Friday, January 31, 2014

172nd Report "Precise issues".- The `precise issues' for consideration before the Law Commission.

Under an order dated August 9, 1999 made  in  Writ Petition  (Crl)  No.33 of 1997, the Supreme Court of India requested the Law Commission "to examine the issues raised  by the petitioners and examine the feasibility  of  making recommendations  for amendment of the Indian Penal Code or deal with the same in any other manner so as to  plug  the loopholes."
The  Supreme  Court  of  India  was approached for-
a) issuance of a writ in the  nature  of   a  declaration  or  any  other  appropriate  writ  or direction declaring inter alia that  `sexual  intercourse' as contained in section 375 of the Indian Penal Code shall include  all  forms  of penetration such as penile/vaginal penetration, penile/oral    penetration,    penile/anal penetration,  finger/vaginal  and  finger/anal penetration and  object/vaginal  penetration  and 
(b)  to   issue   a consequential  writ, order or direction to the respondents in the Writ Petition and to their servants and  agents  to register all such cases found to be true on investigation.
Though the  Law  Commission  was  not made a party to the Writ Petition.  The Supreme Court however directed the Law Commission, by its Order dated 13th January, 1998, to indicate its response with respect to the issues raised in the said  Writ  Petition. The Law Commission in its affidavit  dated  25.3.1998  brought  to the notice of the Hon'ble Court that the 156th Report of the Law  Commission on  the  Indian Penal Code had dealt, inter alia, with the issues raised in the Writ Petition,  but  since  the  said Report  was  not  yet placed on the table of the Houses of Parliament, the matter may be adjourned by a  few  months. The matter  was adjourned by three months.  Meanwhile, the aforesaid Report of the Law Commission was placed  on  the table of  both  the Houses of Parliament.  Thereafter, the Law Commission filed its affidavit dated  28.7.98  setting out  in  extenso  the  portions of the said Report dealing with the issues in question.  Suffice it to  say  that  by and  large  the  then Law Commission (14th Law Commission) did not agree with the viewpoint of the  writ  petitioners except  in certain minor respects which would be indicated at the appropriate stage later.  It is  after  considering the said affidavit and the affidavit filed by the Ministry of  Law,  Justice  and  Company  Affairs, that the Hon'ble Court passed the aforesaid order dated 9th August, 1999.
The  order  of  the  Hon'ble  Court  records   the statement  of the learned counsel for the writ petitioners that  the  contents  of  the  156th  Report  of  the   Law Commission  were  known  to the  petitioners,  but  since according to them the Report did not deal with the precise issues raised in the writ petition, a request was made  by the   counsel   for   the   petitioner   to  seek further consideration of the issues by the Law Commission and  the Government of India.  The Court was inclined to agree with the said submissions.  The Court also noted that the 156th Report  was submitted by the Law Commission prior to these issues being referred to the Commission and  further  that the  said  Report  of  the Law Commission did not in terms deal with various aspects of the issues raised in the Writ Petition. The  order  further  recorded  that   at   the suggestion  of  the Hon'ble Court, the petitioner did draw up a note containing the precise issues  involved  in  the Writ Petition  as  well  as other connected issues.  After perusing the same, the Court asked the Law  Commission  to examine the  said  issues afresh. A copy of the `precise issues' with the appendix and affidavit were sent  to  the Secretary, Law Commission with a request to place the same before   the   Chairman   of   the   Law   Commission  for consideration.   It  was  also  observed  that   the   Law Commission may, if so advised, call upon the petitioner to assist  it  in  such  manner  as  the  Commission  thought appropriate.  The issues,  the  Court  observed,  "need  a thorough examination".      The   matter  was  accordingly adjourned for three months within  which  period  the  Law Commission  was  expected  to  submit  its response to the Hon'ble Court.
The order of the Hon'ble Court was received by the Secretary to the Law  Commission  on 19.8.99  and  placed before the Chairman.
"Precise  issues".- The `precise issues' submitted by the petitioner before the Court  and which have  been sent  to  the Law Commission for consideration are divided into three parts (Annexure-A).  
Part I carries  the  title "Precise  issues  submitted  for  consideration of the Law Commission and the Government of India".  
Part II  carries the heading "Existing inadequacies" and 
Part III is titled "Suggestions for  amendment to the Indian Penal Code".  We shall set out in brief the substance  of  the  submissions made in all the three parts.

Part I: Precise issues submitted for consideration of  the  Law  Commission and the Government of India.- 
(1)  Having regard to the widespread prevalence of child sexual abuse, would it not be appropriate to include all forms of penetration   such    as    penile/vaginal    penetration, penile/oral    penetration,    penile/anal    penetration, finger/vagina    and    finger/anal   penetration     and object/vaginal  penetration  within  the  meaning  of  the expression "penetration" in the Explanation to section 375 of the   IPC.      The   restrictive   interpretation   of  `penetration'  in  the  Explanation to section 375 defeats the very purpose and object underlying section 376(2)(f); 
(2)    Is it not wrong to classify the penetrative  abuse of  a child below the age of 12 as unnatural offence under section 377 IPC or as outraging the  modesty  of  a  woman under   section   354,   depending   upon  the  `type'  of penetration ignoring the `impact' on such child.
(3)    Is   it   not   wrong   to   continue   to   treat non-consensual  penetration  upon  such a child as offence under section  377  IPC  on  par  with  certain  forms  of consensual penetration  (e.g.   consensual homosexual sex) where consenting party can be held liable as an abettor or otherwise.

`Appendix A' appended to  Part  I  contains  three notes, which we shall refer to in seriatum: 
Note 1: The  Explanation to sections 375 and 376 says that "penetration  is  sufficient  to constitute  the   sexual intercourse necessary  to  the  offence  of rape".  By the Criminal Law (Amendment) Act 1983, raping of a woman under twelve years of age  was  made  punishable with  rigorous imprisonment  for  a term which shall not be less than ten years but which may be for life in addition to fine.    In such  a  situation, it would be appropriate to broaden the meaning of  penetration  to  include  not  only   vaginal penetration  but also anal and oral penetration as well as penetration by any part of the body or by any object.
Note 2: In a vast majority of child sexual abuse cases the penetration is   other   than   penile-vaginal.       Such penetration  causes  lasting  psychic damage to the child.  In such a situation, a  restrictive  meaning  attached  to penetration is likely to prove inadequate.
Note 3(a):     The 156th Report of the Law Commission has recommended  that  penile/oral penetration and penile/anal penetration be covered by section 377 IPC and that  finger penetration and object penetration into vagina or anus can be adequately covered under section 354 with a more severe punishment.  This recommendation requires reconsideration. Such  a  restrictive view fails to take into consideration several forms of child abuse and  the further  fact  that very  often  the  sexual  abuse  of children is by persons  known to them.  As  a matter  of  fact,  rape  is  really intended   to   humiliate,  violate  or  degrade  a  woman sexually. It adversely affects the sexual  integrity  and autonomy of   women   and   children.      The   aforesaid  recommendation of the Law Commission therefore defeats the very object underlying the Criminal Law  (Amendment)  Act, 1983  which  inserted  sub-section  (2)  and in particular clause (f)  thereof   in   section   376. 
The   above recommendation  also  does  not take into account the fact that a child of tender years can not discern the degree of difference  in  terms  of  which  orifice   of   hers   is penetrated.    Certain  instances  are  then  set  out  to illustrate the aforesaid point.
Note 3(b):     Under this note, the petitioner has sought to argue in the light of  the  instances mentioned  under Note  3(a)  that  the  156th  Report of the Law Commission requires reconsideration.
Part II:       Existing  Inadequacies.-   Various instances  set  out in Appendix-B to Annexure-A (a copy of the submissions of Sakshi including Appendix-B is enclosed herewith) to this part, the petitioner argues,  would  not
amount  to  rape  and  perhaps not even to natural offence under section 377 or to outraging the modesty of  a  woman under section  354,  in  view  of  the existing law.  They might just be a limited form of assault or criminal force, if at all, though all the said instances are  of  a  grave nature and   extremely   disturbing.     It  is  therefore necessary that there should be a rethinking on this  issue and  the  offence  of  `sexual  assault'  should  be  more precisely defined and its parameters indicated.
Part III:      Suggestions   for   amendment   to Indian  Penal  Code.-  This  part  sets  out  the several amendments proposed by the petitioner.  Suffice it to  say that they seek to substitute the definition of `rape' with the  definition  of  `sexual  assault'  and make it gender neutral.  The object is to widen the scope of the offence. The expression `consent' is also sought to be defined.   A new  section,  section  375A  with the heading `Aggravated sexual assault' is sought to be created.  This new offence seeks to synthesise the offences  now  categorised under sub-section (2) of section 376 as well as sections 376B to 376D.

A copy of the draft of comments prepared by the Law Commission was thereafter forwarded to Sakshi inviting their views thereon and for suggesting changes of a procedural nature, whether in the Criminal Procedure Code or the Evidence Act.  Later on, three other organisations, namely, Interventions for Support, Healing and Awareness – IFSHA, All India Democratic Women’s Association – AIDWA and the National Commission for Women – NCW  also presented their views on the proposed suggestions.

After detailed discussions with these organisations, the Commission has recommended changes for widening the scope of the offence in section 375 and to make it gender neutral. Various other changes have been recommended in sections 376, 376A to 376D.  The commission have also recommended insertion of a new section 376F dealing with unlawful sexual contact, deletion of section 377 of the IPC and enhancement of punishment in section 509 of the IPC.  In order to plug the loopholes in procedural provisions, the commission have also recommended various changes in the Code  of Criminal Procedure, 1973 and in the Evidence Act, 1872.


The Hon’ble Supreme Court forwarded vide its order dated 18.2.2000 the comments of the petitioner on the Response and Recommendations of the Law Commission of India for consideration.  The Commission accordingly considered those comments and submitted its further response and recommendations dated 14.3.2000.


The Report focuses on the need to review the rape laws in the light of increased incidents of custodial rape and crime of sexual abuse against youngsters.  The crime of sexual assault on a child causes lasting psychic damage to the child and as such, it is essential to prevent sexual abuse of children through stringent provisions.  The UN Conventions and various constitutional provisions also underline the need for protecting the child from all forms of sexual exploitation and sexual abuse.  This above Report aims at the attainment of these objectives.


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