Combating Human Trafficking in India: The Role of Non-governmental Organisations

I. Introduction

The history of slavery traces the history of the slave trade from ancient times to the present. Slavery was a legally recognized system in which people were legally considered the property or chattel of another. A slave had few rights and could be bought or sold and made to work for the owner without any choice or pay. This spirit of collectivism contributed to the emergence of society and social values. Over time, however, competition over limited resources, the struggle for survival, and greed strained these norms, and individual interest often prevailed over collective interest. The consequence of these violations has been vulnerability, marginalisation, and a corresponding loss of prosperity and wellbeing.² Human trafficking in the present century is one of the worst kinds of exploitation and abuse that human beings have ever known. Globally, an estimated 50 million people were living in conditions of modern slavery in 2021, comprising both forced labour and forced marriage.³

Defining Trafficking

The dictionary⁴ meaning of ‘trafficking’ denotes ‘illegal or disreputable trade in something’. Thus, we have terms like drug trafficking, arms trafficking and human trafficking. The Protocol to Prevent, Suppress and Punish Trafficking in Persons, Especially Women and Children, supplementing the United Nations Convention against Transnational Organized Crime (Trafficking Protocol) that was adopted in the year 2000 which came into force in December 2003, has perhaps brought the much-needed and widespread consensus on a working definition of trafficking at the global level. India is also a signatory to this. Article 3 of this Protocol defines trafficking as:

“the recruitment, transportation, transfer, harbouring or receipt of persons, by means of the threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of the abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person, for the purpose of exploitation….”⁵

II. Human trafficking in india

Human Trafficking is forbidden by the Constitution of India.⁶ Yet India is a source, destination and transit country for human trafficking principally for commercial sexual exploitation and forced labour,⁷ and with the declining sex ratio, trafficking for marriage is becoming another pull factor for trafficking of women and girls.⁸ The evil system of bonded labour continues despite legislation to combat it.⁹ India continues to be identified as a country of origin, transit and destination for trafficking, and remains placed on Tier 2 of the US State Department's 2025 Trafficking in Persons Report.¹⁰

Even though the crime of human trafficking for any purpose is both under-recorded and underreported, the UNODC's 2024 Global Report on Trafficking in Persons recorded a 25% increase in the number of trafficking victims detected worldwide in 2022 compared with pre-pandemic 2019 levels, with women and girls continuing to account for 61% of detected victims and the large majority of them trafficked for sexual exploitation.¹¹ As per the latest NCRB data, 2,183 cases of human trafficking were reported in 2023, involving 6,288 victims (including 2,687 children), of whom 6,043 were rescued.¹²

Movement of persons is mostly from Nepal and Bangladesh into India, and sometimes beyond, through the porous and lengthy borders that these countries share with India.¹³

There are so many international instruments governing the issue but many stones will remain unturned until the domestic legislation steps up and takes strict action towards combating such menace. Although India has a specific law¹⁴ on trafficking, it does not define trafficking, but defines 'prostitution' to have the usual attributes of trafficking for sexual exploitation.¹⁵ A dedicated Trafficking in Persons (Prevention, Care and Rehabilitation) Bill has twice been drafted, in 2018 and 2021, but has lapsed on both occasions without being enacted.¹⁶

III. Existing legal framework to combat human trafficking

Human Trafficking is prohibited under the Constitution of India, 1950. Article 23 of the Constitution specifically prohibits “traffic in human beings and begar and other similar forms of forced labour”.¹⁷ Article 24 further prohibits employment of children below 14 years of age in factories, mines or other hazardous employment.¹⁸ We have other fundamental rights which have been enshrined in the Constitution relevant to trafficking.

Article 39 of Directive Principles of State Policy¹⁹ states that men and women should have the right to an adequate means of livelihood and equal pay for equal work; that men, women and children should not be forced by economic necessity to enter unsuitable avocations; and that children and youth should be protected against exploitation. Further, Article 39A directs that the legal system should ensure that opportunities for securing justice are not denied to any citizen because of economic or other disabilities. Moreover, Article 43 states that all workers should have a living wage and there should be appropriate conditions of work so as to ensure a decent standard of life.

The Indian Penal Code, 1860 contained more than 20 provisions²⁰ that were relevant to trafficking and imposed criminal penalties for offences like kidnapping, abduction, buying or selling a person for slavery/labour, buying or selling a minor for prostitution, importing/procuring a minor girl, rape, etc.²¹ With effect from 1 July 2024, the Indian Penal Code, 1860 has itself been replaced by the Bharatiya Nyaya Sanhita, 2023; the trafficking offence formerly found in Section 370 IPC is now Section 143 BNS, which for the first time provides a general statutory definition of trafficking in Indian criminal law and expressly includes beggary as a form of exploitation.²² The Protection of Children from Sexual Offences Act, 2012 also overlaps considerably with child trafficking, since offences such as penetrative sexual assault and using a child for pornographic purposes frequently arise from, or facilitate, trafficking for sexual exploitation.²³

The Immoral Traffic (Prevention) Act, 1956 (ITPA), initially enacted as the ‘Suppression of Immoral Traffic in Women and Girls Act, 1956’,²⁴ is the main legislative tool for preventing and combating trafficking in human beings in India. However, till date, its prime objective has been to inhibit/abolish traffic in women and girls for the purpose of prostitution as an organized means of living. The Act criminalizes the procurers, traffickers and profiteers of the trade but in no way does it define ‘trafficking’ per se in human beings. The other relevant Acts which address the issue of trafficking in India are the Karnataka Devadasi (Prohibition of Dedication) Act, 1982; Child Labour (Prohibition and Regulation) Act, 1986²⁵; Andhra Pradesh Devadasi (Prohibition of Dedication) Act, 1988; Information Technology Act, 2000²⁶; the Goa Children’s Act, 2003; and the Juvenile Justice (Care and Protection of Children) Amendment Act, 2006. Besides these, there are also certain other collateral laws having relevance to trafficking. These are Child Marriage Restraint Act, 1929; Young Persons (Harmful Publications) Act, 1956; Probation of Offenders Act, 1958; Criminal Procedure Code, 1973; Bonded Labour System (Abolition) Act, 1976; Indecent Representation of Women (Prohibition) Act, 1986; and the Transplantation of Human Organs Act, 1994.²⁷

The Indian judiciary has been quite upfront in dealing with the cases related to trafficking in human beings. In Vishal Jeet v. Union of India²⁸ the Supreme Court, while putting on record the growing exploitation of young women and children for prostitution and trafficking, reported that in spite of the stringent and rehabilitative provisions of law under various Acts, it cannot be said that the desired result has been achieved. The honourable court ordered an objective, multi-dimensional study and a searching investigation into the matter relating to the causes and effects of this evil and requiring most rational measures to weed out the vices of illicit trafficking. On the directions given by the Supreme Court, the Government constituted a Central Advisory Committee on Child Prostitution in 1994. Subsequently, State Advisory Committees were also set up by State Governments. The outcome of the latter case was the constitution of a Committee on Prostitution, Child Prostitutes and Children of Prostitutes to look into the problems of commercial sexual exploitation and trafficking of women and children and of children of trafficked victims so as to evolve suitable schemes in consonance with the directions given by the Apex Court.

In Gaurav Jain v. Union of India,²⁹ the Supreme Court directed the constitution of a Committee to make an in-depth study into these problems and evolve suitable schemes for the rehabilitation of trafficked women and children. A permanent Committee of Secretaries was formed to review the progress of the implementation on an annual basis, and to take such other steps as may be expedient in the effective implementation of the schemes. The court, taking a proactive view, believed and hoped that the directions would relieve the human problem by rehabilitation of the unfortunate fallen women caught in the trap of prostitution; their children would be brought into the mainstream of the social order; these directions would enable them to avail of the equality of opportunity and of status, with dignity of person which are the arch of the Constitution.

More recently, in Bachpan Bachao Andolan v. Union of India,³⁰ the Supreme Court, acting on a petition filed by the NGO, directed the Central Government to prohibit the employment of children in circuses after finding widespread trafficking of children, particularly from Nepal, into that trade.

IV. What can ngos offer?

In Budhadev Karmaskar v. State of West Bengal,³¹ the Court rightfully observed that “it is ultimately the people of the country, particularly the young people, who by their idealism and patriotism can solve the massive problems of sex workers.” It cannot be denied that all stakeholders have to join hands together to solve this burning issue. The approach as to what can be done to combat this menace of trafficking is the question in front of all of us. There are many big NGOs like Shakti Vahini, Bachpan Bachao Andolan, Prajwala etc.³² and some having international collaborations also, which are working for this cause and they are doing great. Prajwala, for instance, was the petitioner in the public interest litigation that led the Ministry of Women and Child Development to commit to drafting comprehensive anti-trafficking legislation,³³ and many such NGOs also implement the Ministry's Ujjawala Scheme for the rescue, rehabilitation and reintegration of trafficking victims.³⁴ We, like a drop, should take small steps to work for a big cause, after all, “With the falling of drops, the pot eventually gets filled up”. Within the anti-trafficking field, NGOs should play the role others do not play. Cooperation among all stakeholders is essential. NGOs need cooperation with all actors in the anti-trafficking field and can offer their support to other actors.

The following preventive measures need to be taken by NGOs:

• To facilitate and improve the safe return and social inclusion (reintegration) of trafficked persons and to provide direct and indirect support (legal, social, psychological);
• To educate/inform potential victims (risk groups) about the risks of trafficking and educate professional groups about trafficking in human beings, including the identification and treatment of trafficked persons;
• To raise awareness, influence public opinion and advise and stimulate governments and other key actors and to take action towards a human rights based approach to anti-trafficking;
• To fill the information gap on the situation of trafficking in human beings, by providing accurate statistics and case studies and by analysing and conducting research on the issue, in particular on root causes.

Some other measures, if acted upon, would mean that the day is not far when every person can breathe the carefree air of freedom:

• Social Assistance: Social assistance needs to be provided to trafficked persons. Support services like running a hotline, arranging for a safe return home, meeting women at the airport, the railway or coach station, addressing immediate needs such as clothing, food and other basic necessities, facilitating contacts with consulates or embassies to obtain new identity or travel documents, assistance with contacting family members, arranging a safe shelter, providing emotional support, counselling and psychological support or referral, providing healthcare or legal aid, support during court cases and assistance in organising education or in finding a job can be provided.
• Psychological Assistance: Apart from social assistance, it is very important that the victim gets psychological assistance from a well-trained psychologist to get the fear out and live a normal life. NGOs can tie up with such psychologists, who can provide these services pro bono.
• Helplines: NGOs can also provide helpline services that anyone aware of such illicit activity can contact, following which agencies such as the police or the local authorities can be called upon to represent and advocate for the interests of the trafficked persons concerned. ZIPNET (Zonal Integrated Police Network) also exists to monitor missing children, with orders for registration of an FIR in all cases of missing children.³⁵
• Assisting Magistrate, Police etc in rescue of victims: Yes, an NGO can move the Magistrate and seek orders to rescue any person under sections 15 and 16 of the Immoral Traffic (Prevention) Act, 1956.³⁶ NGOs also have a legal right to be a part of the rehabilitation process. The law provides protection to such bona fide helps. Trafficking victims are additionally entitled to free legal aid under section 12 of the Legal Services Authorities Act, 1987, which NALSA has supplemented with a dedicated scheme for victims of trafficking and commercial sexual exploitation.³⁷

V. Conclusion

It is difficult to conclude whether human trafficking has increased or decreased in recent years, and the difficulty is itself instructive. Detected cases measure the reach of enforcement and of data collection at least as much as they measure the underlying crime, so a rise in recorded figures may well signal better reporting rather than a worsening problem. It still remains difficult to define the exact scope of human trafficking in India. Despite the fact that there is little reliable data on trafficking in human beings, it is quite evident that thousands of persons are being trafficked within, to and from India every year.

Three gaps in particular emerge from the foregoing discussion. First, the definitional problem has been narrowed but not closed. The Bharatiya Nyaya Sanhita, 2023 now supplies, for the first time, a general statutory definition of trafficking in Indian criminal law; yet the Immoral Traffic (Prevention) Act, 1956, which remains the principal legislation in the field, continues to regulate prostitution without defining trafficking at all. The two central instruments therefore do not speak the same language, and the burden of reconciling them falls upon the police officer and the magistrate at the very moment when a victim requires protection.³⁸ Secondly, India still has no dedicated statute that brings prevention, protection, prosecution and rehabilitation within a single frame. The Bills of 2018 and 2021 lapsed without enactment, leaving the field to be governed by a patchwork of provisions drawn from several enactments of differing vintage and purpose.³⁹ Thirdly, rescue is not rehabilitation. Sections 15 and 16 of the Immoral Traffic (Prevention) Act, 1956, the Ujjawala Scheme and the NALSA scheme for victims of trafficking together give NGOs a genuine statutory foothold; but whether that foothold translates into a restored life depends upon shelter capacity, trained personnel and sustained funding rather than upon the text of the law. A victim returned to the same conditions of poverty and vulnerability from which she was taken is a victim awaiting re-trafficking.⁴⁰

The work done by our nation’s various governmental and non-governmental organizations is highly appreciable, but there are many gaps unfilled, and the question still remains as to the efficacy of the measures provided. What is required is not merely more law, but the will and the machinery to give effect to the law that already exists: a definition applied consistently across statutes, victim protection that outlasts the rescue operation, and a partnership in which the State treats the NGO not as a supplicant but as a participant. We should not wait for the incident to happen; we should work on the cause to cut it from the nub. Indians live in a democratic society that values freedom. We must work together to ensure that all our citizens can enjoy that freedom and that each person’s human rights are respected.

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Footnotes

1. Author is an Assistant Professor (Law) at Maharashtra National Law University Mumbai, Maharashtra, India.

2. UNODC, An Introduction to Human Trafficking: Vulnerability, Impact and Action, available at <https://www.unodc.org/documents/human-trafficking/An_Introduction_to_Human_Trafficking_-_Background_Paper.pdf> (last accessed 30 September 2025) ↩

3. International Labour Organization, Walk Free and International Organization for Migration, "50 million people worldwide in modern slavery" (12 September 2022), available at <https://www.ilo.org/resource/news/50-million-people-worldwide-modern-slavery-0> (last accessed 30 September 2025) ↩

4. Merriam-Webster, 'traffic', available at <https://www.merriam-webster.com/dictionary/traffic> (last accessed 30 September 2025) ↩

5. Protocol to Prevent, Suppress and Punish Trafficking in Persons, Especially Women and Children, supplementing the United Nations Convention against Transnational Organized Crime, 2237 UNTS 319 (adopted 15 November 2000, entered into force 25 December 2003), art 3(a) ↩

6. Article 23- Prohibition of traffic in human beings and forced labour: (1) Traffic in human beings and begar and other similar forms of forced labour are prohibited and any contravention of this provision shall be an offence punishable in accordance with law. ↩

7. Globally, forced commercial sexual exploitation accounts for around 23% of all forced labour, with almost four in five of those subjected to it being women or girls: International Labour Organization, Walk Free and International Organization for Migration, Global Estimates of Modern Slavery: Forced Labour and Forced Marriage (Geneva, 2022), available at <https://www.ilo.org/resource/news/50-million-people-worldwide-modern-slavery-0> (last accessed 30 September 2025) ↩

8. On the link between skewed sex ratios in parts of northern India and demand-driven marriage migration, see Reena Kukreja, Trafficked or Married? Unpacking Dispossession of Matrimonial Choice in Cross-Region Marriage Migration in India (2024) 59(7) Journal of Asian and African Studies 2170, available at <https://pmc.ncbi.nlm.nih.gov/articles/PMC11490356/> (last accessed 30 September 2025), noting that while genuine bride trafficking occurs, empirical research cautions against treating all such cross-region marriages as trafficking ↩

9. The Bonded Labour System (Abolition) Act, 1976. ↩

10. US Department of State, 2025 Trafficking in Persons Report: India, available at <https://www.state.gov/reports/2025-trafficking-in-persons-report/india/> (for comparative historical data, see UNODC, "Trafficking in Persons: Global Patterns" (2006), available at <https://www.unodc.org/documents/human-trafficking/HT-globalpatterns-en.pdf>, and subsequent editions of the UNODC Global Report on Trafficking in Persons via <https://www.unodc.org/unodc/en/data-and-analysis/tip.html>) ↩

11. UNODC, Global Report on Trafficking in Persons 2024 (December 2024), available at <https://www.unodc.org/unodc/en/data-and-analysis/tip.html> (last accessed 30 September 2025) ↩

12. Crime in India 2023, National Crime Records Bureau (Ministry of Home Affairs, Government of India, 2025), Table 6A.1 (human trafficking cases, victims and rescues) ↩

13. US Department of State, 2025 Trafficking in Persons Report: India, available at <https://www.state.gov/reports/2025-trafficking-in-persons-report/india/> (last accessed 30 September 2025), noting that traffickers fraudulently recruit Nepali and Bangladeshi women and girls across India's open and porous borders for sex trafficking ↩

14. The Immoral Traffic (Prevention) Act, 1956 ↩

15. The Goa Children's Act, 2003 has a definition on trafficking, but that is limited a) to the State of Goa in India, and b) to child trafficking only. The general definitional gap in the ITPA itself remains unamended; however, a general statutory definition of trafficking has since been introduced elsewhere in Indian criminal law: see the discussion of the Bharatiya Nyaya Sanhita, 2023 below. ↩

16. A version of this bill was passed by the Lok Sabha in July 2018 but never introduced in the Rajya Sabha and lapsed; a revised draft, the Trafficking in Persons (Prevention, Care and Rehabilitation) Bill, 2021, was circulated for public comment by the Ministry of Women and Child Development but has not been enacted: Press Information Bureau, "Ministry of Women and Child Development invites comments/suggestions on The Trafficking in Persons (Prevention, Care and Rehabilitation) Bill, 2021" (4 July 2021), available at <https://www.pib.gov.in/PressReleasePage.aspx?PRID=1732617&reg=3&lang=2> (last accessed 30 September 2025) ↩

17. Cf. the international definition of forced labour as "all work or service which is exacted from any person under the menace of any penalty and for which the said person has not offered himself voluntarily": ILO Forced Labour Convention, 1930 (No. 29), art 2(1), available at <https://www.ilo.org/dyn/normlex/en/f?p=NORMLEXPUB:12100:::NO:12100:P12100_ILO_CODE:C029:NO> (last accessed 30 September 2025) ↩

18. Constitution of India, 1950, art 24: "No child below the age of fourteen years shall be employed to work in any factory or mine or engaged in any other hazardous employment." ↩

19. Constitution of India, 1950 ↩

20. Indian Penal Code, 1860 (now largely superseded by the Bharatiya Nyaya Sanhita, 2023, with effect from 1 July 2024; see footnote 22 below for the BNS counterpart provisions) ↩

21. The Indian Penal Code, 1860 (Act No. 45 of 1860), Chapters V, XVI and XVIII (offences of abetment, kidnapping, abduction, slavery, unlawful compulsory labour, sexual offences and offences relating to marriage), available in full at <https://www.indiacode.nic.in/bitstream/123456789/4219/1/THE-INDIAN-PENAL-CODE-1860.pdf> (last accessed 30 September 2025) (the corresponding provisions are now found in the Bharatiya Nyaya Sanhita, 2023, Chapter V, 'Of Offences Against Woman and Child' (ss 63-99), and Chapter VI, 'Of Offences Affecting the Human Body' (ss 100-146), which came into force on 1 July 2024; see footnote 22 below) ↩

22. Bharatiya Nyaya Sanhita, 2023, s 143 (replacing s 370 of the Indian Penal Code, 1860, with effect from 1 July 2024); see the official text at Government of India, The Bharatiya Nyaya Sanhita, 2023 (Act No. 45 of 2023), available at <https://www.indiacode.nic.in/bitstream/123456789/20062/1/a202345.pdf> (last accessed 30 September 2025) ↩

23. The Protection of Children from Sexual Offences Act, 2012 (Act No. 32 of 2012), ss 3-15, available at <https://www.indiacode.nic.in/bitstream/123456789/2079/1/AA2012-32.pdf> (last accessed 30 September 2025) ↩

24. The Act, originally enacted as the Suppression of Immoral Traffic in Women and Girls Act, 1956, was amended and renamed the Immoral Traffic (Prevention) Act by the Suppression of Immoral Traffic in Women and Girls (Amendment) Act, 1986 (Act No. 44 of 1986), which also rendered its principal provisions gender-neutral. For the Act as amended, see <https://www.indiacode.nic.in/bitstream/123456789/15100/1/immoral_traffic_prevention_act_(itpa)_1956.pdf> (last accessed 30 September 2025) ↩

25. The Child Labour (Prohibition and Regulation) Act, 1986 (Act No. 61 of 1986), available at <https://www.indiacode.nic.in/bitstream/123456789/9956/1/child_labour_prohibition_and_regulation_act_1986.pdf> (last accessed 30 September 2025) ↩

26. The Information Technology Act, 2000 (Act No. 21 of 2000), available at <https://www.indiacode.nic.in/bitstream/123456789/1999/1/A2000-21%20(1).pdf> (last accessed 30 September 2025) ↩

27. For a judicial survey of the legislation applicable to trafficking in India, see Bachpan Bachao Andolan v. Union of India (2011) 5 SCC 1, in which the Supreme Court considered the causes of trafficking, the available legislations, India's obligations under international and regional instruments, and the existing child protection mechanisms. It may be noted that the Criminal Procedure Code, 1973 has since been replaced by the Bharatiya Nagarik Suraksha Sanhita, 2023 with effect from 1 July 2024, and that the Child Marriage Restraint Act, 1929 stands replaced by the Prohibition of Child Marriage Act, 2006 ↩

28. (1990) 3 SCC 318 ↩

29. (1997) 8 SCC 114 ↩

30. (2011) 5 SCC 1 ↩

31. (2011) 10 SCC 277 ↩

32. See Shakti Vahini, available at <https://shaktivahini.org/>; Bachpan Bachao Andolan, available at <https://bba.org.in/>; and Prajwala, available at <https://prajwalaindia.com/> (all last accessed 30 September 2025) ↩

33. Prajwala, "Milestones", noting that an Inter-Ministerial Committee was set up by the Government of India to draft comprehensive anti-trafficking legislation as a result of the final decision in the Public Interest Litigation 56/2004 filed by Prajwala, available at <https://prajwalaindia.com/home> (last accessed 30 September 2025) ↩

34. Press Information Bureau, "Achievements Under Ujjawala Scheme" (18 July 2019), noting 254 sanctioned projects, including 134 Protective and Rehabilitative Homes, available at <https://www.pib.gov.in/Pressreleaseshare.aspx?PRID=1579343> (last accessed 30 September 2025) ↩

35. Kamaljit vs State of NCT of Delhi, Crl. Appeal No. 28/2007 and Crl. M.A. Nos. 336 and 338/2007; see also the direction of the Supreme Court (Nagarathna and Mahadevan JJ) of 24 September 2025, on a petition by Guria Swayam Sevi Sansthan, requiring the Union Government to create a dedicated national online portal under the aegis of the Ministry of Home Affairs for tracing missing children, with a nodal officer designated in each State; and the Ministry of Women and Child Development's TrackChild system, now migrated to the Mission Vatsalya portal ↩

36. Immoral Traffic (Prevention) Act, 1956, ss 15 (search without warrant) and 16 (rescue of person), available at <https://www.indiacode.nic.in/bitstream/123456789/15100/1/immoral_traffic_prevention_act_(itpa)_1956.pdf> (last accessed 30 September 2025) ↩

37. Legal Services Authorities Act, 1987, s 12(b), which makes "a victim of trafficking in human beings or begar" eligible for free legal aid; National Legal Services Authority (Victims of Trafficking and Commercial Sexual Exploitation) Scheme, 2015, see National Legal Services Authority, "FAQs", available at <https://nalsa.gov.in/faqs/> (last accessed 30 September 2025) ↩

38. Compare the Bharatiya Nyaya Sanhita, 2023, s 143 with the Immoral Traffic (Prevention) Act, 1956, both discussed above. The Sanhita definition binds the general criminal law, but the ITPA has not been correspondingly amended, and it is the ITPA under which rescue and closure proceedings in brothel cases are ordinarily conducted. ↩

39. On the fate of the Trafficking in Persons (Prevention, Care and Rehabilitation) Bills of 2018 and 2021, see the discussion and sources cited above. For the current legislative position, see Press Information Bureau, "Ministry of Women and Child Development invites comments/suggestions on The Trafficking in Persons (Prevention, Care and Rehabilitation) Bill, 2021" (4 July 2021), available at <https://www.pib.gov.in/PressRelease Page.aspx?PRID=1732617&reg=3&lang=2> (last accessed 30 September 2025) ↩

40. For the schemes referred to, see Press Information Bureau, "Achievements Under Ujjawala Scheme" (18 July 2019), available at <https://www.pib.gov.in/Pressreleaseshare.aspx?PRID=1579343>, and the National Legal Services Authority (Victims of Trafficking and Commercial Sexual Exploitation) Scheme, 2015, available at <https://nalsa.gov.in/faqs/> (both last accessed 30 September 2025). The point is one of implementation rather than of entitlement: the legal right to assistance is established, its practical availability is not uniform. ↩