Introduction
Gender sensitivity in how crimes against women are judged is very important to making sure justice is fair, kind, and focused on the needs of the survivor. Crimes like rape, domestic violence, acid attacks, and workplace harassment are not just legal issues—they are signs of deep problems in society and systems that hurt a woman’s dignity, freedom, and safety.
In this situation, the judiciary has a big role to play—not just in understanding and following the law, but also in changing how the legal system treats gender issues. A court that understands the real-life experiences of women can stop people from being hurt again because of the way they are treated in court and help create a more respectful and caring legal process.
International and Indian laws, like the Istanbul Convention and the Protection of Women from Domestic Violence Act, 2005, clearly say that violence against women is a human rights problem and a type of discrimination based on gender inequality. Looking at these issues with a gender-sensitive view is key for making good policies, enforcing laws, and providing support.
Understanding Gender-Based Violence (GBV)
Gender-based violence (GBV) is any harmful action aimed at someone based on their gender. It comes from unequal power and deep societal unfairness and mostly affects women, girls, and gender minorities, though men and boys can also be victims.
GBV can take many forms, like physical, sexual, emotional, and financial abuse. It happens in both public and private areas and is often caused by cultural beliefs, traditional views that favor men, and unfair legal and government systems.
The World Health Organization says that one in three women globally has experienced physical or sexual violence in her lifetime, often from someone she knows closely.
Types of Crimes Against Women
- Domestic violence
- Sexual assault and rape
- Dowry-related violence
- Acid attacks
- Human trafficking
- Cyber harassment
- Honor killings
These crimes are often repeated acts of abuse that reduce women’s opportunities, freedom, and well-being. Social stigma, fear of retaliation, lack of legal awareness, and weak institutional support further complicate justice for victims.
Global and Indian Statistics
Worldwide: WHO estimates 736 million women have faced physical or sexual violence. In 2022, over 45,000 women and girls were killed by intimate partners or family members.
India (NCRB 2022 data):
- Total cases: 4,45,256
- Major crimes: Cruelty by husband/relatives (31.4%), assault to insult modesty (20.6%), kidnapping (18.7%)
- Rape cases: Over 31,000 reported
Historical Background
Historically, women were seen as property and lacked freedom or legal protection. Laws were patriarchal and often failed to address violence against women meaningfully. Even under British rule, although some reforms happened, gender-based crimes remained largely unaddressed.
Modern Movement
The Indian Constitution (1950) changed the framework with Articles 14, 15, and 21 guaranteeing equality, non-discrimination, and dignity. Over time, landmark cases shaped a more gender-sensitive legal landscape.
Key Cases
- Vishaka v. State of Rajasthan (1997) – Workplace harassment guidelines
- Lilu @ Rajesh v. State of Haryana (2013) – Rape victim rights
- Joseph Shine v. Union of India (2018) – Decriminalized adultery, gender-neutral approach
Key Laws
- Bhartiya Nyaya Sanhita (BNS): Sections 63, 74–77, 79, 80, 85
- Protection of Women from Domestic Violence Act, 2005
- Dowry Prohibition Act, 1961
- Sexual Harassment of Women at Workplace Act, 2013
- Protection of Children from Sexual Offences Act, 2012
- Immoral Traffic (Prevention) Act, 1956
Constitutional Provisions
- Article 14: Equality before the law
- Article 15: Prohibits discrimination; allows special provisions for women and children
- Article 21: Right to life and dignity
- Directive Principles: Articles 39, 42, 46 – equitable opportunities and protection
Role of Judiciary in Promoting Gender Sensitivity
- Expanding the interpretation of fundamental rights to cover gender-based violence
- Introducing victim-friendly procedures: in-camera trials, anonymity, fast-track courts
- Training for judges, prosecutors, and police
- Accountability mechanisms for enforcement agencies
Challenges and Gaps
- Low representation of women judges
- Patriarchal bias and victim-blaming
- Inadequate gender sensitivity training
- Slow legal processes
- Lack of court infrastructure and victim support systems
- Weak enforcement of progressive judgments
Statement of Problem
Despite progressive laws and constitutional mandates, traditional mindsets and lack of gender sensitivity in the judiciary obstruct justice for women. A shortage of female judges leads to biased outcomes and widens gender inequality in court decisions.
Hypothesis
The judiciary has a very important role in promoting gender sensitivity in crimes against women.
Objectives of the Study
- To understand the idea of gender sensitivity in crimes against women
- To look into the role of the judiciary in promoting gender justice
- To check the impact of having female judges
Research Questions
- How well does the judiciary handle gender sensitivity in crimes against women?
- What rules and training are in place for judges on gender sensitivity?
- Does the low number of female judges affect gender sensitivity?
Research Methodology
This study uses qualitative methods and legal comparisons. It analyzes statutes, constitutional provisions, judgments, and institutional practices.
The study compares two time periods: pre-reforms (1975–2000) and post-reforms (after 2013 & 2018). It includes review of case laws, legal texts, NCRB data, and reports by bodies like the Law Commission and National Judicial Academy.
Structure of the Project
Chapter 1: Introduction
Concepts: GBV, gender justice, crimes against women, constitutional and criminal laws, and challenges.
Chapter 2: Judicial Response
Analysis of judiciary’s handling of gender sensitivity through judgments and implementation of laws.
Chapter 3: Rules, Manuals, and Training
Review of SC guidelines and training by judicial academies for gender-sensitive legal processes.
Chapter 4: Landmark Judgments (1975–Present)
Case-wise analysis of legal evolution from pre-reform to post-reform eras in judicial treatment of GBV.
Chapter 5: Impact of Female Judges
Study of how the gender composition of the bench affects empathy, legal reasoning, and fairness.
Chapter 6: Conclusion and Recommendations
Summary of findings with practical steps to improve gender-sensitive legal systems: more women judges, training, and victim-focused legal processes.
Gender Sensitivity In Crime Against Women (Role Of Judiciary)
Introduction
Gender-based violence is one of the most serious violations of human rights globally, and India is no exception. Crimes like rape, domestic violence, acid attacks, dowry deaths, and sexual harassment continue to affect a large number of women. In such a context, the judiciary plays a key role in not only interpreting and enforcing laws, but also in transforming the everyday experiences of women through gender-sensitive justice.
Gender sensitivity in judicial practice means recognizing the historical and structural disadvantages women face and responding in a way that ensures dignity, equality, and fairness. This section assesses how effectively the Indian judiciary has incorporated gender sensitivity in handling cases of crimes against women.
Gender sensitivity in dealing with crimes against women involves understanding and addressing the societal, cultural, and institutional factors that lead to gender-based violence. It emphasizes how traditional gender roles and imbalances in power can result in discrimination and violence against women. Gender sensitivity means being aware of the differences in experiences and challenges based on gender.
In criminal justice, this means recognizing that women are often more affected by certain crimes like domestic violence, sexual assault, and human trafficking. It also means understanding how social norms and stereotypes can influence both the occurrence of crimes and the way law enforcement and the judicial system respond to them.
The presence of female judges in the judiciary plays a transformative role in promoting gender sensitivity, especially in cases involving crimes against women. A diverse bench, which includes women, enriches the judicial process and makes courts more inclusive and responsive to gender-specific issues.
Their presence helps shape a legal culture that is more empathetic, balanced, and aligned with societal realities. Female judges often bring a deeper, more informed understanding of gender-based violence, due to personal and social experiences that shape their viewpoints. This empathy helps in interpreting facts and circumstances in sensitive cases, leading to judgments that reflect the real-life experiences of women.
Moreover, women on the bench actively challenge ingrained gender biases in legal reasoning, contributing to the development of fair and equitable legal principles. Their influence has also been seen in the development of progressive legal precedents.
For example, judges like Justice M. Fathima Beevi, the first female judge of the Supreme Court of India, have played a significant role in building a legal framework that supports and upholds women’s rights. Similarly, Justice Sujata V. Manohar has delivered important judgments that address gender discrimination and protect the dignity of women.
However, despite these contributions, the representation of women in the higher judiciary remains low. This lack of representation often means that the judicial system struggles to fully understand the gendered aspects of violence and inequality. Addressing this gap is essential not only for fairness but also for building public trust in the judiciary.
Increasing the number of female judges is crucial for creating a judiciary that truly understands and addresses gender issues. Their presence enhances judicial empathy, strengthens the fight against legal gender bias, and ensures that the system better serves all members of society, especially women who face systemic injustice.
Importantly, the presence of women judges greatly enhances gender sensitivity. Women on the bench often bring unique perspectives, deeper empathy, and a better understanding of gender-based violence. Their increasing presence has led to more progressive, inclusive, and balanced judgments that support and protect the rights and dignity of women who are victims.
Therefore, making the judiciary more aware of gender issues through changes in the system and by having more women judges is important for achieving real justice in cases where women face violence. A judiciary that understands the real-life situations of women can stop people from being treated unfairly again after they have been harmed and create a more respectful and caring process for dealing with trauma.
Understanding Gender Sensitivity
Gender sensitivity means understanding how roles and power between men and women, not just physical differences, shape experiences, expectations, and weaknesses based on gender.
It involves looking at and challenging old ideas (like thinking women are only caregivers or weaker), which often lead to violence and how institutions respond to it.
In the context of crimes against women, gender sensitivity means recognizing, accepting, and including the differences, unfairness, and power imbalances between genders when understanding, preventing, and responding to crimes against women.
It means treating women not only as victims of violence but also as people whose social, cultural, legal, and economic situations influence how they experience crime and justice.
Most crimes against women are not random; they are part of a larger system that comes from traditional power structures.
Violence such as domestic abuse, sexual assault and rape, dowry deaths, honor killings, and human trafficking are often done because of unequal power between men and women. Without a gender-sensitive approach, these crimes are seen as separate incidents rather than signs of deeper inequality.
Challenges Faced by Victims
Victims of gender-based violence often face unfair treatment because of:
- Unkind or dismissive attitudes from police,
- Blaming the victim during investigations or trials,
- Delays or refusal in getting justice due to biased systems.
Being gender-sensitive ensures that the justice system shows empathy and understands the trauma and social shame that a woman may face.
Judiciary’s Role in Gender Justice
The judiciary plays a key role in promoting gender justice by respecting rights, looking at laws in a gender-sensitive way, and making sure that justice is accessible to women and gender minorities.
Gender justice means fair treatment for everyone regardless of gender, and it aims to break down the legal, social, and institutional barriers that keep inequality in place. Courts can undo unfair laws, issue instructions to protect women’s rights, and make sure that the justice system is fair, accessible, and responsive to the unique problems women face, especially in cases of violence against them.
Judicial Intervention in the Absence of Laws
Judicial bodies often step in when laws do not cover certain issues. An example is the Vishaka v. State of Rajasthan (1997) case in India, where the Supreme Court created guidelines to stop workplace sexual harassment, long before the POSH Act was passed in 2013. In another case, Joseph Shine v. Union of India (2018), the Supreme Court removed the adultery law, saying it was unfair and based on traditional views about men and women. These cases show how the judiciary doesn’t just apply the law; it can change it to match values like equality, dignity, and freedom.
Judicial Efforts to Protect Women
In India, courts have made important decisions to protect women. The Nirbhaya case (2012) led to big legal changes and more attention to crimes against women. Courts have also dealt with issues like acid attacks, marital rights, workplace harassment, and discrimination under family laws.
Even with these advances, challenges remain. There are not enough women in the judiciary, especially in higher courts, and many survivors of violence still struggle to get justice because of slow legal processes, bias in law enforcement, and social stigma.
International Judicial Role in Gender Justice
On the international level, courts and human rights groups have been important in creating laws that care about gender issues.
- The European Court of Human Rights in Opuz v. Turkey held the government responsible for not stopping domestic violence.
- The Inter-American Court of Human Rights in the Campo Algodonero case acknowledged the Mexican government failed to protect women in Ciudad Juarez from femicide.
- The UN’s CEDAW Committee regularly checks how countries follow rules and gives advice to improve gender protections in laws.
Inconsistencies and Challenges
However, the judiciary, both in India and around the world, has often been slow or not consistent in addressing gender justice. In India, many high-profile gender-based violence cases have taken years to resolve, causing victims to lose trust in the justice system.
There have been cases where judges showed bias or traditional attitudes, like suggesting a rape victim marry the accused or questioning a woman’s character based on what she wore or how she lived.
In lower courts especially, there is not enough training on gender issues. A lack of trauma-informed approaches can worsen the victim’s experience. Also, having fewer women in the judiciary reinforces a male-dominated view, limiting diverse perspectives on justice.
Conservative Influences on Global Justice
Internationally, in many developing or conservative areas, courts are still influenced by social taboos, religious traditions, or political pressure, which affects how they deliver fair justice for women.
The Judiciary’s Potential
The judiciary is a strong tool for promoting gender justice. By interpreting laws with a gender-aware approach, ensuring accountability, and understanding the real-life experiences of women and gender minorities, courts can connect legal principles with lived realities.
However, to achieve real progress, legal changes must be combined with:
- More women in the judiciary
- Gender awareness training
- Strong implementation of justice at all levels
Recognizing the judiciary’s weaknesses and addressing them through training, transparency, and accountability is essential for fair and inclusive justice.
Legal and Constitutional Framework for Gender Justice
The Indian Constitution offers a strong base for promoting fairness between genders.
- Article 14 ensures everyone is treated equally under the law.
- Article 15 stops discrimination based on gender.
- Article 21 protects the right to live with dignity and personal freedom.
These articles empower courts to support women’s rights, especially in criminal cases.
Key Gender Justice Laws
- The Protection of Women from Domestic Violence Act, 2005: Covers more than just physical abuse.
- The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013: Based on Vishaka guidelines.
- The Criminal Law (Amendment) Acts of 2013 and 2018: Made after the Nirbhaya incident, increasing penalties for sexual crimes.
Judicial Decisions and Impact
The Indian courts have become more gender-aware through significant rulings:
- Vishaka v. State of Rajasthan: Supreme Court made rules against workplace sexual harassment.
- Lillu Rajesh & Anr. v. State of Haryana: Court rejected the “two-finger test”, upholding victims’ dignity and privacy.
- Joseph Shine v. Union of India: Adultery law struck down for treating women unfairly.
Women judges have expanded gender justice. Judges like Justice Gita Mittal, Justice Hima Kohli, Justice Indira Banerjee, and Justice BV Nagarathna have been key voices in this process.
Gender Representation and Reforms
As of 2024:
- Women are only about 13% of High Court judges
- Less than 12% of lower court judges are women
- No more than three women have served in the Supreme Court at the same time
To support survivors, reforms include:
- Fast-track courts for sexual crimes
- Private court sessions
- Video conferencing to protect dignity
The Delhi Domestic Working Women’s Forum v. Union of India case emphasized the need for legal aid and compensation for rape survivors.
Yet, poor infrastructure, unfilled court positions, and re-traumatizing procedures hinder progress.
Challenges: Systemic and Cultural Barriers
Courts still face challenges like:
- Judgments that question victim behavior
- Low conviction rates for rape (33.6% as per NCRB 2022)
- Delays in investigations and poor prosecution
Judicial Training and Sensitization
Training initiatives exist, such as those by the National Judicial Academy and State Judicial Academies. However, they are often inconsistent or insufficient.
Experts recommend including:
- Feminist legal perspectives
- Intersectionality
- Trauma-informed care
Role of Civil Society and PILs
Civil society has influenced the judiciary:
- Women’s groups filed PILs like the Vishaka case
- NGOs provide support and legal aid to victims
The Nirbhaya case (2012) demonstrated how public pressure led to faster trials and legal reforms.
Conclusion: Toward a Gender-Just Judiciary
Indian courts have taken major steps to address gender issues through rulings, reforms, and awareness. But patriarchy, poor implementation, and lack of diversity remain obstacles.
A holistic approach is essential:
- Increase the number of women judges
- Mandatory gender sensitization for all judges
- Improve fair procedures and accountability
- Reject judgments that go against gender equality
Only then can courts truly uphold the dignity and rights of women in an unequal society.
Rules, Manuals, and Guidelines in Place for Judiciary to Address Gender Sensitivity in Crime Against Women
Crimes against women in India have been ignored for a long time because of traditional beliefs that favor men, lack of interest from authorities, and laws that don’t pay enough attention to gender issues.
However, the judiciary, especially the Supreme Court of India, has been taking active steps in recent years. They have created guidelines, rules for courts, and training programs to make sure that judges and court staff understand and respect gender sensitivity in dealing with cases related to crimes against women. This is important not just to ensure fair trials but also to protect the dignity and rights of survivors, as outlined in Article 21 of the Constitution. Training judges is also key, so they can understand and show empathy when dealing with such sensitive issues.
Supreme Court Guidelines for Gender Sensitivity in Judicial Proceedings
Vishaka Guidelines (1997)
In the case of Vishaka v State of Rajasthan, the Supreme Court noticed that there were no laws to prevent sexual harassment at workplaces. So, they created enforceable guidelines under Article 32 of the Constitution. These guidelines defined sexual harassment clearly and required preventive and redressal measures in all public and private organizations. These were the first guidelines on gender sensitivity from the judiciary and later became part of the Sexual Harassment of Women at Workplace Act, 2013.
Gender equality includes protection from sexual harassment and the right to work with dignity, which is a basic human right.
Vishaka v. State of Rajasthan: Guidelines Against the Two-Finger Test
In Lillu @ Rajesh v. State of Haryana (2013), the Supreme Court found the “two-finger test” used in rape cases to be unconstitutional. The Court said this practice was unscientific, violated a woman’s privacy and dignity, and was humiliating. As a result, they directed the use of more respectful and scientifically sound medical procedures for examining rape victims.
Guidelines on Victim Compensation and Witness Protection
In Delhi Domestic Working Women’s Forum v. Union of India (1995), the Supreme Court asked the government to:
- Provide legal help for victims of sexual violence.
- Offer psychological support.
- Give compensation for the trauma survivors go through.
These instructions formed the basis for Section 357A of the Criminal Procedure Code (CrPC), which started the system of victim compensation.
Similarly, in Nipun Saxena v. Union of India (2019), the Court set up confidential and safe procedures for rape survivors, like:
- Not revealing the victim’s identity.
- Secret or in-camera trials.
- Guidelines for Safe House Accommodation.
- Fast-Tracking Gender-Based Violence Cases.
Fast-Track Courts for Sexual Offences
After the Nirbhaya gang rape case, the Supreme Court stressed the need for fast-track courts to handle sexual offences quickly.
In State of Maharashtra v. Bandu Daulat (2018), the Court again emphasized the importance of fast justice in crimes against women, noting that delays can harm the victim’s chances of getting justice.
Judicial Manuals and Court Protocols
Gender Sensitization Manuals by High Courts
Several High Courts have made Gender Sensitization and Internal Complaints Committees (GSICC) and have released manuals based on Supreme Court decisions:
- Delhi High Court’s GSICC has created rules to make courts safer for women.
- The Madras High Court’s Gender Sensitization Handbook includes what judges should and should not do when dealing with women who are victims or are involved in legal cases.
These manuals guide judges to avoid stereotypes, be neutral, and use a trauma-informed approach in dealing with rape and harassment cases.
Judicial Infrastructure Guidelines
The Supreme Court’s E-Committee and the National Commission for Women (NCW) have suggested several upgrades to court facilities, such as:
- Separate waiting areas for women.
- Video-conferencing options for victims who fear facing the accused.
- Sensitized court staff and support workers.
Training of Judicial Officers: Institutional Mechanisms
National Judicial Academy (NJA), Bhopal
The NJA regularly organizes training on gender justice, especially:
- Training on handling cases of POCSO and rape.
- Modules on women’s rights under both national and international laws.
- Sessions on feminist legal thinking and the social and legal realities faced by women.
These programs are required for new judges and are also provided as ongoing education for current judges.
State Judicial Academies
Each state has a Judicial Academy that follows the NJA model. Some notable efforts include:
- Maharashtra Judicial Academy’s program on gender-neutral laws.
- Kerala Judicial Academy’s training with UN Women on intersectional gender issues.
Judicial officers are trained using:
- Mock trials.
- Case studies of real rape and domestic violence cases.
- Interactions with survivors and non-governmental organizations.
UNDP & Government Collaborations
The UNDP, in partnership with India’s Department of Justice, has developed gender sensitization modules as part of the Access to Justice for Marginalized People Project.
These programs focus on:
- Using respectful language in courts.
- Recognizing the imbalance of power in gender-based crimes.
- Treating everyone equally, regardless of their class or caste background.
Limitations and Challenges
Even though there are many initiatives, there are still several challenges:
- Training quality is not consistent across states.
- Many judges still have hidden biases that can cause victim-blaming.
- There is no clear system to hold judges accountable if they don’t follow gender-sensitive practices.
- There is not enough infrastructure and a shortage of trained psychologists and support staff in trial courts.
A stronger monitoring system along with mandatory certification in gender justice is needed to make sure that what is taught actually happens in court.
The Supreme Court has laid a solid foundation for gender-sensitive justice through important guidelines, victim-centered directions, and suggestions for court facilities.
Training at both national and state levels has also helped make gender awareness part of the judicial system. However, to ensure that these guidelines lead to real justice for women, the system must focus on major reforms, changes in behavior, and regular checks on how courts operate. Only a judiciary that is both legally skilled and socially aware can deliver true justice to women survivors of crime.
Analysis of Important Court Cases from 1975 to Present
The year 1975 was a big moment for women’s rights and gender justice around the world. The United Nations declared it the International Women’s Year, starting the UN Decade for Women (1975–1985). This time period motivated people everywhere to push for legal, social, and political changes to fight against unfair treatment based on gender. This global movement influenced many countries, including India, to take a closer look at their own laws and systems related to gender.
In India, 1975 was also the year the famous report called “Towards Equality” was released. This report was made by a government committee led by Dr. Phulrenu Guha. It studied the situation of women since India gained independence and found that there were still many deep issues of inequality in areas like education, jobs, politics, health, and justice. It pointed out the weaknesses in India’s legal system when it came to protecting women from crimes like rape, dowry deaths, and domestic violence. It called for immediate changes in the law and the courts to better protect women.
Choosing 1975 as the starting point for this analysis is important. It marks the beginning of a stronger movement for women’s rights in India, where the government and society began to see violence against women as a serious problem rooted in social structures. From that point on, courts were more influenced by public pressure, women’s groups, and constitutional challenges when dealing with cases of violence against women. This makes 1975 a key turning point in how courts have started to be more sensitive to gender issues in India.
There were several important court cases between 1975 and the early 2000s where Indian courts gave unfair or backward rulings in cases involving crimes against women. These cases show how judges sometimes showed bias, followed old beliefs about gender, and made poor legal arguments that didn’t support the victims. These cases set the stage for future improvements.
Tukaram v. State of Maharashtra (Mathura Rape Case), 1979
This was one of the most controversial and talked about cases in India’s legal history. In this case, two police officers raped a young tribal girl named Mathura while she was being held in a police station in Maharashtra. Even though there was strong evidence, the Supreme Court found the accused not guilty, saying that Mathura didn’t resist enough and might have agreed to the rape. The Court even claimed that because there were no injuries, the rape must have been consensual.
This decision completely ignored the fact that Mathura was a minor, in a helpless situation, and had no choice. This ruling caused big protests by women’s groups and eventually led to the Criminal Law (Amendment) Act, 1983. This law introduced changes like Section 114A of the Indian Evidence Act (which assumes there is no consent in rape cases where the victim is in custody) and stronger punishments for rape under the Indian Penal Code. Although the judgment was harmful, it led to changes in the law and helped show the need for more gender-sensitive attitudes in the courts.
Bhoginbhai Hirjibhai v. State of Gujarat, 1983
In this case, the Supreme Court acquitted the accused of rape, saying that the woman’s story lacked independent confirmation. The Court focused a lot on small mistakes in her story and gave more weight to her past behavior and lifestyle. While the judgment had some forward-thinking parts, like acknowledging the importance of the victim’s testimony, the final decision showed the court’s unwillingness to trust the survivor’s story unless there were other forms of evidence. This highlighted the ongoing issue of blaming victims and making it hard for them to prove their case.
State of Rajasthan v. Om Prakash, 2002
Although this case is slightly outside the 1975–2000 timeframe, it shows a continuation of the pattern of gender-insensitive rulings. In this case, the Supreme Court gave bail to a man accused of raping a pregnant woman, considering his young age and saying the act might have been consensual. This decision missed the victim’s condition and the seriousness of the crime. It suggested that being pregnant made the rape less serious, which is wrong because a pregnant woman can still be raped.
This decision was widely criticized for downplaying the trauma of the victim and sending a message that sexual violence isn’t as serious as it really is.
Rupan Deol Bajaj v. K. P. S. Gill, 1998
In this case, a high-ranking police officer named K.P. S. Gill was accused of touching a senior IAS officer, Rupan Deol Bajaj, in a way that violated her modesty at a party. The Court found him guilty under Section 354 of the Indian Penal Code but only gave a fine and probation. The punishment was seen as too light, especially since the act was public and caused serious humiliation.
This case also lasted for almost ten years, showing how delays and support from institutions can protect powerful men from being properly held accountable. It also raised concerns about how elite individuals often get different treatment, and how the system struggles to provide justice to victims, especially when the accused has a public position.
Narender Kumar v. State (NCT of Delhi), 2000
In this case, the trial court found the accused guilty of rape based on the victim’s testimony. However, the High Court later acquitted the accused, saying the woman’s statement had inconsistencies and no medical proof supported her claims. The High Court did not consider that a single, credible statement from the victim is enough for a conviction. It also focused too much on the lack of physical injuries, which reinforced the old idea that rape must be accompanied by visible harm.
This decision made it harder for survivors to believe in the justice system and made it more difficult for them to get justice.
Emperor v. Balkrishna Daji, 1950
Although this case was decided earlier, it was often used in court decisions during the 1970s and 1980s to support the idea of “modesty” in crimes against women. This ruling tied a woman’s modesty to her chastity and her social reputation, reducing her independence to what society sees as proper. Even as late as the 1990s, courts still used this standard to judge the seriousness of crimes, often influenced by the idea of what an “ideal woman” should be.
This dependence on old colonial ideas showed how the way judges think is still influenced by backward systems, which affects how they handle cases of violence against women.
These cases showed how courts often used old-fashioned ideas about what women should act like, including being chaste and resistant, instead of using a more understanding approach that takes trauma into account or focuses on the rights of the victim.
The failure of these cases led to more work by feminists in law and eventually to new laws such as the Criminal Law (Amendment) Acts of 1983 and 2013, and the Protection of Women from Domestic Violence Act, 2005. It is important to study these old rulings to understand how justice for women in India has developed over time.
Mahmood Farooqui v. State (Govt. of NCT of Delhi), 2017
In this very controversial case, Mahmood Farooqui, a known author and filmmaker, was accused of raping a U.S. researcher. The trial court found him guilty, but the Delhi High Court cleared him by accepting the idea that consent can be unclear, weak, or hesitant, not always a clear “no.” This reasoning was criticized for going back to old rape myths and ignoring the idea that consent should be clear and enthusiastic. Feminist legal experts said the court’s understanding weakened the meaning of consent and put the burden on the victim to be clear. This decision was very bad for justice for survivors and was strongly criticized by legal and feminist groups.
Satish Ragde v. State of Maharashtra (Skin-to-Skin Case), 2020
In this worrying decision, the Bombay High Court acquitted a man who was charged under the Protection of Children from Sexual Offences (POCSO) Act. The court said that because there was no “skin-to-skin” contact when he touched a 12-year-old girl, the act didn’t meet the definition of sexual assault in the law. The court used a very literal interpretation of the law, which ignored the purpose of POCSO, which is to protect children from all kinds of sexual abuse. Legal experts and child rights activists said this was dangerous and regressive, as it suggested that abusers could avoid punishment by using legal rules. Fortunately, the judgment was stopped and later reversed by the Supreme Court, which found that the High Court misunderstood the law when dealing with child victim.
State of Madhya Pradesh v. Madanlal, 2015
In this case, the Supreme Court convicted a man for sexually abusing an eight-year-old girl. However, the Court then reduced his sentence to the time he already served (less than a year) because the victim was “very young and could be reformed” and the accused had a “future.” This decision was strongly criticized for putting the needs of the person who did the harm above the trauma of the victim. The decision showed a traditional and patriarchal mindset, ignoring the long-term psychological harm that child survivors endure. Such judgments risk sending the message that child abuse is a small mistake rather than a major violation of human rights.
Aparna Bhat v. State of Madhya Pradesh, 2021 (Trial Court Judgment Criticized)
Although the Supreme Court later issued a more forward-thinking ruling, the case came from a trial court order that told a man accused of sexual assault to get a Rakhi (a traditional knot) tied by the victims as a condition for bail. This was widely criticized for making the serious crime of sexual violence seem like a minor family issue. The Supreme Court strongly rebuked the trial judge for this, saying it reinforced gender stereotypes and didn’t understand the trauma and dignity of the survivor. This shows the lack of training in gender awareness at the lower levels of the judiciary, where most cases start.
Sudhakar @ Raja v. State of Tamil Nadu, 2016
In this case, the accused was found guilty of raping and impregnating a 14-year-old girl. During the appeal, the accused offered to marry the victim, and the court agreed to reduce his sentence, saying he was taking responsibility. This was a bad decision because it suggested that marriage was a solution to rape, normalized forced compromises, and ignored the long-term trauma and autonomy of the victim. Legal experts have criticized this logic, warning that it pressures victims into silence and gives abusers a way out through marriage. Although the law now strongly opposes this reasoning, similar attitudes are still seen in some courts.
Priya Patel v. State of Madhya Pradesh, 2006
This case involved a woman being prosecuted for helping her husband commit rape. The Supreme Court convicted her under Section 376(2)(g) IPC (gang rape), which usually applies only to men. Even though the conviction was later reviewed, the initial decision showed a misunderstanding of how rape laws affect women, and it criminalized a woman under a law that was not meant for her. The Court’s reasoning was criticized for being legally incorrect and not considering gender issues, since Indian rape laws are based on male-perpetrated crimes. This case highlights the need for judges to be clear and sensitive when dealing with laws that are gender-specific.
Aparna Bhat v. State of Madhya Pradesh (Rakhi-for-Bail Order), 2021
A very controversial court order came from a trial court in Madhya Pradesh. The judge told a person accused of molesting someone that they had to go to the victim’s home and get a Rakhi (a type of bracelet) tied by her in order to get bail. This made people very upset because it treated a serious sexual crime like a family matter, not as a criminal act. Women’s rights groups and legal experts were very concerned, and they took the case to the Supreme Court. The Supreme Court strongly criticized this decision, saying that judges should not give conditions that reinforce old gender ideas or hurt victims. They said that judges should be empathetic and follow the law, not old-fashioned ideas of forgiveness or settling things through family.
Ravi v. State of Karnataka, 2007
In this case, the accused was found guilty under Section 376 of the Indian Penal Code (IPC), which is for rape. However, during the appeal, the High Court considered that the accused had married the victim during the trial and decided to release him. The court saw this marriage as proof that the accused wanted to take responsibility. This approach was criticized because it suggested that women can regain their dignity through marriage, which is wrong. Rape is about violating a person’s body and freedom, not just about social status.
Krishan v. State of Haryana, 2002
In this case, the court overturned the rape conviction because there was a delay in filing the FIR and no external injuries were found on the victim.
The court said these things made the prosecution’s case weak. But this decision ignored the real challenges victims face in reporting rape, especially in rural areas where there are strong traditional beliefs. The judgment did not show understanding of the psychological and social barriers that stop people from coming forward. It showed a lack of sensitivity to gender issues and might make other victims afraid to report abuse.
Over the years, India has made many laws to protect women from crimes.
These include the Criminal Law (Amendment) Acts of 1983, 2013, and 2018, the Protection of Women from Domestic Violence Act, 2005, and the Protection of Children from Sexual Offences Act, 2012. These laws were pushed for by feminist movements, especially after tragic incidents like the Mathura rape case and the Nirbhaya gang rape. The idea was to create a system that supports victims and ensures justice. However, looking at court decisions from 1975 to today shows a problem. While laws have improved, many judges still use old ideas that favor men and ignore the rights of women. This report looks at court decisions from two time periods—1975 to early 2000s and after 2000—to show that legal changes have not always led to fair treatment of women in court.
Judicial Reasoning: 1975 to Early 2000s
The Mathura rape case is one of the worst examples of how courts treated women unfairly.
In this case, the Supreme Court found two police officers not guilty of raping a young tribal girl inside a police station, saying there was no proof of resistance, so it seemed like the girl agreed. The judgment ignored the fact that the girl was in police custody and how traumatizing that must have been. It also thought that because no physical injury was found, the act must have been consensual. This decision caused a lot of anger among women’s groups, and that led to the 1983 Criminal Law (Amendment) Act, which included Section 114A in the Indian Evidence Act. This section changed the law to assume that in cases of custodial rape, the victim might not have consented.
Even after this new law, courts often continued to blame victims and rely on stereotypes.
In one case, the court acknowledged that rape survivors face social stigma but still said the victim’s story needed to be supported by other people’s testimony, unlike in other crimes. In another case, the court convicted a man for harassing a high-ranking government official but gave him only probation and a fine. The court seemed to take into account the man’s high social status and was not willing to give a harsher punishment, even though there was clear evidence of wrongdoing.
Many other cases, like Narender Kumar v. State (NCT of Delhi), 2000, showed judges focusing on things like delayed reporting, lack of physical injuries, and conflicting testimonies to decide that there was no crime. These factors completely ignored the psychological pain, fear of being shamed, and the pressure of reporting abuse, which are common in cases of gender-based violence.
During this period, the way courts handled crimes against women was strongly influenced by old ideas about women’s purity, honor, and what is considered proper behavior.
The focus was often on the woman’s behavior rather than the actions of the accused. While some court decisions had positive comments, the overall pattern showed deep-rooted sexism and a lack of understanding of gender issues.
Post-2000 Judicial Trends
Post-2000 changes in the law brought many new rules, especially after the 2012 Delhi gang rape case. This led to the Justice Verma Committee’s recommendations and the 2013 Criminal Law (Amendment) Act. This law made rape definitions clearer, added new crimes like voyeurism and stalking, and made punishments stricter. In 2018, more changes were made, including longer minimum sentences and new laws on child sexual abuse. These laws were meant to bring India in line with international human rights laws. But, even with better laws, judges in some big cases showed they didn’t always understand or apply the laws properly.
In the 2017 case, Mahmood Farooqui v. State, the Delhi High Court overturned the rape conviction because the victim’s ‘no’ wasn’t clearly said. The court thought a weak or unsure ‘no’ might not mean refusal, which goes against the idea of clear consent. This weakens the message that any lack of consent makes sexual activity wrong.
Another case, Satish v. State of Maharashtra (2020), known as the ‘skin-to-skin’ case, said that touching a child without direct skin contact wasn’t sexual assault under the POCSO Act. This very technical view missed the Act’s main purpose of protecting children from all forms of sexual harm. The Supreme Court later overruled this decision, saying it lacked common sense and didn’t respect the law’s original intent.
In the 2015 case, State of Madhya Pradesh v. Madanlal, the Supreme Court reduced the sentence of a man who molested an 8-year-old girl. They said he might reform and the child was young, so he could recover. This focused on the man’s future instead of the child’s trauma, which ignored basic justice and equality principles.
The case Aparna Bhat v. State of Madhya Pradesh (2021) showed another example of gender insensitivity. A court had ordered a woman to tie a Rakhi (a sacred thread) on her molester’s wrist as a condition for bail. The Supreme Court cancelled this, saying it was disrespectful and could even retraumatize the survivor.
Despite these legal changes, many judgments still show old biases, like focusing on the accused’s background, suggesting compromise or marriage, doubting the victim, or calling rape a misunderstanding.
So even with modern laws, the way courts interpret them can be regressive or not trauma-informed.
Conclusion
Comparing before and after the reforms shows that changes in the law haven’t matched changes in how judges think.
While there have been some landmark gender-sensitive decisions, like the Vishaka Guidelines and Joseph Shine case, many lower and high court decisions still show patriarchal views. This means just changing the law isn’t enough. Judges need to develop better understanding of gender, power, consent, and trauma. For real gender justice, better training for judges, more women in the judiciary, and changes in legal education are needed. Without this, public trust in the justice system will keep falling.
Role Of Female Judges In Promoting Gender Sensitivity In Crime Against Women
Despite many legal changes like the 1983, 2013, and 2018 Criminal Law (Amendment) Acts, the Protection of Women from Domestic Violence Act (2005), and the POCSO Act (2012), gender insensitivity in how courts handle cases against women remains a big issue.
A major reason could be the low number of women in the higher judiciary. As of late 2024, women make up only 13–14% of High Court judges, and only two women have ever been Chief Justices in India’s 25 High Courts. This raises important questions:
- Can a male-dominated court truly understand and handle crimes against women with empathy and gender-awareness?
- How do judgments from women judges compare?
- Is having more women in the judiciary necessary for more fair and equal rulings?
Female Representation in High Courts (2024)
Recent data shows:
- High Courts have 754–846 judges, of which only 99–106 are women (13–14%).
- Only two women currently serve as Chief Justices across all High Courts.
- Appointment numbers remain low: just 17.
- 5% of 192 new High Court judges in early 2025 were women.
Disparities exist across states:
- Punjab & Haryana HC: 13 women of 54 judges (24.1%)
- Madras HC: 12–13 of 66–67 judges (19%)
- Bombay HC: 10–11 of 63–69 judges (16%)
- Delhi HC: 9 of 37 judges (24.3%)
- Telangana HC: 8 of 27 (29.6%)
- Gujarat HC: 8 of 29 (27.5%)
- Calcutta HC: 6–8 of 45–46 (13–18%)
- Several courts (Meghalaya, Tripura, Uttarakhand) had one or no women judges.
The Role of Women Judges in Gender-Sensitive Jurisprudence
Even though women judges are still a small group, some have made important decisions that show more awareness of gender issues, especially in cases against women.
Justice Sadhana Sanjay Jadhav (Bombay High Court)
In 2013, Justice Jadhav, along with Justice Tahilramani, made an important administrative decision: from then on, all appeals against rape acquittals in the Bombay High Court would be heard by benches with female judges. This was a systemic step to improve gender sensitivity in such cases.
Justice Usha Mehra (Delhi High Court, Retd.)
Justice Usha Mehra led the 2012 Inquiry Commission after the Delhi gang rape case. Her report suggested changes to how evidence is handled, more female police officers, and better support for survivors. These recommendations have helped shape how cases are handled and support systems across the country.
Justice Pratibha Rani (Delhi High Court)
In 2016, she supported the death penalty for the Nirbhaya convicts. She also ruled that not agreeing to sexual intimacy is a form of mental cruelty in marriage-related cases, which helps women maintain their independence. She challenged the misuse of bail provisions under the POCSO Act, ensuring its purpose remains to protect children. Between 2014–2017, she criticized the idea of treating rape as a marital issue, highlighting how it can be used for revenge, correcting earlier legal misunderstandings.
Representation and Institutional Change
Chief Justice Smita Das De and the Calcutta High Court bench, which has eight women judges, marked a high point in female representation. This shows that having more women in the judiciary might lead to more gender-aware legal decisions. Some legal professionals believe women bring a better understanding of the difficulties faced by female litigants and advocates.
Does having more women in the judiciary really make a difference?
While women judges might help in certain ways, their presence alone doesn’t guarantee gender-sensitive application of the law. For example, in Bombay and Delhi where about 24% of judges are women, there are more efforts to make courts gender-aware. However, there are still decisions that ignore women’s issues, such as unclear interpretations of consent or narrow readings of the law.
Despite more women judges in district courts (36–48%), the number decreases sharply in High Courts (14%) and the Supreme Court (9–10%). Reasons include family responsibilities, lack of support, difficult promotion processes, absence of role models, exclusion from networks, and reluctance to appoint women. The male-dominated Judicial Collegium also contributes to this issue.
Impact of Underrepresentation
The underrepresentation of women judges affects two key areas:
- Case assignment and judicial mindset: Male-dominated benches may unconsciously reflect gender stereotypes, seen in overly strict bail conditions or victim-blaming. A gender-diverse bench can resist such views and better consider individual dignity and autonomy.
- Institutional reforms and gender-sensitive processes: Women-led benches have driven changes—such as in Bombay and Delhi High Courts, and procedural reforms in Delhi trials. But insensitive judgments show that laws like the POCSO Act and affirmative consent statutes require strong judicial backing to succeed.
Recommendations for Improving Gender-Sensitive Decision-Making
- Promote more women to High Courts to reach 30–40% representation.
- Provide mandatory gender-sensitivity training for all judges—covering trauma, legal interpretation, and constitutional principles.
- Establish more women-led benches, following the Bombay High Court model.
- Support women judges through childcare, mentorship, and flexible job assignments.
- Track and study how bench composition affects court decisions, sentencing, and victim treatment.
Conclusion
Even though the number of women in India’s High Courts remains low, women judges have shaped a more gender-aware legal system through focused decisions and institutional reforms.
However, ongoing underrepresentation, systemic barriers, and male-centric attitudes continue to obstruct meaningful progress. Real gender justice requires more than just laws—it demands a judiciary that reflects society and understands how gender impacts law, process, and judicial reasoning.
Until women’s presence leads to deep cultural and structural change, the judiciary cannot fully uphold the constitutional values of dignity, equality, and justice.
Recommendations And Conclusion:
Enhancing Gender Diversity in the Judiciary
One of the most important steps to ensure the judiciary treats crimes against women in a fair and sensitive way is to have more women in the judiciary, especially in higher courts.
Even though women make up a large number of law graduates and those who start in lower courts (around 36% in district courts), their presence in higher courts and the Supreme Court is much lower—about 13–14% in High Courts and under 10% in the Supreme Court as of 2024.
This gap shows a “leaky pipeline” where barriers like unfair systems, unclear appointment processes, lack of support, and workplaces that don’t consider gender issues slowly push women out of the judicial system.
Having more female judges not only helps make the system fairer but also brings in different points of view based on real-life experiences of discrimination and inequality.
More women on the bench often means more understanding when it comes to laws about sexual violence, domestic abuse, harassment, and reproductive rights, making the legal process more caring and empathetic.
Mandatory Gender Sensitization and Trauma-Informed Judicial Training
Gender sensitivity must be built into the judicial system through regular and structured training for judges at all levels.
These trainings should go beyond simple awareness and cover important topics like:
- How power works between genders
- The social background of crimes
- The idea of affirmative consent
- Trauma psychology
- Intersectionality (how other factors like caste, class, disability, and religion affect gender-based harm)
The Supreme Court’s 2023 Handbook on Combating Gender Stereotypes is a good start, but it needs to be fully used in training programs and ongoing learning for lawyers.
Training should also teach judges about how to use language in court that doesn’t blame victims or make their trauma seem less important.
Judges must be able to understand and respond to structural inequalities, avoid unfair assumptions, and make decisions that follow the principles of constitutional morality and human rights.
Creating Women-Led or Gender-Balanced Benches in Cases of Crimes Against Women
To build trust and show empathy in cases involving gender-based crimes, courts should create benches led by women or with a mix of genders, especially in cases like rape, sexual harassment, domestic violence, dowry death, and cases under the POCSO Act.
In 2013, the Bombay High Court passed an order stating that all appeals in rape cases must be heard by benches with at least one woman judge. This helped ensure that judges who understood the emotional and social aspects of these crimes handled the cases more carefully.
Other high courts should follow this example. While the legal reasoning must stay fair and objective, the lived experiences of judges can greatly improve how deeply and sensitively they understand these cases. This also builds trust in the justice system among women.
Institutional Support and Infrastructure for Women Judges and Litigants
One important but often overlooked factor in promoting gender-sensitive justice is creating better support systems and physical environments.
Women judges, lawyers, and people who come to court often face practical and physical challenges like lack of:
- Safe transportation
- Restrooms
- Childcare
- Secure workspaces
Courts must urgently fix these challenges by setting up:
- Childcare centers
- Separate restrooms
- Lactation rooms
- Flexible work policies
There should also be effective and accessible ways to deal with sexual harassment inside court buildings, without delays or unfair influence from higher-ups.
Without these systems, women are less likely to continue in legal careers and move up in the judicial hierarchy.
For those coming to court, tools like video conferencing, one-stop crisis centers, and courts that are friendly to victims are essential to reduce stress and make the process less confrontational.
Women-Centric Legal Awareness Programmes and Community Education
A strong court system can’t work alone without the support of the society it serves.
One important recommendation is to create widespread awareness programs for women, especially in rural, tribal, minority, and economically weak areas. These programs should teach women about their legal rights and how to seek justice. Many crimes against women in India are not reported because people don’t know their rights, fear their community, are dependent for money, or don’t trust the courts.
So, the government, courts, and community groups need to work together to spread awareness through:
- Legal help centers
- Schools
- Mobile units
- Social media
- Community radio
- Village meetings
Topics should include laws like:
- The Domestic Violence Act
- The Sexual Harassment of Women at Workplace Act
- Prohibition of dowry
- Updated rape laws
- How to file police complaints
- Access to free legal aid under the Constitution
Paralegals, NGOs, and local legal aid services can play a big role in this.
Awareness should also reach men and boys to help change attitudes and stop the acceptance of sexist behavior.
Judges can help by speaking publicly, organizing workshops, and supporting community-based education. When women are better informed and more confident, they are more likely to seek and get justice.
Empirical Monitoring and Evaluation of Gender Sensitivity in Judicial Outcomes
To track progress and hold the system accountable, there needs to be a Gender Justice Monitoring Mechanism set up under the National Judicial Academy or the Ministry of Law and Justice.
This body should carefully look at:
- The number of men and women on benches
- Trends in how courts handle crimes against women (like bail, conviction, and acquittal rates)
- Average time to finish cases
- Use of gender stereotypes in court decisions
- Number and type of appeals
Regular reviews, scorecards, and performance reports should be published for the public, researchers, and media to see.
This transparency will help spot patterns of bias, guide future reforms, and ensure the courts follow the law and human rights standards. It will also act as a check on unfair or backward thinking in court decisions.
Conclusion
The courts play a key role in making sure that women who face violence based on their gender get fair treatment.
Over the years, there have been many changes in the laws that protect women, like the Criminal Law Amendments (1983, 2013, 2018), the Domestic Violence Act (2005), and the Protection of Children from Sexual Offences (POCSO) Act (2012). However, even with these legal updates, the way courts handle cases often does not match the goals of these reforms.
Judges sometimes show lack of understanding, stick to old beliefs, and follow traditional ideas that hurt the rights of women. Cases like State of MP v. Madanlal (2015) and Satish v. State of Maharashtra (2020), where courts treated serious crimes as minor, show that there is still a gap between the laws on paper and the actual justice given.
At the same time, some female judges, like Justice Pratibha Rani, Justice Gita Mittal, and Justice Usha Mehra, have brought important changes.
They have used more modern thinking and focused on the needs of the victims in cases involving rape, domestic abuse, and workplace harassment. These examples show that when the courts include more women, the decisions are more likely to value human dignity, fairness, and justice for women.
But it’s not enough just to have more women in the judiciary.
There are still many problems that need fixing, like the culture in the courts, the way judges are trained, how they are brought into the system, and the deep-rooted traditions that favor men.
So, there needs to be a wide range of changes—like:
- Making sure more women are chosen for jobs
- Keeping them updated with new knowledge
- Connecting with the community
- Improving court facilities
- Making sure the public can check on how judges are doing
It’s also important to help women know their rights and feel confident to seek justice.
Without that, even the best courts may not help them. So, making the courts more sensitive to gender issues is not just a legal problem, but a big part of democracy. Only when the courts are open, caring, and understand the Constitution can they truly support justice, equality, and respect for all women in India.
Bibliography Statutes and Legal Provisions
- The Constitution of India (especially Articles 14, 15, 21, 39A).
- The Criminal Law (Amendment) Act, 1983, 2013 & 2018.
- The Protection of Women from Domestic Violence Act, 2005.
- The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013.
- The Dowry Prohibition Act, 1961.
- The Protection of Children from Sexual Offences (POCSO) Act, 2012.
- Indian Evidence Act, 1872 (Section 114A on presumption of absence of consent).
- Indian Penal Code, 1860 (Section 354A-D, 375-376, 498A, etc.).
Research Articles and Journals
- Agrawal, Anuja. (2015). “Gendered Justice: Women and the Indian Penal System.” Indian Journal of Gender Studies, 22(2), 157–178.
- Sathe, S.P. (2002). “Judicial Activism: The Indian Experience.” Washington University Journal of Law and Policy, 10, 29–54.
- Baxi, Upendra. (2001). “Rape, Retribution, State and Victim Justice in India.” Journal of Human Rights, 4(1), 5–32.
- Parashar, Archana. (1992). “Women and Family Law Reform in India.” Law & Society Review, 26(2), 641–659.
- Chatterjee, Chandrima. (2017). “Judicial Response to Crimes Against Women: A Critical Analysis.” Indian Bar Review, 44(4), 129–146.
- Ghosh, S. (2018). “Gender Sensitivity and Indian Judiciary: A Critical Study.” International Journal of Research and Analytical Reviews, 5(4), 1032–1038.
- Mukherjee, R. (2020). “Gender Justice and Judiciary in India: A Feminist Critique.” Law and Society Review India, 2(1), 1–18.
Reports, Handbooks & Policy Documents
- Towards Equality: Report of the Committee on the Status of Women in India, Ministry of Education and Social Welfare, Government of India, 1974–75.
- Handbook on Combating Gender Stereotypes, Supreme Court of India, 2023.
- Justice Verma Committee Report on Amendments to Criminal Law, Government of India, 2013.
- India Justice Report 2022, Tata Trusts and Centre for Social Justice.
- National Crime Records Bureau (NCRB) Reports – Crimes Against Women (various years).
- National Commission for Women (NCW) Reports on Gender-based Violence and Legal Reforms.
- All India Judges’ Training Program Manual, National Judicial Academy, Bhopal.
Judicial Decisions (Referenced)
- Tukaram v. State of Maharashtra (1979) 2 SCC 143.
- State of Madhya Pradesh v. Madanlal (2015) 7 SCC 681.
- Mahmood Farooqui v. State (Govt. of NCT of Delhi), 2017 SCC Online Del 10705.
- Satish v. State of Maharashtra (2020) SCC Online Bom 708; reversed in (2021) 5 SCC 527.
- Aparna Bhat v. State of Madhya Pradesh (2021) 5 SCC 512.
- Vishaka v. State of Rajasthan (1997) 6 SCC 241.
- Lillu @ Rajesh & Anr. v. State of Haryana (2013) 14 SCC 643.
- Delhi Domestic Working Women’s Forum v. Union of India (1995) 1 SCC 14.
