CRITICAL ANALYSIS OF CRUELTY AND DOWRY IN INDIAFAMILY LAW SYNOPSIS INTRODUCTION Violence against women is a phenomenon that cuts across boundaries of culture, class, education, ethnicity and age. The feminist movement of the 70s and 80s made a major contribution in getting VAW recognized as a critical area of concern in India. In the 1980s, the incidences of 'dowry death' were steadily rising in India, so women's organizations across the country pressurized the Criminal Law Amendment Committee (1982) and urged the government to provide legislative protection to women against domestic violence and dowry, so that the victim gets justice while she is still alive. As a result of the intense campaigning and lobbying, significant amendments were made in the Indian Penal Code, the Indian Evidence Act and the Dowry Prohibition Act, with the intention of protecting women from marital violence, abuse and dowry demands. The most important amendment came in the form of the introduction of Section 498A in the Indian Penal Code (IPC). This was the first time that an attempt was made to consider domestic violence against women a criminal offence. AIM OF THE STUDY The aim of the study is to make a detailed study and understanding of the sections 498 A and 304B of The Indian Penal Code and analyze their effectiveness and defects. SIGNIFICANCE OF THE STUDY Section 498A is providing relief to women and is sensitizing the Police force on gender issues. The section has saved women, who might have been dead from harassment and torture, had they not used section 498A. Dowry has been a prevalent practice in India's modern era and in this context, it can be in the form of a payment of cash or gifts from the bride's family to the bridegroom's family upon marriage. There are variations on dowry prevalence based on geography and class. This study thus helps to understand these concepts in a better way. SCOPE OF THE STUDY The scope of the study is confined to the social, economic and legal aspects of domestic violence, dowry and other aspects related to the sections of 498A and 304B of The Indian Penal Code in the context of the country India only. HISTORICAL BACKGROUND The system of Dowry existed in India even before the British Rule, but not in the format that is prevalent in the society today. In the pre-colonial period, dowry was an institution managed by women, for women, to enable them to establish their status and have recourse in an emergency. In this ancient system of dowry, the parents of the bride, even her kith and kin, all gave wealth to her in the form of valuable gifts etc. It was just like how parents used to give a part of wealth to their sons, so did they give it to their daughters too during the daughter’s marriage. What is very important to be noted here is that, the valuables or the wealth was given to the bride, and NOT to the groom or his family. In other words, the dowry wealth continued to be owned by the wife and not by the husband or his family. This gave the required financial independence to women who would even manage the income from their agricultural land, etc. REVIEW OF LITERATURE The problem of dowry, which is one of the major causes for violence, cannot be solved only with the help of law. She said that patriarchal norms influence the institution of marriage, subverting the role of women. Further, caste too plays a pivotal role in reinforcing dowry. Marriage within the caste is considered important, with dowry as an essential component. Every time a case relating to dowry death comes up, it causes ripples in the pool of the conscience of this Court Nothing could be more barbarous, nothing could be more heinous than this sort of crime. The root cause for killing young bride or daughter-in-law is avarice and greed. All tender feelings, which alone make the humanity noble, disappear from the heart. Kindness, which is the hallmark of human culture, is buried. Sympathy to the fairer sex, the minimum sympathy is not even shown. The seedling which is uprooted from its original soil and is to be planted in another soil to grow and bear fruits is crushed RESEARCH METHODOLOGY The researcher will do a descriptive and explanatory doctrinal study using various sources viz. books, other research papers and websites like Heinonline, Manupatraand EBSCO. HYPOTHESIS Though section 498A was enacted with many hopes and desires, it has not produced any worthwhile convictions. Many cases end in acquittal and the very process is agonizing as it may take several years. We seem to have trusted the law and rest content after making a law. Law has a very limited role. Just making a law to solve a grave problem like DV is not enough The emphasis should be beyond the law and referred to the role of society. REFERENCES http://www.498a.org/contents/judgements/SC_Defines_498a_and_304b_in_judgment.pdf http://legalsutra.com/1009/a-critical-appraisal-of-s-304b-of-ipc-a-study-through-case-laws/ http://www.hitxp.com/articles/history/origin-dowry-system-bride-woman-india-british/ http://304b.blogspot.in/p/section304b-indian-penal-code-dowry.html CONTENTS INTRODUCTION AIM OF THE STUDY SIGNIFICANCE OF THE STUDY SCOPE OF THE STUDY HISTORICAL BACKGROUND REVIEW OF LITERATURE HYPOTHESIS REFERENCES 1. INTRODUCTION 2. HISTORICAL BACKGROUND 3. 498 A AND STATUS OF WOMEN 4. SECTION 498A: SOME SIGNIFICANT PROBLEMS 5. SEC 498A AND THE ALLEGATION OF MISUSE 6. CRIMINAL LAW ON DOMESTIC VIOLENCE 7. ARTICLE 15 OF INDIAN CONSTITUTION 8. DOWRY ACT 9. CONCLUSION 10. BIBLIOGRAPHY INTRODUCTION This menace of Dowry has become a social menace in modern India leading to the oppression on women, physical violence on the bride, causing a financial and emotional stress on the parents of the bride, marital conflict and so on. This menace exists even today in the society even though it is a criminal offence to take Dowry during marriage. Prevention of domestic violence is a burning issue all over the world. But, as a society, India has not acknowledged the existence of violence within the family. Domestic violence is not confined to any one socio-economic, ethnic, religious, racial or age group. It is an issue of increasing concern because it has a negative effect on all family members, especially children. It has been found that children, who witness violence in the home, suffer many of the symptoms that are experienced in children, who are directly abused. Consequences of cruelty which are likely to drive a woman to commit suicide or to cause grave injury or danger to life, limb or health, whether mental or physical of the woman is required to be established in order to bring home the application of Section 498A IPC. Cruelty has been defined in the Explanation for the purpose of Section 498A. Though women are accused of misusing Section 498A not many women are aware about the law or have used it. The system of Dowry existed in India even before the British Rule, but not in the format that is prevalent in the society today. In the pre-colonial period, dowry was an institution managed by women, for women, to enable them to establish their status and have recourse in an emergency. In this ancient system of dowry, the parents of the bride, even her kith and kin, all gave wealth to her in the form of valuable gifts etc. It was just like how parents used to give a part of wealth to their sons, so did they give it to their daughters too during the daughter’s marriage. What is very important to be noted here is that, the valuables or the wealth was given to the bride, and NOT to the groom or his family. In other words, the dowry wealth continued to be owned by the wife and not by the husband or his family. This gave the required financial independence to women who would even manage the income from their agricultural land, etc. HISTORICAL BACKGROUND Status of Women In Ancient And Medieval India6 In ancient India, women occupied a very important position, In fact, a superior position, to men. "Sakthi" a feminine term means "power" and "strength". All male power comes from the feminine. Literary evidence suggests that kings and towns were destroyed because the rulers troubled a single woman. In Vedic times women and men were equal in many aspects. Women participated in the public sacrifices alongside men. One script mentions a female rishi Visvara. Some Vedic hymns, are attributed to women such as Apala, the daughter of Atri, Ghosa, the daughter of Kaksivant or Indrani, the wife of Indra. Hindureligion has been occasionally criticized as encouraging inequality between men and women, towards the detriment of Hindu women. This presumption is inaccurate. Hindu women enjoyed rights of property from the Vedic Age, took a share in social and religious rites, and were sometimes distinguished by their learning. There was no seclusion of women in India in ancient times. Women were made eligible for admission to what was known as the BhikshuniSangha, the Order of Nuns, which opened to them avenues of culture and social service and ample opportunities for public life. Women must be honored and adorned by their father, brothers, husbands, and brotherinlaw who desire great good fortune. Where women, verily are honored, there the gods rejoice; where, however, they are not honored, there all sacred rites prove fruitless. Where the female relations live in grief, that family soon perishes completely; where, however, they do not suffer from any grievance that family always prospers. The status of women in any civilization shows the stage of evolution at which, the civilization has arrived. The term 'status' includes not only personal and proprietary rights but also duties, liabilities and disabilities. In the case of a Indian woman, it means her personal rights, proprietary rights, her duties, liabilities and disabilities visavis the society and her family members. With regard to the status of women in Indian society at large, no nation has held their women in higher esteem than the Hindus. Perhaps, no other literature has presented a more admirable type of woman character than Sita, Maitriya, Gargi. The Indian civilization has produced great women ranging from Braham vadinis (lady Rishl) to states woman, from ideal wife to warrior queen. It dates back to thousands of years. Hindu mythology witnesses that the status of Hindu woman during the vedic period was honourable & respectable. Now that we are no more under aggression or invasion, we should allow the women community to regain their power, fame and name. It is we, who made Indira Gandhi, a woman as the prime Minister. It is we who placed the Mother before the Father in priority for reverence? Matr devo bhava was the first Upanishad exhortation to the young. Hinduism is the only religion whose symbolism places the Feminine on a par with the Masculine in the profound concept of SivaSakthi culminating in the image of ArdharnariIsvara. We have honored our country as our Motherland "Bharat Mata" and our nationalism has grown up from the seed Mantra "Vande Mataram". To analyze the impact of Islam on the status of women we have to look at the immediate preIslam Meccan society. It was tribal but had an active mercantile class The prophet's first wife was a businesswoman; the prophet had actually been her employee. The first Umayyad ruler's (Muaviya) mother Hinda actually controlled her clan and incited them to fight against Muslims. Women used to openly propose to men. Infact when the prophet accompanied by his uncle, was going to visit his future wife Bibi Khatija to propose to her, a woman stopped him on the way and offered him a hundred camels if he would marry her. "From affection springs grief, From affection springs fear, For one who is wholly free from affection, There is no grief, much less fear." One would expect that in medieval times women were almost like domesticated pets caged in the house, considering all the equality and libertarian movements the mankind has gone though. Lawmaker Manu's oftquoted statement that women are not worthy of freedom strengthens this expectation. However, the inscriptions, literary sources and sculptures of the period give an astonishingly different picture of status of women in South India in medieval times. It is evident from an inscripture of 1187 A.D. that the Jain nuns enjoyed the same amount of freedom as their male counterparts. There were female trustees, priestesses, philanthropists, musicians and scholars. Bondmaids and Working Women All menial tasks like cleaning in temples and private households were undertaken by bondmaids whose position was not high in the society. The saintpoet Basaveshwara tried to better their lot and that of their children by declaring that after initiation into Veerashaivism, the latter were to be considered holy and duly honored. In addition to their household duties, women gave a helping hand to their men in their vocations. The occupation of a nurse (dhatri) was quite common. Women also worked in fields. Institution of marriage Marriage was compulsory for all the girls except for those opted for asceticism. Brahman girls were married between ages 8 and 10 from sixth or century onwards up to the modern times. Polygamy was permitted to all who could afford and it was especially popular among Kshatriaysa for political reasons. According to Mansasollsa, the king should marry a Kshatria girl of noble birth for a chief queen though he is permitted to have Vaisya or Sudra wives for pleasure. Sati or Sahagamana Sati was prevalent among certain classes of women, who either took the vow or deemed it a great honor to die on the funeral pyres of their husbands. Ibn Batuta observed that Sati was considered praiseworthy by the Hindus, without however being obligatory. The Agni Purana declares that the woman who commits sahagamana goes to heaven and Medhatiti pronounced that Sati was like suicide and was against the Shastras. In an age of such divergent views, women of the Deccan followed a middle path. They were not coerced, although several wives committed Sati. The majority of the widows did not undergo Sati. Widows Alberuni writes that Indian women preferred self immolation by Sati to the suffering of life of a widow. Ibn Batuta also felt that the plight of widows was miserable. A widow was considered an inauspicious person and was prohibited from wearing colorful clothes, ornaments, decorate hair, as is seen from descriptions in literature. A few women of the time who despised their husbands, attracted other men by wanton behaviors. A sculpture in Bhatkal depicts a case of a woman's infidelity. A husband catches the paramour of his wife red handed and is about to punish him. Position of women before independence The Conflict of Women in 20th Century India Throughout recorded history, women the world over have been held to different standards than men. They have been consistently oppressed in nearly all aspects of life, from political to personal, pulic to private. In the 20th century, great strides have been taken to end this oppression and level the playing field. To understand the position women found themselves in at the dawn of the 20th century, one must have a general understanding of the numerous historical women's conflicts unique to the Subcontinent. It took the overwhelming success of Gandhi's nonviolent revolution to unite women politically and create the an atmosphere whereby women, empowered by the times, could take a stand for their equality. The 1970's saw the beginning of a highly organized modern women's movement in India. Violence against women was one of the main focuses of the movement. Harassment, wifebeating, rape, and dowry deaths were all too common, and police enforcement was ineffective as were most attempts at prosecution. Commonly called atrocities against women, these acts occurred frequently. The definition of dowry is wide to include all sorts of properties, valuable securities etc. given or agreed to be given directly or indirectly. Therefore the amount of Rs.20,000/ and 1.5 acres of land agreed to be given at the time of marriage is dowry, even though the said land was agreed to be transferred in the name of the deceased as 'pasupukumkuma' by executing a deed; Vemuri Venkateswara Rao v. State of Andhra Pradesh1 The population base of this movement was the rural and the toiling. This was important because the women of this group were already organized, although not all of these organizations with this base turned their focus toward feminist causes. 1974 was a pivotal year for the movement. Not only did it see the founding of POW (the Progressive Organization of Women), but it was the year that the official Status of Women Commission published their report, Towards Equality, on women's low and ever decreasing status in Indian society. This paper would add much fuel to the impending fire and validate it to the mainstream population. There were large conferences in Pune and Trivandrum in 1975 on women's issues further bringing the movement into the mainstream. Many autonomous groups popped up with different agendas and issues. 498 A AND STATUS OF WOMEN Section 498A of the Indian Penal Code (IPC), which defines the offence of matrimonial cruelty, was inserted into the IPC by an amendment in 1983. Offenders are liable for imprisonment as well as a fine under the section and the offence is non bailable, noncompoundable and cognizable on a complaint made to the police officer by the victim or by designated relatives. Article 498 A passed by Indian Parliament in 1983, Indian Penal Code 498A, is a criminal law (not a civil law) which is defined as follows, "Whoever, being the husband or the relative of the husband of a woman, subjects such woman to cruelty shall be punished with imprisonment for a 1 1992 Cri L.J. 563 AP HC. term which may extend to three years and shall also be liable to fine. The offence is Cognizable, noncompoundable and nonbailable. The section provides an explanation that elaborates the meaning of cruelty as follows: a) Any wilful conduct which is of a nature as is likely to drive the woman to commit suicide or to cause grave injury or danger to her life, limb, or health (whether physical or mental) of the woman; or b) harassment of the woman where such harassment is with a view to coercing her or any person related to her to meet any unlawful demand for any property or valuable security or is on account of failure by her or any person related to her to meet such demand." In another case Parveen Mehta vs Inderjit Mehta 11/07/2002 court clearly explained the meaning of the term cruelty as matrimonial offence and cause for granting divorce decree. In this case the defendant and appellant were husband and wife and the wife was suffering from some ailment and under treatment which was not disclosed to the husband during marriage. Thus the husband had appealed for a divorce decree on the grounds of cruelty and desertion which was granted by the High court and confirmed by Supreme Court when appealed against that order. Supreme Court thus dismissed the appeal from the wife and upheld the decision of High Court favouring divorce. 498a can only be invoked by wife/daughter in law or her relative. Most cases where Sec 498A is invoked turn out to be false (as repeatedly accepted by High Courts and Supreme Court in India) as they are mere blackmail attempts by the wife (or her close relatives) when faced with a strained marriage. In most cases 498a complaint is followed by the demand of huge amount of money (extortion) to settle the case out of the court. This section is nonbailable(you have toappear in court and get bail from the judge), noncompoundable (complaint can't be withdrawn) and cognizable (arrests without investigation or warrants) Section 498A: Some Significant Problems Any critical analysis of Sec 498A would be incomplete without understanding the history of crimina law reform in India. The demand for criminal law reform came about because of the large number of women that were dying in their matrimonial homes due to dowryrelated harassment. Therefore, the initial demand was for a law to prevent only dowry related violence. Sec 498A was thus introduced in the IPC in 1983 closely followed by Sec 304B which defined the special offence of dowryrelated death of a woman in 1986 and the related amendments in the Indian Evidence Act 1872. It is believed that Sec 498A and Sec 304B were introduced to complement each other and be part of a scheme, since Sec 304B addresses the particular offence of dowry death and Sec 498A sought to address the wide scale violence against married women for dowry In a bench headed by Justice Chandramauli Kr. Prasad and Justice Pinaki Chandra Ghose, gave a judgment in Arnesh Kumar vs State Of Bihar & Anr on (2 July, 2014) where the Supreme Court gave certain guidelines to be followed, they are, all state governments has to instruct its police officers that they cannot automatically arrest a person under Section 498a of IPC but and under parameters of Section 41 of Cr PC. These police people should be given check list specifying the Section 41(1)(b)(ii). Then these officers should fully add in the reasons which made them to arrest a person and then produce him before magistrate without delay for further actions. Magistrate can then authorise detention of such person only after perusing the reports produced by police officer and then record the same. If a decision has to be put for not arresting the accused, then it must be done within 2 weeks from the institution of the case and it has to be in writing to the Magistrate. Protection Only for Married Women Since the important campaign issue for feminist groups was dowryrelated harassment, all violence faced by women within homes was attributed to dowry both by activists and by the state [Agnes 1998]. This resulted in their articulating a demand for a law on domestic violence only for married women. The IPC was thus amended in 1983 and Sec 498A was added. It reads as follows: Sec 498A: Husband or relative of husband of a woman subjecting her to cruelty. Whoever being the husband or the relative of the husband of a woman, subjects her to cruelty shall be punished with imprisonment for a term, which may extend to three years and shall also be liable to a fine. Explanation – for the purpose of this section, "cruelty" means: (a) any wilful conduct which is of such a nature as is likely to drive the woman to commit suicide or to cause grave injury or danger to life, limb or health (whether mental or physical) of the woman; or (b) harassment of the woman where such harassment is with a view to coercing her or any person related to her to meet any unlawful demands for any property or valuable security or is on account of failure by her or any person related to her to meet such demand. Sec 498A and the Allegation of Misuse In the last 20 years of criminal law reform a common argument made against laws relating to violence against women in India has been that women misuse these laws. The police, civil society, politicians and even judges of the High Courts and Supreme Court have offered these arguments of the "misuse' of laws vehemently. The allegation of misuse is made particularly against Sec 498A of the IPC, and against the offence of dowry death in Sec 304B. One such view was expressed by former Justice K T Thomas in his article titled 'Women and the Law', which appeared in The Hindu.21 The 2003 Malimath Committee reporton reforms in the criminal justice system also notes, significantly, that there is a "general complaint" that Sec 498A of the IPC is subject to gross misuse; ituses this as justification to suggest an amendment to the provision, but provides no data to indicate how frequently the section is being misused. It is important therefore that such "arguments" are responded to, so as to put forth a clearer picture of the present factual status of the effect of several criminallaws enacted to protect women. Domestic violence and abuse by spouses and family members are complex behaviours and the social organisation of courts, the police and legal culturessystematically tend to devalue domestic violence cases. Sec 498A was introduced in the IPC in 1983 and the reforms of the past 20 years have not beenadequately evaluated at all by the government with respect to their deterrence goals, despite the institutionalization of law and policy to criminalise domestic violence. A programme of research and development is urgently required to advance the current state of knowledge on the effects of legal sanctions on domestic violence. The narrow or perhaps almost negligible study done by law enforcement agencies about the deterrent effects of legal sanctions for domesticviolence stands in high contrast with the extensive efforts of activists, victim advocates and criminal justice practitioners in mobilising law and shaping policy to stop domestic violence. It is important to do these studies to correct the general misconceptions that women are misusing the law by filing false cases against their husbands and inlaws in order to harass them and get them convicted. The perspective of the state and its agencies needs to change from that ofzprotecting the husbands and inlaws against potential "misuse" of the laws of domestic violence to that of implementing their real purpose – to recognise that such violence is a crime and protect women who have the courage to file complaints against their abusers. Criminal law on domestic violence On June 23, 2005 the cabinet approved the Protection of Women from Domestic Violence Bill, 2005, after which it received assent from Parliament. This approval brings to fore a new civil law on domestic violence, which provides immediate emergency remedies for women facing violence such as protection orders, non molestation orders, the right to reside in the shared household, etc. At this crucial juncture it is important that we re examine the historical background of these law reforms, and the existing criminal law provisions against domestic violence mainly Section 498A of the Indian Penal Code (IPC) to understand why a coordinated approach including civil and criminal law remedies is needed to address violence against women within the home. Domestic violence has since 1983 been recognised as a crime and also constitutes a considerable part of the workload of police, prosecutors and the courts. Few would claim however that the criminal law alone can solve the problem of domestic violence,1 which laid the foundation for the demand of a civil law to protect women and children. It is nonetheless legitimate to ask what the task of the criminal law should be in this sphere and to examine how far it is currently successful in carrying out that task. Article 15 of Indian constitution Article 15 of the Constitution prohibits discrimination on grounds of religion, race, caste, sex or place of birth. However, it allows special provisions for women and children. Article 21A provides for free and compulsory education to all children from the ages of six to 14 years. Article 24 prohibits employment of childrenbelow 14 years in mines, factories or any other hazardous employment. The court also took note of Article 14 guaranteeing equality, and Article 21 providingthat a person cannot be deprived of life and liberty except according to procedure established by the law. Similarly, Article 23 prohibiting human trafficking and forced labour was also referred to in the court’s judgment. Moving away from fundamental rights to the directive principles, the court pressed into service provisions relating to the health of women and children. Article 39(f) directs the State to ensure that children are given opportunities and facilities to develop in a healthy manner and in conditions of freedom and dignity, and that childhood and youth are protected against exploitation and moral and material abandonment. Article 42 directs the State to make provisions for just and humane conditions of work, and maternity beliefs. Article 45 stipulates that the State shall provide early childhood care and education for all children until the age of six. Article 47 lays down the raising of level of nutrition and standard of living of people, and improvement of public health as a primary duty of the State. Dowry act “Definition of ‘dowry’. In this Act, "dowry" means any property or valuable security given or agreed to be given either directly or indirectly. (a) By one party to a marriage to the other party to the marriage, or (b) By the parent of either party to a marriage or by any other person, , to either party to the marriage or to any other person, At or before [(Note: Subs. by Act 43 of 1986, sec.2) or any time after the marriage] [(Note: Subs. by Act 63 of 1984, sec.2) in connection with the marriage of the said parties, but does not include] dower or mahr in the case or persons to whom the Muslim Personal Law (Shariat) applied. Note: Explanation I omitted by act 63 of 1984, sec.2). Explanation II The expression "valuable security" has the same meaning as in section 30 of the Indian Penal Code (45 of 1860).”2 "Dowry" in the sense of the expression contemplated by Dowry Prohibition Act in a demand for property of valuable security having an inextricable nexus with the marriage i.e. it is a consideration from the side of the bride's parents or relatives to the groom or his parents and/or guardian for the agreement to wed the bridetobe. But where the demand for property or valuable security has no connection with the consideration for the marriage; it will not amount to a demand for dowry. The demand for valuable presents made by the appellants on the occasions of festivals like Deepavali is not connected with the wedding or marriage and these demands will not constitute dowry as defined in section 2 of Dowry Prohibition Act, 1961; Arjun Dhondiba Kamble v. State of Maharashra, 3 Any property given by parents of the bride need to be in consideration of the marriage, it can even be in connection with the marriage and would constitute dowry; Rajeev v. Ram Kishan Jaiswal, 4 2 The Dowry Prohibition Act, 1961 3 1995 AIHC 273. 4 1994 Cri L.J. NOC 255 (All). (iv) There had been no agreement between either parties to give any property or valuable security to the other party at or before or after the marriage. The demand of T.V., refrigerator, gas connection, cash of Rs. 50,000/ and 15 tolas of gold are not demand of dowry but demand of valuable security in view of section 2; Shankar Prasad Shaw v. State, 5 CONCLUSION Domestic violence needs a coordinated and systemic response from the justice system. While Sec 498A has been one of the most significant criminal law reforms protecting women's rights, this reform is not enough. Ultimately we need to remember that criminal law is indeed a blunt tool, as it is very difficult to change police culture; though the law may consider domestic violence against women an offence, the police may still not comply with the law and not implement it effectively. Therefore, in order to move towards an effective working of Sec 498A and other criminal law remedies, it is crucial that we put in place a new model of policing – the victim empowerment model as described above. A model that will put in place proarrest procedures and social service networks at the police station in order to give the victim alternative support services is needed. Most importantly, we need to work on standard and regular policing, which will ensure that domestic violence is taken seriously. Simply passing an Act and jotting it down on legal paper does not ensure that its main purpose will be served. In order to tackle this problem, the Ministry of Women and Child Development has issued another notification laying down rules framed for accurate implementation of the Act which also includes appointment of protection officers, service providers and counselors. Another very important feature of the new Act is women's right to secure housing, the statement said, adding it provides a right to reside in the matrimonial and shared household, whether or not she has any legal title in the household. Bibliography 5 I (1992) DMC 30 Cal. Agnes, F (1998): ‘Violence against Women: Review of Recent Enactments’ in S Mukhopadhyay (ed), In the Name of Justice: Women and Law in Society, Manohar Publishers and Distributors, New Delhi. Bard, M and J Zacker (1971): ‘The Prevention of Family Violence: Dilemmas of Community Intervention’, Journal of Marriage and the Family, Vol. 33, pp 677 82.18 Hoyle, C and A Sanders (2000): ‘Police Response to Domestic Violence: From Victim Choice to Victim Empowerment?’, Brit J Criminol, 40, pp 1436. IACP (1967): International Association of Chiefs of Police, IACP, p 3.
Report "Critical Analysis of Cruelty and dowry in relation to section 408A of Indian Penal Code (IPC)"