International Journal of Legal Science & Innovation

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Women ‘Pursuit’ for Rights and Empowerment among Sikkimese Society

by | Jun 26, 2019

Women Empowerment

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Abstract:

When we talk about the status of women in ancient society they were treated or preached as a Goddess Kali, Saraswati etc described in many texts of Hindus and the majority community in India, because of that they had a very special place in our Indian society. Some scholars have explained this mediocre status of women as a result of patriarchal code of living. The inflexible codes of behaviors as outlined for women in Brahmanical texts were also responsible for the low status of women in India. With time women status are changing where states as well as non state players are playing a significant role in empowering the position and status of women. There are many changes like giving 50% reservation for women in Panchyat after the Sikkim Panchyat (Amendment) Bill has passed in the legislature another changes is schemes like Chief Minister Rular Housing Mission (CMRHM) where house had been named after the women of the family. Besides that there are some non players who are actively participated to uplifment the status of sikkimese women in society. likewise many changes has been taking palce an attempt has been made for suggestion and recommendation in empowering women of both rural and urban areas and giving them a platform of political and economic self reliance so that their major decision making process bring changes in traditional ideas and strengthening and building trust and corporation.

Index Terms: Empowerment, Gender Studies, Sikkimese Women, State and Non- State Actors.

I. INTRODUCTION

Sikkim, a small and beautiful state nested in the Himalayas is a landlocked state bounded on 3 sides by the international border Tibet, Bhutan and Nepal in the North-East, East and West respectively and south by the Darjeeling district of West Bengal. It has a total population of 540851 (according to the 2001 Census) of which 47% are female. The Himalayan state of Sikkim became part of Indian Union in 1975 as a 22nd state. It has a total area of 7096 square km[1] which is the smallest compare to the other adjoining states of the Himalayas its has a total population of 6,10,5772 persons out of which 47.09% consist of women population(Census; 2011).

It’s clear that women are lesser in number compare to men, which also makes them to be in a minority group[2]. Throughout the world the women group has been widely subjugated and excluded from political, social and economic sphere, in which Sikkim is no such exception. On the other hand, it is to be elucidated beyond the two self-explanatory words, ‘Women Empowerment’[3] refers to complete emancipation of women from socio-economic shackles of dependency and deprivations, ‘to give strength and confidence’ to realize an individual ‘potential and capabilities’.  Apart from the various facets of women empowerment that needs to be addressed for a rounded out development are listed here they are as follows:

  • Human Right or Individual Rights
  • Social Empowerment of Women
  • Educational Empowerment of Women
  • Economic and Occupational Freedom
  • Empowerment through Legal Knowledge
  • Political Empowerment of Women

Empowerment “implies the equal distribution of power between those who have more power and who have less power”[4]. The term also denotes increased control over the lives, bodies and environment that is in decision making, economic self reliance, legal rights to inheritance, equal treatment and protection against social discrimination (Kishore; 2004 in Dighe and Wadhwaniya; 3013) In past Sikkim under monarchy had no schemes to empower he local women they had no roles to play in major decision making process, the old law gave no rights to women it was basically about the men and the king. However women played an active role in agricultural, household activities etc., along with male members and some cases contributed more than male members but were confined to private sphere when it came to public sphere in lowest level like village meetings.

In that manner, it becomes important to critically study the role of women, their status in Sikkimese society and also to analyze their pursuit towards empowerment with the aid of state intervention in one hand and themselves in the other. In which former provides a platform by being a facilitator for the latter.

II. PAST WOMEN POSITION: POLITICIAL SOCIAL AND ECONOMIC EXCLUSION

Women’s relative status, however, varied from one ethnic group to another. Their social position in the State seems to be better than that in the rest of the country. At the economic, social, ritual, religious and political levels the women have equal rights with the men as claimed. A woman is considered to be an asset in the household and commands a bride price, but she has no rights of inheritance. It is only when a daughter remains unmarried that parents customarily transferring some property to her. The status of women in Sikkim – their economic contribution, socio-cultural autonomy, authority, involvement in the decision-making process within the household – varies across communities. The practice of polyandry among tribal communities could be one of the variables explaining the higher value attached to women. Similarly, local religious practice also plays a role in influencing the states of women (Dhamala, 1985). During the monarchical period most parts of state was controlled by the landlords (the Kazis) who “acted as a barons”[5] in order to collect taxes for king and rule with an iron grip where no women hold the post of landlords and neither in the kings ministry and the people had to suffer the atrocities in the form of forced labour (Sinha 2008) especially peasant women they were utilized for pleasure by the landlords with the aid of its henchmen. Socially they were exploited and legally they didn’t have any right.

However, with the help and support of Chogyal king Palden Thndup Namgyal along with his American Queen Hope Cook who started to endorse the national identity of Sikkim in International level and which made the two Sikkimese women i.e. Gayatri Devi Gurung and Chum Dorji Wangmo, travelled to Manila to attend a conference on women’s leadership organized by the Associated Country of the Women World where they represented the Sikkim social welfare society where they displayed items like Sikkimese national flag, thanka (religious painting), booklets about Sikkimese historical background etc[6].  On the other hand such initiatives bring a little impact on Sikkimese community and bring a positive impact in future. However, after such development in the year 1969 suddenly ‘Sikkim Durbar on 15th March commenced a proclamation of scrapping Sikkimese citizenship from women who marries outsiders[7] (non-sikkimese).  One of the victims of such proclamation was Ruth Karthak Lepchani who was debarred from her ancient property/asset, simply because she married non-sikkimese (Indian male) who belongs to Muslim Community. Though she revolted against that by forming a political party i.e. Sikkim Independent Front in 1966. But the Sikkim Government alleged her of spreading rumours against the King (Himalayan Observers in Basnet: 1974). Later, she was forced to leave the kingdom and never in her life to return to her birth place. Therefore, the above cited incident clearly marked that women were dominated and barred politically, economically and socially during monarchy.   After the proclamation has been issued by the Durbar for general public from that day onwards women had no rights over property inheritance legally, which was the major gust to the women community. Thus, it was social injustice in the form of gender inequality.

Paljor Namgyal Girls School was started by the Scotland Missionary to educate girls in 1968 but there were only eleven (11) girls in metric who mostly belong to the town and no such opportunities were available in villages (Savatri Rai: 2011). That’s why in the sphere of eduction literacy among women was very low as compare to boys in Sikkimese society. while in PNG, Tashi Namgyal Academy school where at town had ample of students who enrolled for primary education. The enrolment of girl child in education were very low as many would dropout or due to early marriage so once they get married they didn’t have any chance to continue their studies.   That time the state didn’t have open school for such married girls where they could have easily continued their further studies. During the year 1996 United Nations, Sustainable Development Department of Food and Agriculture Organization (FOA) conduct a report on Gender in Development and Socio economic relations in Sikkim which found that the women condition in Sikkim was poor where higher education for boys child was preferred more than the girls, and the reason for that was required household work, taking care of siblings and early marriage (Sikkim Development Report 2003). Due to the old law of Sikkim property inheritance for women was limited especially when she marries an outsider and there was a notable gap between urban educated women and their rural counterparts, and the relative opportunities available to each other[8].

III. PRESENT SCENARIO

Women constitute nearly 47 per cent of the total population of Sikkim. Compared to other parts of the country, the social position of women in Sikkim is better. Fortunately still now the instances of female infanticide or dowry related deaths have not been reported[9]. Women’s participation in decision -making process is more than most of the other states in India. Even their number in government services is greater than that of Sikkimese men (Lama: 2001). In the year 1990’s series of women empowerment policies was initiated by the government to improve, to uplift the status of women from the grass root level. Like ‘Small Family Scheme’ which encourage women to delay in early marriage and continue their studies. Not only that the policy provides an incentive of Rs 2,000 if she marries after the completion of 21 years, an additional incentive of Rs 5,00 if she marries at the age of 22 and if she marries at the age of 23, an additional incentive of Rs 1,000 is paid to her. So far the said scheme has covered over 1,200 children (Lama: 2001).

Women constitute nearly 47 per cent of the total population in Sikkim. Sikkim’s sex ratio (the number of females per 1,000 males) which had been declining between 1931–18 has begun to show improvement over the past three decades. In 2011, there were 889 women for every 1,000 men in Sikkim. Sikkim’s work participation rate is almost 51 per cent. While the figure for males in Sikkim is 60 per cent as against the national figure of 53 per cent, the female work participation rate at 40 per cent is much higher than the national average of around 26 per cent. There has been a shift in the occupational trends for both men and women. With the enhancement of educational opportunities and opening up of employment avenues in the state, the dependence on the primary sector has decreased drastically over the past forty years. The state government has been promoting rural livelihoods by creatively investing in ecotourism, organic farming, and a host of other potentially high-income generating activities. Availing these new opportunities, rural women are now increasingly involved in income-generating activities like food processing, trading agricultural products, handicrafts and weaving. In urban areas, women are making their mark in new fields such as consultancy, marketing, interior decoration, beauty clinics, handicraft, food processing and readymade garments. Notwithstanding this occupational diversification, agriculture continues to be the main source of employment for women 59 per cent of women workers are engaged in agriculture-related work where earnings are typically low and uncertain. Women have also benefited in terms of greater employment opportunities from the emergence of developmental projects and the expansion of the private sector. Women are also actively undertaking entrepreneurial roles. Under a new scheme of the state government “Educated Women Unemployed Co-operative Society” (EWUCS) administered by the Department of Co-operative Societies, women are venturing into the field of contract work and construction. At the same time, rural women are actively participating in employment provided by MGNREGA as indicated by the fact that the state has a total of 163,593 enrolled workers, out of which 53 per cent are men and 47 per cent women. The participation of rural women in self-help groups (SHGs) under the Swarna Jayanti Grameen Swarozgar Yojana is also commendable and outscores the participation of men. Of the total SHGs formed till January 2012, 72 per cent are all-women SHGs.

Government jobs: – The state government has a provision of 30 per cent reservation for women in posts and services to be filled by direct recruitment under the state government and public sector undertakings. This has certainly benefitted the educated women of Sikkim in gaining socio-economic empowerment, which is instrumental in achieving gender equality. However, women continue to be under-represented at the highest levels of bureaucracy. Overall, in spite of reservation, women represent only 21 per cent of total officers in the Groups A and B category. The general trend, however, indicates that steadily women are coming out of traditional shackles and embracing the emerging opportunities open to them.

Panchayat and Municipal Corporation:- Sikkim, one of the youngest states in the Indian Union, has made a slow yet steady progress in terms of the political participation of women. The stipulated reservation of one-third seats for women in Panchayats was increased to 40 per cent, and later enhanced to 50 per cent in 2011. The percentage of women in Panchayats, which increased from 36% in 2005 to 42% in 2010–11, has gone up to 52%  after the 2012 elections. The zilla Panchayat figures indicate a similar trend. These numbers suggest that the process of democratic decentralization has begun in a fair manner in Sikkim. However, political empowerment in the real sense is far from complete.

Female (education) literacy rate: – Education plays an important role in advancing women’s freedom and enhancing their position in society. Over the past 30 years, women in Sikkim have witnessed phenomenal changes in their literacy profile. In both rural and urban areas, the female literacy rates are higher than the national average. Female literacy rates more than tripled from 22% in 1981 to 76% in 2011.

Policies of Government: – The Government of Sikkim has introduced various policies, plans and programmes for improving the status of women and empowering them. The state established the ‘State Commission for Women’ (SCW) as a statutory body under the State Commission for Women Act, 2001 to safeguard the rights and legal entitlements of women. It began implementing the Protection of Women from Domestic Violence Act in 2007. The Act is aimed at providing speedy solutions to the victims of domestic violence by involving protection officers and voluntary organizations as service providers. The state government has appointed eight legal providers who are working towards protecting the rights and interests of women by providing of legal, medical, financial and other forms of assistance under the provisions of the Act. Also implemented and enforced are the Prohibition of Child Marriage Act, 2006; the Immoral Traffic (Prevention) Act, 1956 as amended up to Act No. 44 of 1986; the Sikkim Immoral Traffic (Prevention) Rules, 1990; the Dowry Prohibition Act, 1961 (28 of 1961); and the Implementation of Pre-natal Diagnostic Technique (PNDT) Regulation and Prevention of Misuse Act, 1996. In line with the Supreme Court’s Vishaka Guidelines, the state government has made it mandatory to set up complaint cells against sexual harassment in all government departments and institutions as well as in private organizations. Similarly, the Women and Child Development Division of the Social Justice, Empowerment and Welfare Department has adopted various strategies for empowering women through education and awareness generation. Training programmes have been set up for women in floriculture, knitting, tailoring and beautician courses. Two working women hostels (Deorali and Namchi) have been established to provide secure and economical accommodation to working women in the state. The state has introduced a Short Stay Home Scheme for the welfare of distressed women.

In the domestic sphere though Sikkimese society is not known for women domination in the form of dowry, sati, female infanticide etc. But there is usually presence of Domestic Violence and Violence against women by the study conducted by Society for Promotion of Art, Culture, Education and Environment Excellence (SPACE)[10] which highlights “that 50 percent of women are tattered by men and almost 4.8 percent by their in laws/relatives with the approval of their husband” (SPACE; 2002) and according to their research strongly recommended for the constitution of body (Government and NGO’s) which will guarantee protection of women from domestic violence. There are various milestones which show the empowerment of women in Sikkimese society. Like the formation of Nayuma Women’s Cooperative Society (NWCS) was one of the major milestones in the empowerment of women in Sikkim. And it became the first women cooperative in Sikkim which has women members belonging to the urban and rural areas. It is pro women society which and their end is to benefit the women of Sikkim by employing educated and uneducated women of urban and rural areas.  Another milestone is in the form of NGO Mamtalaya situated at Tadong, East Sikkim, actively participated in protecting women in distress and provide short stay home which works as a rehabilitation centre and runs side by side with Sikkim State Commission for Women. Therefore, such body’s provides a platform where women empowerment in social sphere is assured.  Such positive attitude of women community in Sikkimese society promises better scope for social capital[11] in building mutual trust and cooperation in achieving common goals providing positive effect in the society. Further, paving way for women community to their quest towards empowerment.

Despite the main gains there are few areas of concern regarding women position in Sikkimese society. There are three predominant communities in Sikkim like, Nepalese ethnicity largerly Hindu, whereas the Bhutia ethnicity and the Lepchas are predominantly Buddhists. In spite of the extension of Hindu Marriage Act of 1955 in Sikkim, the Bhutias and Lepchas of Sikkim are still governed and guided by their customary laws with respect to succession, inheritance, and marriage. Like Sikkimese Nepalese, the social systems of Sikkimese Bhutias and Lepchas have a patriarchal structure. All property, both movable and immovable, belongs to the father or male head of the family. Women have no legal rights in the family property, except their personal belongings and ornaments. Bhutia and Lepcha women may, however, acquire property by way of gift or under a will from their fathers or other relations. Under the Married Women Property Regulations Act, 1962, if Bhutia or Lepcha women marry outside their community, they shall surrender their rights to such property.[12] The Sikkim Succession Act, 2008 is progressive to the extent that it gives unmarried daughters the right of inheritance to an equal share in the father’s property along with the sons and wife. According to the Act: ‘When a male Sikkimese who dies having at the time of his death an interest in the property or has self acquired property, the property shall devolve to the extent of his interest by survivorship upon the surviving members of his family which includes his wife, sons and daughters if unmarried in equal proportion’. On the other hand, the Act reinforces traditional practices of inheritance by stating that: ‘Where female heir or descendent marries a person who does not possess Sikkim Subject Certificate/COI or has acquired foreign citizenship, such female heir/ descendent shall follow the personal law of her husband and as such shall not acquire any interest in the property’. Similarly, in the case of divorced women, the Act says: ‘An abandoned or divorced woman having liability to take care of the children and has no source of income, shall have the right to a share in equal proportion along with other heirs to the property as per the law provided that where woman has deserted her husband with or without children and has remarried shall forfeit her right to her share in the husband’s property’.  The National Crime Records Bureau (NCRB) reports show that crime against women in Sikkim is relatively low, numbering 48 cases and accounting for a mere 0.02 per cent of the total cases of the country in 2008, which is also the lowest among the north-eastern states. The figure for 2009 shows the lowest number of cases (41) of crime against women in Sikkim among all the states in India.[13] According to another recent survey by the Ministry of Health and Family Welfare, 16 per cent women in Sikkim are victims of domestic violence. One in every six women in Sikkim has experienced spousal sexual violence. Among women in the age group of 15–49 years in Sikkim, 19 per cent have experienced physical violence, while 4 per cent have experienced sexual violence. In all, 21 per cent women have experienced sexual and physical violence, including 22 per cent of married women. The Report states that women whose husbands consume alcohol and get drunk are much more likely to experience violence. Only 32 per cent[14] of women who have experienced violence have sought help. Almost three out of five women have neither sought help nor told anyone about the violence. Abused women most often seek help from their own families and friends.   The Family Counselling Centre (FCC) run by a non-governmental organization, the Association of Social Health in India (ASHI) and the State Social Welfare Board (SSWB) is an active organization working for women’s rights in the state. The victims generally come to the centre with complaints like adultery, torture and harassment by husbands and in-laws, desertion by husband, and alcohol-related maltreatment.

In wrapping up, women in Sikkim have a relatively better position as compared to their national counterparts and have benefitted, especially in the last decade, from educational and livelihood opportunities provided by the state government. However, as Sikkim strives for gender equality, there are certain areas of concern. A majority of women in Sikkim still have little respite from the drudgery of agricultural work. They continue to be under-represented in the highest levels of bureaucracy and in the legislative assembly. They also have a long way to go in getting an equal share in property and decision-making in public spheres. There is a need for an interventionist policy and a systematic onslaught against this social malady. Effective implementation of women-related programmes and legislations needs to be ensured in Sikkim. Proper awareness regarding their rights and privileges and access to information among women will help further accelerate gender equality and promote gender justice in the State.

IV. CONCLUSION

Women of Sikkim over the years have changed significantly due to global flow of ideas and cultural interactions which is driven by communication, technological revolution and with flourishing tourism and cooperative society. At the same time there is strong initiative from the state government in bringing change in the grass roots levels to empower the women.

The journey of women in the state of Sikkim has both highs and lows though they have not suffered as much as their counterparts in rest of India still gender inequality persist in the form of women property inheritance, domestic violence, a women cannot be pipon “village head” in north district of Sikkim where traditional system of governance “Zumsa” exist. It needs more responsible women cooperative society and caring Mamtalaya in rural parts of state and more state intervention in gender issue for empowerment of women. Lastly Sikkimese women are in progress to reach real empowerment which should come out from women itself helping in their quest of real empowerment.

V. REFERENCES

  1. Mackenzie, ‘The North-East Frontier of India 1995”, New Delhi: Mittal Publications.
  2. Pakem, “The Question of Ethnic Formation among the Hill People of North-East India (1990),” in B. Pakem (ed). Nationality, Ethnicity and Cultural Identity in North-East India. New Delhi: Omsons Publications, pp. 109-120.
  3. Census of India, Provisional Population Totals: Sikkim, paper 2, Vol 2011 (2011) Directorate of Census Operations, Sikkim.
  4. Grootaert and V. Bastelaer, “A Synthesis of Findings And Recommendation From The Social Capital Initiative (2001)”, Published by Social Development Department Publications The World Bank, Washington DC, USA.
  5. Government of India, ‘National rural employment scheme:2006 to 2007’, Department of Rural Development, New Delhi, 2006
  6. Government of India, ‘Sikkim Development Report 2003 (2008)’, Published by Academic Foundation, New Delhi, Under arrangement with planning commission of India, New Delhi.
  7. Government of India, ‘Research Abstracts on Women’s Empowerment 1998- 2008’, Documentation Centre for Women and Children National Institute of Public Cooperation and Child Development, Siri Institutional Area, Hauz Khas, New Delhi, 2009.
  8. Government of Sikkim, ‘MGNREGRA in Sikkim (2001)’ Rural Managment and development department, Gangtok, Sikkim.
  9. Government of Sikkim, ‘Annual Report 2004-2005,’ The Sikkim State Commission for women, Chairperson Smt. Manita Pradhan, Old Secretariat Building 31 A- National Highway, Gangtok, East Sikkim.
  10. Government of Sikkim. ‘Annual Report 2007-2008, The Sikkim State Commission for Women, Chairperson Smt. Subhadra Rai, Old Secretariat Building 31 A National Highway, Gangtok, East Sikkim.
  11. Hiltz, “Constructing Sikkimeses National Indentity in the 1960’s and 1970’s (2003)”, Bulletin of Tibetology 67. Namgyal Institute of Tibetology, Sikkim, India.
  12. Basnet “A Short Political History of Sikkim (1974)” Published by S. Chand & Co. (p) Ltd, New Delhi.
  13. Lotsüro and Angeline, ‘The Place and Role of Women in Tribal Society of Northeast India 2004,’ Jnanadeepa Journal of Theological Reflection, 7 (No. 1, Jan-June), pp. 93-108.
  14. Pawan Chamling, “Social Status of Women in Sikkim (1994)”, President of Sikkim Democratic Front, Headquarters Deorali, Gangtok, East Sikkim.
  15. M. Lama, Sikkim Human Development Report 2001, published by Government of Sikkim and Social Science Press, Delhi (2001).
  16. Dighe and Wadhwaniya, “The Unheard Voices-Empowerment of Women through Participation Socially, Politicaly and economically in India”, (2013), Journal of North East Studies, man and society, Vol X, ICSSR-NERC, Shillong Meghalaya.
  17. Khera et al. “Women workers and perceptions of the NREGA (2009),” Economic and Political Weekly, Vol XLIV No 43, New Delhi.
  18. Ruth Lalsiemsang Buongpui, “Gender Relations and the web of Traditions in Northeast India (2013),” the NEHU journal, Vol XI No.2.
  19. Sikkim Now (2009), SNS special, “Women turn out better”, Sunday Special, Gangtok, Sikkim, 03 May 2009.
  20. Pradhan, ‘NWCS role model of women empowerment (2008)’. Available at http://sikkimreporter.com//otherstories.htm.
  21. Ghatak, “Empowerment of Women- A case study in North Sikkim among the Lachenpa, Anthrolopogical survey of India (2004), 27 Jawaharlal Nehru Road, Kolkata- 700 016. Res: 12/1/G
  22. Eckman, “An overview of Gender-in-Development (GID) and Socio-economic Relations in Sikkim, India (1996). Available at URL:file://localhost/D:/HumanSecurity/08.08.2011/SDPeopleAnOverview ofGenderinDevelopment (GID) andSocio-economicRelationsinSikkim, India.htm
  23. Gandhi, “India of My Dream: Ideas of Gandhi (2009)”, published by Diamond Pocket Books (p) Ltd, New Delhi.
  24. Walter Fernandes, Melville Pereira et al. “Customary Laws in North East India: Impact on Women”, National Commission for Women, New Delhi.

[1]Herein after the acronym KM shall be used for the Kilometer

[2] About 75% of the population resides in rural areas.

[3] Article ‘Women Empowerment: It’s Meaning and Why Is It Important’ Cultural India, 6 Dec 2016. Available at http://learn.culturalindia.net/essay-women-empowerment-meaning-imporatnt.html

[4] Ghatak S. (2004) Empowerment of Women – A Case Study in North Sikkim Among the Lachenpa, Anthropological Survey of India, 27 Jawaharlal Nehru Road, Kolkata – 700 016.Res: 12/1/G Chanditala Lane, P.O. Regent Park, Kolkata-700040

[5] Basnet L. (1974), A Short Political History of Sikkim, published by S. Chand & Co. (P) Ltd, New Delhi.

[6] Hiltz J. (2003), Constructing Sikkimese National Identity In the 1960’s and 1970’s, Bulletin of Tibetology 67. Namgyal Institute of Tibetology, Sikkim, India.

[7] Basnet L. (1974), A Short Political History of Sikkim, published by S. Chand & Co. (P) Ltd, New Delhi.

[8] Eckman K. (1996), An Overview of Gender-in-Development (GID) and Socio-economic Relations in Sikkim, India, [online: web], Accessed 8 Dec 2011 URL:file://localhost/D:/HumanSecurity/08.08.2011/SDPeopleAnOverview of Gender in Development (GID) and Socio-economic Relations in Sikkim, India.

[9] Society, Women and Education in Sikkim, Shodhganga. Available at shodhganga.inflibnet.ac.in/jspui/bitstream/10603/149360/11/11_chapter_03.pdf.

[10] SPACE an NGO based on Gangtok underwent to study the presence of Violence against women and domestic violence in Sikkim in the year 2002.

[11] Robert Putnam defines social capital as those features of social organization, such as networks of individuals or households, and the associated norms and values that create externalities for the community as a whole

[12] Sikkim Human Development Report 2014, Expanding Opportunities, Promoting Sustainability, Government of Sikkim. Available at https://www.sikkim.gov.in/…/Sikkim%20Human%20Developent%20Report%202014….

[13] Ibid 12

[14] Ibid 13

Cite as: Neelam Rai, Women ‘Pursuit’ for Rights and Empowerment among Sikkimese Society, 1 Int’l J. of Legal Sci. and Inno. 2 (2019)