Violence Against Women Within the Household In India And Other Developed Nations
- By Awisha Lakra, Assistant Professor, School of Law, Arka Jain University, India.
- DOI - 10.5281/zenodo.10117231
ABSTRACT
Domestic Violence is the most pervasive form of violence against women, is accepted internationally as a violation of human rights. It not only includes physical abuse but mental, economic and verbal abuse too. Mostly the victims of Domestic Violence are women. Women are subject to grievous hurt, injury, slapping, forced sex, threatening and intimidation within the household set up among the family relatives or persons. Domestic Violence is not typically associated with a particular class or caste or group of the society but it is evident in one form or the other in all socio-economic groups, caste, and class of the people. In India, other developed nations like US and the UK have also recognized domestic violence as heinous crime in society. United Nations Convention has also given a unique insight into the violence against women and made several committees eliminate the discrimination against women. To stop the violence against women, the US has adopted laws to give equal rights n protection to women. The US has a federal law, so different states have different laws. The UK have several laws for the domestic violence which gives special protection to women. India has also recognized the domestic violence and have the act called “The Protection of Women from Domestic Violence Act, 2005.” It provides protection and relief to the victims. In India DV have both civil and criminal remedies.
Keywords: Domestic, Violence, Abuse, Protection, Discrimination etc.
I. INTRODUCTION
Domestic violence is a quiet emergency that happens every day and with exemption from plain view and inside cozy connections in numerous Indian homes. Domestic Violence, is accepted internationally as a violation of human rights. It is the most prevalent form of violence against women. Domestic violence isn't merely hitting, or battling, or an incidental contention. Domestic violence is common among women and has related to poor mental and physical wellbeing. Domestic violence is a severe and ongoing social problem that does not get the attention it deserves. Crime against women is not a new dowry; wife-beating, violence against women is common. In the 21st century, various laws have passed for the equality of women and their betterment. After such a long time, something was done to improve the condition of women. At the international level, people were discussing the protection of the right of women. Domestic violence is a method where one partner gains power and control over the other by instilling fear. Violence can be of several kinds, such as physical, emotional, economical, verbal, and sexual. Domestic violence occurs daily in homes throughout the world.
II. DEFINITION AND MEANING OF DOMESTIC VIOLENCE
Domestic violence is a gross violation of human rights and a serious deterrent to development[1]. There are many domestic violence types, including emotional, sexual, social, financial, spiritual, and physical abuse. Domestic violence means violence, abuse, aggression, including physical, psychological, and other forms occurring within the home at the instance of family members. Domestic violence is also known as domestic abuse, spousal abuse, or Intimate Partner Violence (IPV). Women are subject to grievous hurt, injury, slapping, forced sex, threatening and intimidation within the household set up among the family relatives or persons. Domestic Violence is evident in one form or the other in all socio-economic groups, class, and society's caste.
III. INTERNATIONAL FRAMEWORK ON DOMESTIC VIOLENCE
The first breakthrough towards recognizing violence against women (VAW) Internationally as a severe violation of human rights was the United Nations Declaration on the Elimination of Violence against Women in 1993. By 2006, about 89 countries had some sort of legal provision against domestic violence (United Nations 2006), and this figure increased to 125 countries by 2011.[2]
UN Framework 1996 for Model legislation on domestic violation serves as a drafting guide to legislatures and organizations committed to lobbying their legislatures for comprehensive domestic violence legislation.[3]
The Indian Government officially recognized the gravity of violence against women(VAW) and its adverse impact on the nation in its country report for the 1995 Fourth world conference on women in Beijing. Later, after ten years, India passed legislation on domestic violence in 2005.[4]
International Human Right Conventions- UNCEDAW-
United Nations Committee on the Elimination of Discrimination Against Women in the body of independent experts monitors the convention's implementation to eliminate all forms of discrimination against women. UNCEDAW considers "Domestic Violence as a family violence, as one of the most insidious forms of violence against women within family relationships including battering, rape, other forms of sexual assault, mental and other forms of violence, which are perpetuated by traditional attitudes."
The UNCEDAW committee identified specific measures necessary to overcome family violence and stated the same, which includes "Criminal penalties where essential and civil remedies in cases domestic violence, Services to ensure the safety and security of victims of family Rehabilitation programs for perpetrators of domestic violence.
India signed on 30th July 1980; India ratified, acceded, and succeeded in UNCEDAW on 9th July 1993 to affect its international treaty obligations in compliance with the constitutional provision. India's ratification of UNCEDAW was also a key instrumental factor in the enactment of the DV Act 2005.
Domestic Violence Laws in the United States
The U.S. Office on Violence against Women (OVW) defines domestic violence as a "pattern of abusive behaviour in any relationship that is used by one partner to gain or maintain power and control over another intimate partner. Domestic Violence can take many forms, including physical abuse, sexual abuse, emotional, economic, or/and psychological abuse."[5]
Subchapter III of chapter 136 of title 42 of the US Code:
The term domestic violence include felony or misdemeanour crimes of violence committed by a current or former spouse of the victim, by a person with whom the victim share a child in common, by a person who is cohabitating with or has cohabitated with the victim as a spouse by a person similarly situated to a spouse of the victim under the domestic or family violence laws of jurisdiction receiving grant monies, or by any other person against an adult or youth victim who is protected from that person's acts under the domestic or family violence laws of the jurisdiction.[6]
Federal Law
In 1994, the U.S. government reacted to the country over private and sexual severity by setting up the Violence Against Women Act (VAWA), planned to improve both setback organizations and catch and prosecution of batterers. VAWA 1994 developed gathering encouraged reactions to violent conduct at home and assault (attracting the criminal value system, social organizations, and NGOs), made a National Domestic Violence hotline and assigned considerable resources for different kinds of activities and ventures, including covers and distinctive organizations for battered women, legitimate direction and getting ready tasks, and undertakings to grow push to common women.
1) VAWA not only reauthorized STOP endowments, which reinforce programs expected to upgrade law prerequisite and arraignment reaction to oppressive conduct at home, yet moreover requested that abusive behaviour at home supporters be locked in with the orchestrating and utilization of these projects.
2) VAWA, in like manner, reauthorized holds for Victim and Witness Counsellors, who work with violent conduct at home setbacks in government arraignments, offered confirmations to battered pariah women, and developed chose disciplines for interstate Domestic Violence and assault infringement.
The Victims of Trafficking and Violence Prevention Act of 2000 made another kind of assistance for casualties of domestic violence in the United States. The new Law made "UVisas," which allow pilgrims who are casualties of particular destructive behaviours, including domestic violence, or have information about those infringements, to apply for residency in the United States. A law approval official must certify that the individual's assistance is vital for the examination.
The Institute for Law and Justice conveys Review of State Laws Relevant to Violence Against Women (Domestic Violence, Sexual Assault, Stalking, and Related Laws), Neal Miller, 1 December 2002. This report contains a survey of U.S. state laws on domestic violence, including laws that impact prosecutor and police game plans.[7]
Overhauled Penalties Statutes, by Eve Zamora, portrays the different kinds of enhanced disciplines for domestic violence that have been requested in other states in the United States.
VAWA 2013 extended lodging securities to incorporate extra federally-sponsored lodging programs excluded in the 2005 reauthorization, gave extra insurance to understudies and foreigner survivors and reauthorized basic VAWA allow programs. For more data on VAWA, including stipend programs, see the U.S. Branch of Justice Office on Violence Against Women.
State Laws
Minnesota's Domestic Abuse Act:- Section 518B.01 of Minnesota's statutes creates a civil remedy of associate degree Order for Protection (OFP), designates the procedures that have got to follow in applying for associate degreed granting an OFP, and describes the type of relief that may be given. For example, the Act sets forth the circumstances below that associate degree ex parte order is also granted and requires that a hearing be control inside 10 days when the supply of such associate degree order. The Act also describes penalties for violations of each OFPs and No Contact Orders issued against a defendant in criminal proceedings for violence. It explains how enforcement officials ought to enforce such orders.
Additionally, the Act includes a variety of provisions that facilitate victims' access to the system. For instance, the Act waives the filing fees for orders of protection associate degreed provides that a private filing for an OFP might request that his or her address not be disclosed to the general public.
Section 609.2242 of Minnesota's statutes criminalize violence below this Law; an individual commits the crime of domestic assault by inflicting another to concern immediate bodily harm or death or inflicting or trying to intercommunicate such damage. Penalties are raised once the perpetrator has antecedently committed one or many domestic assaults inside a definite amount of time. Minnesota has also enacted a violence arrest law, Section 629.341, that permits officers to arrest a private while not a warrant if there's evidence that the individual has committed domestic abuse, which needs officers to supply violence victims with notice of their legal rights.
Section 629.342 of Minnesota's statutes provide that police departments develop policies and protocols for handling violence and expressly needs cops to help victims get medical treatment and provide the victim with a notice of their legal rights.
New York Domestic Violence Laws
New York State's force hindrance Act makes a whole administration system for victims of force. The Act needs social administration areas to supply crisis shields and completely different administrations and backing, guiding, and referrals. The Act requires covers that get funding below its arrangements to stay up a private address and orders that alternative government offices keep such tends to classify.
New York State to boot passed a law creating Associate in Nursing workplace for the hindrance of force. The workplace is suspect of prompting the legislator and legislating body "on the most effective courses for the authorities to react to the problem of Domestic Violence" and to "create and execute approaches and programs meant to assist casualties of aggressive behavior reception and their families, and to grant instruction and compensatory action, getting ready and specialized facilitate."
California Domestic Violence laws- A charge of force depends on a special relationship between the litigant and, therefore, the victim. The definition of a domestic relationship is versatile and broad below California law. The subsequent relationships in Associate in nursing assault or battery scenario sometimes trigger force laws and punishments.
Cohabitants signify two unrelated individuals cohabitation in an exceedingly stable relationship that indicates it's meant to be long-run. Consummation of the connection whereas maintaining an equivalent residence, Sharing monetary responsibilities for living expenses, Sharing possession of the property, creating statements, or otherwise indicating that the couple incorporates a husband-wife kind relationship or their domestic partners, and uninterrupted length continuation of the connection.
A dating relationship means frequent, intimate associations primarily characterized by the expectation of emotional or sexual involvement in the freelance of monetary concerns.
Domestic Violence Laws in the United Kingdom
Domestic violence provisions in separate legislations-
1) UK Matrimonial Homes Act 1967,
2) The UK, Domestic Violence & Matrimonial Proceedings Act 1976
3) UK Domestic Proceedings and Magistrates' Courts Act 1978
4) UK, Family Law Act 1996
The UK, Domestic Violence & Matrimonial Proceedings Act 1976- It is to provide the police with powers of arrest for the breach of injunction in domestic violence cases, to make provision for varying rights of occupation where both spouses have the same rights in the marital home.[8]
Issue of Matrimonial Injunction order by country court to Restraining the other party to the marriage from molesting the applicant. Restraining the other party from molesting a child living with the applicant. Excluding the other party from the marital home. It requires the other party to permit the applicant to enter and remain in the marital home or a part of the matrimonial home. These Matrimonial Injunction orders shall apply to a man and a woman living with each other in the same household as husband and wife as it applies to the parties to a marriage.
Arrest order for a man and a woman as husband and wife for breach of injunction order.
IV. DOMESTIC VIOLENCE LAWS IN INDIA
The Indian Penal Code Amendment 1983
A unique area, numbered 498-A, authoritatively made Domestic Violence a Criminal Offense, was added to the Indian Penal Code in 1983. This Section of the Law mainly covers cruelty towards wedded ladies by their spouses or their husbands' families. An accommodating statement in this Section enables woman's relatives to object to them. This is immensely helpful in situations where the Woman is excessively anxious, making it impossible to talk up for herself, for reasons, for example, she could get captured by her significant other or basically can't leave the house. One sort of cruelty that can be punished is conduct that causes a woman's death or genuine damage, or pushes her to confer suicide. Another kind of provocation identifies with threatening the woman or her relatives to surrender her property.
Under the Law, acts of cruelty include, but are not limited to, the following:
a) physical abuse;
b) psychological torture by threatening her or her loved ones (such as children);
c) not giving the woman food;
d) locking her in or out of the house as punishment; and
e) sexual abuse against the woman's will.
Convicted punishers will be charged with imprisonment up to 3 years or fine or both.
Domestic Violence is defined under chapter II Section 3 of the Act[9] as-
a) Harms or injures or endangers the health, safety, life, limb or wellbeing, whether mental or physical, of the aggrieved person or tends to do so and includes causing physical abuse, sexual abuse, verbal and emotional abuse and economic abuse; or
b) Harasses, harm, injures or endangers the aggrieved person with a view to coerce her or any other person related to her to meet any unlawful demand for any dowry or other property or valuable security; or
c) Has the effect of threatening the aggrieved person or any person related to her by any conduct mentioned in clause (a) or clause (b); or
d) Otherwise injures or cause harm, whether physical or mental, to the aggrieved person.
The Act goes ahead through the segment Explanation I to characterize-
1. Physical Violence- Physical Violence is the most visible type of abusive behaviour in the home. It incorporates slapping, pushing, kicking, gnawing, hitting, tossing objects, beating, undermining with a weapon of any kind, or utilizing a weapon. Physical Violence is the deliberate utilization of physical power to cause hurt.
2. Sexual Violence- Sexual violence is a kind of domestic violence that includes sexual coercion and marital rape. Marital rape is not a crime in India[10] except during the period of separation of the partners. It consists of any act of sexual nature that abuse humiliates or violates the dignity of a woman.
3. Emotional violence- It incorporates, Mortifying the person, controlling what the person can and cannot do, intentionally accomplishing brief comment that the person feels embarrassed or humiliated, disengaging the person from loved ones.
4. Economic violence- Economic violence is the abuse where the abuser has complete control over the casualty's cash and other monetary assets. Forcing or pressuring a victim to sign documents, sell things, and edit a will forms is economic abuse. Economic abuse diminishes the victim's capacity to support themselves.
If you are a casualty, you can way to deal with the following specialists under this Law–
a) 'Security Officer' or the
b) 'Specialist organization.'
c) You can find likewise a way to deal with the Police or an Officer straightforwardly Obligations of Authorities the law powers specific commitments on the standard pros accountable for executing this law.
Exactly when a cop, Protection Officer, Service Provider or Magistrate comes to understand that some individual is encountering injurious conduct at home, they ought to instruct the setback of the going with rights:
The setback can apply for any of the reliefs saw under this law, i.e., a confirmation organize, monetary help, specialist orchestrate, residence mastermind or a compensation orchestrate.
a) The loss can use the organizations of certain official Service Providers.
b) The loss can approach a Protection Officer and come them for help.
c) The loss can ask for nothing authentic guide.
d) Moreover, the loss can record a criminal challenge under the general law on infringement (the Indian Penal Code, 1860).
Application to Magistrate – An application in regards to domestic violence can be introduced to the officer by:
a) The bothered individual,
b) Assurance officer in the interest of oppressed individual
c) Some other individual in the interest of oppressed individual.
d) Discipline
Distinctive controls or game plans are being made for women's insurance against domestic violence under the statute, for instance, Sec.304B of IPC identifying with enrichment passing. Under fragment 313-316 of IPC female tyke, kill has been made at fault, which suggests relentlessly finishing women's pregnancy. Diverse zones of IPC dealing with these issues are fragment 305-306 related to abetment of suicide and 340,349 of IPC separately wrongful confinement and wrongful constraint. A complaint can in like manner be recorded under zone 498A of IPC for mercilessness which also falls under forceful conduct at home.
Various types of request issued by Court the judge or the Magistrate can arrange various measures under this law with a specific end goal to guarantee your assurance and prosperity. This incorporates-
a) security orders (requesting the guilty party to stop violence)
b) living arrangement orders,
c) money related help,
d) guardianship orders and
e) Remuneration orders.
Nature of DV Act as both Civil & Criminal – The Act is predominantly civil except for certain criminal offenses; the Act provides certain offenses that are cognizable, providing for imprisonment. For instance, violation of the order by the Respondent under DV Act is a criminal offense.
Besides, in case of continued or repeated breach of order issued by court under the DV Act or persistent violence, the court invokes section 498 of IPC against the perpetrator. In cases where the act of violence is grave in nature and comes under the cognizable offense, the Police may take recourse to criminal law and file FIR against the same.
In addition to this, one of the most distinguished features of this legislation is that it does not restrict initiation of criminal proceedings including FIR under Section 498 of IPC, thus availing civil remedy under this law does not restrict the option of seeking criminal remedy. Previous to the enactment of DV Act, the only civil remedy available to the victim of domestic violence was to file for Divorce on the ground of cruelty, physical abuse or violence. This Act had brought protective or beneficial protection order for safeguarding the interest of victim.
Civil Remedy & Relief – Beneficial Orders for victims of DV under DV Act
One of the most distinguished features of the Act is securing beneficial orders seeking immediate restoration and rehabilitation of the aggrieved party. This characterizes the victim-oriented nature represent the civil remedy and relief available under the Act.
Land Mark Cases:-
1) Tukaram vs. State of Maharashtra the Mathura Rape case was instrumental in the enactment of the Second Criminal law ( second Amendment ) Act 1983, which made offense of Cruelty on women by her husband and relatives a cognizable offence with a strict punishment of imprisonment extending from one year to three years and fine. This judgment set the ball rolling for criminal reforms, legislations.[11]
2) Hiral P. Harsora And Ors vs Kusum Narottamdas Harsora And Ors, 2015- Identification of women victims into two categories—women who can seek relief against husbands and mothers-in-law, & Mothers and sisters who may be victims of domestic violence, but can only seek relief against the son or brother, not against the daughter-in-law or sister-in-law.
Women as victim of domestic violence- women as perpetrator of domestic violence following elimination of adult male, removal of gender , age criteria for perpetrator under the Protection of Women Against Domestic Violence Act (DV Act) Hiral P. Harsora And Ors vs Kusum Narottamdas Harsora And Ors, 2015). [12]
3) Mr.Ali Abbas Daruwala Petitioner v/s. Mrs.Shehnaz Daruwala CIVIL APPELLATE JURISDICTION WRIT PETITION NO. 114 OF 2018 WITH CIVIL APPLICATION NO.518 OF 2018
In a significant judgment, the Bombay High Court has held that merely because parties are governed by the Muslim Personal Law, it should not be an impediment in the wife invoking provisions of the Domestic Violence Act. Justice Bharati Dangre also held there is no embargo on a court to grant relief to a woman who is an "aggrieved person" within the meaning of the DV Act, merely because she is a Muslim.
4) Prakash Babulal Dangi Vs State of Maharashtra SLP no 10280 -10281 / 2017 [13]
In case, a wife obtains an order of maintenance passed in the proceedings filed under Section 125 of CrPC is to be followed, and another order passed in the proceedings filed under the Domestic Violence Act, which of the either is to be followed by the husband or whether he should follow both The Supreme Court has issued notice in special leave petitions filed by a husband against Bombay High Court order which ordered that he should follow both orders.
5) Jaya Sagade vs State of Maharashtra, [Suo Moto PIL No. 104 of 2015] Mediation, ADR in Domestic Violence cases- Bombay High Court comprising Chief Justice Mohit Shah and Justice Roshan Dalvi laid down guidelines for counselling/mediation in domestic violence cases without a court order.
6) D.Velusamy vs D.Patchaiammal on 21 October, 2010 SC, CRIMINAL APPEAL NOS. 2028-2029__OF 2010, [Arising out of Special Leave Petition (Crl.) Nos.2273-2274/2010][14] SC conferred legitimacy to live in relationship as relation in nature of marriage under the ambit of the PWDV Act 2005
SC granted the live in partner civil remedy under PWDV Act 2005 and criminal remedy under sect 125 CRPC to seek maintenance from their live in partner same as marital partner. Domestic relationship between an unmarried woman unknowingly enters into a relationship with a married adult male: An unmarried woman unknowingly enters into a relationship with a married adult male, may, in a given situation, fall within the definition of Section 2(f) of the DV Act and such a relationship may be a relationship in the "nature of marriage", so far as the aggrieved person is concerned. Indra Sarma vs V.K.V.Sarma on 26 November, 2013, Supreme Court of India CRIMINAL APPEAL NO. 2009 OF 2013,(@ SPECIAL LEAVE PETITION (CRL.) NO.4895 OF 2012)
The SC placed reliance on the need for including the non-marital relation but such relationship in nature of marriage as equivalent to marital relation so as to bring under the ambit of the PWDV Act 2005, and the need for recognition of rights of such partner
Domestic relationship between an unmarried woman unknowingly enters into a relationship with a married adult male: An unmarried woman unknowingly enters into a relationship with a married adult male, may, in a given situation, fall within the definition of Section 2(f) of the DV Act and such a relationship may be a relationship in the "nature of marriage", so far as the aggrieved person is concerned.
Domestic relationship between same sex partners (Gay and Lesbians): DV Act does not recognize such a relationship and that relationship cannot be termed as a relationship in the nature of marriage under the Act. Legislatures in some countries, like the Interpretation Act, 1984 (Western Australia), the Interpretation Act, 1999 (New Zealand), the Domestic Violence Act, 1998 (South Africa), the Domestic Violence, Crime and Victims Act, 2004 (U.K.), have recognized the relationship between the same sex couples and have brought these relationships into the definition of Domestic relationship.
Courts and legislatures of various countries now began to think that denying certain benefits to a certain class of persons on the basis of their marital status is unjust where both unmarried and married cohabitants felt the need of those benefits. Courts in various countries have extended certain benefits to heterosexual unmarried cohabitants. Legislatures too, of late, through legislations started giving benefits to heterosexual cohabitants.
In the U.K. through the Civil Partnership Act, 2004, even the same-sex couple's rights have been recognized. Family Law Act, 1996, through the Chapter IV, titled 'Family Homes and Domestic Violence’; cohabitants can seek reliefs if there is domestic violence. Canada has also enacted the Domestic Violence Intervention Act, 2001. In the USA, the violence against women is a crime with far-reaching consequences under the Violence Against Women Act, 1994 (now Violence Against Women Reauthorization Act, 2013).
Barton v. Hirshberg- Purpose of the DV statute is Preventive, Not punitive[15]
Opuz v. Turkey(2009): States must protect women from domestic violence.
Critical Analysis
India already has a special enactment to deal with case of Domestic violence. So, it is in line with the International legal framework & direction of European Court of Human Rights. It is wide in its ambit to include various kind of violence, but if we look at the nature of US legislation as it was held in the case of Barton v. Hirschberg, their legislation is not punitive but protective.
Coming to Indian perspective our law is of mixed nature i.e., both punitive and preventive. So, what we need more is not more laws but access of women to the available remedies and implementation in a right way. The focus should be on reducing the number of crime against the women.
V. CONCLUSION
Now, society and legislature need to understand that DV does mean torture to female it means any physical, verbal, and emotional or any other kind of abuse by one on further with the four walls is crime, and discriminating it on the basis of gender is not just fair and it is against the principle of natural justice. Domestic violence not only effect life of individual but also the lives of their children who are innocent, it doesn't matter violence is against male or female it's violence and so law must stringent for both and not only to men, everyone who commits this heinous crime must be punished We do need act like domestic violence but not in the current form we need it with some amendment like it will not only contain the provision for women but also for male, gay, lesbian etc., all should come under the ambit of such legislation. The present form of this act is wholly biased towards women and men are discriminated against. Their fundamental and legal rights are violated. Now there is a need that media must play an active role in removing this discriminatory and biased law, and only then will society come overcome from this evil.
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References
1. Title 42, Subchapter III, Violence against Women, Code of Laws of the United States.
2. Tulika Saxena, Indian Protection of Women from Domestic Violence Act: Stumbling or striving Ahead?, 21, (2015).
3. Vienna Accord of 1994 and the Beijing Declaration and the Platform for Action (1995).
Statutes
1. Indian Penal Code 1860 Act no. 45 of 1860.
2. Minnesota’s Domestic Abuse Act.
3. The code of laws of United States.
4. The protection of women from domestic violence act, 2005.
5. The UK, Domestic Violence & Matrimonial Proceedings Act 1976
6. UK Domestic Proceedings and Magistrates' Courts Act 1978
7. UK Matrimonial Homes Act 1967,
8. UK, Family Law Act 1996
Web based Resource
ENDNOTES
[1] Vienna Accord of 1994 and the Beijing Declaration and the Platform for Action (1995). Available at: https://www.ohchr.org/Documents/Publications/Commentary_Human_Trafficking_en.pdf , last seen on 31/10/2023.
[2] Tulika Saxena, Indian Protection of Women from Domestic Violence Act: Stumbling or striving Ahead?, 21, (2015), available at http://hdl.handle.net/1885/104291 , last seen on 05/11/2023.
[3] Ibid
[4] Ibid
[5] The United States Department of Justice, https://www.justice.gov/ovw/domestic-violence , last seen on 04/11/2023.
[6] Title 42, Subchapter III, Violence against Women, Code of Laws of the United States.
[7] Domestic Violence: Laws and Policy, Available at http://hrlibrary.umn.edu/svaw/domestic/laws/samplelaws.htm , last seen on 03/11/2023.
[8] The UK, Domestic Violence & Matrimonial Proceedings Act 1976
[9] S.3, The Protection of women from Domestic Violence Act, 2005.
[10] Marital Rape Is Not A Crime In India. But One High Court.... https://www.huffpost.com/entry/india-marital-rape-gujarat-high-court_n_5ac571dce4b0aacd , last seen on 1/11/2023.
[11] Tukaram vs. State of Maharashtra, 1979 AIR 185, 1979 SCR (1) 810
[12] Hiral P. Harsora And Ors vs Kusum Narottamdas Harsora And Ors, 2015
[13] Prakash Babulal Dangi Vs State of Maharashtra SLP no 10280 -10281 / 2017
[14] D.Velusamy vs D.Patchaiammal on 21 October, 2010 SC, CRIMINAL APPEAL NOS. 2028-2029__OF 2010, [Arising out of Special Leave Petition (Crl.) Nos.2273-2274/2010]