"No nation founded upon injustice can stand. From the sand enshrouded Egypt, from the marble wilderness of Athens and crumbling stone of once-mighty Rome Comes a wail as it were the cry that nation founded on Injustice can permanently stand."[1]

Domestic violence is as old as recorded history which has been reported in virtually every society, every civilization. Discrimination and oppression leading to physical, mental or emotional violence have been accepted as a part of every patriarchal society. Except recent reference is found, domestic violence has been both socially and legally acceptable. Some important event, laws, codes, provide historical context, within which conceptualization of domestic violence becomes crystal clear.

Two major elements combined to seal the status of women are male dominance and projecting women as 'property' an object belonging to men and secondly expectations from women as an ideal 'role model' suit each other, in such a way as to make her vulnerable and subject to discrimination, oppression and all sorts of victimization and resultantly compel their subordination.

"Violence against women is a manifestation of historically unequal power relations between men and women, which have led to domination over and discrimination against women by men and to the prevention of the full advancement of women..."[2]

Domestic violence is physical, sexual or psychological abuse directed towards one's spouse, partner or other family member with in the household. Domestic violence occurs when a family member, partner or ex-partner attempts to physically or psychologically dominate or harm the other. It occurs in all cultures, people of all races ethnicities and religions can be perpetrators of domestic violence.

Violence against women is particularly intimate partner violence and sexual violence against women is the major public health problems and violations of women's human right. According to 2013 a global review of available data, 35 per cent of women worldwide have experienced either physical and or sexual intimate partner violence or non-partner sexual violence. However, some national violence studies show that up to 70 per cent of women have experienced physical and or sexual violence in their lifetime from an intimate partner.[3]

In this paper the author has made a sincere venture which maybe aptly called an adventure the author has taken a painstaking and arduous task of highlighting cruelty on women under the garb of Societal Norms and its horrible consequences leading to disintegration of family life and trying to suggest a solution to Domestic Violence, that is a social problem and mist be solved by both social and legal solution because not always legislation by itself can be a solution to deep rooted social problems. Although the statue passed may give the problem of Domestic Violence a little push and have that educative factor as well as legal sanction behind however as Roscoe Pound, said "What there is in the way of preventive Justice Is achieved not by legal but by social agencies. It is done, for the most part not by the agencies of law but by the social workers."[4]

The right to be safe and live free from violence is a fundamental human right, for both men and women. To understand the current status quo, it is very important for us to know that since time immemorial India has particularly been a patriarchal society and pervasiveness of illiteracy among women have been one of the reasons for widespread of violence against women. Furthermore, traditions such as purdah system, satipratha, Female feticide, Female infanticide, and many others have only degraded the condition of women in Indian Society. In India where almost half of the population are women, they have always been ill-treated and deprived of their right to life and personal liberty as provided under the constitution of India.

The misconception that women are always physically and emotionally weaker than the males, is of another reason behind such incidents of Domestic Violence. Behind closed doors of homes all across our country, people are being tortured, beaten and killed. It is happening in rural areas, towns, cities and in metropolitans as well. It is crossing all social classes, genders, racial lines and age groups. It is becoming a legacy being passed on from one generation to another. But offences against women which reflects the pathetic reality that women are just not safe and secure anywhere. According to a latest report prepared by India's National Crime Records Bureau (NCRB), a crime has been recorded against women in every three minutes in India.[5]

Defining Domestic Violence

Under Section 2(f) of the Act, "domestic relationship" means a relationship between two persons who live or have, at any point of time, lived together in a shared household, when they are related by consanguinity, marriage or through a relationship in nature of marriage, adoption or are family members living in a joint family. The scope of this provision is very wide. In a famous case of Nandan Singh Manral v. State[6], the notice was served on the brother-in-law. But it was held that the husband of the married sister, who lived far away from the family of the husband, cannot be said to have lived in a shared household with the aggrieved person as no domestic relationship existed. Hence, the notice served on the brother-in-law was quashed.

In contrast, the scope of Section 498A of the Indian Penal Code was essentially included to punish the husband and the in-laws of the bride for the act of cruelty. In the case of domestic violence also, the perpetrator is the male against a woman. Now, if the husband or the relatives of the husband commits an act of domestic violence through his male relatives or through his female relatives, it is deemed that there was an act of domestic violence for which the relatives and the husband will be held responsible. Here the order of the Magistrate will be binding on the parties, and non- compliance with the orders of the Magistrate amounts to an offence which is punishable under Section 31 of Protection of Women from Domestic Violence Act, 2005. \

Thus, the above definition though, its scope is very large, mentions and points out the true ambit of domestic violence.[7]
Domestic abuse, also called "domestic violence" or "intimate partner violence", can be defined as a pattern of behavior in any relationship that is used to gain or maintain power and control over an intimate partner.

Abuse is physical, sexual, emotional, economic or psychological actions or threats of actions that influence another person. This includes any behaviors that frighten, intimidate, terrorize, manipulate, hurt, humiliate, blame, injure, or wound someone. Domestic abuse can happen to anyone of any race, age, sexual orientation, religion, or gender. It can occur within a range of relationships including couples who are married, living together or dating.

• Domestic violence affects people of all socioeconomic backgrounds and education levels.
• Anyone can be a victim of domestic violence, regardless of age, race, gender, sexual orientation, faith or class
• Victims of domestic abuse may also include a child or other relative, or any other household member.
• Domestic abuse is typically manifested as a pattern of abusive behavior toward an intimate partner in a dating or family relationship, where the abuser exerts power and control over the victim.
• Domestic abuse can be mental, physical, economic or sexual in nature. Incidents are rarely isolated, and usually escalate in frequency and severity. Domestic abuse may culminate in serious physical injury or death.

Origin of Domestic Violence Against Women

It is out rightly said, that the women we admire and preach in the name of Durga, Saraswati, Parvati and Kali, we also abuse them behind those four walls. The status of women in India has been subject to many great alterations over the past few millenniums. From a largely unknown status in ancient times through the low points of the medieval period, to the promotion of equal rights by many reformers, the history of women in India has been lively.

Violence against women is majorly a result of gender relations that has somehow assumed that men are supposed to be superior to women. This has therefore resulted in the subordinate status of women and furthermore considering much of gender violence as normal and it enjoying surprisingly a social sanction. Although but discussion on violence is not required but some types of violence include physical aggression, psychological violence and many others.

The current status quo of women cannot be properly understood without referring to and understanding the previous conditions from which it evolved.

Therefore, delving into the history this paper has divided the status of women into three phases:

• Ancient Society: In ancient India, women enjoyed equal status with men in all fields of life. Summing up the status of women in Ancient India, with a notion of critical appreciation, it can be gauged from the fact that she was known as "ardhangini," which suggests that there was equality between men and women and neither was superior to the other. The word "Patni" in Brahamanas indicates her equal share in the social and religious side of her husband's life. She is the sole mistress of the household. The wife was never looked upon as a slave or a chattel but as a partner in religious matters, as a friend, a confidant, and a guide.
   
• Medieval Society: The advent of Mohammadanism with Arab invasions in AD 712 caused Hindu society's attitude towards women to become more rigid. Later, around 500 B.C., the status of women began to decline with the Smritis and with the Islamic invasion of Babur and the Mughal Empire, and later Christianity curtailing women's freedom and rights. Women enjoyed freedom, status, and prestige in society, but this did not last long, and they finally settled into an indoor life.
  
  The Indian woman's position in society further deteriorated during the medieval period when sati among some communities, child marriages, and a ban on widow remarriage became part of social life. In some parts of India, the Devadasi or temple women were sexually exploited. Polygamy was widely practiced, especially among Hindu Kshatriya rulers. Women lost their identity in the 18th century, and by the beginning of the 19th century, they were totally and forcefully subjected to male superiority, both physically and intellectually.
   
• Modern Society: With the advent of British rule, the Britishers followed the policy of non-interference in the personal laws of Hindus and Muslims. However, the Mayne-Macaulay doctrine, which aimed to introduce Western influences, led to some improvements and manifestations. After independence and the formation of a Sovereign, Socialist, Secular, Democratic Republic, Indian citizens started moving towards the upliftment of women. Women constitute about half of the population of India and as such they cannot be ignored and keeping in mind the famous words of Swami Vivekanand "A Bird with one wing cannot fly"

Causes of Domestic Violence Against Women

There are no single causes/factors that contribute to the violence perpetrated against women. For the purpose of this, the author has divided the types of causes of violence against women into five headings. They are cultural, economic, legal, and political.

Cultural: Acceptability of violence as a means to resolve conflict is the major reason of violence against women. Victims generally feel that it is better to suffer in silence than to be separated from their loved ones.
Economic: Another important factor that contributes to the violence against women is the economic and financial dependence of women on men. This is generally true when the male person is unemployed and feels his power is undermined in the household. The threat and fear of violence keep women from seeking employment or compels them to accept low-paid exploitative labor.

Legal: Improper and inadequate laws and legal status of women is the primary cause for domestic violence. In India, laws relating to divorce, child custody, maintenance and inheritance are always in favour of men, ignoring women's rights. This has further led to violence on the women. The law enforcement agencies are also less sensitive towards women and their problems and always tend to guard the male counter-part.

Political: The isolation of women from communities and less participation in the field of politics also contribute to more of violence on women. As their interactions with strangers or outer people are less, so they become victims of violence. They fear to raise their timid voices, least they fall prey to more violence than before.[8]

Domestic Violence Act - The Legislative Dynamism

Legislature, in right earnest, thought Domestic Violence is one of the most despicable, detestable and condemnable evils that has shocked the social conscience and must be eradicated without any waste of time, failing it would eat away the morals and the valued on which our society lived and thrived and thus The Protection of Women from Domestic Violence Act, it is a laudable and glorious enactment aimed to stop the turbulent flow of Violence which is causing deep erosion of the family mornings.

The Protection of Women from Domestic Violence Act (PWDVA) finally became law in 2005. It was only passed after a great deal of parliamentary deliberation to bridge the gap between existing legal provisions and progressive aims enshrined in the Constitution and international human rights conventions.

The Domestic Violence Act provides female victims of domestic violence legal recourse, both civil and criminal. Specifically, it allows women to seek injunctions and protective orders, along with criminal provisions for imprisonment and fines, which come into play when a perpetrator breaches a civil order. This broader response to domestic violence more effectively addresses the social realities that Indian women face, including threats of violence and mental abuse for which they often require immediate civil remedies. Significantly, the Domestic Violence Act did not limit protection against domestic violence to marital relationships.

The most splendid part about the current legislation is that it has adapted itself with contemporary laws and therefore in contrast to previous domestic violence legislation, the current Act covers "domestic relationships" which happen to include "all relationships based on consanguinity, marriage, adoption and even relationships which were "in the nature of marriage".

Henceforth the new legislation covers all women in abusive relationships, regardless of whether the person responsible for is a spouse, domestic partner, or someone in a live-in relationship. It also protects unmarried women, siblings, and other women living with the alleged perpetrator. This legislation for the first time introduced the concept of "shared household" that covered women in Non-Matrimonial relationships. The term "shared household," has been defined under Section 2(s) of the act, may include a property of the joint family of which the male respondent is merely one of several members.

Also, let's not forget about Section 20(1) of the Domestic Violence Act which empowers magistrates to grant monetary relief in favour of the aggrieved woman. This provision ensures that women who file complaints under new statue are not chucked out of their homes. Since it was seen that previously implementation of this new legislation, women were chucked out of their marital houses after filling cases against their husbands or family or both.

The new legislation further empowers the magistrate to pass an order giving access of the house to any woman who chucked out after filling a case. To be clear, the Domestic Violence Act does not create any new criminal offenses; however, if the domestic violence case reveals any offenses punishable under the Indian Penal Code or Dowry Prohibition Act, magistrates may frame appropriate charges against the respondent and try cases themselves or commit them to the Sessions Court as required.

Unfortunately, the Domestic Violence Act did not provide a useful definition of "respondent." Section 2(q) merely states that "respondent" means "adult male person," suggesting that women do not fall within its ambit. Several High Court decisions have interpreted this provision to include women as respondents, recognizing that, in India, domestic violence is often perpetrated by female in-laws. The Indian Parliament eventually clarified the definition of "respondent" by adding a proviso to this section.

The proviso includes an accused man's female relatives in the definition, where the victim is a wife or woman living in a relationship in the nature of marriage. This means that victims of domestic violence can file cases against not only male but also female perpetrators. More often than once, the constitutionality of this act has been questioned however even in the past the Judiciary has laid down several judicial precedents that have answered all the queries.

For instance, in the case of Krishan Lal V. Union of India[9] the Hon'ble court held that under Article 14 the Indian Constitution accords equality of treatment to all persons similarly situated. It was further held that any invidious discrimination is obnoxious to equality.

Possible Misuses Of Domestic Violence Act

The Domestic Violence Act 2005 was enforced by the legislature to protect women from harassment be it of any kind and vast stress was made on the same but unfortunately, no consideration was given that even men could be victims of such cases of harassment and time has now come for the rethinking of the matter of protection of males from the hands of women as well. In the case of Dr. N. G. Dastane V. Mrs. S. Dastane[10], the Hon'ble Supreme Court had held that cruelty is of two type one is mental and other is physical. It might be true that physical is generally being perpetuated by the husband being a strong one but at the same time this can't be said to be universally true. It is also vice versa in the case of mental cruelty.

Further the Hon'ble Apex Court in the case of Shushil Kumar Sharma vs. Union of India[11] has observed that by misuse of the provision a New Legal Terrorism can be unleashed. Now comes the question can laws made in context to protection of women be misused? To answer this question the Honourable Supreme Court in a case made an observation that "Unfortunately a large number of these complaints have not only flooded the courts but also have led to enormous social unrest affecting peace, harmony and happiness of the society"[12]

This observation was made by the Supreme Court in context to the Domestic Violence Act. It is therefore important to note that the concept of cruelty cannot specify for females only. Men can also be a subject to this and cruelty or harassment need not be physical but also mental in certain cases. Also, Victimization of Male Partners and Police Harassment is a major issue in such cases.

 In 2014, the Delhi Commission for Women submitted a report[13] stating that 53.2% of rape cases registered between April 2013-July 2014 were false. The reports make it abundantly clear that the Victimization of Male Partners is a real problem. Although, victimization does not mean that the entire law against women must be scraped, not does this imply that the law is ineffective. This indicates that changes and updates are necessary in the Law. Protection against domestic violence should be all-inclusive and not biased towards a particular gender.

Critical Analysis of The Protection Of Women From Domestic Violence Act, 2005
In the garb of providing protection, this legislation in fact, strikes at the very foundation of marriage by promoting intolerance and encouraging unnecessary litigation even for petty domestic dispute. The Delhi High Court has expressed worry that there is an "alarming increase" of false cases of rape being registered "only to arm-twist the accused and make them succumb to the demands of the complainant".[14]

The Courts have been seeing a rise in the cases and a record for the same was submitted before the court during the proceedings. This law is based on a wrong notion and assumes man as the sole perpetrators of domestic violence. This is altogether a wrong impression and only confirms the gender bias in favour of women created by this law. The law confers a right in favour of a woman without imposing any liability, while the man is overburdened with discriminative liabilities with total denial of any such similar right. The law is wholly gender specific and rules out any possibility of domestic violence against a man.

In the zeal of providing protection and assistance to women, this Act has given recognition and legal status to extra-marital relationship or other immoral relationship, which are neither recognised by our society or by our existing matrimonial and penal law. The legislature while passing the Act did not notice that having sexual intercourse with any person other than his or her spouse is a ground for divorce. Even sections 24 and 25 of the Hindu Marriage Act, 1955, which provide for maintenance pendente lite and permanent alimony respectively do not recognize any relationship except that of a legally wedded husband and wife.

Besides this section 125 of the Code of Criminal Procedure, which provides for grant of maintenance to wife, children, father and mother in a broader perspective, does not recognize persons having illegitimate relationships, entitled to claim maintenance except an illegitimate child. Section 125(4) specifically prohibits a wife living in adultery from claiming any maintenance from the husband under section 125(1) of the Code of Criminal Procedure.

Prior to this Act there was no comprehensive legislation defining domestic violence except the offence of cruelty punishable under section 498-A, IPC. Critics feel that the term violence should not be given such a wider interpretation. The meaning of the term 'economic abuse' as given in section 3 of the Act implies that even if a male member of family merely misappropriates, or disposes of the share of a women member of the family i.e. movable or immovable assets, he may be hauled up for committing domestic violence. This meaning is against the spirit of the Act and the basic concept of domestic violence. Again the Act does not distinguish between actual abuse and threat of abuse and gives equal weightage to even a likelihood of abuse.

Also in regards to the notion of emotional abuses, insults and verbal abuse, enshrined in the Act, the terms in itself are extremely relative and subjective, often depending on one's mindset and shockingly, the husband does not have any recourse in case of any abuse by the wife. Refusal to pay any sum of money for whatsoever reason will attract the provisions of this law. Non-payment of rent related to the shared household will also constitute an economic abuse even if the husband himself is devoid of sufficient resources or even if he is in jail.[15]

In this enactment the Magistrate has been entrusted with unaccountable powers as he is invested with the responsibility to take cognizance of the case and also for executing his own orders in favour of the aggrieved woman even without being approached for the execution of his orders. An additional disturbing aspect is that the Magistrate trying the case has to evaluate not only the individual incident of violence, but the overall circumstances as well.

Section 14 of the Protection of Women from Domestic Violence Act, 2005 contains a very dangerous provision whereby the Magistrate may order the aggrieved person to undergo counseling jointly with the respondent and any member of the service provider. This goes against all accepted principles of counselling. The victim, and the abuser are in an unequal situation and no joint counselling is possible in that situation. It can only lead to the disempowerment of the unequal party. Counselling is one of the methods of correcting abusive behaviour and hence, it is only appropriate that the abuser and not the victim is counselled. The victim may have the possibility of seeking voluntary counselling.

Section 16 of the Protection of Women from Domestic Violence Act, 2005 allows the Magistrate to hold proceeding in camera if either party to the proceedings so desire. But, in camera proceedings sometime, intimidate the aggrieved party in favour of the respondent. This is especially so when the aggrieved party is the only woman in the court facing a completely male phalanx of hostile, sneering Magistrates, lawyers, officials, police, male respondent, etc. The situation is to change this section is to allow for in-camera proceeding not when either party so desire but only if the aggrieved party so desires. The aggrieved party should be allowed to be accompanied by any relative/woman social worker etc., of her choice for her moral support.

Under the Act, complaint of domestic violence may be given to both the protection officer and the police officer as under section 498-A of the Indian Penal Code. Both the agencies can out their investigations respectively and submit their reports to the Magistrate. In case of contradictory reports of both the agencies, the duty rests upon the Magistrate, who is the ultimate authority to pass the decision. This double enquiry of the same offence is over to the major demerits of the Act.

The Act is silent about non-compliance of some orders. It shuts down the chance of reconciliation in future. The major inappropriate implication would be that it would shut down the chances of reconciliation in future. On the one hand, the Act punishes a man for forcing his wife to leave her job while on the other it provides maintenance to the very same wife. But the law does not provide for any such remedy to a male in any similar circumstances.

Under the Act, when no eye witnesses are available, the women will be the primary witness and her statement is considered as circumstantial evidence, to arrive at a conclusion on the facts of the case. This has virtually empowered all women to punish men at their will. The slack drafting of this, law will allow cunning and unscrupulous women to teach a lesson to any of her male relatives at her sole behest.

No doubt that the Act is a landmark legislation in Indian history and people of India welcomed the same with great enthusiasm yet, there is an apprehension in the minds of the people about the misuse of the Act against the innocent husband and his family members. It definitely cannot be said in general that the troubles and tortures of all kinds and differences always arises from the side of the husband and the in-laws.

The wedded woman cannot be said to be just and fair in all cases. This Act is being misused in a number of cases where it is used as a weapon by the wives and their paternal relatives to put an innocent husband and their relatives to unnecessary harassment. Hence before going to apply the provisions of the Protection of Women from Domestic Violence Act, 2005, the concerned parties and authorities should think about the consequences of the application, so that innocent persons and their families are not put to unnecessary harassment.

Suggestions:

• Women's vulnerability is the Root Cause: The problem of domestic violence in India needs to be understood in the real sense. To understand the reason behind why women become vulnerable and position themselves to be exploited. Most women are illiterate and face silent violence, and they are also under the pressure of tradition in society.
   
• Attitudinal Change is needed among men and women: The basic social structure in India has long been patriarchal, where we see a male-dominated society. The unequal distribution of power relationships is the root cause of violent attacks. There should be a change in attitudes between men and women to overcome the victimization of violence.
   
• Internalization of Legal Norms with Public Consensus: Domestic violence in our country is still considered an "interfamilial affair," preventing intervention from close relatives, outsiders, and the state. The real effective implementation of any legislation requires strong public consensus and acceptance through democratic processes.
   
• The strong legal mandate prescribed for officers and stakeholders: Officers and institutions are responsible for the effective implementation of the Act. It is necessary to eliminate gender discrimination, the traditional relations of a patriarchal society, and male dominance.
   
• Gender Perspective training is necessary: Gender perspective training should be mandatory by law and is crucial for changing the patriarchal mindset of society, police, service providers, medical practitioners, protection officers, and especially magistrates, who often advise women to tolerate violence and "stop complaining."
   
• Counselling by Expertise: At the pre-litigation stage, counseling should be provided to the aggrieved person to restore self-esteem, provide emotional support, and assist her in making decisions regarding the initiation of legal proceedings.

Conclusion
In India and elsewhere in the world, there are no special laws for male. There is Dowry Prohibition Act, Section 498A in Indian Penal Code i.e. offence of cruelty by husband and relatives of husband; section 125 in Code of Criminal Procedure i.e. maintenance for wife; protection of women from domestic violence, in Statute books. But there is no protection of men in Domestic Violence Act, 2005, there is no provision like Section 498B in Indian Penal Code, there is no provision like Section 125A in Code of Criminal Procedure i.e. maintenance to husbands under the Act. Rather the specific laws for women are misused by errant women and police officers. The cry of victimized husbands and their relatives is not heard either in courts or in society.

The practice says 'that real purpose of the women – related specifies laws are misused and thereby husbands suffer for no fault.'[16] In Vijaylakshmi V. Panjab University[17] it was held that as a result of joint operation of Article 15(1) and (3), the State may discriminate in favour of women against men but it may not discriminate in favour of men against women. Wherein is known that protection against domestic violence is a civil right it cannot be forgotten that its misuse cannot be taken lightly.

The other view on the other hand argues that social problems, if remedied by force may lead to stronger reactions from the respondents, which in the end may be detrimental to existence of society itself. [18] There was a constant demand for flexibility of this provision from apex court in numerous cases.[19]

As observed in Malavi Hussain Haji Abraham Umarji V. State of Gujarat, Padma Sundra Rao and others Vs. State of Tamil Naidu and others while interpreting a provision the Court only interprets the Law and cannot legislate it. If a provision of law is misused and subjected to the abuse of the process of law, it is for the legislature to amend, modify or repeal it, if deemed necessary.[20]

It is important that the right balance must be found between the Laws in order to make all genders feel safe and protected. The Domestic Violence Act, 2005 has many issues and contradictions that need to be resolved. The law even though a step in the right direction needs refinement.   

End Notes:

1. The Works Of Robert G. Ingersoll, By Robert Ingersoll, PAGE 220.
2. UNICEF (2000), Domestic Violence against Women and Girls, Innocenti Digest No. 6, available at http://www.unicef-irc.org/publications/pdf/digest6e.pdf
3. Narwadkar, Dr. Pooja P., Law Relating to Domestic Violence in India 9, (Hind Law House Publication, 2014).
4. Roscoe Pound – Criminal Justice In America.
5. Available at http://ncrb.nic.in/StatPublications/CII/CII2014/chapters/Chapter%205.pdf.
6. 2011 (2) RCR (CRIMINAL) 271.
7. IOSR Journal Of Humanities And Social Science (IOSR-JHSS) Volume 19, Issue 10, Ver. IV (Oct. 2014), PP 08-14 e-ISSN: 2279-0837, p-ISSN: 2279-0845.
8. IOSR Journal of Humanities and Social Science (IOSR-JHSS) Volume 19, Issue 10, Ver. IV (Oct. 2014), PP 08-14 e-ISSN: 2279-0837, p-ISSN: 2279-0845.
9. 1994 Cr LJ 3472.
10. AIR 1975 SC 1534.
11. AIR 2005 SC 3100.
12. Preeti Gupta Vs. State of Jharkhand, AIR 2010 SC 3363.
13. http://ncw.nic.in/sites/default/files/Annual_Report_2013-14_English_Full.pdf.
14. https://www.thehindu.com/news/national/delhi-high-court-expresses-worry-over-alarming-increase-of-false-rape-cases/article36042093.ece.
15. Nagpal, Vijay and Singh, K. P., The Protection of Women from Domestic Violence Act 2005 - A Critique, CBI Bulletin, Jan-March, 12 (2007).
16. P.K. Das, Law relating to cruelty to husband, (2008), p.1.
17. AIR 2003 SC 3331.
18. IOSR Journal of Humanities and Social Science (IOSR-JHSS) Volume 10, Issue 2 (Mar. - Apr. 2013), PP 41-44 e-ISSN: 2279-0837, p-ISSN: 2279-0845.
19. Dr. Partha Partim Mitra, "A new look on matrimonial cruelty with criminal law", Indian Bar Review, Vol XL (1) 2013, p.87.
20. AIR 2004 SC 3946.