INCEST: A BLISSFUL OR MISERABLE OMISSION IN THE INDIAN PENAL CODE OF 1860?

Author(s): K. I. Vibhute
Source: Journal of the Indian Law Institute, Vol. 44, No. 1 (January-March 2002), pp. 85-95
Published by: Indian Law Institute
Stable URL: https://www.jstor.org/stable/43951795
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NOTES AND COMMENTS

INCEST : A BLISSFUL OR MISERABLE OMISSION

IN THE INDIAN PENAL CODE OF 1860?

I Introduction

PENAL LAW of a state, depending upon her criminal policy and preval
sexual mores, forbids a set of consensual as well as non-consensual
sexual acts. Such a prohibition, generally, is premised primarily either on
the absence of consent, real or presumed, of victim of sexual assault (e.g.
rape unnatural offences) or moral sentiments of the society associated
therewith (e.g. adultery & incest).
The Indian Penal Code, 1860 (hereinafter IPC), which was shaped
between 1834 and 1860 and influenced, to a great extent, by the then
common law criminal & penal policies and sexual mores , criminalizes
rape; buggery with animals, and consensual as well as non-consensual
unnatural sexual gratification.1 It does not, plausibly owing to its
unfamiliarity with the then prevailing English criminal law system,2
include incest - a consensual heterosexual intercourse between persons
within a specified degree of consanguinity - in its catalogue of specific
offences.3
However, the post-IPC criminal law system in the UK witnessed the
criminalization of incest. The punishment of Incest Act 1908, with a view
to protecting 'children from the vice' and to ensuring 'social moral
purity', made sexual intercourse between persons within a specified
degree of consanguinity a misdemeanour, punishable on conviction with
penal servitude for between three and seven years, or with imprisonment
for any term not exceeding two years. Incest by a man with a girl under
thirteen years of age, however, was punishable as an offence òf carnal
knowledge which, under the Criminal Law Amendment Act 1885, was a

1. See, ss. 375-377 IPC.

2. During the formative period (1834-1860) of the IPC, incest was unknown to the
British criminal law system. It was merely a sin punished by ecclesiastical courts. It
was made punishable by the Punishment of Incest Act 1 908. For its history, see Victor
Bailey & Sheila Blackburn, "The Punishment of Incest Act 1908 : A Case Study of
Law Creation" (1979) CrLR 708 and Sybil Wolfram, "Eugenics and the Punishment
of Incest Act 1908 (1983) CrLR 308.
3. Nevertheless, a consensual as well as non-consensual incestuous relationship
can, to some extent, be brought within it's ambit. For details, see "Incest and the
Indian Penal Code : Legislative Framework" infra.

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86 JOURNAL OF THE INDIAN LA W INSTITUTE [Vol. 44 : 1

felony punishable with penal servitude for life.

The 1908 Act was repealed by the Sexual Offences Act 1
under the 1956 Act, is an offence punishable with seven years'
imprisonment (two years for an attempt) for a man to have sexual
intercourse with a woman whom he knows to be his grand-daughter,
daughter, sister (including half-sister) or mother, and for a woman (of the
age of sixteen or over) to 'permit' her grandfather, father, brother
(including half-brother) or son to have sexual intercourse with her.
However, the post-IPC criminalisation of incest in the UK and in
other jurisdictions did not show any impact on the criminal and penal
policies pertaining to incest in India. In the recent past, however, the
criminalisation of incest has been perceived as an unauthorised state
intervention in individuals' freedom of choice and action in sexual
enjoyment.
Against this background, the present paper endeavours to revisit
rationale of, and reservations for, the (de)criminalisation of incest as a
specific offence and to make a plea for the criminalisation of incest as a
distinct offence in India.

II Criminalisation of incest: rationale and reservations

Recently, in the backdrop of the perceived operational orbits of

criminal law and of moral law, both the premises, namely, the protection
of minors from the vice of incest and the eugenic arguments, of the Act
of 1908 have received attention.
Abolitionists of incest dismiss the eugenic argument. Their prominent
arguments are: Firstly , the existing criminal law dealing with unlawful
sexual intercourse with minors is adequate to protect them from sexual
assaults. Secondly there is insufficient evidence to clearly establish that
incest is dysgenic. Thirdly , incestuous relationship does not invariably
lead to pregnancies and therefore the eugenic risk, if any, exists for
individuals and not for the whole population. Fourthly , even if there is
some (certain) risk of genetic damage in the offspring of incestuous
unions, incest does not deserve to be an offence for, people rarely indulge
in incest to produce children. Fifthly , it is not the business of criminal law
to seek to prevent injury to the children of individual liaisons even though
there is considerable risk of genetic damage in incestuous births. The
law s apathy to some non-family relationships carrying eugenic risks
minimises rationality of the eugenic argument. Sixthly , the Act of 1908
was not passed for eugenic reasons.4

4. See, Victor Bailey & Sarah McCabe, "Reforming the Law of Incest" (1979) Cr
LR 749 (758); Jennifer Temkin, "Do We Need the Crime of Incest?" (1991)44 CLP
185; Sybil Wolfram, "Eugenics and the Punishment of Incest Act 1908" supra note
2, and Richard Card, "Sexual Relations with Minors" (1975) Cr LR 370.

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 2002] NOTES AND COMMENTS 87

Critiques, however, become mo

law to prohibit incestuous rela
Drawing support from the Wo
functional orbits of criminal law
applying the discourse to incest,
incest amounts to an improper u
intervention in the individuals
privacy. It is, they assert, not the
the private lives of citizens and t
behaviour by going beyond its (cr
invariably relied heavily upon the
Committee:6
[T]he law's function, as we see
decency, to protect the citizens fr
and to provide sufficient saf
corruption of others, particu
vulnerable because they are y
inexperienced, or in a state of sp
dependence.
It is not, in our view, the function of criminal law to intervene in
the private lives of citizens, or to seek to enforce any particular
pattern of behaviour, further than is necessary to carry out the
purposes we have outlined.

Incest between consenting adults committed in private, does not, in

the opinion of critiques, fit into the theoretical as well as operational
paradigm of criminal law as it is neither 'offensive or injurious' nor does
it involve 'exploitation and corruption' of a 'specially vulnerable', 'weak'
or 'inexperienced' individual. None of the parties, therefore, they argue,
need protection of criminal law. Such a legislative restriction, in their
perception, amounts to an unauthorised encroachment upon sexual freedom
and an unjustifiable interference with the privacy of the parties involved
in incestuous act. Believing that the Wolfenden Committee's approach to
homosexuality can be applied to incest between two consenting adults,
they suggest that incest, notwithstanding the strong social revulsion

5. See, Antony Grey, "Sexual Law Reforms Society Working Party Report" (1975)
CrLR 321; B. Hogan, "On Modernising the Law of Sexual Offences" in Glazebrook
(ed.), Reshaping the Criminal Law 188 (1978); Victor Bailey & Sarah McCabe,
Reforming the Law of Incest" ibid.' D. J. West, "Thoughts on Sex Law Reform" in
R.G. Hood (ed.), Crime, Criminology and Public Policy 470 (1974), and Rodney
Brazier, "Reform of Sexual Offences" (1975) CrLR 421.
6. HMSO, Report of the Committee on Homosexual Offences and Prostitution
(Cmnd. 247, 1957) 9-10 paras 13-14. For critique of the Wolfenden Report see Devlin,
The Enforcement of Morals (Oxford, 1 965). See also, H.L.A. Hart, Law, Liberty, and
Morality (Oxford, 1968).

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88 JOURNAL OF THE INDIAN LAW INSTITUTE [Vol. 44 : I

against it, should be legalised.

However, one may, in equally assertive tone, argue that
sexual behaviour between 'two consenting adults in priv
homosexuality, has a different pragmatic facet and therefo
incest' should not be equated with 'consensual homosexu
started in younger age may continue into adulthood. Most
who are abused during their childhood, find it difficul
themselves from such relationship owing to their dependen
economical or physical- on their families. Further, thé abus
to all the familial, discreet, exploitative and manipulative d
command to 'exploit' the abused ones to continue the
incestuous relationship. In such a situation it would o
misleading, rather fallacious, to ignore the incestuous r
saying merely that it is a 'consensual' sexual liaison and it is
the law's business.
Further, it would be very unrealistic and misleading to assume that a
consensual incestuous behaviour between two consenting adults, unlike
in a consensual adult-homosexuality, does not cause 'harm'. 'Harm'
resulting from adult-incest may be to the incest-births, to the parties
themselves (particularly psychological and emotional) and to other
members of the family as well as to the family institution. 'Incest can, and
often does', the Scottish Law Commission opines, 'cause psychological
harm not only to the actual participants but to the other members of the
family, either at the time of the incident or later'.8 Incest not only
undermines the family institution but also ultimately causes 'injury' to it.
A scholar, making a strong plea for incest as a specific offence, rightly
observed:

For those who are dedicated to the institution of the family and
the maintenance of the family life, incest must remain an anathema.
It is destructive both to those who participate in it and to those
who are directly involved.... It is vital to the actual security and
sense of security of all members of that unit that within it certain
boundaries are set and preserved. Of these boundaries the sexual
one is the most fundamental. Women living or in contact with
fathers and brothers need to know that sex between them is not
and never will be on the agenda.... It is fitting therefore for the
criminal law to place its weight solidly behind that boundary and
endeavour thereby to protect the individual's safety in the family
situation. An incest law must seek both to protect the family and
the individual from the family.9

7. Jennifer Temkin, "Do We Need the Crime of Incest?" supra note 4 at 187
8. Scottish Law Commission, Report on the Law of Incest in Scotland (Cmnd.
8422, 1981) para 3.10.
9. Supra note 7 at 187-188.

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 2002] NOTES AND COMMENTS 89

Believing that the criminalisation o

Wolfenden Committee's operation
Criminal Law Revision Committee (U
argue that incest not only invariably
youth but also inflicts physical, men
victims as well as upon 'others'.10
retention of incest as a distinct offence can be outlined as under:

1 . In changing, often exploitative, attitudes towards sexuality and

sexual relationships, criminalisation of incest becomes imminent
as it causes harm to the persons associated therewith as well as
to 'others'.

2. Criminal law must convey that it attaches significance to the

sexual intercourse between blood relatives with a view to
preventing 'harm' to others.
3. The existence of sexual relation within family arouses horror
and disgust.
4. It is befitting for the criminal law to place its weight solidly to
protect the family and the individuals in the family as well as
solidarity within the family.
5. The breach of trust, the destruction of familial boundaries, the
genetic risks, do justify the criminalisation of incest.
6. The destructive nature of incest and its gravity has to be conveyed
by the existence of a specific crime.
7 . The social meaning of non-criminalisation of incestuous conduct
after a certain age would be an indication that our society
tolerates it and is open to such conduct.
8. Incest imposes a relatively slight reservation on liberty. It does
not exclude the right to have intercourse altogether but only
with close relatives.

A scholar, 'slightly differently' putting the reasons given by the

Scottish Law Commission for retaining the crime of incest, observed: 1 1
The home can be a dangerous place and the family an oppressive
institution. Within both, parents and some other relatives may

10. See, HMSO, The Criminal Law Revision Committee- Fifteenth Report-Sexual
Offences , (Cmnd. 9213, 1984); Scottish Law Commission, Report on the Law of
Incest in Scotland , supra note 8 and Government of Canada, Sexual Offences against
Children in Canada: Summary of the Report of the Committee on Sexual Offences
Against Children and Youths (1984). See also, West, "Thoughts oil Sex Law Reform"
in R. Hood (ed.), Crime, Criminology and Public Policy supra note 5, and Smith and
Hogan, Criminal Law 467 (Butterworths. 1992Ì.
1 1 . Supra note 7 at 199.

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90 JOURNAL OF THE INDIAN LA W INSTITUTE [Vol. 44 : 1

enjoy a power, which they do not have in the outside wor

temptation to abuse it is always there. The unique opportun
abuse, which the family affords, and the devastating conse
for victims, which this may, entail argue the case for a se
incest offence. Such a crime sets the seal of disapproval o
conduct and signals to society the restraints on power
family that the State will impose.
It is interesting to note that neither the functional paradigm
law perceived by the Wolfenden Committee nor the argumen
thereon have hardly influenced legislative framework
Wolfenden Committee Acts dealing with sexual offen
homosexuality, in the UK and in Scotland. The British Parliam
gave effect, through the Sexual Offences Act 1967, to
recommendations of the Wolfenden Committee by dec
homosexuality between two consenting adults did not th
decriminalise incest even between two consenting adults in
Criminal Law Revision Committee, while suggesting reform
of incest, was also not impressed by the plea for the decrimi
incest between two consenting adults.12
A comparative evaluation, in the backdrop of the Parliam
response to the call for decriminalisation of incest in Britai
positive legislative response to the criminalisation of inc
jurisdictions,13 of the above mentioned arguments advan
against the criminalisation of incest as a distinct offence, in
submission, unequivocally indicates that criminal law has
claim even to criminalise incest between two consenting adul
unmistakably, within the purview of criminal law to protect
as well as major ones and family institution from incestuou

Ill Incest and the Indian Penal Code : legislative frame

Incest, as a specific offence, is unknown to the Indian Pe

However, an incestuous relationship, consensual as well as non
between a girl below sixteen years and her close relative, lik
other man, can be brought within the purview of 'rape' as de
375 of the Penal Code. 'Consent' of the girl does not absolve
his criminal responsibility, as IPC does not treat it a valid c
375, Sixthly , says:
Rape. - A man is said to commit 'rape' who, except in t
hereinafter excepted, has sexual intercourse with a woman
circumstances falling under any of the six following descripti

12. See, the Sexual Offences Act 1956 and the Incest and Related
(Scotland) Act 1986.

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 2002] NOTES AND COMMENTS 91

Sixthly - With or without her c

years of age.
Explanation'. Penetration is suff
intercourse necessary to the of
Similarly, a consensual sexual in
(with her consent but without th
and her relative, married or unmarr
within the ambit of IPC as it
consensual sexual link between a married or an unmarried man and his
unmarried female relative or a divorcee or a widow does not come within
the ambit of IPC as it does not fit into the definitional orbit of 'adultery'.
An incestuous relationship, in the absence of a distinct offence, thus,
can be brought indirectly within the purview of IPC only if it amounts to
'child-rape' (when the victim of incest is below 16 years)15 or 'adultery'
(when the willing female partner to incestuous sexual intercourse is
married to another). IPC, unlike the Sexual Offences Act 1956, thus, does
not forbid sexual intercourse within consanguinity unless it amounts to
'incest-child- rape' or 'incest-adultery'. It, thereby, does not make any
distinction between an incestuous relative and a stranger who establishes
sexual liaison with either an under-aged girl (with or without her consent)
or a consenting adult woman [unmarried, married (but without consent of
her husband), divorcee or widow].
It is needless to mention that the 'child-rape' -'sexual abuse outside
family' - is obviously different from the 'incest-child-rape' - 'sexual
abuse within family'. The latter is not merely linked with exploitation of
the (victim) child by a person because of his position of authority and
trust but it also is the abuse of the relationship of trust and dependency.
Such a peculiar relationship gives an ample opportunity to the person to

13. For example, see the Incest and Related Offences (Scotland) Act 1986 and the
Crimes Ordinance Fart VI of Hong Kong. Criminal laws of Sweden, Australia,
Germany and Italy have long back-criminalised incest. See also, K. I. Vibhute, "Incest
and the Law in Malaysia: Some Reflections on the Existing and Proposed Criminal
Law" Malayan Law Journal lxxxi (1998).
14. Sec. 497 reads: "Whoever has sexual intercourse with a person who is and
whom he knows or has reason to believe to be the wife of another man, without the
consent or connivance of that man, such sexual intercourse not amounting to the
offence of rape, is guilty of the offence of adultery, and shall be punished with
imprisonment of either description for a term which may extend to five years, or with
fine, or with both. In such case the wife shall not be punishable as an abettor." For
comments see K. I. Vibhute, "Adultery and the Indian Penal Code: Need for a Gender
Equality Perspective" SCC (forthcoming).
15. For example, see Gajrajsingh v. State ofM. P., 2000 CrLJ 3765; Pooran Ram
v. State of Rajasthan, . 2001 CrLJ 91 and Mangoo Khan v. State of Rajasthan , 2001
CrLJ 3001.

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92 JOURNAL OF THE INDIAN LA W INSTITUTE [Vol. 44 : 1

'persuade', by resorting to his familial exploitative and press

his victim child for the sexual relationship and to perpet
'incest-child-rape', compared to the 'child-rape', invariably
continuous sexual exploitation, wherein the child (even after
statutory consent) does not have any other alternative except
a variety of pressures from the perpetrator and to suffer in
In fact, such an abuse of relationship of trust and dependen
to be treated as an 'aggravating factor' while quantifying punit
against the perpetrators. But provisions of sec. 375 r.w. 376,
mandate such judicial discretion. However, the fifteenth Law
of India, which was asked by the Supreme Court of India to
rape laws in India, in its 172nd Report (2000), 17 exhibiti
concern for, and sensitivity to, sexual violence against child
their own families, not only, inter alia , suggested that 'sex
(replacing the term 'rape' and widening its scope by includin
well as unnatural 'penetration') on a child (below 16) (as w
woman) by her 'near relative' or by any other person being 'i
of trust or authority' towards his 'victim' be brought within
the Penal Code but it (such a sexual assault) also be met w
penalty. The recommended proposal, inter alia , reads as und
...If the sexual assault is committed by a person in a posi
trust or authority towards the person assaulted or by
relative of the person assaulted, he/she shall be punished
rigorous imprisonment for a term which shall not be less t
years but which may extend to life imprisonment and sh
be liable to fine.

The proposal for reform, if accepted by the legislature, will evidently

take into its fold consensual sexual assaults within family on trusting
'young persons' (i.e. incest-child-rape) as well as non-consensual
interfamilial sexual assaults (i.e. rape) on members of the family. The
recommended clause, however, obviously will not take into its ambit a
consensual incestuous act between two consenting 'near relatives'.
Secondly, the recommended clause seems to be vague as it does not
stipulate categories of the so-called 'near relatives' for the purpose of
sexual assaults.

16. For example, see Sudesh Jhaku v. K.C.J. , 1998 CrLJ 2428 (Delhi). See also,
K. 1. Vibhute, "Sexual Violence against Children and the Indian Penal Code: Proposals
for Reform" 22 DLR (2000) 21- 43.
17. Law Commission of India, One Hundred and Seventy Second Report on Review
of Rape Laws (Government of India, 2000).
18. Ibid., para. 3.2.3.

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 2002] NOTES AND COMMENTS 93

IV Incest: is its omission from the Indian Penal

Code a bliss or misery?
IPC, though it is premised on, and influenced by, the then prevalen
common law rules, does not, unlike the Sexual Offences Act 1956 and i
predecessor, the Punishment of Incest Act 1908, prohibit sex
intercourse, except the 'incest-adultery' between two consenting adul
close relatives. The omission, as stated earlier, may plausibly be attribut
to the unfamiliarity of incest as an offence to the British criminal la
system when IPC was shaped during the early nineteenth century. Oth
plausible reason for the non-criminalisation of incest in India could be t
fact that law of marriages, influenced by religious tenets of the give
community, invariably recognises customary marriages, and some of t
communities in India, as a custom, do permit marriages between som
customarily identified categories of relatives. Nevertheless, almost all
marriage laws treat incestuous relationship outside wedlock as one of t
grounds for dissolving marriage.
However, it would be fallacious to believe that the drafters of the
Indian Penal Code, by not criminalising incest in a secular penal la
believed that the then prevalent sexual mores in British India recogn
the so-called 'sexual autonomy within family'. The idea of the crimalisat
of incest, as its history discloses, did not strike them at all either at t
time of shaping the IPC or subsequent to the enactment of the 1908
in England.
Can, therefore, the non-criminalisation of incest in the Indian Pena
Code be assumed a mere accidental omission? Or, can it, in the backdr
of the absence of any legislative move even after the post- 1908 Act
criminalise incest in the British India and the lack of similar posit
legislative response in the independent India during the post-Wolfend
Committee Report as well as the post-Sexual Offences Act 1956 era, b
treated as an intentional omission? Both the questions can be delved i
rigorously with equally convincing arguments and logic.
However, the present author, in the backdrop of the acknowledge
immeasurable physical, psychological, emotional and heredita
consequences of incestuous relationship, wishes to address to the thre
prominent issues, namely: (i) Is the existing legal framework dealing w
incest-child-rape and 'incest-adultery' adequate and effective to comb
incestuous sexual behaviour in India? (ii) Is it desirable in India t
continue with the non-criminalisation of incest as a distinct offence? a
(iii) Is such an omission - accidental or intentional -, in the IPC a bliss
a misery?
A glance at the provisions of the Sexual Offences Act 1956 dealing
with incest and at that of the IPC dealing with only 4 incest-child-rape '
and 'incest-adultery' unmistakably reveals that the Indian Penal Code is

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94 JOURNAL OF THE INDIAN LAW INSTITUTE [Vol. 44 : 1

not effective to prevent incestuous sexual behaviour

address itself to the incestuous sexual behaviour between t
adults. It only takes to task, though indirectly, the male p
to the child victim for his sexual liaison not for committin
committing (statutory) rape. The Indian society, which i
'conservative sexual mores' , generally inculcates into fem
for the sake of the reputation of the family, to be merely
even if they have been victims of sexual exploitation wit
Further, invariably the 'exploiter' and his whole family
'victim' should be silenced even if she exhibits the 'coura
the sexual liaison. And in case of 'incest-adultery' both
particularly the female partner, for a variety of reasons-
or dependency-will be silent till somebody else knows it. T
in-built or manipulated, familial or social pressures become
when it comes to the coercive sexual exploitation (of a m
woman) by somebody from 'outside the family'. Obvi
provisions of the IPC seem to be less effective to combat
who, either did not have courage to stop the 'exploiter' or
to do so, had to unfortunately commit suicide to relieve t
the disgusting sexual exploitation within the family.19
In the light of preceding para, responses to the remain
(i.e. is it desirable in India to continue with the non-crim
incest as a distinct offence? and is such an omission - accidental or
intentional - in the IPC a bliss or a misery?) outlined above are bound to
be in the negative. In other words, it is not desirable in India to continue
with the non-criminalisation of incest as a distinct offence and such a
continuation would not, in the present submission, be bliss but a misery.
It is, therefore, a high time to criminalise incest as a distinct offence.
The Indian Parliament may take clues from the wordings of sections 10
and 11 of the Sexual Offences Act 1956 while shaping the proposed
criminalisation of incest in India. While criminalising incest even between
two consenting adults in private, the Indian Parliament, like the British
Parliament and the Scottish Parliament, should not unnecessarily be
influenced by the objections premised on the sexual freedom of choice
and action of consenting adults, if it is convinced (and there are, as
discussed above, a number of sound theoretical as well as pragmatic
justifications for the criminalisation of incest) that incestuous relationship
is genetically and psychologically delirious not only to the partners of the
sexual act but also to others as well as to the family institution.

19. It is reported that during 1997 only, 1 87 women (within the age group of below
14 and 44) had committed suicide for their physical abuse (rape, incest etc.). See,
National Crime Records Bureau, Ministry of Home Affairs, Government of India,
Accidental Deaths & Suicides in India ¡997 (1999) at 122.

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 20021 NOTES AND COMMENTS 95

An inevitable implication of the

obviously, be that sexual intercours
of family members would be an off
such a sexual link. However, the Ind
personal laws in vogue in India reco
have to take a pause before identify
purpose of incest. However, it m
controversial pairs for incest. The
to start with could be: grandfather
brother & sister, and son & mother
should obviously commensurate wit
social and moral sentiments to the p
public gravity of resentment, indi
through their parliamentarians, there
in quantifying the punishment for
latest proposal of the creation of a
'trust or authority' deserves a ser
combat interfamilial sexual assau
position of trust and authority.

V Conclusion

Incest, as a distinct offence, even though it arguably amounts to th

enforcement of moral principles through criminal law, fits into t
theoretical as well as functional paradigm of criminal law of a civilise
society. It also fits into the 'principled core of criminal law'.20
However, the offence is unknown to the Indian Penal Code of 1860
Nevertheless, some of its provisions can be invoked to tackle incestuo
relationship only if it amounts to 'incest-child-rape' or 'incest-adulter
It leaves other consensual incestuous sexual acts untouched. Recalli
the increasing incidences of incest and its serious, rather disgustin
consequences on the social system, and inadequacy of the existin
provisions of the Indian Penal Code to combat sexual exploitation with
the family, the criminalisation of incest as a distinct offence in India
becomes inevitable. The Indian Parliament, with a view to doing away t
hitherto miserable omission of incest, may draw inspiration from, an
rely upon, the Sexual Offences Act of 1956 and the Law Commission's
proposal made in its 172nd Report while shaping the penal law of ince
in India.
K. L Vibhute

20. Andrew Ashworth, "Is the Criminal Law a Lost Cause?" 1 16 LOR 225 (2000Ì.
* Professor, Post-Graduate Department of Law, University of Pune.

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