Cyber Crimes against Women in India: A Torment in Society

I. Introduction

India is one of the fastest growing nations in the world. Technological advancement is one of the key factors driving the progress of the nation. It has numerous advantages like easier payments, greater access to communication, online marketplaces and more. The “Right to Internet Usage” has been declared as a human right by the United Nations Human Rights Council.³ The telecom revolution increased the usage of internet manifold. It has allowed internet access to a large majority of the Indian population. There had been a significant increase in the number of users of social networking sites. The users went from, “142.25 million in 2015 to 197.85 million in 2017 to518.92 million in 2020.”⁴ In 2016, a survey was conducted by the Boston Consulting Group which discovered that 29% of the Internet users are women.⁵ This has also led to an increase in Cyber Crimes in India over the years. It can be evidenced by the graph shown below which indicates that Cyber Crime has grown over 30 times in the period of 2010 – 2018.

Recorded Cyber Crime Cases in India (2010 – 2018)

Source: National Crime Records Bureau of India

There are certain downsides to the increasing use of technology in our daily lives. It has given rise to a new type of crime known as Cyber Crime. A Cyber Crime is primarily committed using an electronic device and the victims can be a person, a property, an organisation or even the Government. "Cyber Crime encompasses any criminal act dealing with computers and networks (called hacking). Additionally, Cyber Crime also includes traditional crimes conducted through the Internet. For example; hate crimes, telemarketing and Internet fraud, identity theft, and credit card account thefts are considered to be Cyber Crimes when the illegal activities are committed through the use of a computer and the Internet."⁶

The internet has become a haven for cyber criminals. They often use techniques in order to make themselves untraceable and target vulnerable victims. Women are one of the most common victims of Cyber Crime and it is often perpetrated through social networking sites. Some of the common cyber crimes committed against women include, “harassment via emails, cyber stalking, cyber pornography, obscenity, defamation, violation of body privacy, workplace harassment using digital aid morphing and email spoofing.”⁷

Therefore, there is a need to address the growing advent of Cyber Crimes over the internet, particularly those against women. The Covid-19 Pandemic also had a negative influence on the Cyber Criminals whose activity increased during this period. There have been several legislations enacted by the Indian legislature in order to combat Cyber Crimes. However, they often lack proper implementation. Moreover, the lack of awareness amongst the general population regarding Cyber Crimes also contributes to the increase in the incidences of Cyber Crime.

II. Causes for the growth of cyber crimes against women

The number of incidents related to Cyber Crimes that have taken placed in India have gone up from just 966 in the year 2010 to 27, 248 in the year 2018. In the last one year, the complaints registered with the National Commission of Women have increased from 20,309 in the year 2019-20 to 26,513 in the years 2020-21. A significant increase has been witnessed in the complaints related to Cyber Crimes. Therefore, it is clear that there has been a rise in the crimes against women in the society post the digital revolution. The internet has become easily accessible to a large majority of the Indian population which has furthered the scope of the criminals. Therefore, the legislature and the executive must act expediently and ensure that the menace of Cyber Crime is curbed.

The courts have also understood the implications of the act and have accordingly provided the judgments. However, in order to fully understand and limit the incidence of Cyber Crime, the causes behind the same also need to be analysed. Some of the major driving factors leading to the growth of Cyber Crime against women have been discussed below.

• It has become a profession for some people who make a living out of it. The money involved in Cyber Crime is lucrative and has enabled the perpetrators to make money from the comforts of their home. The activities often do not require sophisticated technical skills which further increases the allure of the crime.
• The Indian society is largely patriarchal and women are often oppressed in families. They use the internet as way to seek liberation and freely express themselves. This provides a vulnerable target for online predators. In addition to this, if a woman becomes a victim of a Cyber Crime and exposes the same to her family, there is a significant chance that they will not report it to keep the family’s honour intact or for various other reasons. This factor further empowers the Cyber Predators.⁸
• The victim also fears on a personal level that if she reports the Cyber Crime, the consequences can be disastrous. Even if she is provided justice, there is a chance that the images are already circulated over the internet and her reputation is tarnished. This makes her life in the society unsustainable.⁹
• There is also a lack of general awareness about the usage of computer amongst new women users. This particularly renders them vulnerable. They are often not aware of the laws against Cyber Crime.¹⁰ In addition to this, identities can easily be faked over the internet. This allows the perpetrators to maintain a fake image and lure the women into their trap, furthering the incidence of Cyber Crime.¹¹
• There has been a change in the lifestyle of women where they use the internet in order to have some time for relaxation and enjoy a break from the regular schedule. It is common for an internet user to make a profile on various social networking sites and indulge in conversations. However, the women are often taken advantage of by the Cyber Predators who commit Cyber Crimes against these women.
• There is a severe lack of Cyber Forensic Labs and Cyber Forensic Experts. The Police often do not possess the technical knowhow to adequately conduct an investigation related to Cyber Crimes. The crimes are often committed anonymously and there is the need for a cyber expert in order to decipher the true identity of the culprit. The Police often miss out on vital clues which leads to acquittal of Cyber Criminals.¹²

III. Impact of cyber crimes on women

The Cyber Crimes also have an adverse effect on the overall well-being of women. The psychological and emotional consequences of cyber victimization include, “depression, suicide, self-harm, anxiety, Post-Traumatic Stress Disorder and fear of future online victimization.”¹³ The consequences of Cyber Crimes for women can be disastrous and lead to disturbance in future relationships. It can also lead the person to isolate herself from her friends and family. There is also the possibility that the victim feels vengeance towards the perpetrator. It might cause the victim to take some extreme step in the moment of rage in order to fulfil the desire for revenge. This could lead the victim turning herself into a criminal as well. This means that when a woman is a victim of a Cyber Crime, it can render her helpless, hopeless and have a significant negative impact on her mental and emotional well-being. It acts as a barrier in the empowerment of the women and has a devastating effect on her growth. Therefore, the impacts are significant and can last for the entirety of the life of the victim.

The Crimes against women and children in general have also been on the rise. This has posed a serious threat to the safety of the women and even their children in India. The graphical representation below shows the incidences of crimes against women and children in 2020. The numbers are significant and a large portion of the population is affected by such crimes. They also indicate the decay of societal values in general and reflect poorly upon the nation.

India’s Crime Graph in 2020

Source: National Crimes and Record Bureau (2020)

IV. Growth in cyber crime during covid-19 crisis

The Covid-19 Pandemic further brought an increase in the online activity which further led to an increase in cyber crimes over the internet. The graph below shows the corresponding increase in Cyber Crime between 2019 and 2020. There has been an increase in number of cases filed in 2020 under Sections and various legislations that deal with Cyber Crime from 44,735 in 2019 to 50,035 last year. This shows the seriousness of the issue and the additional dangers posed by increased online activity.

Graph depicting the rise in the number of cases filed under various sections related to cyber crime

Source: National Crime Record Bureau

The National Commission of Women (NCW) also highlighted the adverse impact of the Covid-19 Pandemic on the women in India. It states that there has been a 25 per cent rise in complaints to the commission recorded by women as compared to the previous year. There was increase from 20,309 complaints in the year 2019-20 to 26,513 complaints in the years 2020-21. A large number of the complaints registered with the NCW were regarding the violation of the right to live with dignity with 8,688 women approaching the commission for the same. The incidences of cases related to domestic violence also increased drastically from 3,369 in 2019-20 to 6,049 in 2020-21. The graph below shows the number of complaints filed by aggrieved women before the NCW.¹⁴

Complaints by Aggrieved Women

Source: National Commission for Women

The increase in Cyber Crime is clearly visible. There are also several reasons for the lower reporting of cases relating to Cyber Crimes due to lack of awareness and the societal fear related to the same. In addition to this, there were several first-time users of the internet during the Pandemic who were not having sufficient knowledge to comprehend that a Cyber Crime was being committed against them or had the knowledge of the appropriate remedies that can be sought.

The Chairperson of the NCW also highlighted the grim situation for women during the Pandemic. She stated that, “At one point during the lockdown, our team was working in three shifts to record and address the complaints of aggrieved women.” Moreover, a report by a Parliamentary Panel led by Congress MP Anand Sharma stated that, “The committee notes that there was a sudden spurt in domestic violence and trafficking of women and children during the unprecedented Covid-19 Pandemic outbreak.”¹⁵

The situation in the National Capital of the country, New Delhi, highlights the prevalence of Cyber Crime during the Pandemic. As per the data by the National Crime Records Bureau (NCRB), there was a decrease of 24% in crimes against women in the year 2020. The incidents came down from 12,902 in 2019 to 9,782 in the year 2020. However, in the same period, there was 55% increase in the Cyber Crimes reported in the National Capital. There was an increase from 107 cases in 2019 to 166 cases in 2020. A Senior Police Officer also made the observation that the increase in Cyber Crimes can be linked to the lockdown induced due to the Pandemic, which provided further opportunities to Cyber Criminals to find ways to cheat people.¹⁶

V. Legal safeguards for women against cyber crimes

Women are one of the most targeted victims of Cyber Criminals. They often prey on new internet users who are vulnerable to their attacks. The chart below shows the figures related to cases registered with respect to crimes against women from 2015 to 2020. It reports the specific sections of Indian Legislation where cases have been reported against women. There is a possibility that the actual figures are greater since a lot of incidents often go unreported and the women have no clue what to do when they become a victim of a Cyber Crime.

Reported Cyber Crime Against Women

Source: National Commission for Women

Some of the most commonly occurring Cyber Crimes against women in India are discussed below.

1. Indian Penal Code, 1860

1.1.1. Section 354 A provides for the definition and the punishment for the offence of sexual harassment.

It states that, “A man committing any of the following acts— (i) physical contact and advances involving unwelcome and explicit sexual overtures; or (ii) a demand or request for sexual favours; or (iii) showing pornography against the will of a woman; or (iv) making sexually coloured remarks, shall be guilty of the offence of sexual harassment.”

It further provides that, “Any man who commits the offence specified in clause (i) or clause (ii) or clause (iii) of sub-section (1) shall be punished with rigorous imprisonment for a term which may extend to three years, or with fine, or with both.” The punishment for a crime contained in clause (iv) is “imprisonment of either description for a term which may extend to one year, or with fine, or with both.”

1.1.2. Section 354 D provides the definition of stalking. It states that,

“Any man who –

(i) follows a woman and contacts, or attempts to contact such woman to foster personal interaction repeatedly despite a clear indication of disinterest by such woman;

(ii) monitors the use by a woman of the internet, email or any other form of electronic communication, commits the offence of stalking.”

It further provides the punishment for stalking. It states that, “Whoever commits the offence of stalking shall be punished on first conviction with imprisonment of either description for a term which may extend to three years, and shall also be liable to fine; and be punished on a second or subsequent conviction, with imprisonment of either description for a term which may extend to five years, and shall also be liable to fine.”

The section has been under the Criminal (Amendment) Act, 2013 and has given stalking a comprehensive definition. Moreover, the legislature also realised that the victims of stalking over the Internet were usually women and the offence as of date can only be made out against a man.

The explanation to Section 354-C of the IPC deals with the instances where the women has given her consent for the pictures to be captured but not for their dissemination. It states that, “Where the victim consents to the capture of the images or any act, but not to their dissemination to third persons and where such image or act is disseminated, such dissemination shall be considered an offence under this section.” The act also provides for the punishment for the perpetrator. It states that the perpetrator, “hall be punished on first conviction with imprisonment of either description for a term which shall not be less than one year, but which may extend to three years, and shall also be liable to fine, and be punished on a second or subsequent conviction, with imprisonment of either description for a term which shall not be less than three years, but which may extend to seven years, and shall also be liable to fine.”

1.1.3. Section 499 of the IPC provides for the definition of the offence of defamation. A person guilty of the offence can be sentenced to imprisonment for u a period of up to two years.

2. Information Technology Act, 2000

There are several instances where the perpetrator befriends the victim and obtains intimate images or videos of the victim. After obtaining these, they are often used as a threat to coerce the victims into sexual acts or distributed online in order to shame the victim. Moreover, they are often used as a tool of revenge by jilted lovers which further creates issues for women. In addition to this, they may even be used for commercial purposes. Section 66 E of the IT Act, 2000 provides for the punishment for such an act.

2.1.1. Section 66E of the IT Act, 2000 provides the “punishment for violation of privacy.”

It states that, “Whoever, intentionally or knowingly captures, publishes or transmits the image of a private area of any person without his or her consent, under circumstances violating the privacy of that person, shall be punished with imprisonment which may extend to three years or with fine not exceeding two lakh rupees, or with both.”

2.1.2. Section 67 of the IT Act, 2000 provides for punishment for “transmitting obscene material in electronic form.” It provides that,

“Whoever publishes or transmits or causes to be published in the electronic form, any material which is lascivious or appeals to the prurient interest or if its effect is such as to tend to deprave and corrupt persons who are likely, having regard to all relevant circumstances, to read, see or hear the matter contained or embodied in it, shall be punished on first conviction with imprisonment of either description for a term which may extend to five years and with fine which may extend to one lakh rupees and in the event of a second or subsequent conviction with imprisonment of either description for a term which may extend to ten years and also with fine which may extend to two lakh rupees.”

2.1.3. Section 67 A of the IT Act, 2000 provides for punishment for “publishing or transmitting of material containing sexually explicit act, etc., in electronic form.” It provides that,

“Whoever publishes or transmits or causes to be published or transmitted in the electronic form any material which contains sexually explicit act or conduct shall be punished on first conviction with imprisonment of either description for a term which may extend to five years and with fine which may extend to ten lakh rupees and in the event of second or subsequent conviction with imprisonment of either description for a term which may extend to seven years and also with fine which may extend to ten lakh rupees.”

3. Indecent Representation of Women Act, 1986

The Section 4 of the Indecent Representation of Women Act, 1986, “prohibits the production, sale, letting to hire, distribute, or circulation by post any book, pamphlet, paper, slide, film, writing, drawing, painting, photograph, representation, or figure which contains indecent representation of women in any form.” The punishment for the same is provided under Section 5 of the act which states that, “Imprisonment which may extend to 3 years and fine which shall not be less than fifty thousand rupees, but which may extend to one lakh rupees.” It further provides for additional punishment in case of a second conviction. The punishment, “may extend to 7 years and fine which shall not be less than one lakh rupees, but which may extend to five lakh rupees.”

This section is useful when dealing with Cyber Crimes against women since the internet is also a place where the indecent representation of women under the purview of this Section can take place.

Therefore, there are several enactments under the Indian Legislation that can be used to tackle Cyber Crime against women. They have been interpreted in a positive manner by the Indian Courts in order to provide justice to women. However, there implementation at the ground level is still inadequate which has rendered them unsuccessful in the reduction of Cyber Crime against Women.

VI. Judicial decisions regarding cyber crime against women

There have been several instances where the courts of the county have faced cases related to Cyber Crime against women which have had a negative impact upon the whole nation. The impact of the cases has been acknowledged by the Courts and they have taken an expansive viewpoint in order to accommodate the new found instances of Cyber Crime.

Yogesh Prabhu v. State of Maharashtra¹⁷

The defendant had been accused of cyber stalking by the complainant. An investigation was conducted into the incident and a clear case of cyber stalking had been established. This led to the conviction of the petitioner under Section 509 of the Indian Penal Code, 1860 and Section 66 E of the Information Technology Act, 2000. It was the first case when an accused had been convicted for the offence of Cyber Stalking. It also influenced the amendment to the Section 354 of the IPC, 1860 where the offence of stalking was specifically added and its definition was enlarged to include the offence of cyber stalking.

Suhas Katti v. State of Tamil Nadu¹⁸

The complainant stated that the accused had been sending her obscene, defamatory and annoying messages on a message group on the Yahoo website. Moreover, she also received emails from the accused which were forwarded by him using a fake account. Moreover, the victim was also receiving calls from people who were under the impression that she was a sex worker. The police located the accused after investigation and arrested him. He was found guilty of offences and convicted under Section 469 and Section 509 of the IPC, 1860 and Section 67 of the IT Act, 2000. This was the first case where the accused was convicted for the offence of posting obscene messages over the internet.

SMC Pneumatics (India) Pvt. Ltd. v. Jogesh Kwatra¹⁹

The employee had been sending out derogatory, defamatory and obscene e-mails about the Managing Director of the company. The e-mails were sent anonymously. They were sent often to several business associates in order to tarnish the image and goodwill of the company. The defendant was identified by the plaintiff by availing the services of a private computer expert. An ad-interim injunction was granted by the Delhi High Court which, “restrained the employee from sending, publishing and transmitting e-mails, which are defamatory or derogatory to the plaintiffs.”

State of West Bengal v. Animesh Boxi²⁰

An intimate relationship had existed between the accused and the victim in the instant case. The accused used the promise of marriage in order to obtain intimate photos and videos of the victim. These photos and videos were later uploaded to a porn site without the victim’s consent. A case was filed by the victim before the Court. The court after understanding the details of the case, found the accused to be guilty and sentenced him to five years of imprisonment and fine of Rs 9,000/-.

Avinash Bajaj v. State (NCT) of Delhi²¹

In this case, the director of an online marketing website, Bazee.com, came under the scanner. A pornographic video was listed for sale on the website which was taken down within two days. However, in the meantime, there had been a few purchases of the video for which the website received a commission. The safety filters of the company failed to detect the video initially and a case was filed against the Managing Director. The court while dealing with the case came to the conclusion that the video was ‘obscene’. Moreover, the company can be said to have committed an offence under Section 292 of the IPC, 1860 due to the listing of obscene material for sale on its website. However, there was no question of the liability of the Managing Director of the company, since the concept of vicarious liability is not a part of the IPC, 1860. There was room to prosecute the director under Section 85 of the IT Act, 2000 if a suit had been filed for the same. The court also highlighted the need for appropriate regulatory framework in order to effectively deal with such cases in the future.

Therefore, the courts also understood the impact of Cyber Crimes, particularly those against women and have given well-reasoned decisions to support the laws meant for the protection of women against Cyber Crime. The Judicial Decisions have come a long way since the Information Technology Act, 2000 in order to ensure that the laws are implemented in a proper manner. This can be evidenced by the fact that the court included cell phone in the definition of a computer system as defined under the IT Act, 2000 in the case of Syed Asifuddin v State of Andhra Pradesh.²² Therefore, it can be seen that the Courts have played their roles in upholding and implementation of the law. The duty of implementation is with the legislature, the executive and the law enforcement agencies who have to ensure that they perform their roles as per the demands.

VII. Conclusion: a way forward

The internet ushered a revolution in human life and changed the world in a way that has never been seen before. However, it also gave birth to a new form of crime; Cyber Crime. Women are most susceptible to Cyber Crime and it can have grave impact upon their life. It was observed by the Union Minister for Women and Child Development, Ms. Maneka Gandhi in May 2016 that, “online abuse of women in India ought to be treated in the same manner as violence against women in the real world.”²³ This led to the creation of a new forum of redressal and instructions were also provided to the National Commission for Women for the creation of a system to take action against the abuse of women over the Internet.

A report was submitted by the National Commission for Women after a consultation on Cyber Crimes in India. The report was titled “Ways and Means to Safeguard Women from Cyber Crimes in India.” In this report, the commission recommended the development of more stringent laws, policies to discourage activities related to hacking, development of dedicated helpline number, imparting of legal knowledge, setting up of cyber forensic labs and imparting special training to members of law enforcement agencies in order to effectively tackle Cyber Crime.

The legislature has taken note of the growing crime against women and has amended the laws accordingly to accommodate for more provisions that specifically deal with crime against women. Moreover, the IT Act, 2000 and the IPC, 1860 have been regularly amended in order to keep pace with the changing times. The courts have also taken a progressive viewpoint and ensured that online perpetrators do not go unpunished. Despite the measures taken and the enactment of laws, implementation remains a key concern. In addition to this, there is a general lack of awareness amongst first-time internet users about the potential dangers of the internet. Moreover, the victims are often clueless as to how to report the crime and the situation tends to overwhelm them. In addition to this, in cases where the crime is accompanied by threats, it can become even more difficult to report it. Therefore, the State must take measures to remedy the situation and ensure that the internet is a safe space for women and they do not fall victims to Cyber Crime.

The menace of Cyber Crime is limited not only to India, but is a global phenomenon. Therefore, the efforts of one state cannot be sufficient. There is a need for global cooperation on the issue so that it can be tackled more effectively. In addition to this, the mechanisms for the redressal of grievances should be made more accessible. The public must be informed about the ways to register grievances. The major objectives should be to enhance the ease of lodging of complaints and reducing the delay in prosecution and investigation.

VIII. Suggestions

The following suggestions can be implemented in order to ensure that the Internet becomes a safer place for women and they are protected against Cyber Crime.

• Online Complaints Portal – The access to the portal for filing cases related to Cyber Crimes should be made easier and more user friendly. Any server related issues should be fixed at the earliest.
• Awareness Sessions – There should be regular sessions conducted across the country by the Governmental authorities and NGOs in order to educate women about the dangers of the internet and the potential setups used by Cyber Criminals. They should be taught how to identify dangers on the internet and contact the cyber cell in order to file a complaint.
• Strong Passwords – The women should be encouraged to make strong passwords and not share them with anyone, including their closest friends and family members. Different passwords should be used for different websites, so that even if one of them is compromised, it does not provide the predator access with more information related to the woman.
• Make the social media networks responsible: the social networking sites often protect their users and refuse to divulge information even when a crime is involved. Responsibility also needs to be placed upon them to develop grievance redressal mechanisms and cooperate with law enforcement authorities when dealing with Cyber Crime.
• Promoting the use of Antivirus Software and Firewalls – They are extremely useful in preventing the reach of Cyber Criminals and protect the users from malicious Cyber Attacks. The promotion of the usage of these kinds of software would assist in the reduction of the rates of Cyber Crimes.
• Increase in efficiency of the Justice Delivery Mechanism - The internet is a place where the content spreads like wildfire and the more the delay, the more the damage is caused to the victim. Therefore, it is essential that the steps related to investigation and prosecution are carried out expediently.
• Mental Health Counselling for victims of Cyber Crime – The victims of Cyber Crime often face serious mental health issues which may cause them to take irrational decisions that can lead to self-harm. The provision of counselling services for the victims of Cyber Crime will help them deal with the situation better and deal with the adverse effects of the incident.

“Violence against women isn’t cultural, it’s criminal. Equality cannot come eventually. It’s something we must fight for now.”

Samantha Power

Cyber Crime against women is one of the most recent forms of violence against women that has grown manifolds in recent times. The growth was furthered by the advent of the Covid-19 Pandemic. Therefore, it is essential that appropriate steps are taken in order to effectively deal with the menace of Cyber Crime against women.

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Footnotes

1. Author is a Research Scholar at Faculty of Law, Aligarh Mumbai University, India.

2. Author is an Advocate at UP Bar Council, Allahabad, India.

3. ‘The Promotion, Protection and Enjoyment of Human Rights in the Internet’, A/HRC/32/L.20, 27th June’2016. ↩

4. Number of social network users in India from 2015 to 2021 https://www.statista.com/statistics/27840 7/number-of-social-networkusers-in-india/ Last visited on: 5/11/2021. ↩

5. Boston Consulting Group & Retailers Association of India (2016), Decoding Digital @ Retail: Winning the Omnichannel Consumer ↩

6. Cyber Crime, Available at http://chandigarhpol ice.gov.in/cyber-crime.html (Accessed 6th Dec, 2021). ↩

7. Sharma A. & Singh A. (2018) Cyber Crimes against Women: A Gloomy Outlook of Technological Advancement, IJLMH, 3(1), 1-12. ↩

8. Halder, D., &Jaishankar, K. (2008). Cybercrimes against women in India: Problems, perspectives and solutions. TMC Academic Journal, 3(1), 48-62. ↩

9. Halder, D., &Jaishankar, K. (2011a). Cyber Gender Harassment and Secondary Victimization: A Comparative Analysis of US, UK and India. Victims and Offenders, 6(4), 386- 398. doi: 10.1080/15564886.2011.607402. ↩

10. Halder, D., &Jaishankar, K. (2008). Cybercrimes against women in India: Problems, perspectives and solutions. TMC Academic Journal, 3(1), 48-62. ↩

11. Saha, T., &Srivastava, A. (2014). Indian Women at Risk in the Cyber Space: A Conceptual Model of Reasons of Victimization. International Journal of Cyber Criminology, 8(1), 57-67. ↩

12. Lahiri, A. (2014, May 13). "Cyber forensic facility in India is inadequate". Retrieved from https://www.governancenow.com/views/interview/cyber-forensic-facility-india-inadequate. ↩

13. Brown, C. F., Demaray, M. K., & Secord, S. M. (2014). Cyber victimization in middle school and relations to social emotional outcomes. Computers in Human Behaviour, 35, 12-21. ↩

14. Sumi Sukanya Dutta, 25 per cent rise in plaints from women during Covid Pandemic: NCW latest report, The New Indian Express, available at: https://www.newindianexpress.com/nation/2021/jul/06/25-per-cent-rise-in-plaints-from-women-during-covid-Pandemic-ncw-latest-report-2326127.html (last accessed on 6^th December, 2021). ↩

15. Ibid. ↩

16. The Hindu, Crimes against women dip by 24%, cybercrimes see 55% rise: NCRB data, available at https://www.thehindu.com/news/cities/Delhi/crimes-against-women-dip-by-24-cybercrimes-see-55-rise-ncrb-data/article36486113.ece (Accessed on 6^th December, 2021). ↩

17. Yogesh Prabhu v. State of Maharashtra, C.C. No. 3700686/PS/2009. ↩

18. Suhas Katti v. State of Tamil Nadu, C No. 4680 of 2004. ↩

19. SMC Pneumatics (India) Pvt. Ltd. v. Jogesh Kwatra, CC No. 4680 of 2014. ↩

20. State of West Bengal v. Animesh Boxi, C.R.M. No. 11806 of 2017. ↩

21. Avinash Bajaj v. State (NCT) of Delhi, (2008) 150 DLT 769. ↩

22. Syed Asifuddin v State of Andhra Pradesh, 2006 (1) ALD (Cri) 96. ↩

23. Online trolling against Women to be considered violence: Maneka Gandhi, Deccan Chronicle, 18th May’2016. ↩