpse into the experiences of individuals who identify as LGBTQ+.
 
Tahir Naqvi’s Remarks on Ismat Chughtai’s
‘The Quilt and Other Stories:
Originally the stories were written by Ismat Chughtai but later on translated by author and renowned translator Tahir Naqvi. He mentions that the world of Ismat is full of middle-class people who have unfulfilled desires and who try to break the gender roles. The same-sex inclinations of the Nawab's male and the Begum's female characters are portrayed as predatory towards children. We see Begum taking advantage of the maid, and the Nawab seems to exploit the young boys. Chughtai plays straight into the stigmatizing notions of queer people as pedophiles and, in general, dangerous individuals by portraying homosexual urges through the eyes of the child as something to be terrified of.
 
One can question whether the author supports the "goodness" of heterosexuality versus the "danger, mystery" of homosexuality.
 
“Kulli Bhatt” – An Autobiography of Suryakant Tripathi Nirala:
“Kulli Bhatt" is an extraordinary autobiography that explores an individual's life journey through the lens of their LGBTQ+ identity. It offers a poignant and empowering account of self-discovery, resilience, and triumphs in the face of societal expectations and discrimination. This autobiography sheds light on individuals' unique challenges and experiences navigating their gender and sexual identities. It celebrates the journey of self-acceptance and embracing a queer identity. The autobiography chronicles the protagonist's exploration and realization of their authentic self, highlighting the complexities and triumphs of accepting one's sexual orientation and gender identity. The autobiography challenges heteronormative expectations and societal norms by sharing the protagonist's experiences. It sheds light on the pressure to conform to traditional gender roles and heterosexuality and the subsequent liberation of embracing one's queer identity. It stands as a testament to the power of personal narratives in promoting understanding, acceptance, and social change for the LGBTQ+ community.
 
“A truth about me: A Hijra Life” by A. Revathi:
"A Truth About Me: A Hijra Life" is an autobiographical account written by A. Revathi, a transgender activist and author. The book offers an intimate and powerful narrative that sheds light on the experiences, struggles, and triumphs of Revathi's life as a Hijra (a transgender woman) in India[10].  The book's main storyline follows Revathi's personal journey, beginning with her childhood in a conservative village where she grapples with her gender identity. Revathi candidly shares her experiences of facing discrimination, rejection, and violence due to societal prejudices against transgender individuals. She explores the challenges of growing up in a society that often marginalizes and stigmatizes transgender people. As Revathi grows older, the narrative delves into her initiation into the Hijra community, a distinct social and cultural group in South Asia. She provides a rare glimpse into the Hijra community's traditions, rituals, and customs, allowing readers to understand their unique identities and struggles. The book also explores Revathi's personal relationships, including her friendships, romantic encounters, and the pursuit of love and acceptance. Through these experiences, she examines the complexities of navigating relationships and intimacy as a transgender woman in a society that often denies her humanity. While recounting the hardships and discrimination faced by Hijras, Revathi also emphasizes the community's resilience, strength, and unity. She highlights the support, sisterhood, and collective activism that emerges as a response to societal marginalization. Revathi's story is one of empowerment, as she actively advocates for the rights and visibility of transgender individuals, fighting against social injustices and working towards greater acceptance and equality. In "A Truth About Me: A Hijra Life," Revathi challenges gender norms, exposes the realities of transgender life in India and offers a powerful voice to a marginalized community. The book serves as a call for empathy, understanding, and social change, inviting readers to reevaluate their perceptions and to recognize and respect the diverse gender identities and experiences of transgender individuals.
 
“A Married Woman” by Manju Kapoor:
“A Married Woman" by Manju Kapoor is a thought-provoking novel that delves into the complexities of love, desire, and societal expectations in the context of a married woman's life. Set in contemporary Delhi, the book follows the journey of Astha, a middle-class woman who finds herself between her roles as a dutiful wife and a woman seeking personal fulfillment.
 
The story begins with Astha, a young woman who enters into an arranged marriage with Hemant, a successful businessman. Astha's marriage initially seems ideal, with Hemant providing for her material needs and her in-laws expecting her to conform to traditional gender roles. However, as time passes, Astha becomes disillusioned and feels stifled by the expectations placed upon her. Astha's life takes an unexpected turn when she meets and befriends a talented and free-spirited artist named Pipeelika. Astha finds herself drawn to Pipeelika in unforeseen ways as their friendship deepens. Their connection transcends societal norms and traditional definitions of love as they embark on a passionate and unconventional relationship. The novel explores the internal conflicts Astha faces as she grapples with her desires, societal expectations, and commitment to her husband and family. Kapoor sensitively portrays the complexities of Astha's emotional journey, highlighting her struggles and sacrifices in her pursuit of personal happiness. “A Married Woman" also sheds light on India's social and political landscape during the 1990s—the narrative touches upon issues such as religious tensions, political upheaval, and gender inequality. Astha's journey becomes intertwined with the larger sociopolitical context, reflecting individuals' challenges in a rapidly changing society. Throughout the book, Kapoor skillfully presents multiple perspectives, examining the impact of Astha's choices on her relationships with her husband, family, and society. The novel prompts readers to question societal norms and conventions, challenging the rigid boundaries imposed upon women and their capacity for self-fulfillment. At its core, "A Married Woman" is a story of self-discovery, empowerment, and the complexities of navigating personal desires within the constraints of societal expectations. Kapoor's vivid storytelling and nuanced character development invite readers to reflect on themes of love, marriage, sexuality, and personal freedom.
 
It is a compelling and evocative novel exploring love and marriage's multifaceted nature. It delves into the complexities of a woman's journey toward self-discovery, challenging societal norms, and pursuing personal fulfillment in a society that often restricts and limits women's choices.
 
“The Man who was a Woman and Other Queer Tales from Hindu Lore” by Devdutt Patnaik:
Devdutt Patnaik's "The Man Who Was a Woman and Other Queer Tales from Hindu Lore" is a collection of captivating stories from Hindu mythology highlighting gender and sexual diversity. Through these tales, Patnaik explores the presence of LGBTQ+ themes and characters within Hindu mythology, providing a unique and inclusive perspective. The book weaves together various narratives, drawing from ancient Hindu texts such as the Vedas, Puranas, and the Mahabharata to shed light on the fluidity of gender and sexual identities within Hindu lore. Patnaik's storytelling skillfully reveals characters who challenge binary notions of gender, blur the lines of sexual orientation, and embrace diverse expressions of love and desire. One of the main stories in the collection is that of Shikhandi, a character from the Mahabharata. Shikhandi is born female but later transforms into a male through divine intervention. This tale not only showcases the complexity of gender identity but also explores themes of acceptance, self-discovery, and the pursuit of one's true nature.
 
Another tale featured in the book is that of Ila, who undergoes a gender transformation from male to female and back again, alternating between identities across different stages of their life. This narrative challenges traditional notions of fixed gender identities, emphasizing the fluidity and versatility of gender expressions[11]. Additionally, Patnaik explores the story of Aravan, the son of Arjuna, who offers himself as a sacrificial bride to the goddess Kali. Aravan's sacrifice symbolizes the celebration of non-binary and transgender identities within Hindu mythology, highlighting the acceptance and acknowledgment of diverse gender identities within the religious framework. It also touches upon the divine manifestations of deities who defy traditional gender roles. For instance, Ardhanarishvara, the half-male and half-female form of Lord Shiva, represents the harmonious union of masculine and feminine energies, blurring the boundaries between genders and highlighting their interconnectedness. Through these narratives, Patnaik provides an LGBTQ+ perspective within the rich tapestry of Hindu mythology. The book challenges conventional interpretations and invites readers to embrace a more inclusive understanding of gender and sexuality. It celebrates the existence and validity of diverse gender identities, offering a platform for the LGBTQ+ community to find resonance within ancient Hindu texts. In conclusion, "The Man who was a Woman and Other Queer Tales from Hindu Lore" explores LGBTQ+ themes within Hindu mythology. Devdutt Patnaik's collection of stories presents a fresh perspective that unveils the presence of gender and sexual diversity in ancient Hindu lore. By highlighting these tales, the book fosters inclusivity, acceptance, and a deeper understanding of the fluidity of gender and sexual identities within the Hindu tradition.
 
Conclusion:
In conclusion, Indian literature and LGBTQ rights are interconnected through a complex tapestry of historical depictions and cultural expressions. While explicit discussions of LGBTQ rights may be limited in ancient texts, Indian literature has portrayed diverse sexualities, non-binary identities, and same-sex relationships across different periods. These literary works shed light on the existence and acceptance of various gender and sexual identities in Indian society. By exploring these narratives, we gain a deeper understanding of the multifaceted nature of human experiences and the ongoing struggle for equality and acceptance. Indian literature is a testament to the interconnectedness of LGBTQ rights with the rich tapestry of Indian culture, challenging societal norms and paving the way for greater inclusivity and understanding.


[1] Universal Declaration of Human Rights,1948, UNDR Booklet,2015.
[2] European Convention on Human Rights, 1950, Protocol No.15.
[3]  Inter-American Convention on Human Rights, 1950, Organization of American States.
 
[4] 10 SCC 1.
[5] Section 377, IPC ,1860-
Unnatural offences:
Whoever voluntarily has carnal intercourse against the order of nature with any man, woman or animal, shall be punished with 1 [imprisonment for life], or with imprisonment of either description for a term which may extend to ten years, and shall also be liable to fine.
Explanation. —Penetration is sufficient to constitute the carnal intercourse necessary to the offence described in this section.
[6] National Legal Services Authority v. UOI, (2014) 5 SCC 438.
[7] Navtej Johar Singh and Others V. UOI, (2020) 10 SCC 1.
[8] Bhagavat Purana, G.V. Tagore,1950.
[9] Journal of Positive School Psychology, 2022, Vol. 6, No. 3, 917–920.
[10] International Journal of Creative Research Thoughts, 2021, Volume 9, Issue 11 November 2021, ISSN: 2320-2882.
[11] Pattanaik, Devdutt, The Man Who Was a Woman and Other Queer Tales from Hindu Lore. New York: Harrington Park Press, 2002. Print.

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