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Critical analysis of sex determination laws in India and Government policies to prevent Gender discrimination
Dr. Mithilesh Narayan Bhatt1 Deeksha Upadhyay2
Abstract
This research paper provides information that gender discrimination, and deep-rooted backward mentality, social norms, and practices increase crime related to women like female feticide, teenage pregnancy, child domestic work, child marriage poor education and health, sexual abuse, exploitation, and violence. Many of these manifestations will not change unless girls are valued more.3 This research paper also provides deep knowledge about the legislation which is provided by the government to curb the problem related to female feticide, immoral trafficking, or other related crimes. This research paper also deals with some important case laws related to these crimes. Female feticide is the reason because the mortality rate of girls is higher than boys, according to the data released by National Crime Records Bureau for the year 2019, In Madhya Pradesh, every month at least 3 girls were killed before they were born. In 2019, Madhya Pradesh had earned the lead in the list of states in female feticide because M.P.
reported thirty-two cases of feticide, Rajasthan-twenty-two, Haryana-seventeen, Gujarat- fifteen and Bihar –fifteen in a year. There are many incidents related to female feticide, immoral trafficking, and other women- related crimes faced by the government of India. Legislations made by the government to prevent these problems and these legislations have some loopholes because of that these Acts.
Keywords: Women, PC-PNDT Act, Miscarriage, Female Feticide, Government Policies.
Introduction
According to the UNICEF organization, there must be no discrimination between a boy child and a girl child, every child is entitled to get their full potential but gender inequalities in their lives prevent this reality.4 In India, gender inequality results in unequal opportunities are the aftereffect of gender inequality, and it affects not only girls but also boys but we can say who affected the most is girls. In India, more girls die than boys but when we see globally, who have the highest survival rate are girls but in India girls, the mortality rate is high because they are treated as unwanted children just because of the gender and the backward mentality of the people. In India, boys have more freedom than girls and girls have to face more other difficulties and limitations on them. It can be related to education, work, marriage, and social relationships.5 Nowadays as we can see Some Indian women got the opportunities and become global leaders and powerful voices in diverse fields but in India, the problem is that these opportunities can’t reach because girls do not get the full benefit from many of their rights due to deep-rooted patriarchal views, mentality, norms, traditions, and structures. If India wants to become a fully developed country for that, India should support girls and boys equally to reach their full potential.6 In India, the mortality rate of girls is higher than boys because of female feticide; people kill the girl child even before the birth of the girl child. The government of India provides legislation to prevent any type of crime related to women and
1 Assistant Professor (Law) Sardar Patel University of Police, Security and Criminal Justice, Jodhpur
2 Student (Ll.M-Criminal Law) Sardar Patel University Of Police Security And Criminal Justice Jodhpur, Rajasthan
3 UNICEF,” Gender equality | UNICEF India” available at: https://www.unicef.org/india/what-we-do/gender-equality (last visited Aug. 29, 2021).
4 Supra note 1
5 Id.
6 UNICEF,” Gender equality | UNICEF India” available at: https://www.unicef.org/india/what-we-do/gender-equality (last visited Aug. 29, 2021).
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also provides more other facilities for enhancing the growth and status of the girls' children.
Female foeticide
According to The United Nations Population Fund (UNFPA) State of World Population Report, 2020, which is themed as ‘Against My Will – Defying the practices that harm women and girls and undermine equality, in the year 2020 almost 4.6 crores (45.8 million) females are 'missing' in Indian demography mainly due to pre and post-birth sex selection practices, because of the treated girls child as an unwanted child, son preference and gender inequality.7 The biggest contributor is China with 7.2 crores 'missing females' that is 50.7 % of all missing females in the world and India is the second-highest contributor with one-third 32.1
% of the total 142.6 million missing females.8 Definition
The destruction of the foetus at any time before birth is known as foeticide and the unlawful destruction of a newly born child is considered murder in law.9 An unborn child from after the third month of pregnancy until birth known as Foetus.‘ Female Foeticide’ can be described as the termination of the life of a foetus in the womb only for being female. It is also known as the selective abortion of female fetuses.10 When there is no technology for sex determination exist, a child is born and when it is found that the child is a girl the cultures like drowned in the milk mixed with opium prevail at that time but after the innovation sex detection technologies, it became easier to determine the sex in the womb of the mother and these technologies misused by using it for the termination of the life of a foetus in the womb only for being female.11
PC-PNDT ACT12Introduction
This Act contains 34 sections and 8 chapters ,chapter 1 deals with preliminary part (section 1- 2),chapter ii regulation of genetic counseling centre’s, genetic laboratories and genetic clinics (section- 3,3a,3b),chapter iii regulation of pre-natal diagnostic techniques (section 4-6),chapter iv central supervisory board (section 7-16),chapter-v appropriate authority and advisory committee (section17- 17a),chapter vi registration of genetic counseling centers, genetic laboratories and genetic clinics (section 18-21) chapter vii offences and penalties (section 22-28)and chapter viii deals with miscellaneous part that contains section 29-34. Rules have also been framed under the Act. Parliament enacted the Pre-Conception and Pre-Natal Diagnostic Techniques (PCPNDT) Act, one of the most essential legislation for the prohibition of sex selection, before or after conception and it came into force on 1-1- 1996.
Amendments
Some important Amendments are made in the Act of 1994 because during the implementation some inadequacies and practical problems in the administration of the Act came into the light of the Government and simultaneously the techniques have come into light by which the sex of the child can be selected before conception which may cause the declining sex-ratio.13The Pre- Natal Diagnostic Techniques (Regulation And Prevention Of misuse)Amendment Act, 2001 (ACT NO. 32 OF 2001) came into effect on 3rd September 2001 under this Act amendment made in section 8 of Act 57 of 1994 in clause (a), the word"
and" shall be omitted and also Provided that as soon as the member becomes a Minister or Minister of
7 Sravani Sarkar, UNFPA report - The Week, THEWEEK, 2019, https://www.theweek.in/news/india/2020/07/01/about-46- crore-females-missing-in-india-due-to- son-preference-unfpa-report.html. (last visited Aug. 30, 2021),
8 Id.
9 Anchal Chhallani, Law on Abortion: retaliation to Female Foeticide in India - Jus Dicere, JUS DICERE, (last visited Sep.
7, 2021). https://www.jusdicere.in/law-on-abortion-retaliation-to-female-foeticide-in-india/ .
10 Nidhi Ranka, Female Foeticide A Socio-Legal Enigma, 2 IJLMH (2018), (last visited Sep. 7, 2021), https://iasscore.in/national-issues/female- foeticide-and-infanticide.
11 Id.
12 The Pre-conception and Pre-natal Diagnostic Techniques (Prohibition of Sex Selection) Act, 1994 No. 57, Acts of Parliament, 1994 (India).
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State or Deputy Minister, or the Speaker or the Deputy Speaker of the House of the People, or the Deputy Chairman of the Council of States or ceases to be a member of the House from which she was elected term of office of a member elected under clause (f) of sub-section (2) of section 7 shall come to an end.14In the case of Centre for Enquiry into Health and Allied Themes (CEHAT) v. Union of India & Ors15, the Supreme Court considered these developments and observed that amendments to the PNDT Act are necessary.
On 4th May 2001, an order was passed by the court despite the order, affidavits did not file by certain States/UTs after that on 19th September 2001, an order was passed by the court that States/Union Territories have not submitted quarterly returns to the Central Supervisory Board on performance and implementation of the Pre-Natal Diagnostic Techniques (Regulation and Prevention of Misuse) Act, 1994 so it was directed by the court that the quarterly returns by the States/Union Territories to Central Supervisory Board should be submitted and containing the all information related to Registration and action taken against unregistered bodies, Survey of Centre’s, Laboratories, Search and Seizure, Number of awareness campaigns, and the results of campaigns the Pre-natal Diagnostic Techniques (Regulation and Prevention of Misuse) Act, 1994.16 The Act has been amended and titled “The Pre-conception and Pre- natal Diagnostic Techniques (Prohibition of Sex Selection) Act” On March 31, 2003, because of directions which are issued by this Court, and also said that no further directions are necessary except that the direction issued by this Court on 4th May 2001, 7th November 2001, 11th December 2001 and 31st March 2003 should be complied with.17
The Central Government, State Governments/UTs are directed this Act must be implement effectively; by the electronic media and advertisements information should be published and process should be sustained until awareness is not provided to the public that there should be no discrimination between male and female child, the records of the meetings of the Advisory Committees shall maintain by the appropriate authority, and also submitted the Quarterly reports to the Supervisory Board that report should be consolidated and also published annually for information of the public at large, the Central Government constitute a National Monitoring and Inspection Committee for conducting periodic inspection shall continue to function till the Act is effectively implemented, the reports of National Monitoring and Inspection Committee placed before the Central Supervisory Board and after that State Supervisory Board for any further action, and public would have access to the records which is maintained by different bodies constituted under the Act would have accessed by the public As provided under Rule 17(3) under this Act.16
Objective of the Act
Prevention of the misuse of techniques for pre-natal sex determination and also for matters related to it that lead to female foeticide is the main object of this Act. It affected the radiologists and Sonologist on a large scale The Act came into force on 1st January 1996 after the enactment of the PNDT Act; appropriate actions for its implementation did not take by State Governments and the Central Government. The main function of this Act has been to ban the use of sex-selection techniques before or after conception, the misuse of these techniques for sex-selective abortions and to provide regulation for such techniques. PNDT Act and Rules have been amended keeping in view the emerging technologies for selection of sex before and after conception and problems faced in the working of implementation of the ACT and certain directions of Hon’ble Supreme Court after a PIL was filed in May 2000 by CEHAT and Ors, an NGO on slow
14 The Pre- Natal Diagnostic Techniques (Regulation And Prevention Of misuse) Amendment Act, 2001,No. 32 , Act of Parliament,2001 (India)
15 CEHAT & Ors. v. Union of India & Ors., (2001) 5 SCC 577; CEHAT & Ors. v. Union of India & Ors., (2003) 8 SCC 406;
CEHAT & Ors. v. Union of India & Ors., (2003) 8 SCC 409; CEHAT & Ors. v. Union of India & Ors., (2003) 8 SCC 410;
CEHAT & Ors. v. Union of India & Ors., (2003) 8 SCC 412.
16 Pre-natal Diagnostic Techniques (Regulation and Prevention of Misuse) Act, 1994, Supra note 11 at 128-130
17 Pre-natal Diagnostic Techniques (Regulation and Prevention of Misuse) Act, 1994, Id. at 132.
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implementation of the Act. 18The PNDT Act was amended and renamed as the Pre-Conception and Pre- Natal Diagnostic Techniques (Prohibition of Sex Selection) Act, 1994 (PCPNDT Act), to strengthen the PNDT Act. This Act does not talk about abortion and providers of abortion, because it is specifically regulated under the Medical Termination of Pregnancy Act, 1971.
The Medical Termination of Pregnancy Act, 1971
It is important to consider that the PNDT Act has a significant connection with the Medical Termination of Pregnancy Act. As we know abortions were considered illegal in our country and the same could be punishable under the Indian Penal Code but it is changed after 1971 because the MTP Act was passed which provides for the termination of certain pregnancies by registered medical thus it is clear that abortion is not legal for in all cases of pregnancy but only in the case of certain pregnancies. According to this Act abortion, up to twenty weeks of pregnancy is legally valid but there are certain circumstances and the authority of termination is provided to the registered medical practitioner at a registered medical facility.19 Further, this Act (The Medical Termination of Pregnancy Act 1971) was revised in 1975 to advance its effectiveness and to make it less complicated. This Act contains 8 sections, section 1 talks about the short, title, and extent, section 2 provides definitions in which four definitions ((a) Guardian (b) Lunatic (c) Minor (d) Registered medical practitioner) are provided. Section 3 of this Act talks about when registered medical practitioners may terminate pregnancies. Section 4 mentioned the places where abortion can be done by the registered medical practitioner, section 6 provides power to the central government to make rules to carry out the provisions of this Act and section 7 provides power to the State government to make regulations to carry out the provisions of this Act. Section 8 of this Act protects any registered medical practitioner from any type of legal proceedings for the termination of pregnancy in good faith. The definition of good faith is provided under section 52 of Indian penal code 1860, according to the definition any act which is done with due care and caution comes under good faith and a person is not liable for the damage caused by that act.
Objective of the Act
The main objective of this Act was to provide safer abortions in a legalized way in particular situations.20 In this Act, the licensed registered medical practitioners provide authority for safer abortions or termination of pregnancy. In the preamble of this Act, it is mentioned that the right of termination of pregnancy in particular situations is only provided to license registered medical practitioners.21
The experience which is suffered by a woman after a miscarriage can be physically and emotionally difficult especially when it is not because of the unfortunate event or particular person involved in it and a person involved in it victim may want to file a case against that person.22
Provisions related to Miscarriage in the Indian Penal Code 186023
There are provisions provided under the Indian Penal Code under which punishment is provided to these persons who are responsible for the miscarriage. Sections 312 to 318, chapter XVI of the Indian Penal Code 1860 deal with this crime.
18 State Legal Service Authority, (last visited August 29, 2021),
http://chdslsa.gov.in/right_menu/act/pdf/PNDT.pdf,Chandigarh
19 The Medical Termination of Pregnancy Act 1971, https://www.livemint.com/science/health/why- india-needs-a-new-mtp- act-1567317067262.html (last visited Dec. 6, 2021).
20 Gupta Seep, Medical Termination of Pregnancy Act, 1971 along with the Amendment Bill, 2020 : a critical analysis
- iPleaders, IPLEADERS (last visited Oct. 28, 2021), https://blog.ipleaders.in/medical-termination-pregnancy-act-1971- along- amendment-bill-2020-critical-analysis/
21 Id.
22 Khatri Sonali, Causing of miscarriage - iPleaders, IPLEADER (last visited Dec. 1, 2021)), https://blog.ipleaders.in/causing- miscarriage/
23 The Indian Penal Code, 1860, Act No. 45, Acts of Parliament, 1860
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Section 312 of the Indian penal code24talks about causing miscarriage, according to this section any person who is voluntarily meant with the intention, or knowledge or have a reason to believe that means or act causes the miscarriage to the woman with the child and that miscarriage is not caused to save the life of the woman or in good faith comes under this section and punishment with imprisonment maximum three years, or fine, or both and, the woman who is quick with child,
shall be punished with imprisonment maximum seven years, and fine. It is a non-cognizable, non- bailable offense, non-compoundable, and triable by Magistrate of the first class.
Section 313 of the Indian penal code deals with a miscarriage caused without the consent of a woman. According to this section if any person commits an offence which is provided under sec 312 but the offence has done by the person without the consent of the women, that person is punishable under this section with imprisonment for life, or with imprisonment maximum of ten years, and fine in both the cases whether the woman is quick with a child or not. It is Cognizable, Non-bailable, Non- compoundable, and Triable by Court of Session.
Section 314 of the Indian penal code mentioned any act done to cause the miscarriage and death of the women caused because of the act done by that act. According to this section if any person by any act with intent to cause the miscarriage does any act by which the death of such woman is caused comes under this section and that person is punishable with imprisonment maximum of ten years and fine and if there is no consent is provided by the woman for the act done then the person is punishable with imprisonment for life, or with maximum 10 years and fine. The person who committed the offence doesn't need to know that the act done is likely to cause the death of the victim. If the imprisonment is for ten years and fine It is cognizable, non-bailable, non- compoundable, and triable by Court of Session, and if the imprisonment for life and fine it is cognizable, non-bailable, non- compoundable and triable by court of session.
Section 315 of the Indian penal code provides that if an act done with the intention to prevent a child from being born alive or if the child born alive after being born alive cause it to die comes under this section according to this section any person before the birth to prevent the child to be born alive does any act and that act causes the death of the child or that act became the reason of the death of a child after the birth punishable under this section of Indian penal code. The act done by the accused must not be done in good faith for saving the life of the mother. Under this section, the offence is punishable with imprisonment maximum of 10 years, a fine, and both. Under this section, the offence is Cognizable, non-bailable, Non-compoundable, and Triable by Court of Session.
According to Section 316 of the Indian penal code mentioned that by the act which is amounting to culpable homicide becomes the Cause of death of the quick unborn comes under this section.
According to this section, any person who does any act which is amounting to culpable homicide and because of that act the death of the woman is caused comes under culpable homicide and if by such act death of a quick unborn child is caused, punishable under this section. Under this section, the offence is punishable with imprisonment maximum of ten years, and a fine. So according to this section if a person with the knowledge that such an act may cause the death of the pregnant woman does nay act and death is caused because of that act would amount to culpable homicide and by such act, the pregnant woman is injured, and death is not caused but the death of an unborn quick child is caused the person is liable for the offence defined in this section. Under this section, the offence is Cognizable, Non-bailable, non-compoundable, and triable by the Court of Session.
Section 317 of the Indian penal code talks about a child under 12 years who are exposed and left with the intention to abandon, by parent or person having care of it comes under this section. According
24 The Indian Penal Code, 1860, Id.
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to this section, a child who is under the age of 12 years intending to wholly abandon such child, expose or leave such child in any place by the father or mother is punishable under this section. The offence under this section shall be punished with imprisonment extending to seven years, or fine, or both. But if a child dies because of this act this section the accused person is liable for murder or culpable homicide. The offence under this section is cognizable, bailable, non- compoundable, and triable by a magistrate of the first class.
Section 318 of the Indian penal code talks about the secret disposal of a dead body for hiding the birth of a child. According to this section if any person does any act with the intention to hide the birth of a child or tries to hide the birth of a child by secretly burying or disposing of the dead body. It does not matter that child dies before or after or during its birth punishable under this section. The punishment for this offence is imprisonment with two years, or fine, or both. The offence under this section offence is Cognizable, Bailable, Non-compoundable, and triable by Magistrate of the first class.
Government Policies
Mukhbir Yojana: - Chief minister Yogi Adityanath, launched a scheme known as Mukhbir Yojana’
in Uttar Pradesh, to stop female foeticide and under this scheme anyone who provides information related to the participation of any medical staff or doctor in sex determination and female foeticide to the state authorities, the government will provide up to Rs 2 lakh to the person who provides the information.25This scheme showed the fear over reducing the female population in the state because of female foeticide and with the help of this scheme, informers provide information and based on the information traps are made by using decoy couples against individuals, organizations, and the individual who is involved in aiding and abetting these illegal practices of sex determination tests and female foeticide. For monitoring the progress of this scheme there is the district and state-level committees and these monitor the progress on regular basis and at least once in three months, it can be through formal meetings. There are precautions is taken by the government to the prevention of misuse of this scheme. This scheme has been launched under the Pre-Conception Pre-Natal Diagnostic Technique (PCPNDT) Act. Rajasthan is the first state by which this scheme was launched to check female foeticide. Uttar Pradesh has become the second state after Rajasthan.26
Pradhan Mantri Sukanya Samriddhi Yojana: - This scheme is started by the prime minister (the central government of India). It is like one of the small savings investment plans and the purpose of this scheme is to aid the parents in supporting the dreams of acquiring higher education by securing the economic future of the female child.27 this scheme is only for the Indian Citizens only for those girls who are born within the borders of India and plan on staying in the country for the entire tenure and for taking the benefit of this scheme the girls age must be under the age of ten years if the girl is not under the age of ten will not be allowed to open the account and invest money.28
Pradhan Mantri Surakshit Matritva Yojana: - The government has launched and implemented the Pradhan Mantri Surakshit Matritva Yojana because in pregnancy the women need extra care because it is a critical stage so if proper medical assistance is not provided it is dangerous for the life of both. Free medical checkups and examinations for all registered candidates are provided under this scheme, both in rural and urban areas. This scheme includes medical treatment and checkups to
25 Female foeticide, (July 19, 2021), https: //www.Hindustantimes.com/india-news/adityanath-launches- scheme-to-stop- female-foeticide-improve-up-s-skewed-sex-ratio/story-XPAyHRqNXiNriqo0RslK2O.html
26 Id.
27 Sukanya Samriddhi Yojana (Calculator, Chart, Interest Rate) - PRADHAN MANTRI YOJANA, (last visited Dec 30, 2021), https: //www.pradhanmantriyojana.co.in/sukanya-samriddhi-account-scheme/
28 Pre-Conception Pre-Natal Diagnostic Technique (PCPNDT) Act,Id.
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all registered candidates who get the facility of having ante-natal services, also get blood pressure, sugar, and other required examinations but not ultrasound tests. This scheme is basically to help the poor and women in the low-income group, medical facilities will be provided at no charges.
According to this scheme on the 9th of every month for the protection of the pregnant women from any complications and also ensure the safety of the unborn child, all medical and health checkups are going to be conducted, and the newborn child will also get medical checkups and treatments for the period of the first few months.29
Beti Bachao Beti Padhao Yojana: - The main objective of this initiative by the Modi Government is to bring in more awareness to save and educate their girl child among the Indian citizens. The Government has paid attention to facts about the current ratio of girls and boys, women and men because the power of a nation is based upon the strength of its citizens. The nation's growth automatically increased if the native works for his growth.30 This scheme came for the overall development of citizens and the nation. The Prime Minister Mr. Narendra Modi” to make the nation stronger with the strength of its Women and for the growth of the nation, has come up with the new Campaign named as “Beti Bachao, Beti Padhao.31
Immoral Trafficking: - When men, women, and children are taken from one place to another, for forced labor, domestic servitude, forced sex work, unsafe agricultural labour, etc. comes under immoral trafficking.32 Human trafficking is a violation of human rights and freedoms which is provided by the constitution of India. Article 23 of the constitution of India provides that trafficking in any form is prohibited in India. Section 370 of the Indian penal code also deals with the trafficking of a person, and 370-A deals with the exploitation of a trafficked person.33The Suppression of Immoral Traffic in Women and Children Act, of 1956 also deals with immoral trafficking.
Provisions Related To Immoral Trafficking In Indian Penal Code 186034
Section 370: - According to this section if any person by using threats, force by abduction, fraud, inducement, and by any other type of money to receive consent has control over the person who is recruited, transported, harbored, transferred or received, for exploitation commits the offence of trafficking. According to this section if any person commits an offence under this section is punishable with rigorous imprisonment minimum of seven years and more but a maximum of ten years, and a fine. If more than one person is trafficked by the accused person is punishable with rigorous imprisonment minimum of ten years but maximum imprisonment for life, and fine. If a minor is trafficked it is punishable with rigorous imprisonment minimum of ten years, but maximum imprisonment for life, and fine and if more than one minor trafficked it shall be punishable with rigorous imprisonment minimum of fourteen years, but maximum imprisonment for life, and fine and on more than one occasion, then accused is liable for imprisonment for life and fine. If any public servant or a police officer is involved that public servant or police officer is punishable with imprisonment for life and fine. Section 370A deals with the exploitation of a trafficked person according to this section any person who knows that a minor has been trafficked that minor uses or engages in any type of sexual exploitation punishable under this section. The punishment for the offence committed under this section is punishable with rigorous imprisonment minimum of five
29 Pradhan Mantri Surakshit Matritva Yojana , Id.
30 Beti Bachao Beti Padhao Yojna Scheme Benefits and Success 2020 - PRADHAN MANTRI YOJANA, (last visited Dec. 30, 2021) , https://www.pradhanmantriyojana.co.in/beti-bachao-beti-padhao/
31 Beti Bachao Beti Padhao Yojana, Id.
32 Immoral Trafficking, Indian Institute Of Legal Studies, (last visited Dec 30, 2021). , https://www.Iilsindia.com/blogs/immoral-trafficking/
33 The Suppression of Immoral Traffic in Women and Children Act, 1956 Id.
34 The Indian Penal Code, 1860, Act No. 45, Acts of Parliament, 1860
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years, a maximum of seven years, and a fine. If the person who is trafficked is not minor, this offence is punishable with rigorous imprisonment minimum of three years, but a maximum of five years, and a fine.
The Suppression Of Immoral Traffic In Women And Children Act, 1956: -
President Assent provided on 30th December 1956. India signed the United Nations International Convention for the “Suppression of Women in Traffic in Persons and of the Exploitation in Others” in New York on 9th May 1950, based on this convention and for the prevention and suppressing of immoral traffic in women this Act came in to force. There are a total of 25 sections and one schedule and to make this Act more effective or more gender-neutral this Act has undergone two amendments in the years 1978 and 1986 respectively.35
Conclusion
Equal rights are provided by India's legal framework is not gender-biased. Nowadays awareness campaigns, workshops, and seminars, units like Doordarshan directorate of field publicity, press information bureau, have been played an important role to implement and intimate the provisions of the act among the citizens. Save the girl child campaign, pradhan Mantri Suraksha Matritva Yojana, Beti Bachao Beti Padhao Yojana, Mukhbir Yojana, etc are the initiatives that were taken and legislations like PC-PNDT Act, etc made by the government to deal with female foeticide. The suppression of immoral traffic in the women and children Act, of 1956 and other Indian penal provisions made to tackle immoral trafficking.
35 Saji Shebin the Immoral Traffic (Prevention) Act, 1956 - iPleaders, IPLEADERS (Nov., 4, 2020), https://blog.ipleader