Gender-based violence, while primarily perceived as a social issue, it's impact that transcends various dimensions of human relationships, including political, economic, and legal aspects of society. According to the definition of the New York State Office for the Prevention of Domestic Violence, 'Gender-based violence is harm, or threats to harm, committed against a person(s) based on actual or perceived sex, gender, sexual orientation, gender identity or expression, or other such sex/gender-related characteristics. Gender-based violence may include physical, sexual, emotional, psychological, and financial abuse or threats of abuse.

People of all genders, sexual orientations, and gender identities may experience gender-based violence, but women and girls are impacted the most.'[1] According to the UNHCR definition, this social evil is now seen to be spread against the LGBTQ+ community, boys, and men.[2]

Nevertheless, the UNICEF report on Gender-based violence suggests that women and girls remain the major victims of GVB even in this millennium, as they face the greatest threat [3]. It persists as an alarming issue that the WHO has long recognized violence against women as a 'global public health issue'[4]

In data published by The National Crime Records Bureau (NCRB), titled 'declining trend in the crime against women', it is shown that crime against women has dropped to 3,71,503 in the year 2020, as against 4,05,326 in the year 2019.[5] At the same time, in a research article published by Frontier in Public Health, it was recorded that CAW has seen a surge of 15.3% in 2021 over 2020 and 4% in 2022, despite several efforts taken by the government.[6]

There are numerous legislation enacted to address this issue in the country and it is formulated under two heads: women-specific legislation and women-related legislation.[7] Apart from the legislature-enacted laws, there are various judgments of the Hon'ble Supreme Court as well as the High Courts of the country that have taken prerogative actions as a response to this problem in terms of orders, directions, and so on.

Accordingly, to study and analyze the same, the first part of the paper delves into key laws adopted and the historical development of the legal framework against GVB. The second part focuses on judicial responses, development, and its significance to address the issue and the final part focuses on the implications of the research paper.

Objective of the research
The major objective of the research is to analyze various legal measures adopted in terms of legislation, laws, or rules, and judicial responses in terms of judgments, orders, or directions to address the issue of gender-based violence. The paper examines the historical developments of the legal framework to address GBV and attempts to provide general recommendations and implications in the conclusion.

Research methodology
This paper has adopted the analytical method as the primary research methodology. This method involves the systematic study of various legislation in-depth and critically evaluating its efficacy and implications in the legal system. Other methodologies include doctrinal and non-doctrinal methods.

It has extensively examined primary legal instruments, statutes, judicial decisions, and observations to form a comprehensive conclusion. Secondary sources include various reports of the government, including NCRB reports, Human Rights Commission reports, Press Information Bureau reports, and Census reports.

Research question

• What are the legislative measures adopted to address gender-based violence in India?
• What are the judicial responses to gender-based violence in India?
• What is the existing legal vacuum to address the issue of GBV?

Analysis of the legislative measures against GBV
India's legislative framework to address the issue of gender-based violence comprises laws in the form of fundamental rights as enshrined in Part III of the constitution, to various special enactments specifically focusing on preventing, penalizing, and punishing the actions of such violence. Article 14 of the Indian constitution provides for "equality before the law and equal protection of the law"[8] and Article 15 states that "the State shall not discriminate against any citizen on grounds only of religion, race, caste, sex, place of birth or any of them"[9].

At the same time, Article 15 (3) enshrines that:
'Nothing in this article shall prevent the State from making any special provision for women and children.'[10] It is with careful consideration of the prevailing conditions of our society that the constituent assembly has decided to add this non-obstante clause, which is regarded as the special provision for women in the constitution. In the case of Govt. of A.P. v P.B. Vijayakumar,[11] Justice Manohar observed that 'Article 15(3) is an affirmative action provision. The objective of such provisions, according to the SCI, is to remedy the oppression faced by women.[12]'

The laws related to women in India can be classified into two heads, women-specific laws (special laws) which include The Immoral Traffic (Prevention) Act, 1956, [13] and The Dowry Prohibition Act, of 1961[14] (28 of 1961) (Amended in 1986, Indecent Representation of Women (Prohibition) Act, 1986, [15] The Commission of Sati (Prevention) Act, 1987[16] Protection of Women from Domestic Violence Act, 2005,[17]

The Sexual Harassment of Women at Workplace (PREVENTION, PROHIBITION, and REDRESSAL) Act, 2013.[18] The women-related laws (general laws) include provisions under Bharatiya Nyaya Sanhita 2023 and Bharatiya Sakshya Adhiniyam, 2023.

Historical Developments of the legal framework to address GBV
GBV, recognized as a global issue, is not anonymous to Indian society either. The familial structures of Indian culture have always relegated women to a subordinate position within the family itself. Thus, it was perpetuated to an extent where it became an element and characteristic of Indian society.

In addition, some of the cultural practices, such as the dowry system, child marriage, the heinous acts of honor killings, and female infanticides, continue to fuel gender-based violence and can be traced back to these important historical influences that have become part of the fabric of society over time.

However, the measures to transform the existing socio-cultural conditions can be traced back to the pre-independence era, when the British government enacted laws like Bengal Sati Regulation, 1829, the Hindu Widows' Remarriage Act, 1856, Female Infanticide Prevention Act, 1870, and Age of Consent Act, 1891, Child Marriage Restraint Act 1929. The period following the independence also regarded GBV as a pressing issue that was handled with gravity. This is reflected in the enactments passed in terms of specific laws.

Analysis of Key Enactments
In this section of the paper, the major provisions under the laws enacted against gender-based violence are investigated. According to the definition of UNICEF, 'GBV is a pervasive human rights violation that results in the infliction of harm upon a person because of the male-female power imbalance uprooted in society. It takes several forms, such as "sexual violence, intimate partner violence, female genital mutilation, child marriage, sex trafficking, and femicide are all forms of gender-based violence. GBV can be physical, sexual, mental, or economic in nature.'[19]

Analyzing the key enactments from this perspective, it is to be noted that domestic violence exists as the most prevalent and rampant form of GBV in India. Domestic abuse or cruelty by husbands and/or relatives was the highest reported crime against women across India, with 140,019 cases in 20222. [20]

Protection of Women from Domestic Violence Act, 2005
Domestic violence is the major form of GBV in India. In 1989, the Committee of the United Nations dealing with the Convention on Elimination of All Forms of Discrimination Against Women, which is CEDAW, delivered General Recommendation No. XII [21] and called upon State parties to adopt appropriate measures to take effective actions in favor of protecting women from all forms of violence, specifically domestic violence.

Thus, the Protection of Women from Domestic Violence Act of 2005 was enacted. The SC has observed that the statute's interpretation should conform to such international convention.[22] Even though cruelty by the husband or his relatives is recognized as a punishable offense under Section 498-A of the IPC[23] (Sections 85 and 85 of BNS 2023), a civil remedy for such women was nowhere addressed in any laws previously.

In Indra Sarma v. V.K.V. Sarma, (2013) [24], it was held that:
'DV Act is enacted to provide a remedy in civil law for the protection of women from being victims of domestic violence and to prevent the occurrence of domestic violence in society.'[25]

Chapter II of the Act defines domestic violence in a wider scope. It defines:
The expression "domestic violence" includes actual abuse or threat of abuse that is physical, sexual, verbal, emotional, or economic. Harassment by way of unlawful dowry demands to the woman or her relatives would also be covered under this definition. [26].

In the case of Lalita Toppo V. State of Jharkhand[27], the SC has held that the act or omission defining domestic violence under the Act is wide enough to include any aggrieved person who is not a legally wedded wife and those not entitled to maintenance under Section 125 of CrPC as well.

Further, the act of economic abuse is also regarded as an offense under the DV Act. In the case of Saraswathy v. Babu,[28] the SC opined that 'Economic abuse' includes prohibition or restriction to continued access to resources or facilities which the aggrieved person is entitled to use or enjoy by domestic relationship including access to shared household"

Chapter IV of the DV Act, which deals with the procedure for obtaining orders and reliefs[29] is regarded as the cornerstone of the Act. Section 12 of the Act under this chapter enables an aggrieved person or any person on behalf of that person to present an application before the Magistrate for seeking one or more reliefs, including relief forthe issuance of payment of compensation. Such applications are required to be disposed of within 60 days of their first hearing.

Section 17 of the Act provides for the "right to reside in a shared household," which speaks about the right of every woman in a domestic relationship to reside in the shared household irrespective of her beneficial interest in it. In Vimal Ajitbhai Patel v. Vatslaben Ashokbhai Patel[30], it was observed that "Section 17 provides for a higher right in favor of the wife. She not only acquires a right to be maintained but also thereunder acquires a right of residence which is a higher right. However, said right, as per the legislation extends only to joint properties in which the husband has a share".

A more profound stand was taken by the SC in Ishpal Singh Kahai v. Ramanjeet Kahai[31], where it highlighted a salient aspect of the Act that determines rights under Section 17 of an aggrieved wife. The court held that:
'Victims can apply for a residence order to the court in a shared household, including their matrimonial home, in which they have a title or not. The very consideration of ownership rights would put materialism before matrimony.'

Section 19 of the Act enables the aggrieved woman to seek an alternative accommodation as well. 'The same shall be on par with the shared household which she enjoyed at some point in time'[32].

Dowry Prohibition Act, 1961
The perception of women as subordinate is complemented by the long practice of another social evil in society that has led to physical, mental, and psychological abuses of women and sometimes extends to their family members as well. Even in 2022, the number of dowry deaths has been reported as around 6400 cases (though it is less compared to 8500 cases in 2014) [33] Thus, the social evil of the dowry system remains a crucial concern in eliminating gender-based violence in India. Nevertheless, the enactment of the act led to the penalization of:
'Not only the actual receiving of dowry but also the very demand of dowry made before or at the time or after the marriage where such demand is referable to the consideration of marriage'[34] is a milestone in the Indian legal system. The following part deals with the analysis of important provisions of the Act.

Section 2 of the Act deals with the definition of dowry. The provision was explained in understanding various occasions under which the act of receiving or demanding dowry can be connected, in the case Kamesh Panjiyar v. State of Bihar,[35] as:
'Before the marriage, at the time of marriage and at any time after the marriage in connection with the marriage.' In the case of Ashok Kumar v. State of Haryana, the court has also held that the expression "in connection with the marriage" should be given wide meaning and understood generally. [36]

Section 3 deals with punishment for giving and taking of dowry, which extends imprisonment up to 5 years and a fine not less than the value demanded as dowry. Section 4 deals with demand for such dowry, which leads to an imprisonment of 6 months and extends up to 2 years, and a fine which may extend up to Rs 10000.

In the case of L.V. Jadhav v. Shankarrao Abasaheb Pawar,[37] the court held that:
'Section 4 should not be strictly construed to mean a woman or man who has just been married or is about to be married and shall be included in the phase before the time when the woman had become a bride or the man had become a bridegroom. It shall be given a liberal interpretation.'[38].
Moreover, the provisions of criminal breach of trust have also been assimilated to prevent any misuse of 'stridhan' provided to the bride at the time of marriage.

In the Surinder Singh v. Rajinder Kaur case, the SC stated:
'Failure to return articles of dowry after one year or mis-utilizing them within one-year amounts to criminal breach of trust. The provisions of CrPC would apply to the case trial under Section 6 of the Dowry Prohibition Act.'[39]

The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013
This Act is another significant piece of legislation enacted by the Parliament to address and eliminate GBV in society. This was enacted following the landmark judgment of the SC Vishaka v. State of Rajasthan[40] to protect against sexual harassment of women in the workplace and establish a systematic complaint redressal for such matters. It is protective legislation; hence the Delhi HC has held that an interpretation that promotes and advances its object shall be adopted.[41]

A section of the Act deals with the definition clauses. In Global Health (P) Ltd. v. Local Complaints Committee,[42] the SC held that the term "sexual harassment" under Section 2 (n) must be given the widest interpretation as it is an inclusive provisional clause and "it shall not receive any narrow and pedantic meaning.

Section 3 prohibits sexual harassment in the workplace and enlists circumstances that amount to sexual harassment. It recognizes even an implied sexual advance or sexual undertone in the promise of preferred treatment, or threat of detrimental treatment, as an offense.

Section 4 of the Act deals with the duty of the employer to constitute a Committee known as the "Internal Complaints Committee" for the inquiry of any complaints related to sexual harassment at the workplace.

Section 9 deals with how complaints of sexual harassment are to be treated. In the case of Addl. District & Sessions Judge 'X' v. High Court of M.P[43]., it was held that:
'Any case of allegations about sexual harassment against sitting judges of High Courts or Supreme Courts is to be enquired in 'In-House Proceedings 'only' [44] it is to protect institutional credibility as well as unbiased justice to the parties.

The Immoral Traffic (Prevention) Act, 1956:
This Act was enacted in pursuance of the International Convention for the Suppression of the Traffic in Persons and the Exploitation of the Prostitution 1950[45] to which India is a signatory. Article 23 of the constitution prohibits human trafficking[46]. In India, women and children remain the major victims of human trafficking. Hence, this Act was introduced with the object of preventing the commercialization of the vice and trafficking among women.

Section 3 of the Act deals with running a brothel or letting premises for a brothel as a punishable offense with rigorous imprisonment for a minimum of 1 year. In the case of State v. Gaya, 1959, the Bombay HC has observed that:
Sub-section 1 to section 3 intends to hit at persons who establish and maintain houses of prostitution or act or assist in keeping or managing them. It was never intended that the women used for such traffic should be liable to punishment.' [47] However, in reality, it is the helpless women who are destitute and devoid of any familial support and forced into prostitution by exploitation and sex trafficking who are arrested and prosecuted under the Act.

The big influential exploiters or traffickers or pimps who run the racket often circumvent the law and escape from the This is regarded as a criticism of the effective enforcement of the Act.

Section 4 of the ITPA punishes the person who knowingly lives on the earnings of prostitution. It is a gender-neutral provision as it makes no distinction between male and female.[48]
Section 10-A deals with Detention in a corrective institution. It provides for keeping such women arrested under the Act in a Protective Home, as such persons also have the right to dignity. [49] Similarly, in the case of Budhadev Karmaskar v. State of W.B., it was also held that prostitutes or sex workers have a right to live with dignity under Article 21 and the responsibility of the State to take steps to rehabilitate such persons.[50]

Section 16 of the Act deals with the 'Rescue of person' and Section 21 deals with the establishment of 'Protective Homes' by the State Governments. In Gaurav Jain v UOI, the SC emphasized the need to rescue, rehabilitate, and provide an alternative livelihood for the children of prostitutes.[51] Further, in the case of Budhadev Karmaskar v. State of West Bengal, the court affirmed that the government shall take measures to ensure supplying ration cards and voter IDs to sex workers and make requirements for the school admissions of children of sex workers. [52]

The Indecent Representation of Women (Prohibition) Act, 1986:
Indecent representation of women is regarded as one of the grave forms of gender-based violence in society. Even though there might not be any form of physical violence against women, the psychological harm and mental distress as a result of such representation causes grave anguish. It also leads to the perpetuation of prejudicial, stereotypical, or customary roles formed based on the idea that women as inferior.

This ultimately serves no good but rather reinforces patriarchal practices, encourages misogyny, legitimizes gender inequality, and leads to gender-based outbreaks of violence. Despite having provisions in the general penal law that penalize obscenity under Sections 293, 294 (Section 294, 295, and 296 OF BNS), women are being subjected to indecent representation. This section of the article focuses on the specific law that is implemented to prohibit such indecent representation of women.

The Indecent Representation of Women (Prohibition) Act was enacted in 1986 to punish publishers and advertisers who knowingly disseminate any material that indecently depicts women. Section 3 of the Act prohibits such advertisements in any form. In the case of Aveek Sarkar v. State of West Bengal, the test to determine obscenity was held to be determined from 'The point of view of an average person and also by considering the context of contemporary standards.' [53]

Section 6 punishes any person who contravenes Section 3 with imprisonment for a term extending 2 years, a fine extending Rs 10000, and a higher punishment for repeated offenses.
Section 7 punishes when such an offense is committed by companies. And natural persons are vicariously held liable for the offense committed by a company [54]

However, historically many art forms like literature, theatre, satirical acts, etc. are often mixed with the elements of obscenity, and the court in such cases has adopted a rational approach as it involves the right to expression of creative freedom as well.

In Ajay Goswami v. UOI, the court has held that:
'Where art and obscenity are mixed, what must be seen is whether the artistic, literary, or social merit of the work outweighs its "obscene" content,'[55] Therefore, there is also a need to consciously scrutinize such work to prevent any misuse of such exceptions.

The Commission of Sati (Prevention) Act, 1987
Sati is a deep-rooted societal malignancy that was widely prevalent and practiced in Indian societies for thousands of years. It is a harmful practice where a widowed woman will immolate herself on the funeral pyre of her deceased husband. It represents critical gender-based violence as it is an extreme violation of women's rights and dignity, which is preceded by the patriarchal norm that women cannot lead an independent, dignified life without men they depend upon. It was manifested as a virtuous act and thereby naturalized GBV. The Sati Prevention Act was enacted to eradicate this social evil from society.

In Ch. Khemi Shakti Mandir Trust v. UOI, it was held that the object of the Sati Prevention Act is to prohibit sati and its glorification, and it is a legitimate objective. [56]
Sections 3,4, and 5 deal with punishment for offenses relating to Sati, which includes punishment for attempt to commit sati, abetment to sati, and glorification of sati, respectively.
Section 16 casts the burden of proof on the accused in the case charged under Section 4.

The last reported case of Sati in India in 1987 and the strict implementation of the law have managed to eradicate the commission of Sati gradually from society. This is a remarkable, at the same time quintessential phenomenon to address any form of gender-based violence in society.

Judicial Responses to Gender-Based Violence:

The judicial response to gender-based violence in India has been instrumental in adopting measures to eradicate the deeply entrenched societal inequalities and render justice to the aggrieved parties of the GBV. The contribution of the Indian courts is remarkable not only in interpreting the statutes and advancing the effective implementation but also in delivering landmark judgments in the form of rules, orders, and directions by assimilating the changing needs and reinforcing the fundamental rights of women in society. This part of the paper analyzes such landmark judicial responses to the GBV.

• Vishaka and others v. State of Rajasthan (1997)
  This case comes before the SC as a result of the filing of a Public Interest Litigation by a women's group led by Naina Kapur and Sakshi following the gang-rape of a social worker in Rajasthan. It recognized the right of working women to work with dignity and the right against any kind of sexual harassment at workplaces under Art. 21 of the Constitution. The decision of the SC, in this case, is transformative in terms of providing not only a definition of sexual harassment in the workplace but also laying critical guidelines and establishing a standard framework for preventing such incidents.
  
  'In the absence of domestic law occupying the field, to formulate effective measures to check the evil of sexual harassment of working women at all workplaces, the contents of international conventions and norms (Convention on the Elimination of All Forms of Discrimination against Women and Protection of Human Rights Act 1993) are significant for interpretation of the guarantee of gender equality, right to work with human dignity in Articles 14, 15, 19(1)(g) and 21 of the Constitution and the safeguards against sexual harassment implicit therein.'
  
  The SC prescribed these guidelines and norms for strict adherence in all workplaces for the enforcement of gender equality and to eradicate any gender-based violence against women. This direction of the SC was held to be followed as long as appropriate legislation is implemented. This led to the enactment of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013.
   
• Laxmi v. Union of India (2016)
  This case is regarded as one of the significant judicial responses taken by the judiciary to firmly act against deeply concerning forms of gender-based violence in India. In this case, the petitioner was attacked with acid by a man for refusing his marriage proposal. As a young girl who had no proper supportive mechanism as an acid-attack survivor and underwent severe physical and psychological wrath filed a PIL before the SC for the implementation of stringent measures in the procuring and sale of acids.
  
  The judgment led to the specific criminalization of acid attacks under Section 326A and 326B of the IPC (Section 124 of BNS). The judgment is also instrumental in the grant of adequate compensation and compulsory medical treatments, and rehabilitation of the affected women. It also led to the rule of sale of acid only to individuals above the age of 18 years with valid ID proof and submission of a statement of purpose.
   
• Mukesh & Anr v. State for NCT of Delhi & Ors (2017)
  Also known as the Nirbhaya Case, it is the most significant case that led to serious amendments and transformation of the legal system in India's criminal law and implementation of the Criminal Law (Amendment) Act, 2013.
  
  The SC upheld the death penalty for the convicts of this case who committed the heinous offense of assault and gang rape of a 19-year-old young woman in a running bus, which ultimately caused her to death. The judgment discussed the significance of adopting a 'victim-centric' approach by accentuating the need to recognize the rights of victims and their family members.
   
• Independent Thought v. Union of India (2017)
  This case penalized marital rape of girls under the age of 18 years. It highlighted the need to adopt a harmonious and purposive construction to a pro-child statute that is specifically enacted for the purpose of protecting the rights of children. Martial rape which is not a punishable offense under the criminal law of India has been criminalized through this judgment in the cases dealing with the marital rape of a girl child below the age of 18 years by emphasizing the necessity for prevailing of provisions of the POCSO Act and JJ Act over the IPC to prevent child abuse and GBV.
   
• Shayara Bano v. Union of India (2017)
  Shayara Bano case, popularly known as the 'triple talaq' case, is one of the most controversial yet path-breaking judgments rendered to advance gender justice in India. The judgment while trying to strike a balance between personal laws and constitutional rights, declared the practice of triple talaq as unconstitutional and the Muslim Personal Law (Shariat) Application Act of 1937 was held void to the extent it validated the Talaq-e-Bidat (triple talaq) as it violated the Article 14 of Part III of the Constitution.
  
  The practice of triple talaq, which allows the husband in a Muslim wedlock to unilaterally divorce his wife instantly with no effect of reconciliation of marriage, was declared to be void by applying the test of manifest arbitrariness. Thus, the court took a proactive measure to address the longstanding issue of GBV among Muslim women.

Conclusion
India is home to around 1.42 billion people, and it has an estimated sex ratio of 1020 females per 1000 males. [63] This is a remarkable transformation in social dynamics when compared to the sex ratio statistics of 2011, which were 943 females per 100 males. [64] This reflects a change in the mindset of society regarding the bringing up of a girl child. This shows that the number of female infanticides in the country has drastically reduced. But the primary question is whether the violence against women has been equally reduced. Historically, the practices and customs in Indian societies revolved around the patriarchal norms assigning stereotypical gender roles and restraining women within the walls of their homes due to the perception of women as subordinates.

However, the constant measures adopted by the organs of the government of independent India to strive for an equal society in terms of treatment and opportunity and achieve the tenets of the preamble as to social, economic, and political justice, including gender justice, are gradually reflected. Addressing the GBV in society requires something more than having numerous legal instruments, nevertheless, it is the major device for socio-legal transformation. Even today, many households in Indian society are patriarchal, and this transformation requires socio-cultural restructuring through education and gender awareness.

The judicial responses to GBV have contributed tremendously to the country by adopting international conventions and assimilating them with domestic laws. It has also persuaded lawmakers to enact laws to address the potholes and loopholes in the legislative system and implement more stringent and protective laws to prevent gender-based violence and ensure gender equality in the country. But there are still areas that require a proactive step from the end of legislators and the judiciary to eliminate the issue of GBV. The issue of marital rape among women is still not a punishable offense in India.

Similarly, Anti-trafficking laws must be made more stringent in a way to punish real offenders like traffickers rather than helpless prostitutes who are subjected to trafficking. This must be addressed expeditiously. Apart from this, a major contemporary concern is technology-facilitated gender-based violence. With the rise of open-source AI systems, determining liability for complicity in enabling synthetically generated content, such as deepfakes, remains unaddressed by the existing legal framework.

Therefore, as long as these concerns are not addressed according to the changing needs of society, complete gender justice cannot be achieved.

End Notes:

1. What is Gender Based Violence?, Office for the Prevention of Domestic Violence, https://opdv.ny.gov/gender-based-violence, December 20, 2024.
2. Protecting lesbian, gay, bisexual, transgender, intersex and queer (LGBTIQ+) persons, https://emergency.unhcr.org/protection/persons-risk/protecting-lesbian-gay-bisexual-transgender-intersex-and-queer-lgbtiq-persons, UNHCR, December 20, 2024.
3. Gender-Based Violence, https://www.unicef.org/protection/gender-based-violence-in-emergencies, UNICEF, December 28, 2024.
4. Violence against women, https://www.who.int/news-room/fact-sheets/detail/violence-against-women, World Health Organization, December 20, 2024.
5. Press Information Bureau, Government of India, Ministry of Women and Child Development, https://pib.gov.in/Pressreleaseshare.aspx?PRID=1843007, Declining trend in the crime against women, December 28, 2024.
6. Crime against women in India: district-level risk estimation using the small area estimation approach, https://pmc.ncbi.nlm.nih.gov/articles/PMC11288248/, Frontiers in public health, Pooja, B. S., Guttate, V., & Rao, K. A. (2024), December 28, 2024.
7. Laws Related to Women, http://ncw.nic.in/important-links/List-of-Laws-Related-to-Women, National Commission for Women, December 20, 2024.
8. India Const. Art. 14
9. India Const. Art. 15 (1)
10. India Const. Art. 15 (3)
11. Govt. of A.P. v P.B. Vijayakumar, (1995) 4 SCC 520.
12. Unnati Ghia, National Law School of India Review, 2020, Affirmative Action Under Article 15(3) - Scholarship Repository, https://repository.nls.ac.in/cgi/viewcontent.cgi?article=1086&context=nlsir, December 28, 2024.
13. Immoral Trafficking (Prevention) Act, 1956, No. 104, Acts of Parliament, 1956 (India)
14. The Dowry Prohibition Act, 1961, No. 28, Acts of Parliament, 1961 (India)
15. The Indecent Representation of Women (Prohibition) Act, 1986, No. 60, Acts of Parliament, 1986 (India)
16. The Commission of Sati (Prevention) Act, 1988, No. 3, Acts of Parliament, 1988 (India)
17. Protection of Women from Domestic Violence Act, 2005, No. 43, Acts of Parliament, 2005 (India)
18. Sexual Harassment of Women at Workplace (Prevention, Prohibition, and Redressal) Act, 2013, No. 14, Acts of Parliament, 2013 (India)
19. Gender Based Violence, https://www.unicef.org/protection/gender-based-violence-in-emergencies, UNICEF, December 22, 2024.
20. India: reported crimes against women by types 2022, https://www.statista.com/statistics/633038/reported-crimes-against-women-by-type-india/, Statista, December 22, 2024 (August 23, 2024).
21. General recommendations made by the Committee on the Elimination of Discrimination against Women, https://www.un.org/womenwatch/daw/cedaw/recommendations/recomm.htm, United Nations, December 28, 2024.
22. Vandhana v. T. Srikanth, 2007 SCC OnLine Mad 553.
23. Section 498-A IPC, Husband or relative of husband of a woman subjecting her to cruelty.
24. Indra Sarma v. V.K.V. Sarma, (2013) 15 SCC 755.
25. Indra Sarma v. V.K.V. Sarma, (2013) 15 SCC 755.
26. Chapter II, Section 3 of DV Act https://lddashboard.legislative.gov.in/actsofparliamentfromtheyear/protection-women-domestic-violence-act-2005
27. Lalita Toppo v. State of Jharkhand, (2019) 13 SCC 796.
28. Saraswathy v. Babu, (2014) 3 SCC 712.
29. Chapter IV, Sections 12-29 of DV Act.
30. Vimlaben Ajitbhai Patel v. Vatslaben Ashokbhai Patel, (2008) 4 SCC 649.
31. Ishpal Singh Kahai v. Ramanjeet Kahai, 2011 SCC OnLine Bom 412.
32. M. Muruganandam v. M. Megala, 2010 SCC OnLine Mad 6012.
33. India: dowry deaths 2022, https://www.statista.com/statistics/632553/reported-dowry-death-cases-india/#:~:text=Number%20of%20reported%20dowry%20death%20cases%20in%20India%202005%2D2022&text=In%202022%2C%20reported%20dowry%20death,number%20was%20approximately%208.5%20thousand., Statista, December 24, 2024 (February 14, 2024).
34. S. Gopal Reddy v. State of A.P., (1996) 4 SCC 596.
35. Kamesh Panjiyar v. State of Bihar, (2005) 2 SCC 388.
36. Ashok Kumar v. State of Haryana, (2010) 12 SCC 350.
37. L.V. Jadhav v. Shankarrao Abasaheb Pawar, (1983) 4 SCC 231.
38. L.V. Jadhav v. Shankarrao Abasaheb Pawar, (1983) 4 SCC 231: 1983 SCC (Cri) 813.
39. Surinder Singh v. Rajinder Kaur, 1971 SCC OnLine P&H 364.
40. Vishaka v. State of Rajasthan, AIR 1997 SC 3011.
41. Sohail Malik v. Union of India, (2023) 3 HCC (Del) 228.
42. Global Health (P) Ltd. v. Local Complaints Committee, SCC OnLine MP 5453.
43. Addl. District & Sessions Judge 'X' v. High Court of M.P., (2015) 4 SCC 91.
44. Addl. District & Sessions Judge 'X' v. High Court of M.P., (2015) 4 SCC 91.
45. https://www.ohchr.org/en/instruments-mechanisms/instruments/convention-suppression-traffic-persons-and-exploitation
46. Indian Const. Art 23 - Prohibition of traffic in human beings and forced labour.
47. State v. Gaya, 1959 SCC OnLine Bom 46.
48. Moainuddin v. State of Andhra Pradesh, 1985 SCC OnLine AP 208.
49. Prajwala (II) v. Union of India, (2005) 12 SCC 136.
50. Budhadev Karmaskar (1) v. State of W.B., (2011) 10 SCC 538.
51. Gaurav Jain v. Union of India, (1997) 8 SCC 114.
52. Budhadev Karmaskar v. State of W.B., (2011) 10 SCC.
53. Aveek Sarkar v. State of W.B., (2014) 4 SCC 257.
54. Municipal Corporation of Delhi v. Bhagwan Dass, 1972 SCC OnLine Del 47.
55. Ajay Goswami v. Union of India, (2007) 1 SCC 143.
56. Ch. Khemi Shakti Mandir Trust v. Union of India, (2010) 15 SCC 768.
57. Vishaka v. State of Rajasthan, AIR 1997 SC 3011.
58. Vishaka v. State of Rajasthan, (1997) 6 SCC 241.
59. Laxmi v. Union of India, (2016) 3 SCC 669.
60. Mukesh & Anr v. State for NCT of Delhi & Ors, (2017) 6 SCC 1.
61. Independent Thought v. Union of India, (2017) 10 SCC 800.
62. Shayara Bano v. Union of India, (2017) 9 SCC 1.
63. Update on Child Sex Ratio, https://pib.gov.in/PressReleasePage.aspx?PRID=1782601, Press Information Bureau, December 28, 2024.
64. Sex Ratio in India, https://mospi.gov.in/sites/default/files/reports_and_publication/statistical_publication/social_statistics/WM16Chapter1.pdf, Ministry of Statistics and Programme Implementation, GOI, December 28, 2024.