IMPACT OF THE BHARTIYA NYAYA SANHITA, 2023 RELATING TO SEXUAL OFFENCES

ABSTRACT

The Bhartiya Nyaya Sanhita, 2023 (BNS), a significant reform in Indian criminal law, introduces provisions relating to sexual offences. The study examines the impact of these changes on victims, accused, and witnesses, focusing on their alignment with criminal jurisprudence and constitutional principles. The BNS includes redefining sexual offences, strengthening victim-centric approaches, and introducing measures to safeguard under-trial people and witnesses. It aims to expedite justice, enhance protections, and ensure victims dignity. However, concerns about potential gaps, such as subjective interpretations of consent or implementation challenges, remain. The recalibration of the accused's rights raises questions about the adequacy of procedural safeguards in preventing misuse and wrongful convictions. Witnesses gain some protection through provisions to shield their identities and reduce harassment. Systemic challenges like delays, intimidation, and lack of support mechanisms may undermine these measures. The study looks at the BNS through the lens of criminal law, looking at concepts such as mens rea, proportionality, and due process. It then compares these to constitutional values such as fairness, equality, and dignity. The ultimate impact of the BNS will depend on consistent judiciary interpretation, robust enforcement mechanisms, and complementary societal reforms.

Keywords: Bhartiya Nyaya Sanhita 2023, Sexual Offences, Victim, Accused, Witness

Introduction:

The Bhartiya Nyaya Sanhita, enacted in 2023, replaced the Indian Penal Code of 1860, focusing on sexual offenses to modernize the legal system, protect justice, and ensure fairness. This research examines the BNS framework for sexual crime victims, suspects, and witnesses, determining its validity against constitutional requirements and criminal law principles. Sexual assaults violate human rights, assaulting personal dignity and endangering women and marginalized populations. The BNS framework aims to address current circumstances and ensure justice for all.[1]

The Bhartiya Nyaya Sanhita sets out methods to boost accountability while improving victim support programs and protecting the rights of everyone from defendants to witnesses. These changes will only be effective when implemented correctly as per established legal standards and constitutional frameworks. The impact of BNS on the criminal justice system receives analysis through an integrated research approach which includes doctrinal assessments and critical analysis.[2]

During the time when the IPC of 1860 received its legal framework India operated in a different sociopolitical environment than current times. Today's society widely condemns the existing sexual offence laws of the 19th century even though these standards were revolutionary at their time. Many people think that "modesty" in Section 354 of IPC remains outdated and patriarchal because it fails to properly address comprehensive sexual abuse problems. Public demonstrations led by public outcry alongside legal judgment in the Nirbhaya case during 2012 confirmed a need for new methods to deal with sexual violence crimes.[3] The 2013 Justice Verma Committee Report pointed out major deficiencies in existing laws and backed extensive reform proposals that aimed to resolve gender inclusivity problems as well as victim-focused procedures and systemic efficiency issues. Small amendments were introduced to the law during both 2013 and 2018 time periods. The BNS aims to develop an entire strategy which addresses identified problems through constitutional principles including Article 14 equality bounds and Article 21's dignity protections and Article 15's nondiscrimination clauses.[4]

The British National Standards Service (BNS) has made significant changes to improve sexual offences handling. These include a broadened definition of sexual offences to include digital voyeurism, stalking, and cyber harassment. The changes aim to address legislative deficiencies in the IPC, and include enhanced punitive measures like extended incarceration and increased fines. Victim-centric changes include expedited case processing, improved compensation programs, and private trials to prioritize victim dignity and mitigate trauma.[5]

Moreover, the use of gender neutrality in the definition of specific sexual offences acknowledges a wider range of victims and offenders outside conventional gender boundaries. The BNS incorporates protections for the accused and witnesses, guaranteeing procedural fairness and tackling systemic issues like intimidation and harassment.[6]

The BNS aims to address structural prejudices that have traditionally marginalised victims in the legal system. Augmented definitions and more stringent sanctions embody a victim-centered ideology that recognises the need for legal acknowledgement of the increasing manifestations of sexual assault. Nonetheless, the pragmatic difficulties of enforcement continue to be a problem. The efficacy of initiatives such as fast-track courts and compensation programs depend on strong infrastructural support and informed judicial staff. Also, the implementation of gender-neutral legislation, even though it is a positive step forward, makes people wonder how well public opinion and court interpretations match up with these changes to the law.[7] The BNS seeks to reconcile punitive actions with procedural protections to avoid the abuse of legislation. Provisions that guarantee equitable trials, like obligatory legal counsel and acceptable investigative timetables, are praiseworthy. Concerns emerge over the alteration of the burden of evidence in certain offences, thereby undermining the presumption of innocence, a fundamental principle of criminal law.[8] The implementation of mandatory minimum penalties for some offences raises concerns about judicial discretion and proportionality. Witnesses are crucial in ensuring justice in sexual crime situations. The BNS's efforts to safeguard witnesses against intimidation and harassment represent a commendable advancement. Nonetheless, structural challenges, including delays, insufficient witness protection programs, and public stigmatization, persist as substantial obstacles. Confronting these difficulties requires both legislative changes and administrative and social actions.[9]

The BNS's stipulations conform to constitutional tenets, including equality, dignity, and the safeguarding of life and liberty. The focus on gender neutrality, victim recompense, and witness protection demonstrates a progressive reading of Article 21 of the Constitution. When stricter laws and procedural protections work together, they cause lawyers to argue about the right balance between punishing people and changing their behaviour. Bhartiya Nyaya Sanhita, 2023, aims to modernise India's criminal justice system, especially with sexual assaults. The provisions indicate advancement; however, their efficacy relies on successful implementation, judicial awareness, and social change. The BNS aims to safeguard constitutional values and principles of criminal jurisprudence by balancing the rights of victims, the accused, and witnesses.[10]

the amendments made in rape laws

Amendment Act

Impetus

Key Changes in    IPC

Key Changes in    CrPC

Criminal Law (Second Amendment) Act, 1983

Mathura Rape Case (Tukaram v. State of   Maharashtra, 1972)

- Section 228A: Prohibition on disclosing the   victim’s identity.
 - Expanded definition of rape under Section 375.
 - Section 376: Increased punishment for rape.
 - Section 376A: Intercourse by husband during separation.
 - Section 376B: Intercourse by public servant with a woman in custody.
 - Section 376C: Intercourse by Superintendent of jail, remand house, etc.
 - Section 376D: Intercourse by hospital staff with a woman in hospital.

- Section 327(2) & (3): In-camera trials and   restriction on publication.

Criminal (Amendment) Act, 2013

Nirbhaya Rape Case (2012)

- Section 166A: Punishment for public servants   failing to record complaints.
 - Section 166B: Punishment for non-treatment of victims.
 - Section 376A: Punishment for rape causing death or vegetative state.
 - Section 376B: Sexual intercourse by husband during separation.
 - Section 376C: Sexual intercourse by person in authority.
 - Section 376D: Gang rape.
 - Section 376E: Punishment for repeat offenders.

- Section 154(1): FIR for sexual offences must be   recorded by a female officer.
 - Section 161: Statements of victims should be audio/video recorded.
 - Section 164(5A): Magistrate must record rape victim’s statement   immediately.
 - Section 197: No sanction required to prosecute government officials.
 - Section 309: Rape trials must be completed within 2 months.
 - Section 357B: Compensation must be paid in addition to the fine.
 - Section 357C: Immediate first aid and medical care for victims.

Criminal (Amendment) Act, 2018

Unnao & Kathua Rape Cases

- Section 376(1): Minimum punishment increased to   10 years.
 - Section 376(3): Rape of a girl under 16 years – punishment of 20 years to   life.
 - Section 376AB: Rape of a girl under 12 years – punishment of 20 years to   life or death.
 - Section 376DA: Gang rape of a girl under 16 years – life imprisonment.
 - Section 376DB: Gang rape of a girl under 12 years – life imprisonment or   death penalty.

- Section 374(4): Appeals in rape cases must be   resolved within 6 months.
 - Section 377(4): Appeals against rape punishments must be resolved in 6   months.
 - Section 438(4): No anticipatory bail in child rape cases.
 - Section 439(1A): Presence of informant required at bail hearings in child   rape cases.

Bharatiya Nyaya Sanhita, 2023

Legal Reforms – Replacing IPC

- Section 63: Definition of rape (Exception 2   raised marital rape exemption age from 15 to 18 years).
 - Section 64: Punishment for rape.
 - Section 65: Punishment for rape of minors (under 16 & 12 years).
 - Section 66: Punishment for rape causing death/vegetative state.
 - Section 67: Intercourse by husband during separation.
 - Section 68: Intercourse by person in authority.
 - New: Section 69: Punishment for deceitful intercourse (false promise   of marriage, job, etc.).
 - Section 70: Gang rape (combines 376DA & 376DB from IPC).
 - Section 71: Punishment for repeat offenders.
 - Section 72: Prohibition of victim’s identity disclosure.

- Largely retains prior CrPC provisions.

Ready Reckoner: Tougher Laws for Sexual Offences in BNS 2023 [11]

The BNS, 2023, signifies a substantial reform of India’s criminal justice framework, particularly concerning the protection of women and children from sexual offences. The BNS laws expressly tackle several facets of sexual assault, creating a more thorough and rigorous framework to protect against these offences.  The Bharatiya Nyay Sanhita (BNS), 2023 has included a new chapter entitled 'Offences against Women and Children.' Positioning this in the first section of the act (i.e., as Chapter V) underscores the significance attributed to addressing crimes against women and children. The use of electronic First Information Reports (e-FIRs) would facilitate prompt reporting of egregious acts necessitating urgent action. All provisions of POCSO will be applied if a minor is subjected to rape. The age threshold for consenting rape cases has been increased from 15 years to 18 years.[12]

Provisions in New Criminal Laws concerning Sexual Offences[13]

“Section 69: Sexual Intercourse by employing Deceitful Means etc.-

· Deceitful means includes inducement, false promise of employment, promotion, or marriage, and marrying by suppressing identity.

· The provision aims to address instances where sexual intercourse occurs based on false promises or inducement.

· Penalties: Offenders can face imprisonment for up to ten years. Fines may be imposed as an additional punitive measure.

Section 70: Gang Rape-

· The law now treats all cases of gang rape with equal severity, irrespective of the victim's age.

· Death sentence was provided under section 376DB of IPC for gang rape of woman under 12 years of age. No death penalty was provided for gang rape of woman aged below 16 years but above 12 years in section 376DA.

· Now, section 70(2) of BNS provides death penalty for gangrape of woman under 18 years of age.

· It renumbers existing rape provisions and harmonises the treatment of gang rape of minor women with the POCSO.

· Stringent Punishments:

o Offenders can face life imprisonment or even the death penalty for gang rape.

o The rationale behind such stringent penalties is emphasizing the gravity of the crime and the need for a strong deterrent.

· Just and Reasonable Fines:

o Any fines imposed are directed towards victim rehabilitation and medical expenses.

o Fines are intended to serve a just and reasonable purpose, aligning with victim-centric principles.

Section 82 (vs. IPC Section 494): Marrying Again During Lifetime of Husband or Wife:

· Marrying again during the spouse's lifetime is considered an offence.

· Exceptions exist for cases where the previous marriage has been declared void or in situations of absence for the space of seven years.

· Penalties:

o Offenders may face imprisonment for up to seven years and also fine.

o In case of deliberate concealment of the offence from the person with whom the subsequent marriage is contracted, punishment is imprisonment upto 10 years and fine.

o These penalties are in place to discourage bigamy and uphold the sanctity of marital relationships.”

Additional important changes[14]

· In addition to the aforementioned modifications in BNS relative to IPC, there are many significant changes in the provisions that have intensified the penalties and made them gender-neutral.

· Section 64 (1) imposes a penalty of ten years to life imprisonment for rape offenders, whereassection 64(2) prescribes a sentence of ten years to life imprisonment for severe types of rape, extending for the duration of the offender's natural life.

· The age of consent for a married woman, as defined in "Section 63 BNS and s. 375 IPC," has been raised from 15 to 18 years. “Exception 2 to s. 375 IPC” stipulates that sexual intercourse between a man and his wife, if the woman is not under the age of 15, does not constitute rape. “Section 63 of the BNS” preserves the marital rape exception.

· Section 75 BNS: This section delineates the offence of sexual harassment perpetrated by a male, including uninvited physical contact, explicit sexual advances, solicitation of sexual favours, non-consensual display of pornography, and sexually suggestive statements. The penalties for such offences include imprisonment for a maximum of three years, fines, or both.

· Section 77 BNS: This section addresses the act of seeing, recording, or distributing intimate photos of a woman without her permission. The word "private act" is defined, and the penalty for the first conviction is imprisonment for a minimum of one year, perhaps up to three years, in addition to a monetary fine. Subsequent convictions incur a more severe punishment of imprisonment for a minimum of three years and a maximum of seven years, in addition to a monetary fine.

· Section 78 BNS: This section pertains to the crime of stalking perpetrated by a male, characterised by persistent efforts to initiate human contact with a female despite evident indifference or surveillance of her internet communications. Stalking is subject to a maximum imprisonment of three years and a fine for the first conviction; for successive crimes, the sentence may grow to five years, accompanied by a fine. Exceptions are granted if the actions are aimed at avoiding crime, adhering to legal requirements, or are considered reasonable and justifiable under certain circumstances.

· Section 79 BNS: This section addresses the aim to offend a woman's modesty using verbal, auditory, or gestural means, or by displaying things meant to be seen by her. The penalty for this offence comprises simple imprisonment for a maximum of three years and a monetary fine. This section also addresses violations of a woman's privacy.

· Section 75 “Sexual Harassment”, defining the offence of sexual harassment, elucidating the actions that constitute sexual harassment, and detailing the associated punishments.

· BNS implemented gender-neutral laws concerning assault, the use of criminal force, and voyeurism in “Sections 76 and 77”.

· Section 96 (Changes to Section 366A of IPC): The BNS substituted the term "minor girl" with "child" in Section 96 to include both male and female individuals under 18 years of age.

· Section 135 “Kidnapping of All Children”: Criminalises the abduction of all individuals under the age of 18. It underscored the comprehensive safeguarding afforded to all youngsters.

· Section 137 (Changes to Section 361 of IPC): Broadens the definition to include the abduction of all individuals under 18 years as a criminal act. Section 361 criminalises the abduction of females under 18 years and boys under 16 years, but Section 135 BNS seeks to classify the abduction of all children under 18 years as a crime.

· Section 141 “Gender-Neutral Importation Offence”: This made the offence of importing humans from other nations gender-neutral by substituting "importation of girl" with "importation of girl or boy" to expand its reach.

LOOPHOLES IN THE BNS OF 2023

Despite BNS 2023, which includes several commendable initiatives, it also presents some disadvantages. The absence of marital rape as a distinct criminal offence is a significant concern. The legal uncertainty it generates compromises the BNS's ability to fully safeguard women. The BNS 2023 does not explicitly classify marital rape as a crime. This creates a significant legal protection void for married women. While certain instances of marital rape may fall under existing assault laws, this is not totally clear. This uncertainty discourages women from reporting marital rape, as they are uncertain about their legal alternatives. Moreover, it complicates the justice system's ability to hold criminals responsible for this egregious conduct.[15]

The efficacy of the BNS 2023 is contingent upon a strong legal framework. Efficient law enforcement, supported by adequate training, is essential for addressing sexual offences. This entails accelerating the procedures for collecting evidence and equipping law enforcement with sensitivity training. To provide justice for victims and deter future crimes, it is essential to establish a supportive judiciary that prioritises expedited trials and convictions. Expedited Justice: An accumulation of cases and delayed trials may diminish the impact of the BNS. Expedited justice ensures swift resolution for victims and conveys a clear message to potential perpetrators. These limits underscore the need to safeguard women in several aspects. We must efficiently execute legal reform and transform societal perceptions around sexual assault.[16]

The judiciary's legal interpretations are crucial for clarifying the application of existing laws in cases of marital rape. This may include examining texts that address violence or sexual assault by an authority person to see whether they might be interpreted to encompass marital rape. Women would be more inclined to report marital rape if there were unequivocal interpretations, assuring them that their cases would be treated with seriousness and adjudicated impartially.

There are no specific laws addressing marital rape. While rape incurs more severe punishments, the application of these sanctions to marital rape remains ambiguous. In these situations, the implementation of existing law requires the counsel of legal experts. This ambiguity renders women vulnerable in marriages. Preservation of IPC Provisions Regarding Sexual Harassment and Rape: The BNS2 upholds the IPC's stipulations against sexual harassment and rape. It overlooks the Justice Verma Committee’s (2013) recommendations, which advocate criminalising marital rape and establishing rape as a gender-neutral offence.[17]

The Bharatiya Nyaya Sanhita Act, 2023's omission of unnatural activities creates a substantial void in India's penal law. This section pertains to transgressions against the natural order, which are often rather rare. Nonetheless, the absence of regulations governing this kind of crime leads to a flagrant disregard for it, resulting in many offences being unpunished. The repeal of legislation concerning unnatural conduct regrettably empowers criminals, since they are no longer legally constrained from committing these offences. The Indian legislature's blatant ignorance is a violation of women's rights to equality.[18]

The BNS report, “Crack in the Shield,” exposed troubling deficiencies in combating sexual offences in 2023. Predators exploited systemic vulnerabilities, circumventing protections and infiltrating communities with alarming ease. Insufficient support systems and flawed reporting protocols rendered survivors vulnerable, and bureaucratic impediments often silenced their voices. The breach underscored the pressing need for comprehensive change, emphasising survivor-centric strategies and effective preventive measures. It ignited a broad demand for action, advocating for institutional accountability and cultural shifts in the understanding of consent and gender-based violence.[19]

Eradicating sexual offences requires a comprehensive overhaul of institutions and society norms, rather than just superficial remedies.

Conclusion

Bhartiya Nyaya Sanhita, 2023, signifies a gradual transformation in the treatment of sexual offences, integrating victim-centric changes while safeguarding the rights of the accused and witnesses. Nonetheless, effective execution, aligned with constitutional principles and doctrines of criminal law, is essential. The Bhartiya Nyaya Sanhita, 2023 (BNS), signifies a revolutionary method for addressing sexual offences within India's criminal justice framework. It seeks to optimise processes, augment victim protection, and accelerate trials; nevertheless, its effects on victims, accused persons, and witnesses must be understood within the framework of criminal jurisprudence and constitutional principles.

The legislation aims to enhance the rights and safeguards of victims of sexual offences by facilitating a more helpful judicial procedure. The accelerated investigation and trial schedules seek to minimise delays that often result in prolonged trauma for victims. This method demonstrates a commitment to prioritising justice and alleviating the hardships faced by victims in protracted cases. Moreover, measures to preserve the name and dignity of victims, including prohibiting the public revelation of their identities, are essential safeguards. The legislation guarantees that victims get legal assistance, ensuring their views are acknowledged with decency and respect. This signifies a departure from previous methods that often left victims vulnerable to public examination and condemnation. The implementation of more severe sanctions, including the death penalty for certain extreme instances, indicates a stricter approach to sexual assault, aimed at deterring prospective perpetrators.

Nevertheless, several critics indicate that the BNS emphasises punitive measures, especially the death penalty. The law prioritises punishment; however, detractors contend that a restorative approach may be advantageous for healing and crime prevention. Furthermore, while the legislation provides safeguards for victims, some sections may unintentionally impose further strain on them, particularly when they are required to testify in emotionally charged settings that might intensify their suffering.

The BNS aims to strike a compromise between safeguarding the victim's rights and upholding the rights of the accused. The hurried trial process may alleviate the emotional burden on the accused; yet, there are apprehensions that the rapidity of the process might compromise the comprehensiveness of investigations and the defense's capacity to contest the claims. This may result in unjust judgements or hasty conclusions, perhaps causing false convictions. In addition, harsh punishments, like the death penalty in some cases, raise questions about whether or not this kind of harsh system is really necessary to do justice, especially when there are doubts about the truth of the accusations.

Witnesses are essential in the judicial process, especially in sexual crime instances when physical evidence may be inadequate. The BNS includes rules that safeguard witnesses from intimidation and harassment, including measures such as anonymity where required. This guarantees that witnesses may provide testimony without fear of retribution, which is particularly crucial in sexual offence cases when cultural pressures and personal safety concerns may deter persons from stepping forward. On the other hand, the law's heavy reliance on witness testimony may put a lot of stress on them, especially if they know the accused or the victim. This may lead to a reduction in witnesses coming forward or result in false or pressured testimony, adversely impacting the fairness of the trial process.

Bhartiya Nyaya Sanhita, 2023, signifies a transition to a more victim-centered paradigm in criminal law. By prioritising speed and efficiency, it seeks to alleviate victims' pain and provide prompt justice. The law's emphasis on punitive measures prompts enquiries over its ability to sufficiently balance the constitutional rights of the guilty with those of the victims. The legislation tackles notable deficiencies in the criminal justice system; nonetheless, its ultimate efficacy will depend on its adherence to constitutional principles while ensuring robust protection and justice for victims of sexual assaults.

The BNS emphasises the need to ensure that its implementation does not compromise the integrity of the judicial system. Using both restorative justice and punitive measures may be the best way to deal with sexual assault as a whole, promoting social healing while making sure that everyone is treated fairly in the legal process. In order to make the law better and make sure that it works fairly for both victims and the accused, it is important to keep looking at how it is being applied and how it affects the criminal justice system.

[1] Kushwah, Jai Prakash, and Suraj Pratap Singh Kushwah. "Impact of the Bhartiya Nyaya Sanhita, 2023 Relating to Sexual Offences: A Study of Its Effects on Victims, Accused, and Witnesses in the Light of Criminal Jurisprudence and Constitutional Principles." Research Inspiration 9, no. II (2024): 08-24.

[2] Gupta, B. D. "Law of Rape: Sec 63 of Bharatiya Nayay Sanhita: Does it require amendment? Yes." Journal of Indian Academy of Forensic Medicine 46, no. 2-Suppl (2024): 414-416.

[3] Kannan, D. "Criminal Law 2023: A New Face of Criminal Jurisprudence Critical Study." Issue 1 Int'l JL Mgmt. & Human. 7 (2024): 1950.

[4] Singh, Priyamvada. "Offences Against Women and Children under Bharatiya Nyaya Sanhita." Available at SSRN 4973425 (2024).

[5] Nanda, Ashim, and Archana Gupta. "Critical Analysis of The Bharatiya Nyaya Sanhita Bill 2023 With Special Regard to Laws Concerning Rape And Unnatural Offences." Panjab University Law Magazine-Maglaw 2, no. 1 (2023).

[6] Akhil Kumar, K. S. "The Bhartiya Nyaya (Second) Sanhita 2023: An Integrated Perspective-A Comprehensive Study and Analysis." Jus Corpus LJ 4 (2023): 350.

[7] Mehta, Akta. "Evolution of Criminal Law in India: Analysing the Bharatiya Nyayaa Sanhita 2023 in the Context of Historical Legislation." GLS KALP: Journal of Multidisciplinary Studies 5, no. 1 (2025): 50-58.

[8] Khajanchi, Priyam. "Beyond the Facade: Gender Bias in India's Reformed Criminal Law." Nyaayshastra L. Rev. 4 (2023): 1.

[9] Shrivastava, Himanshu, and Sabeeh Akhter. "A Comparative Study of the Indian Penal Code and the Bharatiya Nyaya Sanhita’s Gender-related Provisions." Statute Law Review 45, no. 2 (2024): 33.

[10] Naik, Yeshwant. "The Bharatiya Nyaya Sanhita (BNS): A Critical Examination of India's New Penal Code." Available at SSRN 4884622 (2024).

[11] https://bprd.nic.in/uploads/pdf/202401261019259420204Tougherlawsforsexualoffences.pdf

[12] Chadha, Vaibhav, Shreya Saxena, and Manya Pundhir. "Conundrum of rape, consensual intercourse and perjury in India." Statute Law Review 45, no. 3 (2024): hmae053.

[13] Uma, Saumya. "Why the Bharatiya Nyay Sanhita is a missed opportunity for gender justice." The Wire (2024).

[14] Ali, SM Aamir, and Pritha Mukhopadhyay. "Bharatiya Nyaya Sanhita: Decolonizing Criminal Law or Colonial Continuities?." International Annals of Criminology (2024): 1-20.

[15] Gaur, Shiksha, and Vaishnavi Chauhan. "Aftermath of Nirbhaya case: An analysis on rape laws." (2024).

[16] Negi Advocate, Chitranjali. "Legal Evolution in India: Transitioning from Colonial Legacies to New Frontiers-An In-depth Analysis of Bharatiya Nyaya Sanhita, Bharatiya Nagarik Suraksha Sanhita, and Bharatiya Sakshya Bill in 2023." Bharatiya Nagarik Suraksha Sanhita, and Bharatiya Sakshya Bill in (2023).

[17] Mehta, Akta. "Evolution of Criminal Law in India: Analysing the Bharatiya Nyayaa Sanhita 2023 in the Context of Historical Legislation." GLS KALP: Journal of Multidisciplinary Studies 5, no. 1 (2025): 50-58.

[18] Arora, Simran, Satish Suhas, Guru S. Gowda, Venkata Senthil Kumar Reddi, and John P. John. "Avertible filicide: a call to action for early intervention and mental health support in India." Archives of Women's Mental Health (2025): 1-9.

[19] Naik, Yeshwant. "The Bharatiya Nyaya Sanhita (BNS): A Critical Examination of India's New Penal Code." Available at SSRN 4884622 (2024).