Women have been serving in the defence forces of developed countries for a long time. India as a nation isn't all that experienced concerning the introduction of women in the armed forces. Women have crossed various milestones in all aspects of life. They are also actively coming forward in large numbers to join the defence services but the role of women in combat forces is still a matter of debate today.

Earlier they were allowed to only serve for a limited period after joining the service through Short Service Commission. While delivering its verdict to grant permanent commission to women in the armed forces the Supreme Court shattered the glass ceiling for lady cadets and came down heavily on the gender stereotypes employed by the government. This paper concludes that as long as a candidate is qualified for the post, their gender is arbitrary.

Cultures change over time and the male subculture can change as well. This nullifies the governments' argument about the readiness of soldiers mostly from rural backgrounds to take orders from a female officer. Administrative issues should not be cited as a barrier to women's entry. There is a need to mould the attitude of society at large particularly of male soldiers to enhance the acceptability of women in the military. The daughters of our country are kissing the skies on their fighter aircraft. The battle for gender equality is about confronting the battles of the mind.

Introduction
Gender equality in India has always been a troubled and controversial subject. Women and the third gender are struggling for their rights and are still fighting in this patriarchal society. Gender stereotypes still create barriers for the third gender and women in professional spaces and also worsen gender discrimination in the workplace, one such example of this is the Indian defence. India has the most powerful and extremely capable military power after the US, Russia, and China and has been ranked fourth in the world, but gender disparity has always been a part of armed forces since it was established. The supreme judicial body of India, The Supreme Court of India in many of its recent judgments has set aside such patriarchal notions by granting women officers permanent commission and allowing women to take NDA (National Defense Academy) exam.

Recently, it was found out that there has been an increase in the number of women and it is rising consistently. It is rising to a level that we can say that the Indian army has a lot of women, in comparison to men. There is just 0.56 per cent of them, but if we talk about the number of women it has increased in recent times especially after 2015.

The lowest number of women in percentage is in the Indian army that is 0.56%, in the Indian air force there is only 1% of women, and in Indian naval forces there are 6% of women which is slightly greater than the other two forces.[1] Women's participation in defence services has taken an upturn lately, which is a piece of good news for the country. Many developed countries have women as officers who are serving in defence services for their country for a long period.

Role of women in defence
The Indian army has a total of 1,455,550 active troops making it the fourth country with the highest military power in the world. The role of women in the Indian Army began in 1888 when the Indian Military Nursing Service was formed during the British Raj. In 1992, the Indian military started admitting women as officers in non-medical roles but was and still are not allowed to participate in combat units such as infantry, armoured corps, and mechanized infantry other than specialized combat forces such as Garud Commando Force, MARCOS, Para commandos, etc.[2]

But over the years, women have been inducted into various branches of the three services. In 2015, India also opened up new roles in combat aviation for women as fighter pilots and inspired women to become helicopter pilots in the Indian Air Force.[3]

The first female peacekeeping force for the United Nations was in 2007, which involved 105 Indian women deployed to Liberia. The part of women in defence expanded with the establishment of WAP (Women Auxiliary Corps) which gave them the opportunity to serve in non-combat roles i.e., communications, interpreters, administration, etc.

Noor Inayat Khan is one of the legendary names who served during World War II in Special Operations Execution. The involvement of women in the armed forces has been tremendous during the time of war. When Netaji Subhas Chandra Bose's Azad Hind Fauj was established, a women's combat regiment known as Rani of Jhansi Regiment was made wherein female warriors were seen fighting in the battlefront versus the Japanese army. Barbara Ghosh was the only female officer who attained the position of commander in the Indian Navy.[4]

She served as the first woman medical officer who received a permanent naval commission. Dr Punita Arora became the first female officer who reached the second-highest rank as Lt. General and first woman Vice Admiral. Many legendary names like Gunjan Saxena, Sreevidya Ranjan, Deepika Misra, Nivedita Choudhary, Priya Jhingan, Ruchi Sharma made it to the list with their astounding work and dedication towards their profession.

Recruitment into the Indian Army is voluntary, which means that every Indian citizen is eligible regardless of caste, religion, gender, etc. Young, bright, and energetic men and women constitute the bulk of the military force. India is gradually moving towards optimistic change, but there is still a long way to go. The Indian government should realize that the nature of war in the future will be completely different from the war India has experienced in the past. For sustained growth, a strong nation like India must strengthen its military capabilities by bringing more women into the military with the shifting domain of the battlefield in mind.

Grounds for under-representation of women
Women have faced plenty of challenges for their rights and to get what they deserve. This long legal battle of equality and equal opportunity will not end until justice has been served accurately. One such example of the under-representation of women in the professional sector is the Indian defence in which the low number of females has become an alarming situation. Various issues cause hindrances for women to be inducted in the combat operations, the reasons for such problem are:

• The natural physical differences in stature, strength, and body composition between the sexes make women more vulnerable to certain types of injuries medical problems, particularly during rigorous and intensive training. There is a stereotype against women that they are physiologically weaker and they are much more vulnerable to be captured as Prisoners of war.
   
• Lack of privacy and sanitation can result in increased incidents of genital urinary infections.
   
• Women tend to be more attached to their families, thus there is great mental stress in them. Requirement of social support to sustain themselves during prolonged separation from their families.
   
• Prospects of women in combat roles are also discouraged by conventional cultural barriers.
   
• The patriarchal notion, the idea of patriarchy that says that women are the primary caretakers of the family. They will need to lead to the call of marriage pregnancy and childbirth.
   
• Some women have been moulded in such a way that they have accepted the fact that they are the only caretakers and have the entire responsibility of taking care of the family, nurturing the child falls only upon them.

Permanent Commission or Short Service Commission
This topic has been in the news lately as there has been a lot of discussion regarding the granting of permanent commission and short service commission to the existing as well as upcoming female officers. Plenty of judgments has also been passed by the Supreme Court in this matter. In the army, there are two ways through which a person can join the service. The first way is through the Permanent Commission and the other way is through the Short Service Commission. As the name suggests, a Permanent Commission means a career in the army until one retires which varies between 54-60 years.

Officers opting for PC are trained in NDA (National Defense Academy), Pune and IMA (Indian Military Academy), Dehradun. On the other hand, Short Service Commission is a path through which officers are inducted for 10 years. They also have the option of a 4-year extension. After the end of this duration, they are provided with two options i.e., to elect for PC or opt-out from the service. Officers who are appointed through SSC are trained in OTA (Officers Training Academy).

Women officers who joined the armed forces through SSC were not offered ab initio permanent commission in any of the forces. While the male officers who joined armed forces through SSC could opt for PC at the end of 10+4 years of the service, this option was not available to women officers and was highly discriminatory.[5] Thus, they were kept out of any commanding appointment. This led to numerous litigations which brought vital changes in the field of defense.

Judiciary has played an important role in explaining this issue correctly. In the Indian Navy in the year 1999 February, a letter was sent to the chief of the naval staff by the Union Government specifying the rules and regulations that opened a path for the female officers for getting a Permanent Commission. In the case of Lt. Cdr. Annie Nagaraja & Ors. v Union of India,[6] Delhi High Court stated that SSC officers of the navy who opted for but were not granted PC should be granted PC within six weeks.

This decision of the High Court was contradicted by the AFT (Armed forces tribunal) saying that it does not have enough materials to decide the grant of PC and further decisions will be left to the suitable authorities. Further in this case the decision was taken in favor of the petitioner and PC was granted to the female officers same as their male counterparts. Indian Air Force started enrolling females in November 1991. They were only appointed through SSC and not PC.

In the case of Jasmine Kaur vs. Union of India,[7] Wg. Cdr. Jasmine Kaur was the first female officer who filed a writ petition asking for the grant of PC to all the female officers on SSC. The judgment was in favor of the female officers and PC was granted, thus making the way forward.

In January 1992, the Union Government of India made amendments in the Indian Army by making females eligible in specific branches of the army on SSC. In 2003, a case was first filed in Delhi High Court by women officers seeking a permanent commission. Many senior officers namely Major Leena Gaurav and Lt. Col. Seema Singh also moved to the court regarding the same issue. Delhi High Court in 2010 ruled in favor of the female officers and held that women who were already serving under SSC shall be granted PC after 5 years of service with all the benefits within 2 months of the order. Later in 2011, this judgment of the Delhi High Court was challenged in the Supreme Court as the appeal was filed by the Army.

In February 2019, in the case of Secretary, Ministry of Defence v. Babita Puniya & Ors.,[8] the Union Government ordered to grant PC to all SSC recruited female officers in eight combat support services with less than 14 years of service. Later in February 2020 Supreme Court finally regulated a notice to the Union Government regarding the grant of PC to female officers and further steps were taken to grant all women the right to be on the same level as their male counterparts resulting in a 17 years-long court battle coming to an end. This was only about permanent commission and command roles in non-combat streams of the army. Women officers are still not allowed to serve in combat units like the infantry, the armored corps, mechanized infantry, etc paving the way to another battle for women officers to conquer.

Breaking the stereotypes
The number of female officers in the Indian Defense service is comparatively less than male officers. The reason behind this is the patriarchal thought-process of the society and the restricted participation of women in this sector. But after the Supreme Court's Judgement regarding the same issue, the participation of females has increased drastically. The government has come down strictly on the gender stereotypes and has cleared the way for females to participate fully in this sector without any hindrance.
  Table 1 explains the insights according to the 2020 report, the number of male officers in the Indian army is nearly around 12 lakh which is greater than the number of female officers that constitute only 3.89%. In the Indian Air Force, there are 13.28% of female officers (Excluding Medical and Dental personnel). On the other hand, the Indian Navy has 6.7% female officers, which is more as compared to the other two forces.

Recently, a petition was filed in the Supreme Court in which violation of Articles 14, 15, 16, and 19 were raised by denying the eligible women to join NDA.[9] In this matter, the apex court passed an interim order stating that women will be allowed to take an exam to NDA (National Defense Academy) from the year 2022 as before it was not available for females to take admission in NDA. The Supreme Court bench of Justices Sanjay Kishan Kaul and Hrishikesh Roy criticized the Indian army and its policy's decision as gender discrimination for not allowing females to participate in NDA exams and proclaimed to change their mindset.
 

Number Of Females (%) Â
Year	Army	Navy	Air Force
2014	3	2.8	8.5
2018	3.80	6	13.09
2020	3.89	6.7	13.28

Conclusion
India as a developed country needs to think about opening the opportunities for females to serve in combat roles as well because many countries such as Canada, Israel, North Korea, Germany, France are open to women being inducted in combat positions and to keep pace with the other developed economies, this needs to be done. There is a change that is being brought about step by step but we need to catch up.

By striking at the core of the patriarchal notions that only females have to take care of the family as it is their primary responsibility and everything else including their career is secondary and especially a career in the armed forces is out of their reach.

We need to understand and look at it from a different perspective that women and men stand equally when we talk about being the fulfiller of domestic obligations. Thus, expecting and putting everything on one gender is not justifiable. This needs to be taught to the youngsters of the society that women are no less than men when it comes to being physiologically, mentally, and emotionally equal. Until and unless the government is supporting the cause of women and thrusts its belief through different reforms this can't be achieved.

End-Notes:

1. Subhasish Chakraborty, Women in Indian armed forces. She is unique, Economy and Politics (19/09/2021), available at https://wsimag.com/economy-and-politics/66942-women-in-indian-armed-forces-she-is-unique, last seen on 20/11/2021.
2. Preethi Amaresh, Regendering Equality: Women in the Indian Armed Forces, Extraordinary and Plenipotentiary Diplomatist (11/05/2020), available at https://diplomatist.com/2020/05/11/regendering-equality-women-in-the-indian-armed-forces/, last seen on 20/11/2021.
3. SUPRA 2.
4. Women in Indian Armed forces, Wikipedia, available at https://en.wikipedia.org/wiki/Women_in_Indian_Armed_Forces, last seen on 25/11/2021.
5. Kruthika R and Mihir R, Court Recognises indirect discrimination & strikes down army's gender discriminatory promotion practices, Supreme Court Observer, (2021), available at https://www.scobserver.in/journal/court-recognises-indirect-discrimination-strikes-down-armys-gender-discriminatory-promotion-practices/, last seen on 12/10/2021.
6. W.P(C) 7336/2010, CM Nos. 9348/2012 & 6859/2014
7. WP (C) 8492/2009
8. Civil Appeal Nos 9367-9369 of 2011
9. Supreme Court allows women to take NDA exam, slams Indian Army for 'gender discrimination', The New Indian Express (18/08/2021), available at https://www.newindianexpress.com/nation/2021/aug/18/supreme-court-allows-women-to-take-nda-exam-slams-indian-army-for-gender-discrimination-2346436.html, last seen on 25/10/2021.