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ANALYZING THE SIKKIM STATE COMMISSION FOR WOMEN ACT AGAINST DOMESTIC VIOLENCE AND PRE-LITIGATION OPTIONS

Prasanata Chhetri

Assistant Professor, ICFAI University Sikkim School of Legal Studies

Abstract- The family is regarded as a haven of safety by many. If you are a woman who has been beaten or tortured as a wife and discriminated against in your daughterhood and neglected in your widowhood, this may not be true for everyone. Because women are a vital part of the family, they are subjected to brutality and torture within the four walls of the home as well. Torture, savage beatings, and murders of women are taking place in rural areas, villages, cities, and metropolises. Violence in the house is a growing problem that affects all social levels, genders, races, and ages, and is known as "Domestic Violence."

Physical, sexual, economic, and emotional abuse are all possible manifestations of this violence. For the protection of women from domestic abuse, the Protection of Women from Domestic Violence Act of 2005 was passed by Parliament. There have been a number of laws enacted to safeguard women. Because domestic abuse is a sensitive matter, victims prefer to seek help from organizations such as the National Commission for Women (NCW), State Commission for Women (SCW), Human Rights Commission (HRC), Women's cell, Family Counseling Center (FCC), and Non-Governmental Organizations (NGOs).

A small state like Sikkim is affected by domestic violence, and this study examines the reasons, modes, and extent of domestic violence. This study also highlights the state's pre- litigation options and their effectiveness in safeguarding victims of domestic violence.

Keywords: Domestic Violence, Pre-Litigation, Women Act

I. INTRODUCTION

Approximately half of India’s populations constitute women. The various roles that women assume in the family are those of wife, partner, daughter, mother, teacher and so on. Moreover, being a women part of today’s society, women play a key role in the socio-economic development of the society. Despite women assuming important roles facilitating the development of the nation, they are often considered physically and emotionally weaker than men and are subjected to torture and exploitation. Universally evidence proves that women are grilled and enunciated in their homes as well as outside irrespective of their age, class, caste, race, status, religion and nationality. This form of exploitation of and violence against women within the fours wall of their home is referred to as

“domestic violence”.

According to National Crime Record Bureau 2019 report in every 4 minutes women is subjected to cruelty by

husband and in-laws, in every 2-3 days women are victims of acid attack, in every 1 hour and 13 minutes women is subjected to dowry death, in every 16 minutes women gets raped, in every 1 day and 6 hours women gets gang raped and murder and in every 6 minutes women is subjected to offence of assault with intent to outrage her modesty.

Women in their own homes are subjected to a variety of forms of violence, including abuse from their husbands or family, marital rape, assault and domestic violence. Violence in the home is by far the most common. Torture, savage beatings, and murder of women are taking on behind closed doors in homes all around the country. In rural areas as well as in towns and cities. It is called

"domestic violence" when women are exploited and abused within the confines of their own homes. It is also called domestic abuse or intimate relationship violence. Also known as domestic

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violence, it is the act of harming someone with whom we are in a relationship, whether it is a spouse or a child or a grandmother. Anyone can be either a victim or a perpetrator of victimization.

For the year 2018, domestic violence against women was the most common kind of violence against women, according to the National Crime Records Bureau's "Crimes in India" report (NCRB).

In 2018, 89,097 incidences of crimes against women were reported in India.

This year's 86,001 cases under this heading show little improvement. In 2018, the crime rate per lakh women is 58.8, up from 57.9 in 2017.

Protecting Women from Domestic Violence Act, 2005 was passed by the Indian government in 2005.

With this statute, the history of legal control and judicial reaction to domestic abuse issues has been rewritten.

Objectives

i) Understand the concept and nature of domestic violence

ii) Analyze and understand the Sikkim State Commission for Women Act.

iii) Analyze and understand the role of family counseling centers in curbing domestic violence.

Hypotheses

i) Lack of awareness regarding the existing legal provisions results in the crime going unnoticed

ii) The existing pre-litigation options are adequate to settle domestic violence cases in Sikkim.

iii) The victims of domestic violence are satisfied with the decision given by the state commission and other counseling centers.

Methodology

This study includes doctrinal and non- doctrinal methods and observations at family counseling centers.

Sources: text books, legislations, journal articles, reports, and so on

II. LITERATURE REVIEW

It's no secret that domestic violence is a hot topic in academia. Nationally and internationally, there has been a great deal of academic scholarship. In spite of this, there is a plethora of useful literature on this topic. As a result of its increasing prevalence (as evidenced by data and statistics from throughout the world), the issue requires re-orientation and re-interpretation. A few highly important works on domestic violence against women have been discovered by researcher throughout the literature review. These include:

Susmitha B (2016) It's no secret that women's concerns have been hotly contested on a variety of forums throughout the past few decades.

Domestic violence, i.e., violence that occurs within the victim's home or by members of her family, is one of the most essential components of this discourse.

Concerning the growing problem of domestic violence, some international references have been cited in order to have a better knowledge of the situation on a worldwide scale There is no separation between women and men in a family, a culture, or a country as a whole.

To have a healthy family, a healthy society, and a healthy nation, both must work together. In order to improve the quality of life of persons, efforts must be made to improve the quality of life of individuals. Any additional effort without undertaking the base work will just address the issue at the surface level, and the problem will always persist beneath the surface of the Endeavour.

Rakesh Choudhary et. all (2014) In India, domestic violence against women is a well-known and widespread problem.

Violence against women is regarded as a condition that is fostered and promoted by gender norms and attitudes that place women in a subservient position in comparison to men. In this study, the prevalence of domestic abuse among Indian women is criticized in detail.

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Domestic abuse was assessed using an interview schedule. To acquire an accurate result, 50 ladies from Lucknow were interviewed. Women's domestic violence has been linked to drinking in men, the study found. According to the study's findings, domestic abuse is still prevalent in Indian society, and women are generally unaware of the laws and organizations that deal with domestic violence. Domestic violence against women has been linked to drunkenness among husbands.

Amy Hornbeck et. all (2007) Women in India now have more rights and protections under the Protection of Women from Domestic Violence Act than they have ever had in the past. Domestic abuse is defined extensively under the Act, as opposed to earlier legislation, which only afforded protection in cases of dowry death and extreme cruelty. As a result of this legislation, there are civil remedies to bridge the gap between the restricted criminal laws and divorce, which is the most extreme civil remedy.

As a result of this, women in India have a unique right to live in the joint household.

Appiah Seth et. all (2013) Domestic violence occurs within the context of a domestic relationship. The study had as its main objective detailing domestic violence abuses against women at the Oforikrom sub metro district. It is meant to unravel the myth surrounding domestic violence abuse. Specifically, the study sought to:

1. Find out the factors that promote domestic violence abuse and specifically against women

2. Detail whether women who domestically abuse their male partners is on the increase at the Oforikrom sub metro district

3. Examine whether women are able to take appropriate action (legal or otherwise) against their partners when they are domestically abused 4. Analyze the policy implications,

relevance and efficacy of the passage

of the domestic violence act in addressing the domestic violence problem as well as the integrative strategy for combating the menace.

Leshui He (2017) Presented in this research is a pre- litigation settlement model. Some private legal harm is inflicted on an un-risky plaintiff by an un- risky (possible) defendant. But he does not know the exact magnitude of the harm. For example, the plaintiff may decide to settle with the defendant before filing suit in exchange for avoiding further litigation. The issue is concluded if the defendant pays a fair compensation.

Another option is to sue, which incurs additional legal costs for both parties if the case has substance. This occurs after some legal fees are incurred, and the defendant learns what has really happened through discovery. Each side will then have another opportunity to settle before a court judgment is rendered.

Jeffrey (1993) Policing has become prevalent due to the dissolution of matrilineal social structure and rigid caste system, according to his book 'Politics, Women, and Well- Being' Women have won and lost in this process, but they have kept a unique position of autonomy in India. A combination of politics and women's liberty has led to the alleged "well-being" associated with the

"Kerala model," according to this book.

Agarwal (1994) During her research, she focused on the economic status of women and the incidence of violence against them. There's a direct link between women's vulnerability to assault and their economic standing, according to her analysis. Affluent women who own their own homes and land are less likely to be victimized by violence.

Bose (2000) Women in India:

Ancient, Medieval and Modern examines the status of Indian women over time.

These women's lives have a wealth of untapped original sources of knowledge, which is a challenging Endeavour to do.

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Indian- born women who have done substantial research on the country's history, literature, and culture have contributed to this collection. Due to this, some studies seek feminist critical analyses, some focus on textual or historical evidence, while others offer historical surveys. All of this is an attempt by the authors to help readers realize some of the most important issues in women's lives and their cultural roots, as well as the resources available for studying them.

Bhattacharya (2004) When it comes to the plight of Indian women,

"Behind Closed Doors" is a must-read.

'Real' domestic violence, she says, is when a husband or lover molests, abuses, and rapes a woman in her own house, but society never recognizes this form of violence as 'real'. Criminal acts against women are never questioned or redressed because they occur behind closed doors of family conventions and values.

Sambodh (2007), female infanticide and child marriage are two social ills in Rajasthan that have been studied in depth, both in terms of their causes and prevalence. These two immoral practises, which are also emphasized, were fought against by a variety of castes (social groups) in Rajasthan. Also revealed in this book are previously hidden and overlooked facts.

We've tried to understand the socio- economic, psychological, and political factors involved in this horrendous crime.

III. Types of Domestic Violence

Violence against a family member is defined as violence towards someone with whom we have a relationship; this could

be a

wife/girlfriend/mother/sister/grandparen t or any other family member. It is possible to be both a victim and a perpetrator in the same situation.

It's possible to be violent in a variety of ways, including physically, emotionally and financially.

This includes pushing, kicking and punching as well as other forms of physical violence such as slapping and biting. Other forms of physical violence include choking and shaking as well as pinching, biting and grasping as well as burning and killing. There are several types of mental abuse such as bullying and verbal abuse such as insults, humiliation and taunting about not having children or not having a male kid, as well as threats to bring physical harm on the aggrieved person's behalf to others.

As far as sexual abuse is concerned, it is any sexual conduct that humiliates, denigrates, or violates the dignity of women. Forcing someone into undesired, risky, or demeaning sexual activity constitutes sexual assault. As one example of sexual harassment, a person may ridicule another person to try to limit their sexuality or reproductive options (forcing someone to look at pornography, or forcing someone to participate in pornographic film-making). This includes the deprivation of all or any resources that the aggrieved person is entitled to under any law or custom, whether payable through an order of court or otherwise, and which the aggrieved person needs out of necessity, including but not limited to household necessities for the aggrieved person and her children."

Sexual assault and other forms of domestic abuse not only inflict physical harm on victims and perpetrators but also have a negative impact on the victim's social, economic, physiological, spiritual, emotional, mental, and spiritual well- being. Children who witness violence between parents are more likely to become violent themselves and to engage in inappropriate behaviours such as drug or alcohol abuse. The suicide rates due to domestic abuse are also a cause for concern because they are on the rise.

The case of Sikkim is the subject of this study. China borders Sikkim in the north, Bhutan in the east, Nepal and

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West Bengal in the west, while West Bengal borders Sikkim in the south.

Sikkim, the least populous and second smallest state in India, is located in the Siliguri Corridor and Bangladesh. In 1975, the Himalayan state of Sikkim joined the Indian Union as the 22nd state of the country. Sikkim has a total size of 7096 square kilometers and a population of roughly 6 lakhs (West). Sikkim's capital, Gangtok, has a population of about 200,000 people.

It was determined that Sikkim was the safest place in the country for working women in a 2017 report by the National Crime Records Bureau (NCRB). Sikkim, on the other hand, has a history of domestic abuse and violence against women. It was shown in the SPACE 2000 survey that 50% of women are assaulted by men. It was strongly advised that government and non-governmental organizations (NGO's) form a body to safeguard women from domestic violence.

the proportion of women experiencing sexual violence has climbed from 2.6% in 2019 to 12.1% in 2020, according to NFHS-5 Sikkim data.

153 women were harmed in 2016, 163 in 2017, and 172 in 2018 in Sikkim according to the NCRB report.

According to a survey conducted by the Ministry of Health and Family Welfare, 16% of women in Sikkim are victims of domestic abuse. Sikkim also has a high rate of spousal sexual violence, with one out of every six women having experienced it. In Sikkim, 19% of women between the ages of 15 and 49 have experienced physical violence, while 4%

had been sexually abused. Overall, 21% of women, including 22% of married women, have experienced sexual and physical assault. In addition, women whose spouses consume alcohol and get intoxicated are more likely to encounter marital abuse, according to the report. In contrast, just 32% of women who were victims of violence went to get support from a social worker. Most of the ladies

haven't sought treatment or notified anybody about the abuse they've endured.

This is one of the reasons why domestic violence cases aren't reported more often.

The police (5 percent) and social service organisations (2 percent) are the only institutions where women seek help.

In Sikkim, alcohol consumption and extra-marital affairs are regarded as the most common cause of violence against women. Alcohol consumption is traditionally acceptable in the Sikkimese society. Liquor is easily available in the state and it is common practice among elders to drink openly in the presence of young children. However, the economic dependency of victim, fear of emotional damage to children and cultural and religious constraints are also a contributing factor for domestic violence in some cases.

3.1 Problem of Domestic Violence The fact that women are at danger even within the four walls of their homes is a tragedy. All of these inhumane and cruel crimes are perpetrated against women of all ages, whether they are infants or widows, in the confines of the house.

Female family members treat them poorly despite their financial comfort, and they are socialised to maintain a negative, disempowering self-image despite accepting their lower place in the family.

Because of this, women (who are the biggest victims) accept domestic violence as something that is socially, culturally, spiritually, and even biochemically acceptable.

3.2 Psychological factors of Domestic Violence against women:

As a symbol of sacrifice, charity, patience, devotion and other virtues in the Indian culture, women are revered. You can never expect anything in return from a woman. Should accept all complaints but never make any herself. A woman's husband is often seen as her lord (Pati Parmeshwar). History demonstrates that

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Indian women are constantly urged to sacrifice and face or cope because of this psychological factor alone. At times, it takes the shape of "sati" (the custom of burning off a widow with her husband's funeral pyre so that she will remain a slave for the rest of her life) or "jauhar"

(burning oneself to avoid embarrassment) or Dasi Pratha (keeping slave females) etc.

In patrilineal, unilineal, and kinship systems, Indian women are always expected to do well at home, mothering, and taking care of the family. Women are expected to achieve perfection in this area. Girls/women and newlyweds are taught the family's customs by both male and female members of the household. On the other hand, violence is considered as a respectable way to teach her the proper behaviour. When newlyweds, young women must adapt to a variety of new gender roles as they settle into their new home. When it comes to cooking, dressing, and behaving properly, family members want the in-laws to be taken care of by their family elders, who are responsible for meeting their expectations.

IV. ECONOMIC CAUSES OF DOMESTIC VIOLENCE

A woman's economic dependence on her family members and spouses is considered one of the most significant factors that contribute to domestic violence against her. Limited access to cash and credit, discriminatory laws regarding inheritance, property rights, and maintenance after divorce or widowhood are all economic factors that contribute to domestic violence against women. Women also have limited access to formal and informal employment opportunities, education and training opportunities, as well as the inability to provide basic necessities such as food, clothing, and medicine. This means that economic violence can range from the denial of property rights for women to the normative exploitation of their unpaid

labour in the home, to the denial of equal access to education, to discrimination on the job market, and even dowry. It is more likely that domestic abuse will occur when women lack the resources or economic stability to leave abusive relationships due of a lack of assets or productive employment. As a result, economic security can play a crucial role in protecting women from domestic violence and empowering them.

V. PRE-LITIGATION OPTIONS AVAILABLE TO WOMEN IN SIKKIM SIKKIM STATE COMMISSION FOR WOMEN

Being a sensitive issue, victims of domestic violence tolerate everything silently instead of disclosing to others.

This is one of the major factors for non- reporting of domestic violence cases. They usually seek help from the family members rather than from the appropriate authorities. This is because authorities such as police personnel treat domestic violence as a family matter.

Consequently, the victims have to return to the perpetrators without any reconciliation thereby encouraging the perpetrators to commit the offence repeatedly. Furthermore, litigations in the court of law are highly technical, expensive and lengthy thereby posing major hurdles for the victims of domestic violence to get immediate relief and justice. Among the National Human Rights Commission (NHRC), State Human Rights Commission (SHRC), Women Cell, Family Counseling Centre, One Stop Centre and NGOs the National Commission for Women at the centre and State Commission for women in the state level are regarded the most effective modes for providing justice to the victims within a short period of time. An independent statutory agency formed under the National Commission for Women Act 1990, the National Commission for Women reviews and recommends legislative remedies for

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women, assists in grievance resolution, and advises government on all policy topics affecting women. Upon realizing the complexity of examining women's issues across the country, the National Commission for Women advised that the states create women's commissions in the same vein. State commissions were set up in all 50 states. Sikkkim officials approved a law in 2001 and created a commission to protect women's rights and legal entitlements. Gangtok, East Sikkim, is home to the Sikkim State Commission for Women. A major goal of the commission is to raise knowledge about the rights of women under CEDAW and the Indian Constitution, especially amongst the weaker groups of society, such as SC/STs and others.

The other objectives of the SCW include the following:

1) “Enable the women in general to become aware of the various central and state government schemes for the social and economic upliftment.”

2) “Empower women to fight violence against them to gain access to free legal aid.”

3) “Campaign to create awareness about the inheritance rights and maintenance rights.”

4) “Create awareness for the empowerment of women by disseminating information regarding various schemes and programmes as launched by Central Government and state Government from time to time.”

In addition to the chairwoman, the State Women for Commission consists of 12 other members. In addition, there is a woman as the chairwoman. Chairman and each member must serve for a period not exceeding three years, as determined by the State Government. To defend women's rights and interests, the state government has chosen eight legal providers who provide legal, financial or other types of support in accordance with the terms of the Act. This state commission has been striving to protect women in Sikkim since its inception. To educate women about their rights and protection, they organize awareness programmes every year in practically every region of the state, especially in

rural areas.

Table I: Cases reported before the Sikkim State Commission for Women (Year 2003- 2012)

Source: Sikkim State Commission for Women

Number of Cases Reported Before the Sikkim State Commission for Women

2003- 2004- 2005- 2007- 2008- 2010- 2011-

2004 2005 2006 2008 2009 2011 2012

103 159 100 162 110 101 65

Table II: Cases reported before the Sikkim State Commission for Women (Year 2017-2018)

The numbers of cases reported to the Commission in 2017- 2018 are mentioned in the table below:

Year 2017-2018 No. of Complaints Received

Dispose d Pending Referred to family court

Physical Assault 05 05 - -

Domestic Violence 205 176 15 14

Harassment/ Mental torture

16 16 - -

Illicit Relations 16 16 - -

Matrimonial Dispute 77 70 05 02

Source: Sikkim State Commission for Women

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Services of Special Cell

The Cells working against the crime with the help of police machinery are established in various states, providing help to the victims of violence. The 'Crime against Women Cell' works against different types of violence against women.

In this cell, women police officers, social workers and professional counsellors ensure peaceful settlement in family disputes and conciliation. In Sikkim, the CID wing has set up a cell for women's crimes. Police have also been trained on how to deal with victims of rape, molestation, or domestic violence. Civil police positions are reserved for women at a rate of 30 percent in the state, and female officers in all police stations maintain the safety and well- being of women in the state.

Family Counselling Centers (FCC) Families Counselling Centers (FCC) are a government- sponsored programme that has been conducted by the Central Social Welfare Board through voluntary organizations across India since 1983. By using crisis intervention and organized counselling, the FCCs strive to provide preventive and rehabilitative services to women and families who have been victims of atrocities and familial maladjustments. This organization's major goal is to safeguard women from domestic violence and also to provide them with educational and career counselling, as well as legal help. At the village level, workshops and awareness programmes are held on a variety of topics. En outre, the federations work to raise awareness and organise public opinion on social issues impacting women's status.

NGOs

The term NGOs or non-governmental organizations is popularly used to denote association working outside the formal administrative frame work of government.

NGOs can be registered or unregistered.

Generally, NGOs are registered under the societies Registration Act of 1860. NGOs play a great role for the promotion of development activities particularly at grassroots level. However, there are NGOs in India which are playing a great role in the emancipation of women. These NGOs are fighting against different crimes against women including domestic violence and act as the bridge between the authorities and the victim. Their advice and aid in submitting a request to the National Commission for Women or the State Commission for Women assists women in establishing their rights. Some of the services provided by NGOs to domestic abuse victims include medical help, shelter, and counselling.

VI. PREVENTION OF VIOLENCE/CRIME Since the dawn of society, there has always been a need to combat crime.

Preventing illegal behaviour is the best alternative. It is the goal of crime prevention to reduce victimization and dissuade crime. Government measures to suppress crime, uphold the law and sustain criminal justice are especially addressed. A crime prevention strategy or policy is one that minimizes or eliminates the overall degree of victimization or the risk of individual criminal activity. It comprises government and community- based programmes to reduce the frequency of risk factors connected with criminal participation and victimization rates, as well as attempts to influence perceptions of criminals and criminal justice systems.

Prevention, in general, tries to eliminate those conditions or variables that lead to victimization or that inspire criminals to commit crimes. There are many types of preventive measures that are available. It's possible that it has to do with sensitizing people to modify their mental propensities and orientation.

Criminality prevention is a comprehensive approach that includes all tactics (such as social and cultural reform,

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empowerment in the economy and politics, use of legal punishment as deterrence) to prevent crime from occurring.

VII. FINDINGS

i) Pre-litigation options are really efficient and effective means to settle disputes and provide protection to the victims of domestic violence ii) The procedure for settling the

disputes is simple.

iii) One of the reasons people opt for pre-litigation options is at the secrecy of the procedure.

iv) The Commission plays a vital role in unifying the families involved in the disputes.

VIII. SUGGESTIONS

i) The Sikkim State women Commission for Women should be further strengthened through opening of offices in remote areas with the support of village Mukhya and NGOs to propagate the avenues available to women.

ii) The men should be enlightened about the impact of drinking habits on the family and children as well as image in the society.

iii) Mobile vans creating awareness about women protection should be sent to interior hills areas of the state.

IX. CONCLUSION

Sikkim being a small state with a low incidence of violence against women pre- litigation options are effective and efficient means to settle dispute and provides protection to the victims of domestic violence in Sikkim. The procedure for settling the dispute is simple such that both the parties are given opportunities to discuss the issues and conclude the case.

One of the reasons people opt for pre- litigation is the secrecy of the procedure.

The procedure for settling the disputes in these commissions are not open as that in

courts. The cases in the commission are settled by discussing with the parties. The welfare of the child and the protection of the women is the prime concern while settling the disputes before the commission. Since the procedure for settling the dispute remain a secret, there are maximum chances of reuniting the couples. Therefore, only few cases of domestic violence are registered at present as maximum number of cases are settled with the pre litigation process before the commission. In the name of religion, culture, or patriarchy, violence against women has been practised for hundreds of years. Violence against women has a unique history, but it also has a universal incidence and acceptance.

Women are abused physically, sexually, and psychologically in all societies, regardless of income, status, or culture.

Violence is not just a violation of women's human rights, but also a hindrance to their growth. 'Private' acts of violence against women are as common as public acts. "Domestic violence" is defined as

"violence that has made women feel unsafe in their own "honour" and where the perpetrators are related to them in some way."

REFERENCES

1. J.N Pandey, the Constitutional law of India, Central law Agency.

2. Dr. G. B Reddy, Women and the Law, Gogia Law Agency.

3. Dr. Suman Rai, Law relating to Protection of Women from Domestic Violence, Orient Publishing Company.

4. The Protection of Women from Domestic Violence Act, 2005, Bare Act, Universal Law Publication

5. The Sikkim State Commission for Women Act, 2001, Bare Act

6. Sikkim.gov.in Sikkim human development

report 2014 Available at

http://www.sikkim.gov.in

7. National Crime Records Bureau(NCRB) Report

8. Available at

https://sikkim.gov.in/departments/social- justice-empowerment-and-welfare-

department/boards- commissions

9. Jeffrey, Robin (1993). Politics. Women and Well- Being: How Kerala became 'A Model', Delhi:

Oxford University Press.

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10. Agarwal, Bina. A Field of One's Own Gender and Land Rights in South Asia, Cambridge:

Cambridge University Press; 1994.

11. Susmitha B. “Domestic Violence: Causes, Impact and Remedial Measures” SAGE Publications 2016.

12. Rakesh Choudhary, Manish Kaithwas, Gaurav Rana “Domestic Violence Against Women’s in India A Study” Research gate 2014.

13. Amy Hornbeck, Bethany Johnson, Michelle LaGrotta, Kellie Sellman “The Protection of Women form Domestic Violence Act: Solution or Mere Paper Tiger?” Spring 2007.

14. Appiah Seth Christopher Yaw, Abubakari Mohammed “Domestic Violence and its Effect on Women” Research Gate 2013.

15. Leshui He “A Theory of Pre-litigation Settlement and Patent Assertion Entities” Research Gate 2017.

16. Bose Mandakranta (ed.). Faces of Feminine in Ancient Medieval and Modern India, New Delhi:

Oxford University Press; 2000.

17. Bhattacharya, Rinki (ed). Behind Closed Doors:

Domestic Violence in India, New Delhi: Sage Publications India Pvt. Ltd.; 2004.

18. Goswami, Sambodh. Female Infanticide and Child Marriage, Jaipur: Rawat Publications;

2007.

Referensi

Dokumen terkait

ix Section 3 explanation (ii) of Protection of Women from Domestic Violence Act 2005- sexual abuse includes any conduct of a sexual nature that abuses,