The world without the internet is unimaginable, one of the significant invention of all times. Internet is an only tool which drives you throughout the day. The internet can be defined as a global network of billions of computers and other electronic devices. You may now speak with anyone in the globe, search virtually any database, and perform a plethora of other tasks thanks to the Internet.[1]Cyberspace is a term that refers to the ever-expanding network of computers, technologies, and the internet a computer network that allows people to communicate with one another virtually.[2]

Internet have surely upheld its true objective, to make human life easier, however its dark side is overshadowing its true objective. Mankind should have expressed its gratitude towards the remarkable invention but somehow the actions of mankind itself are questioning upon its remarkable position. The internet has evolved into a live, breathing copy of the real world..[3] Physical world has shown us all the possible manner, through which a women suffers pain and trauma. Even the internet world has left women surprised with all the possible challenges and hardships.

Both the world does have opportunities for women to explore, but however its dark side is supressing women growth and is shocking them with different forms of violence. If we specifically focus upon internet world, with the advancement of technology, internet is very much accessible to everyone, Cybercrime and victimisation of women have resulted as a result of this, and it is a serious threat to the overall security of an individual.

Computer and network crimes are included in cybercrime, as are traditional crimes carried out via the internet. To purposefully inflict bodily or mental harm on a single person or group of people through the use of modern telecommunication networks, including but not limited to the internet, is considered an act of criminal misconduct.

In the last four years, cybercrime in India has surged by 306%, or four times its previous level. In 2016, there were 12,317 reports of cybercrime; by 2020, that number is expected to rise to 50,035. As a result, the National Crime Records Bureau estimates that every day in 2020, India will have recorded 136 new cases of cybercrime.

These documents, therefore, raise serious questions about India's legal framework for tackling cybercrime. It was all about making our lives easier, but we didn't realise that we were creating a platform for criminals to commit a slew of additional offences by establishing the internet.

Major Reason for the Growth of Cyber Crime Against Women
Since the dawn of human civilization, crime has been a continual problem, and efforts to address this issue have not yet been successful. Criminality and criminal behaviour plague all societies. Emile Durkheim argues that crime is a natural occurrence that shifts in tandem with societal progress, and that even societies populated primarily by angels must contend with it.

We certainly cannot detach crime from the society yet we can determine the reasons why people are prone to commit such horrible crime. With advancement of technology, the countries are witnessing immense growth of cybercrime against women. Thus, it is very important for the countries to take measures against it and make an attempt to find out what actually is driving them to commit such dreadful crimes.

It is impossible to find every single reason behind each crime, though these following reasons can be largely taken to considerations:

1. Improper education regarding electronic devices and internet:
   Improper here refers to partial education of electronic devices and internet. Internet being a universal thing has attracted the attention from almost everyone and collectively each person wants to try out how internet works and so on. The curiosity driven minds here, are passionate about how the internet is being used or how the electronic gadgetsare used.
   
   In respect to that, whatever partial education they receive from their peers becomes the 'actual education' to them which results into improper usage of the internet and electronic devices. That actual education lacks the elements of privacy, security, education regarding how one should regulate their actions, keeping dignity etc. Cyberspace is space where imaginations are grown and nurtured but somehow the improper education regarding the cyberspace ruins the growth of that imaginations.
    
2. Quick access to victim's information:
   Remember when you filled in your personal detail before signing up in any of the social media handles? There you provide your personal information which is easily accessible to anyone. For a profile to be visible, individuals must enter information about themselves. Many of the social media handles or website does publishes the information which the users have entered, which is visible to public.
   
   Unknowingly, the first registrants including females give away their private details to these website or social media handles, without even knowing the consequences becomes the victims of dreadful crimes. These first registrants aren't aware of their legal rights to privacy protection from social intrusion or of the best practises for safeguarding their personal information when using social media sites like Facebook and Twitter.
    
3. No authenticity of profiles:
   Many websites or social media is filled with false profiles or accounts. Thesehandleor website allows a user to change their profile picture which maybe or may not be true to their actual physical appearance, their names, addresses and other personal details. An unauthentic detail filled by a perpetrator can be presented as his 'accurate details'. False profiles are hard to detect which becomes the basis of cyber-crime. These fake profiles are just another drawback of internet, which have put the females in danger and risk.
    
4. No fear of sanctions:
   However long-standing the problem of online criminality has been, the punishments are still lenient when compared to those for more traditional offences.[4]Fear of sanction holds a lot of weightage in order to regulate society's behaviour as is a deterrent to future offences as well as a role model for those with criminal tendencies to follow. The IPC and the IT Act of 2000, both of which were passed in India and later updated in 2008, recognise some crimes but do not recognise all of them.
    
5. Cases Left Unreported:
   In general, women rarely report to the upper authorities, as they often fear of being blamed or not believed. The women in this situation are vulnerable as to what actually is the right step in order to keep them protected.[5] The elements of patriarchy in the society plays a crucial role in order to suppress women from complaining against the offenders and are often are blamed for their 'unsatisfactory behaviour'.
   
   This ambiance where the victims are suppressed to complain against their wrongdoer is shame to the society and somewhat threatens the basis of the Constitution. Crimes left unreported is one the major reasons why we are facing the growth of cybercrimes against women as no fear of sanction builds up the spirits of culprits to get given higher.

Types of Cyber Crimes Committed Against Women
When it comes to cyber bullying and cybercrime, young women, especially those who have recently been introduced to the internet and do not fully comprehend its ills, are the most vulnerable.

The following are examples of cybercrimes specifically targeted at women:

1. Cyber Harassment:
   Constantly writing love letters under fictitious identities or sending embarrassing emails to the recipient's inbox is a kind of harassment, as is blackmailing, threatening, and other forms of intimidation. This type of action is meant to frighten someone by using the internet. There are numerous sorts of harassment that are specifically sexual in character, but sexual harassment is one of the most important because it takes into account frequent and unwelcome sexual acts.[6]
   
   Also included in this section is a call to action for performing sexual favours, making sexually explicit jokes, and forcibly exhibiting pornography are all examples of inappropriate sexual behaviour. Despite the fact that the IT Acts 67 A and 67 B address sexual harassment in connection with the publication or transmission of pornographic or sexually explicit content comprising minors, e-mail blackmailing, threatening, and even cheating are all commonplace in the online world. Harassment by email resembles harassment via letter, but it is far more difficult to track down those responsible for cyber harassment due to the prevalence of phoney online identities.[7]
    
2. Cyber Stalking:
   To put it simply, cyber stalking is the intentional and repetitive harassment of another person with the intention of alarming, tormenting, or terrorising that person. One of the crimes committed over the internet that receives the most attention in today's society is this one. In cyber stalking, a person posts remarks or flooding them with emails and other messages. Women and children are the most common victims of cyber stalking, with men stalking women and paedophiles stalking youngsters. Cyber stalkers follow their victims throughout the internet, harassing them through various mediums like as email, chat rooms, and open publishing websites.[8]
   
   RituKohli Case
   For the first time in Indian history, Ritu Kohli lodged a police report against a person who had been using her name for four days in a row on the micro.com website, primarily in Delhi. This person was allegedly using her identity and address in an Internet chat, according to Mrs.Kohli's complaint. RituKohli's phone number was also purposely shared with other chatters, urging them to reach out to her at odd hours.
   
   The result was that Mrs.Kohli received about 40 calls in three days, most of them at odd times of the day or night. The complainant's personal life was ruined by the contact, so authorities tracked down the caller's IP address and eventually arrested him. He was arrested and then released on bail after a charge was filed against him under IPC section 509. For the first time, an internet stalking case has been documented.
   
   India's present cyber laws do not encompass cyber stalking, such as email harassment. When it comes to breaking confidentiality and privacy, only Section 72 of the IT Act allows for distant prosecution. There is also a chance that the accused will be charged with criminal trespass under Section 441 of the Indian Penal Code, as well as outraging the modesty of females under Section 509 of the Indian Penal Code once more. Both of these sections of the code are applicable in India.[9]
    
3. Cyber Bullying:
   It is a crime committed by a single person or a group of persons who intend to bully or harass another person on a regular basis through the use of cyberspace. Cyber bullying victims are typically those who lack the ability to defend themselves. Among the many forms of cyber bullying are disclosing a victim's private information or images to the public, sending obscene or sexually explicit messages, stalking, and gaining unauthorised access to a victim's account. There are various mediums through which cyber-bullying can occur, like, social media (Instagram, Facebook, etc.), text messages, E-mail, Instant messaging services (WhatsApp, messenger, etc.).[10]
   
   Cyber Bullying in India:
   India has ranks number 3 for cyber-bullying crimes, and this is not even shocking anymore as the number of users is rising day by day and most of them are fake accounts. On the other hand, a study by the non-profit organisation CRY (Children Rights and You) indicated that nearly half of the children in Delhi NCR who were bullied online didn't tell their parents or guardians about it. Another national poll performed by Symantec found that 8 out of 10 persons are victims of cyber-bullying in various forms.[11]
   
   Cyber Defamation:
   When someone uses computers and the internet to spread false information about another person, this is known as cyber defamation, which is also a tort. It occurs when individuals begin publishing libellous claims or pornographic content on a variety of social networking websites available on the online platform. All users can access a user's bulletin board, therefore anyone can write a defamatory message and it will be available to everyone. Cyber smearing and cyber defamation are both terms used to describe the same thing.[12]
   
   In SMC Pneumatics (India) Pvt. Ltd. v. JogeshKwatra-Jogesh Kwatra,[13] it was stated that a company's employee (defendant) began sending derogative and sexually explicit emails regarding the company's managing director (the plaintiff). The anonymous and frequent emails were sent to several of the plaintiff company's business acquaintances in order to destroy the company's reputation and goodwill.
   
   It was possible for the plaintiff to track down and bring a lawsuit against the defendant in Delhi thanks to the help of an independent computer expert. The court issued an ad-interim injunction,and the employee was ordered to refrain from writing, publishing, and transmitting any electronic messages that are slanderous or disparaging toward the plaintiffs.[14]
   
   Another famous case involving a women was The State of Tamil Nadu VsSuhasKatti[15] -A divorcee woman's filthy, libellous, and unpleasant message was posted in a Yahoo messaging group, which is the subject of this lawsuit. The accused also sent e-mails to the victim asking for information through a fake e-mail account he had set up in the victim's name. Because of the post, the lady received a slew of unwanted phone calls from people who mistakenly thought she was soliciting.[16]
    
4. Cyber Pornography:
   Internet pornography is described as the publication of sexual content online. Female internet users are once again at risk since they don't know what they're doing online is being recorded and could end up being viewed by millions of people across the world. Photos and videos of victims are obtained and social media accounts, and these can ruin the victim's life in the real world if they are leaked online. IT Act 2000 Section 67 provides some coverage for the offence.[17][18]
   
   As an example, the DPS MMS controversy, in which an MMS clip of a schoolgirl in an inappropriate scenario was created and disseminated through multiple internet networks, is well-known. Similarly, a Swiss couple forced slum youngsters in Mumbai to pose for obscene images, which they subsequently uploaded to paedophile-specific websites after gathering the children. The couples were taken into custody by Mumbai police on suspicion of pornography. Another case of Delhi Metro CCTV footage leaks has been revealed, where police security cameras have filmed couples having sex in metro stations and other public places.[19]
   
   Section 67[20] of the IT Act 2000 provides some protection for cyber pornography, which is regarded an exceptional instance of the IT Act 2000. In addition to the IT Act, numerous sections of the IPC can be used to penalise the offender.
    
5. Cyber Grooming:
   "Befriending" a young person on the internet is known as "cyber grooming," and the purpose is to set up sexual encounters between the two parties. It is common for an adult to befriend a child online with the purpose of sexually abusing, exploiting, or trafficking the youngster in the future.
   
   The primary objectives of cyber grooming are to earn the child's trust and to collect sensitive and personal information from the child (typically of a sexual nature, such as sexual discussions, images, or videos), with the intention of using this information to blackmail or threaten the youngster into providing additional improper content.[21]

LAWS, STATUTES AND LEGAL PROVISIONS IN INDIA AND THE GAPS
Cyber space is a completely different domain of human survival.[22] As technology evolved, the need to control human behaviour evolved too. Technology did provide ease of life to the human beings, but at the same time, also brought some challenges pertaining to safety. Here, just like physical world challenges were awaiting to affect women at large.

It got necessary for the state to provide sanctions and implement laws in accordance with cybercrimes as the cyber violence committed were gender specific and would only affects girls. Cyberspace with no physical boundaries created several major difficulties for the state. Thus, no special law was implemented in order to govern the cybercrimes. In recent times, the cases brought into light are generally delt under the previously enacted laws.

The Indian Penal Code (IPC) and the Special and Local Laws control and punish cybercrimes in the country of India (SLLs). The Indecent Representation of Women (Prohibition) Act of 1986 and the Information Technology Act of 2000 are the two SLLs in question. Of these two acts, only the Information Technology Act is not gender-specific; nevertheless, it does contain a few clauses that deal with gender-specific issues and prescribe penalties for activities that violate these provisions. Obscene depiction of women in advertising, publications, writings, paintings, or figures is the primary focus of the Indecent Representation of Women (Prohibition) Act, which was adopted in 1986.[23]

The IT Act,2000 does not only provide sanctions for cybercrimes against women but also recognizes other offences under the ambit of cybercrimes.

Majorly the following stated sections primarily deals with offences committed against women:

• Section 66A of IT Act: Punishment for Offensive Messages through Communication Service.[24]
• Section 66E of IT Act[25]: Punishment for Violation of Privacy.
• Section 67 of IT Act[26]: Publishing Obscene information.
• Section 67A[27] of IT Act: Punishment for Publishing or Transmitting of Material Containing Sexually Explicit Act, etc in Electronic Form.
• Section 67B of IT Act[28]: Punishment for Child Pornography.
• Section 72 of IT Act[29]: Breach of Confidentiality and Privacy.

The Indian Penal Code in Indian context is considered as one of the most powerful law which provides sanctions to almost every criminal, nature offense. Section 354 of IPC[30]recognizes voyeurism, stalking and sexual harassment as a crime and provides punishment for the same.

Though India is not well enriched with laws pertaining to cybercrime but the above statues does cover some part of it. Apart from regulation or providing special law to cybercrime certain measures should be taken in order to improve cyber security. As an example, e-mail security should be a priority. If you want to avoid spam, phishing attacks or other threats to your e-mail security, you should utilise an encrypted mail server.

There is also the possibility that token-based identification systems are applicable. Evolution of laws and legislation is one of the major concerns for the society.[31]As the above stated statues are adequate enough to deal very distinct activities of cybercrime, proving partial security with thee above statues are acting as a helping hand to the offenders.

Apart from establishing proper statues, the police officials must also be trained in such a manner that they are able to resolve or understand the problems which are confronted by women. Recent time is an evidence for the evolution of NGOs, the police official and the government must innate with NGOs for the sake of women security. Finally, there is room for improvement in the technology sector itself. The first step is to look at ways to prevent cyber attacks.

Recommendations and Conclusion
The following recommendations have been given to tackle cybercrime effectively and efficiently in accordance with the current developments in cyber laws:

1. National Plan to Combat Cybercrime:
   The Indian government, like the governments of other industrialised countries, should adopt a national plan to tackle cybercrime. The following goals and top priorities should be the focus of this national strategy:
   
   1. Educating the community as to how to avail the benefits of technology while protecting them.
   2. Encouraging an approach based on intelligence and disseminating data.
   3. Increasing the agencies' capabilities to combat cybercrime.
   4. International collaboration on cybercrime should be improved.
   5. An efficient criminal justice system must be maintained.[32]
       
2. Cyber Crime Prevention Guide to Users:
   Ignorance and carelessness of the users can lead them into serious trouble.
   
   Therefore, in order to prevent cybercrime, the users must practice these following guidelines:
   
   1. Maintaining Frequent Updates to the Computer System
   2. Choosing secure passwords that cannot be figured out by anybody else. Avoid using personal information in your passwords, such as your birthday, wedding anniversary, or other such dates;
   3. Keep changing the passwords regularly;
   4. Using security software and hardware firewalls to keep computers safe.
   5. Protecting one's personal information;
   6. Keep an eye out for spam emails;
   7. Pay attention to privacy policies;
   8. If you receive an email or other contact asking for personal information, please do not respond;[33]
   By the above stated guidelines one can ensure safety against cybercrime and can experience the brighter side of technology. It has been mentioned that prevention is preferable to treatment; hence, it is advised that the government should provide these guidelines, which have been stated above, to the public at large.
    
3. Specialized Agency to Investigate Cyber Crime:
   Investigative work is critical in identifying and punishing the true perpetrator. Experts are needed to investigate cybercrime because it is a highly specialised and intellectual crime. Since the victim deserves equal justice, it is recommended that expert investigators are appointed. In addition to this, the police should, in general, be provided with better equipment and trained more extensively in technological skills so that they are able to adequately trace down those responsible for the crimes.[34]
    
4. Proper Legal Framework in Accordance with Cyber Crime:
   All of India's current laws were enacted long ago, taking into account the political, social, economic, and cultural context of the time in which they were written. Nobody back then had any idea what the Internet would look like. Master draughtsmen could never have predicted the needs of cyberspace, no matter how great their insight. There have been various thorny legal issues that have arisen since the advent of the Internet, necessitating new Cyber laws. Even with the most charitable and liberal reading of India's existing laws, it is impossible to cover all aspects of varied activities in cyberspace within the existing rules. In the same way, no existing laws recognised or sanctioned the acts taking place in the virtual world of Cyberspace. Hence, a proper legal framework in accordance with Cyber Crime is much needed.
    
5. Promoting Cyber Literacy:
   Finally, the government should launch efforts to educate the public about cyber world and cybercrime in order to make them more aware of the use and exploitation of these technologies. Further, it is advised that cyber illiteracy should begin at the grassroots level, at institutions, computer centres, schools, and among individuals. No amount of legislation will be able to curb cybercrime's scourge until the general public acknowledges the positive role that ICTs play in society's inclusive growth and the negative impact that their improper usage has on it. As a result, in addition to enhancing legal protection against cybercrimes, the government should raise public awareness about the use and exploitation of ICT. [35]

CONCLUSION
Following these conclusions, it is apparent that cybercrime is becoming more common as technology advances. Apart from availing the bright side of the internet, the society is yet under the oppression of its dark side. Cyberspace when introduced in the society encouraged everyone to dream or imagine freely, however cybercrime acts as an obstacle in that freedom.

Women is worshipped as goddesses in most of the countries which itself sends a powerful message of women empowerment. It is quite disheartening to know that the same countries crimes rated rises up to several percent. With the invention of internet women were all set to take off with their imaginations but crimes in cyberspace have burst the bubble of imaginations.

Annual increases in online crime are estimated to reach 1.4%, according to a number of different studies. Many people find it difficult to accept that merely posting photographs of someone online constitutes a crime because of the overall lack of respect for women in today's culture, and because of this, cybercrimes against women are still viewed as minor offences.

There is no moral support for cybercrimes such as morphing and e-mail spoofing in society, and as a result, they are viewed lightly. In order for society to progress, people need to be aware of their own rights and those of others, as well as the definition of what constitutes a criminal offence.

Women and young girls who are victims of cyber bullying need to be educated about their rights and how to protect themselves. For instance, they should get in touch with a women's aid cell or a non-governmental organisation (such the All India Women's Conference, Sakshi, Navjyoti, or the Centre for cyber victims therapy) as soon as possible. This will enable them to receive assistance and direction throughout the process, and it will also ensure that the police do not treat any case flippantly.

An examination of the legal issues raised in India's courts reveals a lack of confidence in the country's legal system, which allows criminals to flee prosecution. A proper legal framework is required in order to provide adequate punishment for the offenders and thus, becomes the lesson to other offenders inculcated with criminal tendencies. With on growing nature of technology it is necessary for the countries to amend the laws in accordance with the crimes, which are new to their society and needs proper identification.

End-Notes:

1. Internet Basics - What is the Internet? (last visited May 01, 2022 8:01 PM), Internet Basics: What is the Internet? (gcfglobal.org)
2. Veena Kumari, Cyber Law - I (last visited May 01, 2022 9:18 PM), SM_aec24985-8fe2-4500-8414-85de787ab1e6_30.pdf
3. Deepshikha Sharma, Cyber Crime in India: Are Women a Soft Target (last visited May 01, 2022 9:43 PM), Cyber Crime In India: Are Women A Soft Target (legalserviceindia.com)
4. Anthony Ortega, Are Cybercrime Laws and Penalties Good Enough? (last visited May 03, 2022 10:08 AM). Are Cybercrime Laws and Penalties Good Enough? | Toolbox It Security
5. Rajat Mishra, Cyber Crime Against Women (last visited May 03, 2022 10:32 AM), SSRN-id2486125.pdf
6. Supra Note 6.
7. Supra Note 9.
8. Ibid.
9. Ibid.
10. Soumya Triphati, Cyber Bullying in India and Applicable Laws (last visited May 03, 2022 01:08 PM), Cyber-bullying in India and Applicable Laws (uniquelaw.in)
11. Ibid.
12. Supra Note 6.
13. SMC Pneumatics (India) Pvt. Ltd. v. JogeshKwatra-JogeshKwatra, Suit No. 1279/2001, District Court of Delhi.
14. Supra Note 9.
15. The State of Tamil Nadu VsSuhasKatti, C No. 4680 of 2004.
16. Supra Note 9.
17. Supra Note 6.
18. IT ACT, 2000 � 67
19. Supra Note 9.
20. Supra Note 22
21. Child Safe Net, Cyber Grooming (last visited May 03, 2022 5:43 PM), Cyber Grooming - ChildSafeNet
22. Zeeldavda58, Laws Applicable in Cyberspace in India (last visited May 04, 2022 7:09 PM), Laws applicable in Cyberspace in India - Legal Desire
23. Supra Note 6.
24. IT ACT, 2000 � 64
25. IT ACT, 2000 � 66E
26. Supra Note 22.
27. IT ACT, 2000 � 67A
28. IT ACT, 2000 � 67B
29. IT ACT, 2000 � 72
30. INDIAN PENAL CODE, 1860 � 354
31. Bret Pladna , The Lack of Attention in the prevention of Cyber Crime and How to Improve it , (last visited May 04 2022 8:34 PM), BPladna_Cybercrime.pdf
32. Indian Penal Code, 1860 � 354
33. Cyber Crime Law & Practice , The Institute of Company Secretaries of India , Pg No. 142
34. Ibid.
35. Cyber Crime Law & Practice , The Institute of Company Secretaries of India , Pg No. 143
36. Ibid.