DR.

RAM MANOHAR LOHIYA

NATIONAL LAW UNIVERSITY, LUCKNOW

ACADEMIC SESSION: 2014-15

CRIMINAL LAW-II : FINAL DRAFT

“CASE ANALYSIS : Tukaram and Another versus The State
of Maharashtra 1979 (2) SCC 143”

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 TABLE OF CONTENTS

INTRODUCTION ..................................................................................................................... 3

STATEMENT OF FACTS ........................................................................................................ 4

ISSUE(S) INVOLVED .............................................................................................................. 5

LAW ON THE POINT .............................................................................................................. 5

DECISION OF THE COURT ................................................................................................... 5

PRINCIPLE OF LAW LAID DOWN: THE RATIO ................................................................. 5

CASE ANALYSIS..................................................................................................................... 6

LATER DEVELOPMENTS .................................................................................................... 11

CONCLUSION ........................................................................................................................ 14

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 INTRODUCTION

Rape is a sordid reality in India; in all its gruesome manifestation, reflects society’s attitude
to treat women as subservient. The distress and the psychological damage caused to a victim
of rape destroys her aspirations in life, is unendurable and deplorable. The mindset of the
society adds fuel to her intolerance. The Delhi incident awakened the conscience of the
citizens and their solidarity compels the law makers to think about a change of law. “Law
should not sit limply; while those who defy it go free and those who seek its protection lose
hope”.

The criminal justice system in India is under serious strain. It is not because of dearth of
effective laws. The two major problems that have besieged the criminal justice system are the
huge pendency of criminal cases and the inordinate delay in disposal of criminal cases on the
one hand and the very low rate of conviction in cases relating to serious crimes. Low
conviction rate leads to loss of faith in the criminal justice system. The real reason for the
huge pendency and delay is not addressed by many committees constituted for this purpose.
In many cases, the institutional prejudices make the system ineffective and its impact is much
on the vulnerable sections of the community.

Certain judgments of the Apex Court reflect the mythology that prior experience on the part
of the victim of rape is a reasonable provocation to the perpetrators to commit this heinous
crime and absence of medical evidence to prove resistance has often been interpreted as
consent. However, there is a change in the approach of the judiciary in last decade.

The Mathura case,1an unfortunate decision of the Supreme Court, sacrificing the dignity and
human rights of women, led to public outcry, coupled with the intensification of pressure by
the legal fraternity and social organisations, paved the way to the 84th Report. The role
played by the legal fraternity by strongly responding against the judgment of the Supreme
Court was extraordinary. The response against the judgment in Mathura case was an eye
opener to the policy makers to make proper law to tackle with the indignity suffered by
women.

This project is a case comment upon the judgment of the Supreme Court in the same case of
Tukaram & Anr. v. State of Maharashtra (AIR 1979 SC 185), popularly known as the
Mathura rape case.

1
Tukaram & Anr. v. State of Maharashtra, AIR 1979 SC 185: 1978 CriLJ 1864: (1979) 2 SCC 143.

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 STATEMENT OF FACTS

Mathura was an orphan girl who lived with her brother, Gama. Both of them worked as
labourers. Mathura used to work at the house of a lady named, Nushi. During the course of
her visits to their house, Mathura developed an intimacy with Nushi’s nephew Ashok, who
was residing with the latter. They decided to get married. On March 26, 1972, Gama lodged a
complaint at police station Desai Gunj alleging that Mathura had been kidnapped by Nushi,
her husband Laxman and Ashok. The report was recorded by Head Constable Baburao.
Mathura and other three persons complained against were brought to the police station on his
instance. The statements were recorded. Gama presented the relevant document proving
Mathura’s age which was registered. Baburao then left for home.
When Mathura and others were leaving, the appellants asked Mathura to wait at the police
station and asked her companions to move out. When they did so, one of the accused Ganpat
took Mathura to a latrine in the police station, where he loosened her underwear and stared at
her private parts using a torch. He then dragged her to the rear of the police station and raped
her. Tukaram, the other accused, then came and fondled with her private parts. He could not
rape her owing to his highly intoxicated state.
The others grew suspicious finding lights turned off and entrance door being closed from
within. They went in calling for Mathura. Finally Mathura emerged and told the others about
the whole incident. Nushi took Mathura to a doctor to get her examined. The doctor told them
that they should first get an FIR registered.
Baburao was called back and he registered the FIR. Mathura was examined the next day. The
girl had no injury on her person. Her hymen revealed old ruptures. The vagina admitted two
fingers easily. There was no matting of the pubic hair. The age of the girl was estimated by
the doctor to be between 14 and 16 years. No traces of semen were found on her body,
though it was found in the clothes worn by both the girl and the accused.
The learned Sessions Judge found that there was no satisfactory evidence to prove that
Mathura was below 16 years of age on the date of the occurrence. He further held that she
was "a shocking liar" whose testimony "is riddled with falsehood and improbabilities". It was
finally concluded that the prosecution had failed to prove its case against the appellants. The
Bombay High Court reversed the judgment finding Ganpat guilty under Section 376 and
Tukaram under Section 354 of the Indian Penal Code. The two of them then came before the
Supreme Court in appeal against the High Court judgement.

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 ISSUE(S) INVOLVED

Whether the victim had been subjected to or was under any fear or compulsion such as would
justify an inference of any “passive submission”?

LAW ON THE POINT

 Section 354 of the Indian Penal Code (IPC) relating to “Assault or criminal force to
woman with intent to outrage her modesty”.
 Section 375 of the Indian Penal Code (IPC) relating to “Rape”.

DECISION OF THE COURT

The appeal was accepted. The judgement of High court was reversed and the conviction
recorded against as well as the sentences imposed upon the appellants by it were set aside.

PRINCIPLE OF LAW LAID DOWN: THE RATIO

For the proposition that the requisite consent was lacking in the present case, reliance on
behalf of the State can be placed only on clause Thirdly so that it would have to be shown
that the girl had been put in fear of death or hurt and that that was the reason for her consent.
To this aspect of the matter the High Court was perhaps alive when it talked of "passive
submission" but then in holding that the circumstances available in the present case make out
a case of fear on the part of the girl, it did not give a finding that such fear was shown to be
that of death or hurt, and in the absence of such a finding, the alleged fear would not vitiate
the consent. Further, for circumstantial evidence to be used in order to prove an ingredient of
an offence, it has to be such that it leads to no reasonable inference other than that of guilt,
We have already pointed out that the fear which clause Thirdly of section 375 speaks of is
negatived by the circumstance that the girl is said to have been taken away by Ganpat right
from amongst her near and dear ones at a point of time when they were, all leaving the police
station together and were crossing the entrance gate to emerge out of it. The circumstantial
evidence available, therefore, is not only capable of being construed in a way different from
that adopted by the High Court but actually derogates in no uncertain measure from the
inference drawn by it.

In view of what we have said above, we conclude that the sexual intercourse in question is
not proved to amount to rape and that no offence is brought home to Ganpat appellant.

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The only allegation found by the High Court to have been brought home to Tukaram
appellant is that he fondled the private parts of the girl after Ganpat had left her. The High
Court itself has taken note of the fact that in the first information report (Ex. 5) the girl had
made against Tukaram serious allegations on which she had gone back at the trial and the acts
covered by which she attributed in her deposition to Ganpat instead. Those allegations were
that Tukaram who had caught hold of her in the first instance, had taken her to the latrine in
the rear of the main building, had lit a torch and had stared at her private parts in the torch-
light. Now if the girl could alter her position in regard to these serious allegations at will,
where is the assurance that her word is truthful in relation to what she now says about
Tukaram? The High Court appears to have been influenced by the fact that Tukaram was
present at the police station when the incident took place and that he left it after the incident.
This circumstance, in our opinion, is not inculpatory and is cable of more explanations than
one. We do not, therefore, propose to take the girl at her word in relation to Tukaram
appellant and hold that the charge remains wholly unproved against him.

CASE ANALYSIS

The case under analysis was an extraordinary decision in stark violation of human rights of
women under the law and the Constitution. The Court provided no cogent analysis as to why
the factors which weighed with the High Court were insufficient to justify conviction for
rape. As per the judgment given by the Supreme Court, the main contention raised on behalf
of the appellants was that no direct evidence being available about the nature of the consent
of the girl to the alleged act of sexual intercourse, the same had to be inferred from the
available circumstances and that from those circumstances it could not be deduced that the
girl had been subjected to or was under any fear or compulsion such as would justify an
inference of any “passive submission”, and this contention appeared to the Hon’ble Court as
well- based. (para 14)
The Hon’ble Court relied upon the facts that no marks of injury were found on the person of
the girl after the incident to infer that the “alleged intercourse was a peaceful affair, and that
the story of a stiff resistance having been put up by the girl was all false.” What must be
noticed here is that the victim was an illiterate village orphaned tribal girl, who was there at a
police station involved in a complaint filed by her brother against her lover. People from such
backward classes of society even today, possess an innate fear for the policemen and this is a
case dating back to 1970s. The High Court very rightly observed that at the relevant time the

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girl was in the police station where she would feel helpless in the presence of the two
appellants who were persons in authority and whose advances she could hardly repel all by
herself and inferred that her submission to the act of sexual intercourse must be regarded as
the result of fear and, therefore, as no consent in the eye of law.
The Supreme Court held that this view of the High Court was flawed on the count that the
girl had stated during the cross-examination that when she was leaving the police station with
her brother, Ganpat had caught her by the arm and she had cried out. The Court held that the
cries and alarms were “a concoction on her part.” In furtherance, the Court said “If that be so,
it would be preposterous to suggest that although she was in the company of her brother…
she would be so overawed by the fact of appellants being persons in authority or the
circumstance that she was just emerging from a police station that she would make no
attempt at all to resist”. (para 15)
The Supreme Court evidently failed to acknowledge the state of circumstances victim was in
when the crime was committed upon her. The girl was in the police station in the “dead hour
of night” stuck amidst two men in authority. The High Court found it impossible to believe
that she might have taken initiative for intercourse. The fact remains that she was asked to
remain in the police station even after her statement was recorded and her friends and
relations were asked to leave. One may ask why? The fact again remains that Tukaram did
nothing whatsoever to rescue the girl from Ganpat. Why? The Court says in its narration of
facts, presumably based on the trial Court records, that Tukaram was intoxicated. But this is
not considered material either. Why? Again one may ask why were the lights put off and
doors shut?
It is indeed unreasonable of the Apex Court of the land to expect a young girl 14-16 years
old, when trapped by two policemen inside the police station, to successfully raise alarm for
help. Does it seriously expect the girl, a labourer, to put up such stiff resistance against well-
built policemen so as to have substantial marks of physical injury? Does the absence of such
marks necessarily imply absence of stiff resistance?
Even if we consider that the evidence of shouts for help and “stiff resistance” is all “a tissue
of lies” but how can the absence of shouts justify an easy inference of consensual intercourse
in a police station? In restoring the decision of the Sessions Judge, the Supreme Court
actually believed that Mathura had “invented” the story of rape, and even the confinement in
the police station in order “to sound virtuous” before Ashok. The Court believed that even
when her brother, her employer, and her lover were waiting outside the police station, a girl
of 14-16 years during those times could not let go of the opportunity of having sexual

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intercourse with two unknown policemen, and that too in the area adjoining the police station
latrine.
After it happened, she might as well have worn a scarlet letter on her chest. Such was the
stigma of rape in India then. She was brave to speak out and did what few women back then
did. She took her case to court.2
The relevant provision relating to rape considered by the Court was:

375. 'A man is said to commit "rape" who except in the case hereinafter excepted, has sexual
intercourse with a woman under circumstances falling under any of the five following
descriptions :

First.-Against her will.

Secondly.-Without her consent.

Thirdly.-With her consent, when her consent has been obtained by putting her in fear of
death, or of hurt.

Fourthly.-With her consent, when the man knows that he is not her husband, and that her
content is given because she believes that he is another man to whom she is or believes
herself to be lawfully married.

Fifthly.-With or without her consent, when she is under sixteen years of age.

Explanation.-Penetration is sufficient to constitute the sexual intercourse necessary to the

offence of rape.

Exception.-Sexual intercourse by a man with his own wife, the wife not being under fifteen
years of age, is not rape.'

The Supreme Court only focused on third component of the provision which applies when
rape is committed with the woman’s consent, when “her consent has been obtained by putting
her in fear of death or hurt”. But the second component of Section 375 is when rape occurs
without her consent. There is a clear difference in law, and common sense, between
‘submission’ and ‘consent’. Consent involves submission; but the converse is not necessarily
true. Nor is absence of resistance necessarily indicative of consent. It appears from the facts

2
Moni Basu, “The Girl whose Rape Changed a Country”, available at
<http://edition.cnn.com/interactive/2013/11/world/india-rape/> last accessed: 01/04/2015.

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as stated by the Court and its holdings that there was submission on the part of Mathura. The
finding on the crucial element of consent was missing in the judgement.

Going by the strict law, Ganpat was charged with rape on the third component of description
of rape. For that matter, the issue before the Court was simply whether the act was committed
with her consent, under fear of death or hurt. But still the question whether there was
‘consent’ was quite relevant; indeed, it was crucial. From the facts of the case, all that is
established is submission, and not consent, while the Court took an altogether different view.
Pre-marital sex with a man in those days was considered a social stigma for a woman.
Questions were thus, raised over Mathura’s character which had absolutely nothing to do
with the case. She was stigmatized for two things – for having pre-marital sex and for being a
rape victim. Even the Sessions Court Judge had made a shocking inference in regard to this.
He observed that Mathura was habituated to sexual intercourse and Ganpat was also no
novice. The stains of semen on his pyjama could be due to him having sexual intercourse
with persons other than Mathura and the seminal stains on Mathura could be similarly
accounted for. He attributed the fact of finding semen stains on her clothes to the fact that
“she was living with Ashok and very much in love with him”.

The Sessions Court Judge had given even other very disparaging remarks regarding the girl.
He called Mathura a “shocking liar” and stated that her statements “are riddled with
falsehood and improbabilities”. The Judge even went on to say she could not have admitted
that she had voluntarily surrendered her body to the constable because her lover, Ashok and
his aunt, Nushi were present in the crowd. In order to appear virtuous in front of them, she
invented the story of having been confined at the Police Station and raped.

The Supreme Court for lack of any finding relating to “fear of death or hurt” which could
vitiate consent, held Ganpat not guilty under Section 375. While the Honorable High Court
on the contrary had taken the opposite view. The fact that semen was found neither on the
pubic hair nor on the vaginal-smears taken from her person was considered to be of no
consequence by reason of the circumstance that the girl was examined by the lady doctor
about 20 hours after the event, and of the probability that she had taken a bath in the
meantime. The High Court proceeded to observe that although the learned Sessions Judge
was right in saying that there was a world of difference between sexual intercourse and rape,
he erred in appreciating the difference between consent and “passive submission”.

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In coming to the conclusion that the sexual intercourse in question was forcible and amounted
to rape, the High Court said that “Mere passive or helpless surrender of the body and its
resignation to the other’s lust induced by threats or fear cannot be equated with the desire or
will, nor can furnish an answer by the mere fact that the sexual act was not in opposition to
such desire or volition. On the other hand, taking advantage of the fact that Mathura was
involved in a complaint filed by her brother and that she was alone at the police station at the
dead hour of night, it is more probable that the initiative for satisfying the sexual desire must
have proceeded from the accused, and that victim Mathura must not have been a willing party
to the act of the sexual intercourse. Her subsequent conduct in making a statement
immediately to her relatives and to the members of the crowd leaves no manner of doubt that
she was subjected to forcible sexual intercourse.” The Nagpur bench of the Bombay High
Court, thus, set aside the judgment holding that that passive submission due to fear induced
by serious threats could not be construed as willing sexual intercourse. The High Court’s
judgment reflects forward thinking and social sensitivity.

While on the other hand, Ganpat was acquitted by the Supreme Court owing to the apparent
consent by Mathura. What is even more egregious in the decision is the rationale employed
by the Hon’ble Supreme Court for holding Tukaram not guilty. He was acquitted because the
court believed that Mathura’s words were inconsistent and that as she had lied about raising
an alarm, she must have lied about Tukaram molesting her also. This is certainly not the kind
of reasoning the Apex Court of the land is supposed to employ in deciding cases. The judges
should have adopted a more sensitive attitude towards the rape victim. The circumstances in
the case were held to be insufficient to hold the two men guilty and thus, the appeal was
allowed. The Hon’ble Supreme Court tragically failed to draw the line between “active
consent” and “passive submission”. The unwillingness cannot possibly be solely checked on
parameters of physical injuries as was done by the Court. The most disappointing part in
judgment is that the Supreme Court gave such a decision when on the same set of facts, the
High Court in a well-reasoned judgment had held the two policemen guilty.

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 LATER DEVELOPMENTS

The unfortunate decision of the Supreme Court in Mathura rape case led to four law teachers
writing an Open Letter to the Chief Justice of India criticising the judgment. The Open Letter
generated nationwide protests from women's organisations and different sections of the
Indian society. Their collective demand was for reform of the law on rape. The Union
Government responded to the public campaign and referred the matter of reforming rape laws
to the Law Commission. The Law Commission sent its 84th Report on “Rape and Allied
Offences; Some Questions of Substantive Law, procedure and Evidence” to the Government
in 1980.

In the 84th report, the Law Commission pointed out that the victim needs empathy and safety
and a sense of reassurance. The report considered the 42nd Law Commission
recommendations, for example, changing the definition of rape, incorporating custodial rape
as a specific offence, etc. The major concern of the Report was defining the term “consent”,
since the nuances of consent are important in deciding rape cases. The 84th Law Commission
had suggested adding an explanation to Section 375 i.e “A mere act of helpless resignation in
the face of inevitable compulsion, acquiescence, non resistance and passive giving in when
volitional faculty is either clouded by fear or vitiated by duress cannot be deemed to be
consent.” However, this was not materialised. Hence, the Commission suggested to add “free
and voluntary consent”.

When the Criminal Law Amendment Bill, 1980 was placed in Parliament, the same was
referred to the joint committee of Parliament; the committee did not accept the expanded
concept of consent. But in the Act the punishment for rape was increased to a term of ten
years to life with a mandatory minimum requirement of 7 years. The judge can impose a
lesser punishment than the minimum prescribed with adequate and special reasons. But the
recommendation to add Section 114-A in the Indian Evidence Act, 1832, the presumption of
guilt of the accused if the victim in her statement admits that she did not consent for the
sexual intercourse, was accepted and inserted in the Criminal Law (Amendment) Act, 1983.
Since the presumption under Section 114-A is rebuttable, the non insertion of the explanation
to Section 375 or adding of free and voluntary consent in the section makes no change from
the earlier provision. The Criminal Law (Amendment) Act, 1983, amended Sections 375 and
376 and inserted Sections 376-A, 376-B, 376-C and 376-D. Another important addition was
that of Section 228A in IPC relating to disclosure of identity of the victim of certain offences,

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etc. The Government of India directed the Law Commission to submit a report for revising
IPC. The Government of India appointed a Committee on Reforms of the Criminal Justice
System in the year 2000 to examine the fundamental principles of criminal jurisprudence, to
examine whether there is a need to amend the substantive criminal law and procedural law in
tune with the demand of the time and the need of the society. The considered opinion of the
Committee to the Supreme Court was that such a wider interpretation to the definition of rape
is not reasonable. The Committee therefore recommended that other forms of forcible
penetration including penile/oral, penile/anal, object or finger/vaginal and object or
finger/anal should be made a separate offence prescribing punishment broadly on the lines of
Section 376 IPC. The Committee also discussed the scope of granting death penalty to rape.
After long deliberations, the Committee did not pursue with the death penalty in view of the
interest of the victim. The Committee recommended sentence of imprisonment for life
without commutation or remission.

The Criminal Law Amendment Bill, 2003, was introduced in the Rajya Sabha after the
submission of the Report of the Committee on Reforms of the Criminal Justice System, 2003.
The Bill did not contain provision for amendment of rape laws, but substantial amendments
in the procedural law were proposed by the Bill. It contained provisions for enhancement of
punishment for perjury, introducing plea bargaining, amendment in section 195 IPC. The
Criminal Law (Amendment) Act, 2005 was passed on 11-1-2006.

After the unfortunate Delhi rape incident, for almost two months, Criminal Law Ordinance
was in force which was a significant period as for that time period the population in India was
governed by gender neutral laws relating to sexual offences. When the Criminal Law
Amendment Act 2013 came in force, the laws went back to being gender-specific. Some
significant changes were introduced though. The definition of the word “Rape” has been
explicitly stated so as to make it more precise under Section 375, in view of Delhi Gang Rape
incident. Further, inclusion of sixth and seventh description under the Section holds a lot of
significance as a woman may not be mature enough to give her consent below 18 years of age
or may not be able to communicate her consent to sexual activity due to her physical or
mental disability respectively. It is correct not to consider consent to sexual activity just on
the fact that she has not physically resisted to do the same, as provided under Explanation 2
of the Section, since a person, looking at the circumstance wherein she could not escape the
situation or has a reason to believe that such resistance would end in dismal, may not resist to
the unlawful conduct of the other person. Further, the punishment for rape has been extended

12
to the members of the armed forces 3 , relatives, guardian or teacher of, or a person in a
position of trust or authority towards the women4. In addition, relief for rape committed on
women suffering from physical and mental disability 5 as well as during communal or
sectarian violence6 adds to the scope of IPC. Section 376, clause (2), sub-clause (m) and (n)
have been added in the light of the above mentioned case, wherein the internal body and
organs of the prosecutrix were grievously harmed during rape repeatedly by the six people
accused.

The Criminal Law Amendment Act, 2013 has further incorporated punishment for causing
death or resulting in persistent vegetative state of victim7 which could be extended to even
death, which may serve as a deterrent for such crimes in future. It also raises liability on
husband and on the persons which enjoy a position of authority, apart from public servant or
superintendent of jail, remand house, etc. which was only earlier included in Sections 376B
and 376C respectively. In addition, punishment for gang rape, defined under Section 376D,
has been extended to a minimum of 20 years of imprisonment, from the earlier 10 years for
the same and punishment for repeat offenders has also been inserted. In addition, inclusion of
Sections 354A, 354B, 354C, 354D, 326A and 326B imposes huge liability in cases of sexual
harassment, assault or criminal force with intent to disrobe, voyeurism, stalking, acid attack
or attempt to acid attack respectively. Section 354B holds a great importance in rural areas
wherein many cases of disrobing a woman have been reported in the past. Also, the scope of
Section 354 is wide by incorporating those consents which a woman gives but not to
disseminate those captured photos to the third person. Section 354D quashes the nexus
between crime and technology by imposing a criminal liability on person monitoring the use
by a women of the Internet, email or any other form of electronic communication, and raises
liability if the same offence is committed twice or subsequent times. Further, the Act extends
the punishment for rape and sexual assault as an account of breach of trust on the part of
public officials and also adds to punishment for those who disobey directions under the law,
defined under Section 166A and 166B. For securing the modesty of the women and thereby
increasing the status of women in society, the punishment for not adhering to the above
provision has been raised to a maximum of 5 years imprisonment.

3
Indian Penal Code, 1860, S.376(2)(c).
4
Indian Penal Code, 1860, S.376(2)(f).
5
Indian Penal Code, 1860, S.376(2)(l).
6
Indian Penal Code, 1860, S.376(2)(g).
7
Indian Penal Code, 1860, S.376A.

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 CONCLUSION

The Supreme Court in the case Tukaram & Anr. v. State of Maharashtra evidently enough,
tragically failed to distinguish between “active consent” and “passive submission”. Such
submission due to fear cannot imply consent. It is the very point where the reasoning of the
Supreme Court faltered, thereby resulting in shocking miscarriage of justice. Consent is a
concept which is capable of rendering the immoral moral, the painful pleasurable, and the
reprehensible commendable. It plays an invaluable role in transforming the illegal into the
legal.
The difference between consent and submission is misunderstood in many cases. All consents
are submission but all submissions are not consent. Submission may be by fear, coercion, and
threat or like factors. Inability of the victim to get out of the act of the perpetrators is given
paramount importance while considering the concept of consent in sexual offences. But like it
happened in the present case, unwillingness on the part of the victim i.e., the lack of consent
should not be determined solely on the parameters of physical injuries. This is where the
problem arises.
Though the case led to the radical amendments in rape laws in the Indian Penal Code making
them more victim-friendly, the decision of the Supreme Court in the case was indeed a big
blot on the face of Indian Judiciary. The Court should have adopted a more sensitive attitude
towards the victim. There is not a single word in the judgment condemning the very act of
calling Mathura, and detaining her at the police station which was in gross violation of the
law. Nor is there a single word condemning the use of the police station as a theatre of rape or
submission to sexual intercourse. There is no direction to the administration to follow the
law. There are no strictures of any kind.
The Court unfortunately enough, gave no consideration whatsoever to the socio-economic
status, the lack of knowledge of legal rights, the age of victim, lack of access to legal
services, and the fear complex which haunts the poor and the exploited in Indian police
stations and that too an orphaned illiterate tribal girl of fourteen or sixteen.

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