1

SNDT WOMEN’S UNIVERSITY OF LAW

IIND YEAR B.B.A L LB
SEMESTER IV

NAME: PREETI KUMARI SHAH

CLASS: BBA LLB

ROLL NO.: 25

SUBJECT: PRACTICAL TRAINING D

PROJECT: CASE LAW

DATE OF SUMISSION TEACHER’S NAME

13/03/2024 MS. JANKI MISHRA
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Acknowledgement
I would like to express my sincere gratitude and appreciation to Ms. Janaki Mishra for their
invaluable guidance, support, and mentorship in the execution of the project focused on the
case law. This project has been a remarkable learning experience, Ms. Janaki has not only
provided the necessary academic and research direction but has also inspired and encouraged
me throughout the project. Their dedication to fostering a deep understanding of this critical
subject matter and their unwavering commitment to social justice issues have been truly
inspiring.

The knowledge, insights, and analytical skills that I have gained during this project under Ms.
Janaki's guidance are invaluable, and they have broadened my perspective on the challenges
and complexities surrounding Indian rape laws. I am deeply grateful for the opportunity to
work on this project under her mentorship, and I look forward to applying the knowledge and
insights gained to contribute positively to the discourse on improving and strengthening rape
laws in India.

Once again, thank you, for your unwavering support, and for empowering me with the skills
and knowledge necessary to engage meaningfully in discussions on this important subject
matter. Your guidance will undoubtedly have a lasting impact on my academic and personal
development.

Thank you !
Preeti. K. Shah
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Index
S.R CONTENT Page
No. No.

1. Misuse Of Sec 498a 4

2. Sec 498a Of Ipc 5

Case Law
Rajesh Sharma V/S State Of Up 5 - 17

3. Facts 6

4. Arguments By 6-8

5. Statistics 8-9

6. Issue 9
7. Courts Observation 9

8. Judgement 9-11
9. Case Analysis 11 – 12

10. Flaws In Reasoning Of Supreme Court 12- 14

11. Social Action Forum For Manav Adhikar & Another V. Union Of 14- 16
India Ministry Of Law And Justice & Ors.(2018)
• New Guidelines Isuued By The Supreme Court
12. Conclusion 26

13. Opinion & Suggestion 17

14. Reference 18
 4

MISUSE OF SEC 498A

Introduction
Sec 498A of IPC deals with the crime of cruelty against women by her husband and her in-
laws and provide for the punishment of the said offence. India as a nation is witness to a
patriarchal structure of society with an outdated and orthodox mindset that is submissive to
women. Therefore, these laws pertaining to domestic violence, cruelty, physical and sexual
harassment etc. that safeguard women's rights and offer legal redress have been developed to
address the issue of exploitation and discrimination. However, trend of women using these
laws meant for their protection against men is becoming common. Innocent families are
being victimized.

Unfortunately, section 498A of the Indian Penal Code is one such law that is increasingly
being misused by women against their in-laws and husband. Inculpable families have been
imprisoned only on the basis of the allegations. Many women are using the laws to satiate
their greed for money. They use the law to extract money from the husband and in-laws. As
per the report of NCRB (National Crime Record Bureau), 2020. The total number of cases
registered under section 498 A were 1,11,549 out of these 5,520 were considered as false by
police and 16,151 cases were closed due to mistake of false fact or law, Insufficient Evidence,
Mistake or Civil dispute. In such scenario it becomes evident for the law makers and law
protectors to take measures to ensure that women do not misuse the law and that they are
provided with adequate protection from gender-based discrimination.

Subsequently, Supreme Court has given many landmark judgements and issued various
guidelines that underscored the importance of protecting innocent individuals from false or
exaggerated accusations under Section 498A, and promotes a balanced approach to address
the issue of matrimonial cruelty while safeguarding the rights of the accused.

This paper will present a case study on Rajesh Sharma v. State of Uttar Pradesh, a landmark
case regarding the prevention of misuse of Section 498A of the Indian Penal Code, which
addresses dowry harassment.
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SEC 498 A OF IPC,1860

Background
Previously, cases on matrimonial cruelty of a woman were dealt with by general provisions of
Indian Penal Code like hurt, grievous hurt, assault etc. In the year 1983, the Indian Penal
Code was amended for inserting Section 498A which primarily concerns “Cruelty against
women”. The main objective behind this amendment was to protect women from being
harassed by her husband or relatives of the husband. An offence under this section is
cognizable, non-compoundable and non-bailable.

Definition
498A of IPC defines "cruelty against women as

a) Intentional behavior or any willful conduct that could make a woman want to harm herself
or cause serious harm to her life, body, or well-being, whether it's mental or physical.

b) Harassment of the woman where such harassment is with a view to coercing her or any
person related to her to meet any unlawful demand for any property or valuable security or is
on account of failure by her or any person related to her to meet such demand.

Filing of complaints
As per the sec 498 A of IPC

a) complaint must be filed within the time period of 3 years from the time the alleged last
incident of cruelty happened

b) the complaint can either be filed by the aggrieved married woman, or any other person
related to such aggrieved married woman by blood, adoption, or marriage.

c) The complaint can be filed against the husband or his relatives and distant relatives.

Punishment

The offenders booked under Sec 498 A of IPC shall be punished

a) with imprisonment for a term which may extend to three years or

b) shall also be liable to fine.

(c) the person can be convicted of both imprisonment as well as fine.

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RAJESH SHARMA V/S STATE OF UP

Title

In the case of Rajesh Sharma v. State of Uttar Pradesh, the Supreme Court was presented
with a plea to issue directives regarding cases involving the offense of dowry, in order to
prevent the victimization and harassment of innocent husbands and their relatives.

Case Name

Rajesh Sharma & Others v/s State of U.P. & Another

Citation

Criminal Appeal No. 1265 of 2017 [Arising out of Special Leave Petition (Crl.) No. 2013 of
2017]

Court

At, Supreme Court of India

Bench
1. THE HONOURABLE MR. JUSTICE ADARSH KUMAR GOEL &
2. THE HONOURABLE MR. JUSTICE UDAY UMESH LALIT

Decided On,
On 27 July 2017

Case Laws
• Section 498A of the Indian Penal Code (IPC)
• Arnesh Kumar V State of Bihar (2014) 8 SCC 273
• Gian Singh vs. State of Punjab (2012) 10 SCC 30
• Section 41, Section 438, Section 482 of the Criminal Procedure Code (CrPC).
• The Protection of Women from Domestic Violence Act, 2005
• The Dowry Prohibition Act, 1961
 7

FACTS

• The appellant no. 1, (Rajesh Sharm), and the respondent, (Sneha Sharma), were married
on November 28, 2012.
• The father of Sneha Sharma provided the appellant with dowry to the best of his ability.
• However, the appellants demanded Rs.3,00,000/- and a car, which the family was unable
to provide.
• Unhappy with the dowry amount, the appellants began mistreating the respondent,
subjecting her to daily abuse and exploitation.
• Eventually, the appellant left the respondent at her home after her pregnancy was
terminated.
• A complaint was filed on December 2, 2013, by respondent, the wife of appellant No.1
and Appellants 2 to 5, who are the parents and siblings of appellant No.1
• Under the direction of complaint, appellant No.1 was summoned under Section 498A
and Section 323 IPC but appellants 2 to 5 were not summoned.
• However, a revision petition was filed by respondent No.2, arguing that appellants 2 to 5
should also be summoned.
• The Additional Sessions Judge accepted the revision petition, instructing the trial court
to reconsider the matter.
• On August 18, 2015, the trial court summoned appellants 2 to 5 as well.
• The appellants then filed a petition in the High Court under Section 482 CrPC against
the summoning order.
• Despite attempted mediation, the High Court found no grounds to interfere with the
summoning order and dismissed the petition.
• Subsequently, the appellants move to the Supreme Court via Special Leave Petition.

ARGUMENTS BY
❖ By Appellant
• It was argued about the necessity to address the practice of implicating all family
members in resolving a marital dispute.
• It was contended that blanket accusations against the husband's relatives should not be
automatically accepted as true, as typically only the husband or his parents are accused
of dowry demands or cruelty.
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• It was claimed that in order to prevent the misuse of implicating multiple family
members, substantial evidence is required to take action against individuals beyond the
husband and his parents.
• It was argued that respondent ,the wife herself chose to leave the matrimonial home,
which raises doubts about her credibility in this matter.

• It is asserted that appellants 2 to 5 had no motive to make dowry demands, as they were
well-established and leading fulfilling lives.
• It was argued that false cases were being filed under Section 498A to settle personal
scores and extort money from the husband’s family.
• It was also argued that the police were making arrests without conducting proper
investigations, which was leading to the harassment of innocent people

❖ By Respondent
• The learned counsel representing respondent No. 2 provided arguments in support of the
impugned order and the allegations outlined in the complaint.

❖ By Amicus Curae
• Learned ASG submitted that Section 498A was enacted to check unconscionable
demands by greedy husbands and their families which at times result in cruelty to women
and also suicides.
• He, however, accepted that there is a growing tendency to abuse the said provision to
rope in all the relatives including parents of advanced age, minor children, siblings,
grand-parents and uncles on the strength of vague and exaggerated allegations without
there being any verifiable evidence of physical or mental harm or injury.
• At times, this results in harassment and even arrest of innocent family members,
including women and senior citizens.
• apart from the husband, all family members are implicated and dragged to the police
stations. Though arrest of those persons is not at all necessary, in a number of cases, such
harassment is made simply to satisfy the ego and anger of the complainant.
• Learned ASG suggested that there must be some preliminary inquiry on the lines of
observations in Lalita Kumari versus Government of Uttar Pradesh 7.
 9

• Arrest of a relative other than husband could only be after permission from the concerned
Magistrate.
• There should be no arrest of relatives aged above 70 years.
• Power of the police to straight away arrest must be prohibited.
• While granting permission, the court must ascertain that there is prima facie material of the
accused having done some overt and covert act.
• The offence should be made compoundable and bailable.
• The role of each accused must be specified in the complaint and the complaint must be
accompanied by a signed affidavit.
• The copy of the preliminary enquiry report should be furnished to the accused.
• 12. Shri V. Giri, learned senior counsel assisted by advocates Ms. Uttara Babbar, Ms.
Pragya Baghel and Ms. Svadha Shanker submitted that arrest in an offence under Section
498A should be only after recording reasons and express approval from the Superintendent
of Police.
• In respect of relatives who are ordinarily residing outside India, the matter should proceed
only if 7 (2014) 2 SCC 1 the IO is convinced that arrest is necessary for fair investigation.
• In such cases impounding of passport or issuance of red corner notice should be avoided.
• Procedure under Section 14 of the Protection of Women from Domestic Violence Act,
2005, of counseling should be made mandatory before registration of a case under Section
498A

STATATICS
• The statistics provided by the Crime Records Bureau (CRB) paint a troubling picture of
the situation. For instance, in 2005, there were 58,319 cases reported under Section
498A, leading to 1,27,560 arrests, with 6,141 cases declared false.
• Similarly, in 2009, there were 89,546 cases reported, resulting in 1,74,395 arrests, and
8,352 cases declared false. In 2012, a staggering 197,762 people were arrested under
Section 498A, including 47,951 women, yet the conviction rate remained low at 14.4%.
The charge-sheet filing rate of 93.6% in 2012 is particularly alarming, as is the large
number of pending cases (3,72,706), with a projected acquittal of 3,17,000.
• The Crime in India, 2013 report further underscores the issue, revealing that of the
4,66,079 cases pending in 2013, only 7,258 resulted in convictions, 38,165 in acquittals,
 10

and 8,218 were withdrawn. These statistics highlight the urgent need for a more balanced
and fair implementation of Section 498A to ensure that justice is served without
infringing on the rights of innocent individuals.

ISSUE
• Whether any directions are called for to prevent the misuse of Section 498A, as
acknowledged in certain studies and decisions.

COURTS OBSERVATION
• The court has taken note of a significant rise in the number of cases filed under Section
498A, indicating a potential misuse of the law.
• It was observed that many of these cases were being initiated not to seek justice for
actual instances of dowry harassment, but rather to settle personal vendettas or extort
money.
• Furthermore, the court highlighted that a concerning trend was emerging where cases
under Section 498A were being filed against the entire family of the husband, including
elderly parents and minor children.
• This unjust practice was leading to the harassment of innocent individuals who were not
involved in the alleged wrongdoing.
• In making its decisions, the court referenced statistics from the Crime Records Bureau
(CRB) to ensure a fair and just outcome.

JUDGEMENT
The Supreme Court gave the following directions:

1. In every district one or more Family Welfare Committees be constituted by the

District Legal Services Authorities preferably comprising of three members.
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a) The constitution and working of such committees may be reviewed from time to time
and at least once in a year by the District and Sessions Judge of the district who is also
the Chairman of the District Legal Services Authority.
b) The Committees may be constituted out of para legal volunteers/social workers/retired
persons/wives of working officers/other citizens who may be found suitable and
willing.
c) The Committee members will not be called as witnesses.
d) Every complaint under Section 498A received by the police or the Magistrate be
referred to and looked into by such committee. Such committee may have interaction
with the parties personally or by means of telephone or any other mode of
communication including electronic communication.
e) Report of such committee be given to the Authority by whom the complaint is
referred to it latest within one month from the date of receipt of complaint.
f) The committee may give its brief report about the factual aspects and its opinion in
the matter.
g) Till report of the committee is received, no arrest should normally be effected.
h) The report may be then considered by the Investigating Officer or the Magistrate on
its own merit.
i) Members of the committee may be given such basic minimum training as may be
considered necessary by the Legal Services Authority from time to time.
j) The Members of the committee may be given such honorarium as may be considered
viable.
k) It will be open to the District and Sessions Judge to utilize the cost fund wherever
considered necessary and proper.
l) Complaints under Section 498A and other connected offences may be investigated
only by a designated Investigating Officer of the area. Such designations may be
made within one month from today. Such designated officer may be required to
undergo training for such duration (not less than one week) as may be considered
appropriate. The training may be completed within four months from today;

2. In cases where a settlement is reached, it will be open to the District and Sessions
Judge or any other senior Judicial Officer nominated by him in the district to dispose
of the proceedings including closing of the criminal case if dispute primarily relates to
matrimonial discord;
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3. If a bail application is filed with at least one clear day’s notice to the Public
Prosecutor/complainant, the same may be decided as far as possible on the same day.
Recovery of disputed dowry items may not by itself be a ground for denial of bail if
maintenance or other rights of wife/minor children can otherwise be protected.
Needless to say that in dealing with bail matters, individual roles, prima facie truth of
the allegations, requirement of further arrest/ custody and interest of justice must be
carefully weighed;

4. In respect of persons ordinarily residing out of India impounding of passports or

issuance of Red Corner Notice should not be a routine;

5. It will be open to the District Judge or a designated senior judicial officer nominated
by the District Judge to club all connected cases between the parties arising out of
matrimonial disputes so that a holistic view is taken by the Court to whom all such
cases are entrusted; and

6. Personal appearance of all family members and particularly outstation members may
not be required and the trial court ought to grant exemption from personal appearance
or permit appearance by video conferencing without adversely affecting progress of
the trial.

7. These directions will not apply to the offences involving tangible physical injuries or
death.

CASE ANALYSIS
In the case of Rajesh Sharma v. State of UP, the Supreme Court has issued a directive stating
that any complaint of cruelty towards a woman by her husband or his relatives, which does
not involve physical injuries, must be referred to the Family Welfare Committee of the district.
This decision was made in light of the Court's observation that Section 498-A of the IPC is
sometimes misused by certain individuals, particularly to target elderly in-laws. The Court
referenced data from the National Crime Record Bureau (NCRB) to support this assertion.
 13

The Family Welfare Committee may consist of para-legal volunteers, social workers, retired
officers, or even the wives of serving officers. However, these members will not be called
upon as witnesses if the police or magistrate opt to investigate a specific case. While the
Court's intentions are clear, the chosen course of action - substituting investigation - raises
several concerns.
It is evident that the Court is aiming to address the issue of misuse of Section 498-A, but the
implications of bypassing the direction of investigation methods are significant. This
decision prompts a critical examination of the balance between protecting the rights of
women and ensuring fair treatment for all parties involved.

FLAWS IN THE REASONING OF SUPREME COURT JUDGMENT

❖ Reflection of patriarchy and male values

o The concerning issue at hand that is widely discussed is the judge's reliance on data
rather than considering the true impact of the law.
o The judges failed to acknowledge the significant reduction in physical violence and
dowry-related crimes due to the existing laws.
o Furthermore, the judges neglected to contemplate the consequences of weakening the
dowry law. This mindset stems from a patriarchal society that values male dominance
and power.

• Feminist perspective

• Feminists critique this judgment as a reflection of the deeply entrenched male values in
our society, evident in every aspect.
• The judgment implies that women who file complaints on trivial issues lack the ability to
foresee consequences, suggesting that women's rationality and reasonableness are
considered inferior to men's.
• The court labels any woman fighting for her rights as 'disgruntled,' reinforcing the idea
that anything diverging from mainstream male thinking is deemed deviant.
• Furthermore, the court's emphasis on the importance of family in Indian society portrays
a wife's role through a male-centric lens.
• Women are expected to prioritize family unity and comply with their husband's
wishes, depriving them of their natural rights.
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• The judgment revealing that 30 percent of accused individuals in cases are the
mother or sister of the husband highlights how women's rationality has been
influenced by male perspectives.

❖ Realists’ perspective

o It appears that the judges have expressed their belief that the application of a law in
practice may differ from its intended principles, and with society constantly
evolving, it is necessary to reassess the law and consider the actual circumstances.
o However, this line of reasoning by the judges is fundamentally flawed. Instead of
thoroughly examining the law, they immediately criticized it, suggesting that it has
led to an overwhelming number of cases.
o The judges' reliance solely on data from the National Crime Records Bureau, without
taking into account surveys, analyses from various NGOs, and other sources of
information, indicates a bias towards a male perspective.
o The NCRB data, which only reflects the number of cases filed and the low
conviction rate of 14%, highlights the complexities of the Indian judicial system and
the patriarchal nature of society. Many women, out of fear or societal pressure, may
choose not to pursue legal action, while those who do often face challenges due to
inadequate police investigations.
o For numerous women, experiencing violence and discrimination on a daily basis has
become so normalized that they have internalized these injustices. As a result, they
typically only seek legal recourse when the violence reaches extreme levels.

SOCIAL ACTION FORUM FOR MANAV ADHIKAR & ANOTHER V.

UNION OF INDIA MINISTRY OF LAW AND JUSTICE & ORS.(2018)

• In Social Action Forum for Manav Adhikar and Another, the judgment of Rajesh
Sharma and others v. State of U.P. and another3 passed by the Hon'ble Supreme Court
came in question.

• In Social Action Forum for Manav Adhikar and Another, a petition was filed under
Article 32 of the Constitution. The petitioners contended that it is not untrue that there are
 15

a number of women suffering from violence at the hands of husband and his relatives and
that the accusation that Section 498A is being misused is not supported from any concrete
date on such misuse. It was further argued that the social purpose behind Section 498-A
IPC is being lost as the rigour of the said provision has been diluted and the offence has
practically been made bailable by reason of various qualifications and restrictions
prescribed by various decisions of this Court including Rajesh Sharma v. State of U.P.

• In Social Action Forum for Manav Adhikar and Another,the Hon'ble Supreme Court
examined whether the Court in Rajesh Sharma could, by the method of interpretation,
have issued above such directions. With due deliberations, the Hon'ble Supreme Court
was pleased to modify the directions issued in Rajesh Sharma case.

NEW GUIDELINES ISUUED BYTHE SUPREME COURT

• With respect to the constitution of Family Welfare Committee, the Court has ruled that
constitution of the Family Welfare Committees by the District Legal Services Authorities
and the prescription of duties of the Committees and further action thereof are beyond the
IPC and the same does not really flow from any provision of the IPC and have nothing to
do with the IPC. Accordingly, the same was impermissible.
• The Court issued direction to the officers investigating under S 498-A to be careful and
be guided by the principles propounded in the landmark Supreme Court judgments
of Joginder Kumar v. State of U.P and others, D.K. Basu v. State of W.B5, Lalita Kumari
v. Government of Uttar Pradesh and others and Arnesh Kumar v. State of Bihar and
another.
• Further, with respect to the direction regarding disposal of the case by District and
Sessions Judge or any other senior Judicial Officer nominated by him in cases where
settlement was reached, the Court observed that the same was not a correct expression of
law and in a criminal case which was not compoundable, only the concerned High Court
has the power to quash proceedings under S. 498-A. Thus, the same could not be done by
District or the Sessions judge and it was open to the parties to approach the High Court.
• The Court did not interfere with respect to the directions pertaining to Red Corner Notice,
clubbing of cases and postulating that recovery of disputed dowry items may not by itself
be a ground for denial of bail.
 16

• With respect to the directions regarding clubbing of "appearance of all family members
and outstation members by video conferencing", the Court directed that an application
could be filed either under Section 205 or Section 317 of Criminal Procedure Code
depending upon the stage at which the exemption is sought.
• The Hon'ble Supreme Court therefore, found that some of the directions given in
the Rajesh Sharma case had potentially entered into the legislative field. Keeping this in
mind, the Hon'ble Supreme Court undertook a re-examination of the directions and only
retained the ones that find their bedrock within the Indian Penal Code - and in doing so -
propounded a more balanced approach towards the application of section 498A.

CONCLUSION

The case of Rajesh Sharma v State of UP is a significant one that highlighted the issue of the
misuse of Section 498A of the Indian Penal Code, which deals with dowry harassment. The
Supreme Court’s judgment in the case aimed to prevent the misuse of the law while also
protecting the rights of women.

The judgment recognized the need to strike a balance between protecting the rights of women
and preventing the misuse of the law. The court acknowledged that dowry harassment is a
serious problem in India, and that women need to be protected from such harassment.
However, the court also recognized that false cases of dowry harassment are often filed with
malicious intent, and that this can lead to innocent people being harassed and even arrested.

The court’s guidelines to prevent the misuse of Section 498A were aimed at ensuring that the
law is used only in genuine cases of dowry harassment, and that innocent people are not
harassed or arrested. The guidelines emphasized the need for a fair and just process, and the
need for the accused to be given an opportunity to defend themselves.

The judgment in Rajesh Sharma v State of UP has been both praised and criticized. Some
have welcomed the court’s guidelines as a step towards preventing the misuse of the law,
while others have criticized the guidelines as being too restrictive and as diluting the
protection provided to women.
 17

Social Action Forum for Manav Adhikar and Another is one of the significant case that
confronted the validity of the directions issued in the Rajesh Sharma case. The court re-
examined the judgement and enforced new guidelines that comprised for a balanced approach
towards the issue of dowry harassment. While it is important to protect the rights of women,
it is also important to ensure that the law is not misused to harass innocent people. The
Supreme Court’s judgment in the case provides a framework for achieving this balance, and
it is now up to the government and the judiciary to implement these guidelines effectively.

OPINION & SUGGESTION

In the Rajesh Sharma case, the Supreme Court's order stating that the law on cruelty against
women is being misused is based on conclusions drawn from NCRB figures. While the data
collected may have some validity and show a need to address the growing problem of
misuse of section 498A, it doesn't tell the whole story. The Court doesn't consider the data
from NFHS-3, which shows that in the same year, at least 59 million women experienced
some form of physical or violence in the previous 12 months.

If we're going to look at the data, why not consider the actual and horrific cases related to
dowry that the NCRB has collected? In 2020, a total of 111,549 cases were registered under
498A. Out of these, 5,520 were closed by the police as false, and a total of 16,151 cases
were closed for various reasons like being false, a mistake of fact or law, or a civil dispute.
That means 14.4% of cases were closed by the police for lack of merit. Last year, 96,497
men and 23,809 women were arrested under 498A, totaling 120,306 arrests. Out of 18,967
cases tried in court, 14,340 resulted in acquittal and 3,425 in conviction. There were 651,404
498A cases pending trial at the end of 2020, with a pendency rate of 96.2%.

In this scenario, the guidelines issued by the Social Action Forum for Manav Adhikar and
Another could be considered more pertinent. The court should actively work to promote a
robust, comprehensive, and balanced approach to addressing the issue of matrimonial cruelty
while also safeguarding the rights of the accused. By incorporating these guidelines, the
judicial process can better ensure a fair and just resolution that takes into account the
complexities of the situation and upholds the principles of justice and human rights.
 18

Reference

• Rajesh Sharma vs The State Of Uttar Pradesh on 27 July, 2017 (indiankanoon.org)

• Rajesh Sharma V. State of U.P. - Legal Vidhiya
• Rajesh Sharma V. State of U.P. - Legal Vidhiya
• Rajesh Sharma v State of UP - Case analysis on Dowry Death and 498A (ipleaders.in)
• Rajesh Sharma vs State of U.P. - Supreme Court Important Judgment 2017
(indianconstitution.in)
• Section 498A Of IPC: A Weapon Or A Shield? – Supreme Court Of India - Crime - India
(mondaq.com)
• Social Action Forum for Manav Adhikar & another vs. Union of India Ministry of Law &
Justice & ors. - Law Times Journal
• NCRB Report 2020 | Crimes Against Women | Cases Registered V/s False; Conviction
Vs Acquittal – Voice For Men (voiceformenindia.com)