The Constitution of India in Article 51 A (g) states that it is the fundamental duty of every citizen to India to protect and improve the natural environment including forests, lakes, rivers and wild life and to have compassion for living creatures . However, there are number of animal cruelty cases in India some are reported and some unreported. Despite the fact that it is the fundamental duty to have compassion for living creatures, human beings are mercilessly executing inhuman practices towards animals such as puppies set on fire, dog beaten to death, dog breeding, rape of cows, death of pregnant elephant, etc. There are various types of animal cruelty such as physical abuse, emotional abuse, sexual abuse or bestiality, killing of animals etc.

Bestiality is a term which refers to an intercourse between human and animal. It is the degrading and inhuman act of human being having sexual intercourse with animal. Bestiality is a type of sexual offence in which animals are used to fulfill the sexual desire of humans which includes the sexual molestation of animals by anal, vaginal or oral penetration, fondling their genitalia, penetration with an object, oral-genital contacts from person to animal or vice-versa and injuring and killing of animal for sexual gratification.

Animals Mostly Used In Bestiality And Case Studies:

In India dogs are mostly involved in bestiality. However, India is witnessing bestiality on other animals as well such as cow, goat, lizard, bulls, dear, horse and buffalo.

Factors Responsible For Bestiality:

Sexually deviant behaviour is typically seen in males from rural areas of India with low educational background who works in animal farms and have minimum social exposure in his life and sometimes it is also observed in people who has been a victim of sexual abuse in childhood. Apart from this there are many factors which leads to human in committing the heinous crime of bestiality such as lack of sex education, people with people who have limited access to human partners and paraphilic disorder:

Paraphilia or paraphilic disorder or sexual deviation one of the important factor responsible for bestiality. It is defined as unusual fantasies, urges or behaviour that are recurrent and sexually arousing.

There are eight types of paraphilia which are as follows:

• Fetishism: a person who uses non-living things like undergarments, shoes for sexual enjoyment.
• Transvestic Fetishism: when a person develops sexual feeling when he dressed up opposite to his gender.
• Exhibitionism: exposure of private parts in front of stranger for sexual pleasure.
• Voyeurism: person watching the sexual activity of other for sexual pleasure.
• Sexual Masochism: person suffers from sexual abuse or harassment at his childhood.
• Sexual sadism: when a person abuse, harass, torture other person for sexual pleasure.
• Paedophilia: person engaged in sexual fantasies for children.
• Frotteurism: person touches or rubs body of another person for sexual pleasure.

Case Reports:

• Bestiality with Dogs:
  Dogs are more prone to bestiality. In India there many case where dogs have become the victim of bestiality such as a 19 year old boy was arrested for bestiality in the year 2021, according to the FIR, the boy was found sexually abusing stray dog which was recorded by a passerby on his phone. Similarly a 67 year old man was arrested in Gurugram for bestiality in the year 2021.
  
  He was found sexually assaulting one dog of his neighbor. In the year 2021, a 67 year old man was arrested in Mumbai for committing rape on more than 30 stray dogs. A 40 year old man sentenced to six months imprisonment with fine amounting to Rs.1,000/- in Thane, Mumbai for raping a female stray dog. Ahmed Shah, a 67 years vegetable trader was arrested for raping over 30 stray dogs in Juhu Area, Mumbai.
   
• Bestiality with Goats:
  A horrifying report was reported in Kerala that three men alleged raped and killed a four months pregnant goat. Similarly, Ameerul Islam, who booked under charge of murder a laws student was also found of having sex with goat owned by his family and he not raped the goat, he mutilated the private parts of the goat which was recorded in video by the migrant worker. In Haryana, a pregnant goat died after being gang raped by eight men.
   
• Bestiality with Cow:
  A horrifying incident of animal cruelty where a 57 year old man was arrested in raping a cow at dairy in Uttar Pradesh. Another heinous incident from Rajasthan where in the police came into action when a video in which four men were seen raping cow went viral. A person named Kishan was arrested for raping a cow of his employer at the shed in Hoodi, Bangalore. A man named Rajkumar was arrested for raping cows of shelter after being caught red handed by the volunteers of the shelter.
   
• Bestiality with monitor Lizard:
  On 29th March, 2022, India witnessed another inhuman act of human wherein the camera of forest department traps captured four men gang raping a Bengal Monitor Lizard and killing and eating afterward at Sahyadri Tiger Reserve, Maharashtra.

Position Of Bestiality In India And Current Problems:

The Indian Penal Code, 1860:

• Section 377
  "Unnatural offences-Whoever voluntarily has carnal intercourse against the order of nature with any man, woman or animal, shall be punished with [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".

People for the Ethical Treatment of Animals (PETA) India:
PETA India, in the year 2018 after the horrific incident of gang rape and killing of seven year old pregnant goat by eight men in Haryana, urged the Government of India to amend the Prevention of Cruelty to Animals Act, 1960 and include and make bestiality as a cognizable and punishable offence.

Current Problems:
Horrifying stories of humans raping cows, dogs, goats and other animals appears in our newspaper and social media many times and still the laws enacted in India does not adequately punish these disturbed criminals. Section 377 of Indian Penal Code only covers the carnal intercourse which means penetration. It does not cover rest of other sexual abuses which the animals is suffering. Despite the fact that there are several laws enacted for the protection and welfare of animals, however, there isn't any mention of bestiality in any law.

Conclusion And Recommendations:
Animals are an integral component of human existence, they improve the quality of our life and it is our responsibility to do the same for them. This change will come only if there is a change in mind set of people starting respecting and begin treating animal better rather than abusing them. In order to make change there should be stringent rules, legislations and severe punishment and penalties for the cruelty towards animals.

Articles Referred:

• Suyansh Mishra, Bestiality: Is it a Practice or Behavioural Problem, International Journal of Law Management & Humanities, Vol.5 Issue 1, https://enalsar.informaticsglobal.com:2116/HOL/Page?public=true&handle=hein.journals/ijlmhs15&div=62&start_page=663&collection=journals&set_as_cursor=0&men_tab=srchresults
• Mabel Chandra, Nitin Nishad, Mahesh A Tripathi, Bestiality: A Cruelty Towards Animal", Indian Journal of Forensic Medicine & Technology, July-September 2021, Vol.15, no.3.
• Paraphilia human behaviour", Britannica, https://www.britannica.com/science/paraphilia
• Animal Abuse: Study on Inhumanity and Cruelty, ipleaders Intelligent Legal Solutions, https://blog.ipleaders.in/animal-abuse-a-study-on-inhumanity-and-animal-cruelty/#Sexual_Abuse_Bestiality
• Forensic Examination of Bestiality and Related Case Studies of India, SIFS India, https://www.sifs.in/blog-details/forensic-examination-of-bestiality-and-related-case-studies-of-india/47
• 4 cases of dog rape in Mumbai in past few months as concerns over animal safety grow: All you need to know, Opindia, https://www.opindia.com/2021/03/4-cases-of-dog-rape-emerged-from-mumbai-all-you-need-to-know/