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Judicial Activism in Protection and Promotion of Women in India with special reference to Indian Con

"You can tell the condition of a nation by looking at the status of its women".... Jawaharlal Nehru[1]

Women who constitute half a human population have been discriminated harassed and exploited irrespective of the country to which they belong, un-mind of the religion which they profess and oblivious of the timeframe in which they live.[2] Everywhere women are confronted with many challenges. In all societies to a greater or lesser degree women and girls are subjected to physical, sexual and psychological abuse that cuts across lines of income, class and culture.

Unfortunately, India is one of the few countries where offences against women have been increasing in tremendous way. In fact since ages the status and the position of women in India is a controversial subject, as it reflects the contradictory and the paradoxical nature of the Indian society. In one way people offers prayers to women as goddess, more over Indian tradition and the culture says that "yatra nari pujyante tatra ramante devta"[3]. But at the same time and in other side women are considered to be in the secondary position and they are put to atrocities even before birth till death.

In mean time constitutional law and ordinary law through judiciary has been working as a savior of women from atrocities and also giving helping hand in numerous ways for perk up status of women in all spears of their life.The status of women in our country has risen to the present level which may not be up to the mark but still satisfactory is because of active judiciary as well as public spirited people who successfully manoeuvred the status of women of our country to the present level. The unbiased and independent judiciary has always played the role of a true Guardian of justice. Since independence many a times the judiciary has pro-actively interpreted and amplified the ambit of legislative provisions in favour of the unprivileged half of the society, i.e., the women of our country.

The position of women in India in different periods[4]
From the Vedic age to till today, status and position of women has been changing with the passing of time.[5]Historical studies and the scriptures indicate that Indian woman enjoyed a comparatively high status during the early Vedic period, later, the condition and status of women in India declined with the passage of time. During the medieval period, woman was given a position subordinate to man. Law and religion did not recognize the equality and equal rights of man and woman. Finally, when the British came in to contact with the Indian people in the latter half of the 18th century, the position of Indian woman had deteriorated to the lowest level. Ideologically, women were considered a completely inferior species, having no significance, no personality. But because of contributions made by many social reformers like Raja Ramohan Rai, Veresa Lingam, Ishwar Chandra Vidyasagar, Vivekananda, Jyothira Phule, Anne Besant, Mother Teresa, Mahatma Gandhi[6], Nehru, Dr. B. Ambedkar, Vinoba Behave etc. British government introduced some laws for the protection of women like the widow remarriage Act, 1856, Civil Marriage Act, 1872, Married women’s property Act, 1874, The Child Marriage Restraint Act, 1921, The Prevention of Prostitution Act, 1923, The Hindu Inheritance Act, 1929, Sati Prohibition and more importantly special provisions for women protection in Indian Penal Code, 1860 etc.

After independence, Indian government passed several general as well as special laws especially constitutional provisions for protection of women to safeguard and to empower women in India. The improvement in women’s position and status became further evident when immediately after the independence, Indian women made their mark by becoming Governors, Cabinet ministers, and ambassadors. Several measures were taken by the Government of India to assign equal status to women in the economic, political and social fields.

The rights available to woman in India can be classified into two categories, namely as constitutional rights and legal rights. The constitutional rights are those which are provided in the various provisions of the constitution, which is the basic law of the land. The legal rights, on the other hand, are those which are provided in the various laws. The Constitution of India pledges equality of status and opportunity to men and women.[7]Being a custodian of constitution apex court has been trying to fulfill constitutional objectives by numerous pronouncements in several cases.

Finally it will be evident from history that the atrocities against women are since time immemorial. And at the same time protection of women from atrocities is also as old as atrocities against women in the form of religion, custom, ethical, moral values and through social movements, national and international legal protections etc. but among all these the significant role has been playing by law through judiciary as a savior of women from atrocities in modern era. Legal safeguards not only protect women from atrocities, violations etc but also empowering women in social, economical, educational, political fields.

Constitutional rights and safeguards toWomen - Concept of Protective discrimination
The constitution of India not only granted equal status to women par with men, but also empowers the state to adopt measures of positive discrimination in favour of women[8]for neutralizing the cumulative socio economic, education and political disadvantages faced by them. Constitutional framers also empowered the state to make special laws, policies, plans and programmes with in a democratic polity for advancement of women in all spheres. The framers of constitution aimed to provide justice, liberty and equality irrespective of gender, it can be witnessed in Preamble, Fundamental Rights, Directive Principles of state policy, Fundamental duties and in other provisions.

The preamble is the key to open the mind of the makers. Constitutional framers aimed to provide justice, liberty and equality to people irrespective of gender, status, religion, creed and cast etc. by this one can understand that framers would like to establish a society with gender equality, which directly or indirectly tries to uphold the women empowerment.

The rights and safeguards enshrined in the constitution for women in India
1.The right to equality and equal protection of laws [Article 14]
2.The state shall not discriminate against any citizen of India on the ground of sex [Article 15(1)].
3.The state is empowered to make any special provision for women. In other words, thisprovision enables the state to make affirmative discrimination in favour of women [Article15(3)].
4.No citizen shall be discriminated against or be ineligible for any employment or office under the state on the ground of sex [Article 16(2)].
5.Traffic in human beings and forced labour are prohibited [Article 23(1)].
6.The state to secure for men and women equally the right to an adequate means of livelihood [Article 39(a)].
7.The state to secure equal pay for equal work for both Indian men and women [Article 39(d)].
8.The state is required to ensure that the health and strength of women workers are not abusedand that they are not forced by economic necessity to enter avocations unsuited to theirstrength [Article 39(e)].
9.The state shall make provision for securing just and humane conditions of work and maternityrelief [Article 42].
10.The State to promote with special care the educational and economic interests of the weaker sections of the people and to protect them from social injustice and all forms of exploitation [Article 46].[9]
11.The State to raise the level of nutrition and the standard of living of its people [Article 47].[10]
12.It shall be the duty of every citizen of India to renounce practices derogatory to the dignity ofwomen [Article 51-A(e)].
13.One-third of the total number of seats to be filled by direct election in every Panchayat shallbe reserved for women [Article 243-D(3)].
14.One-third of the total number of offices of chairpersons in the Panchayats at each level shallbe reserved for women [Article 243-D (4)].
15.One-third of the total number of seats to be filled by direct election in every Municipalityshall be reserved for women [Article 243-T(3)].
16.The offices of chairpersons in the Municipalities shall be reserved for women in such manneras the State Legislature may provide [Article 243-T(4)]. Etc.
17.The elections to the House of the People and to the Legislative Assembly of every State shall be on the basis of adult suffrage; that is to say, every person who is a citizen of India and who is not less than eighteen years of age irrespective of gender, status etc entitle to be a voter. [ Article 325[11]and 326[12]].

Article 14ensures that the state shall not deny to any person equality before law. It prohibits class legislation but permits reasonable classification. This is a very important provision which provides equal legal protection to women against any women basedcrime. Article 15 (1)prohibits discrimination against any citizen based on religion, race, caste, sex or place of birth while Article 15 (3) permits ‘protective discrimination’ in favour of women according to which state can make special provision for women and the scope of this article is wide enough to cover the entire range of state activity including employment. Article 16(2)of constitution of India ensures equal employment opportunity to every citizen of India. Article 42 empowers the state to make laws for women workers and by which it can provide special maternity relief to women. Like, above with the help of fundamental rights and directive principles of state policy state can provide protective discrimination towards women, which will not infringe general equality. The reason behind this is physical structure and performance of maternal functions of women place her at a disadvantage in the struggle for subsistence and her physical well being becomes an object of public interest and care in order to preserve the strength and vigour of the race makers has given these safeguards to women. It is evident from numerous pronouncements of the court.

Role of Judiciary for empowering women
All provisions of the Constitution and all laws enacted by the legislature get their real meaning and import through the process of judicial interpretation. The Constitutional mandate and the various laws providing for protective discrimination in favour of women relating to several aspects of their social, economic and political life have come up before the courts. Through various devices like judicial review, judicial activism, social action litigation and the duty of enforcement of fundamental rights the superior Courts in India have evolved a gender jurisprudence which has given substance and life to the constitutional scheme of protective discrimination in favour of women. Below is detailed overview of the judicial approach in various cases, where the Courts have successfully delivered their verdict to strengthen position of women.

1.Judicial Approach in the matters relating to Education:
Education is a part of the development of the personality of all in general and woman in particular. In P. Sagar v. State of Andhra Pradesh[13],The Andhra Pradesh High Court observed that Article 15(3)is an exception engrafted to clause (1) of the Article 15. Thus, in view of the Article 15(3) reservation for women cannot be denied. Similarly, the reservation for sports women does not offend the provisions of Articles 15(1) and 29(2) of the Constitution.[14]

In Padmaraj Samarendra v. State of Bihar[15],allotment of some seats for girl students in Medical Colleges was challenged on the ground that it is solely based on sex. The Court while justifying the allotment of seats for girl students held as reasonable and it cannot be said to be discrimination on the ground of sex alone.

2.Judicial Approach in the matters of Employment:
In Miss C.B, Muthamma, I.F.S v. Union of India,[16]In Air India v. Nergesh Meerza and other,[17] In A.N. Rajamma v. State of Kerala,[18]the Court upholding the principle of equality of status put the female employees at par with male employees and struck down the various rules as unconstitutional.

In Vijay Lakshmi v. Punjab University[19],court held that appointment of lady Principal in Women’s college or a lady teacher therein, cannot be held to be violative of Articles 14 and 16 of the Constitution, because classification is reasonable and it has a nexus with the object to be achieved. More over it is a precautionary, preventive and protective measure based on public morals and particularly in view of the young age of the girl students to be taught.

In a plethora of cases such as Peoples Union for Democratic Rights v. Union of India[20], Randhir Singh v. Union of India[21], Sanjit Roy v. State of Rajasthan[22], Uttarakhand Mahila Kalyan Parishad v. State of Uttar Pradesh [23]and Mackinnon Mackenzie and Co. Ltd. v. Andrey D’ Costa [24]etc cases Judiciary has played an active role in enforcing and strengthening the constitutional goal of "equal pay for equal work" enshrined in Article 39(a), which implicit in Article 14 and 16 of the Constitution. The court has brought the equal remuneration within the contours of fundamental right of equality.

In several cases court has held that the State is competent under Arts. 15(3), 16(2) and 16(4) of the Constitution to give preference to women in government jobs where they are equally meritorious but more suited than men. The Court made it clear that giving preference to women is only an affirmative action and not a reservation which normally implies a separate quota which is reserved for a special category of person who are less meritorious.

Moreover, court also accepted that under Factories Laws, the State prohibits the appointment of women in the factories in certain categories, i.e., on the dangerous and hazardous machinery, the working hours are also restricted for the women and the State prohibits women in working in the night times.

Finally court held that allotment of seats in buses, educational institutions for ladies is also not gender discrimination, but is a protective discrimination keeping in view of the weak physical structure of women, and social safety in the society.

-Prevention of sexual abuse at work places
In Vishaka v. State of Rajasthan,[25] Supreme Court had framed guidelines and norms for protection of working women at work place, and it held that it is the duty of the employer to protect women from sexual abuse, which are later parliament, recognized and enacted Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013.

3. Humanitarian approach of the Judiciary towards sex-workers and sexually abused women:
In Budhadev Karmaskar v. State of West Bengal[26], Court held that generally,our society views prostitutes as women of low character but, refuse to look at their situation from their perspective. The bench in this case must be appreciated not just for recognizing their right under Article 21 and directing the state and central governments to act for their welfare but also, to understand their perspective and impoverished situation. Not only this, but the bench acted quite actively and gave the directions to Central and State government to prepare schemes for giving technical/vocational training to sex workers and sexually abused women in all cities in India.

4. Judicial role in Stop Acid attacks, regulate and restrict the sale of acid:
In Laxmi v. Union of India[27]On account of increase in number of acid attacks on women in the past few years, Supreme Court in order to curb these gave directions to Home Secretary, Ministry of Home Affairs associating the Secretary, Ministry of Chemical & Fertilizers to convene a meeting of the Chief Secretaries/concerned Secretaries of the State Governments and the Administrators of the Union Territories to curb and restrict the sale of acid throughout the country.

Acid attacks on women and girls in 2013 and 2014 have been 56 and 47 in number respectively as per the statistics of acid survivors’ organization.[28]Acid attack on a women is equal to taking away her identity from her and such rampant increase in this heinous crime was leading to terror amongst women and Supreme Court took a vital step and certainly led to the empowerment of women to an extent and was an important step towards the safety of women in country. the Supreme Court issued several directions for the protection of acid attack victims such as: minimum 3 Lakh Rupees compensation for victims, adequate publicity of victim compensation schemes, private hospitals must not refuse treatment to victims, and full treatment must include medicines, food, bedding and reconstructive surgeries.

5. Role of judiciary in upholding special provisions for women in criminal law:
In Yusuf Abdul Aziz v. State of Bombay,[29]Supreme Court held that under section 497 of IPC man only be punished for offence of adultery and woman will be exempted though she may be equally guilty as an abettor was valid. It is reasonable classification under Article 14 and it was saved by virtue of Art. 15(3). In a Sowmithri Vihnu v. Union of India,[30] the court held that the contemplation of the law, evidently, is that the wife, who is involved in an illicit relationship with another man, is a victim and not the author of the crime. In Revathi v. Union of India, [31]the court held that that Section 497 of the Indian Penal Code is so designed that a husband cannot prosecute the wife for defiling the sanctity of the matrimonial tie by committing adultery. Thus the law permits neither the husband of the offending wife to prosecute his wife nor does the law permit the wife to prosecute the offending husband for being disloyal to her. Thus both the husband and the wife are disabled from striking each other with the weapon of criminal law.

6. Judicial approach in recognizing women guardianship rights:

In Githa Hariharan v. Reserve Bank of India[32]etc apex court struck down those rules and regulations even legislative Act which were causing for gender bias. Held that even a mother can be a legal guardian to her children whether father a live or not. In ABC v. The State (NCT of Delhi)[33]theSupreme Court declared landmark judgment saying that an unwed mother is not bound to disclose the name of child’s father and also, she would have all the rights as a guardian to child under guardianships rights. She need not take father’s consent for guardianship rights. Not only it was necessary to protect the child from social stigma but, also to protect mother’s fundamental right. It was certainly an avant-garde verdict on gender quality.

7.Judiciary presumed live-in-relationship for long term as deemed marriage:
In Dhannulal and ors. v. Ganeshram and ors[34],it was held that continuous cohabitation of a couple together that is, ‘live-in relationship’ would raise the presumption of marriage unless otherwise proven.In this matter, the woman had been living with a man as his wife for around 20 years until his death in the same house with the respondent-relatives who alleged that she was only a mistress and not the legally wedded wife.The woman clearly failed to prove that she was the legally wedded wife of deceased but, the bench still held that she was eligible to inherit the property.

8. Role of judiciary in recognizing women’s rights in the context of maternity benefit in case of surrogacy:
In P Geetha v. Kerala Livestock Development Board Ltd[35], the petitioner, who became a mother through surrogate procedure, was not granted maternity leave by the Respondents on the ground that birth of the child was not under normal circumstances. The High Court held that while granting maternity leave, women could not be discriminated merely because the baby was obtained through surrogacy.

9.Judiciary conferring property rights on women par with men:
Property is one of the important endowments or natural assets to accord opportunity, source to develop personality, to be independent, thus effectuating the right of equal status and dignity of person to women. In Pratap Singh v. Union of India[36], Jagannathan Pillai v. Kunjithapadam Pillai[37], ThotaseshaRathamma v. Thota Manik yamma[38],C. Masilamani Muddaliar v. Idol of Sri Swaminathaswami[39], and Velamuri Venkata Siva Prasad v. Kothuri Venkateswarlu[40]etc cases Judiciary emphasised on gender equality as the prime consideration in interpretation of statutes conferring property rights on women, has encouraged legislation in this regard. The Supreme Court paved way for other courts to follow it as a precedent while deciding cases of women’s right to property.
Finally, now the Hindu Succession (Amendment Act), 2005 recognized coparcenary property rights of women.

10.Role of judiciary in safeguarding rape victim:
-Rape is an offence against right to privacy and dignity of women

In Delhi Domestic Working women’s Forum v. Union of India,[41]in Bodhisathwa Gautam v. Subhra Chakraborty,[42] and in Chairman, Railway Board v. Chandrima Das,[43] etc cases court held that women also have the right to life and liberty; they also have the right to be respected and reacted as equal citizens. Their honour and dignity cannot be touched or violated. They also have the right to lead an honorable and peaceful life. Rape is a crime against basic human rights and is also violative of the victim’s most cherished of the fundamental rights, normally, the right to life and privacy contained in constitution under Art. 21 and court had provided compensation to rape victims.

-Two finger test, it’s like getting raped once again
In Lillu @ Rajesh & Anr vs State of Haryana[44],For the first time, the Supreme Court in this case realized the agony and trauma of a rape victim who had to go through two finger test give her character certification and after analyzing through various precedents, held that it is violation of victim’s right to privacy and dignity. Court held that medical procedures should not be carried out in a manner that constitutes cruel, inhuman, or degrading treatment and health should be of paramount consideration while dealing with gender-based violence. The State is under an obligation to make such services available to survivors of sexual violence. Proper measures should be taken to ensure their safety and there should be no arbitrary or unlawful interference with her privacy.

-Rape is not a compoundable offence
With regard to determination of rape cases, in State of Madhya Pradesh v. Madan Lal[45], the Supreme Court once again clarified that rape cases cannot be compromised or mediated, as rape is a non-compoundable offence. The Court held that compromise in rape cases would be against the victim’s honor and dignity, which are sacrosanct. Bench also held that allowing compromise is not a good sign to society and"such an attitude reflects lack of sensibility towards the dignity, the elan vital, of a woman."

11. Role of Judiciary in safeguarding right to freedom of women:
Articles 19 to 22 of The Constitution of India provide a detailed scheme of Right toFreedom.Article 19 (1)guarantees 6 freedoms[46] for citizens with reasonable restrictions and Article 21provides for Right to life and personal liberty of each and every person in India which includes Right to live with human dignity, right to livelihood, right to work, right to privacy, right against sexual harassment etc.

-Virginity test is violative of right to privacy
In Surjit Singh Thind v. Kanwalji Kaur,[47] apex court held that allowing the medical examination of a women’s virginity violates her right to privacy under Art. 21 of the Indian Constitution.

-Women has right to choose her partner without any compulsion
In Ravi Kumar v. State[48], Lata Singh v. State of Uttar Pradesh[49]and in Lata Singh v. State of Uttar Pradesh, it was held that Right to Marriage is an essential part of the right under Art.21 and that people have the right to choose their partners without any compulsion. For there, it also held that "This is a free and democratic country, and once a person becomes a major he or she can marry whosoever he/she likes. If the parents of the boy or girl do not approve of such inter-caste or inter-religious marriage the maximum they can do is that they can cut off social relations with the son or the daughter, but they cannot give threats or commit or instigate acts of violence and cannot harass the person who undergoes such inter-caste or inter- religious marriage.

-Recognizing sex selection and female feticides as offence against right to life of women
In CEHAT v. UOI and others [50]the Supreme Court had given several directions regarding sex selextion and sex selective abortion and for proper implement of Pre-Natal Diagnostic Techniques Act by saying that female foeticide as a heinous act and an indicator of violence against women.

The Indian Parliament also enacted Medical Termination of Pregnancy Act, 1971,The Indecent Representation of Women (Prohibition) Act, 1986,Pre-Conception and Pre-Natal Diagnostic Techniques (Prohibition of Sex Selection) Act, 1994,Protection of Women from Domestic Violence Act, 2005and many more laws to protect the women life and liberty.

But in fact "Freedom cannot be achieved unless the women have been emancipated from all forms of oppression"[51].

12.Judicial approach in protection of women from exploitation:
Right against exploitation is recognized under Article 23 and 24 of the Constitution of India. Article 23prohibits "traffic in human beings and beggar and other similar forms of labour". The expression "traffic in human beings is evidently a very wide expression including the prohibition of traffic in women for immoral or other purposes. Alsothe Suppression of Immoral Traffic in Women and Girls Act, 1956has been enacted with the object of inhibiting or abolishing the immoral trafficking of women and girls. Articles 21 & 23also impose the duty on state to identify, release and rehabilitate freed bonded labourers.

In Gaurav Jain v. Union of India,[52]the Supreme Court held that the children of the prostitutes have the right to equality of opportunity, dignity, care, protection and rehabilitation so as to be part of mainstream social life.

Besides above there are several issues in like recognizing right to get maintenance by women not only under personal law but also under criminal procedure code irrespective of their religion[53], a step mother[54]and adoptive mother[55]is also able to get maintenance , a women, who for long term in live-in-relation[56]also able to get maintenance because of judicial verdict only.

Finally one can say that in India there are so many laws by legislatures, rules by administrator and judicial pronouncements and more importantly individual as well as group women organizations continuous affords for women protection and empowerment but too little justice to her because of lack of unawareness, un-interest among women and people in society. It is the need of the hour to have aware and empowered women. An empowered woman not only protects herself but also protect people around her. So, it is time to break silence; women should fight for her place in this male dominated society. It should be start from family itself. The mindset and the patriarchal views that have engulfed Indian people mindset since ages should be change then only the real fruits of law will be enjoyed by women.
"A woman with a voice is, by definition, a strong woman." – Melinda Gates[57]

*Assistant Professor, Smt. V.D. Siddartha Law College, Kanuru, Vijayawada, Krishna District, Andhra Pradesh, India. E-mail: [email protected]

[1]Available at :
[2]Dr. K.C. Jena, "Heirship of Women under Indian Personal Laws. A comparative study", Ph.D. Thesis (1998).
Available at:
[3]It means where the women are respected, the God will be pleased.
[4]viz. Ancient, Medieval, British and Independent period.
[5]Puja Mondal, Status of Women in Vedic and Post-Vedic Period - Available at :
[6]Mahatma Gandhi was having absolute faith in inherent power of women, he emphasized it by saying- "complete emancipation of women and her equality with man is the final goal of our social development, whose realization no power on earth can prevent" - Available at:
[7]Article 14 of the Indian constitution.
[8]Art. 15(3)
[9]To achieve this aim states providing reservations in educational and employment for women as well as to other weaker sections of society.
[10]To achieve this goal states providing necessary food for below poverty line people through PDS (Public distribution stories) and nutrition food for woman during their pregnancy through Anganvadi services.
[11]Article 325: No person to be ineligible for inclusion in, or to claim to be included in a special, electoral roll on grounds of religion, race, caste or sex.
[12]Article 326 : Elections to the House of the People and to the Legislative Assemblies of States to be on the basis of Adult Suffrage.
[13]1968 AIR 1379, 1968 SCR (3) 565
[14]Sukhdeo v. Governmentof A.P., 1966-1 Andhra WR 294
[15]AIR 1979 Pat 266
[16](1979) 4 SCC 260
[17](1981) 4 SCC 335
[18]1983 Lab.I.C. 1388
[19]AIR 2003 SC 3331
[20]AIR 1982 SC 1473
[21]AIR 1982 SC 879
[22]AIR 1983 SC 328
[23]AIR 1992 SC 1695
[24]1987 AIR 1281
[25]AIR 1997 SC 3011
[26]JT 2011 (8) SC 289, 2011 (8) SCALE 155, 2011 (4) UJ 2675 (SC)
[27](2014) 4 SCC 427
[28]Available at : last accessed on 8th July, 2015 (Visited on 10thDecember, 2017)
[29]AIR 1954 SC 321.
[30]AIR 1985 SC 1618
[31]AIR 1988 SC 835
[32]1992 (2) Supreme 123.
[33]AIR 2015 SC 2569
[34]AIR 2015 SC 2382
[35]Case number :W.P.(C). No. 20680 of 2014 (H)
[36]AIR 1985 SC 1695
[37]AIR 1987 SC 1493
[38]1991(4) SCC 312
[39]AIR 1996 SC 1697
[40]2000 (2) SCC 139
[41](1995) 1 SCC 14
[42](1996) I SCC 490
[43]AIR 2000 SC 988
[44]AIR 2013 SC 1784
[45]Case number :Criminal Appeal No. 231 of 2015
[46]From sub clause (a) to (g)like speech and expression, assembly, association or unions, movements, residence, profession and occupation.
[47]AIR 2003 P&H 353
[48]124 (2005) DLT 1
[49](2006) 5 SCC 475.
[50]AIR 2003 SSC 3309
[51]Nelson Mandela
[52]1990 AIR 292, 1989 SCR Supl. (2) 173
[53]Mohd. Ahmed khan v. Shah bano Begum & other AIR 1985 SC 945.
[54]Pitei Bewa v. Larimidhi, 1985 Cr LJ 1124 (Ori)
[55]Rewal v. Kamalabai, 1986 Cr Lj 282 (Mp)
[56]S.P.S. Balasubramanyam v Suruttayan Andalli Padayachi & Ors. And Abhijit Bhikaseth Auti v. State Of Maharashtra and Others
[57]Available at :

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