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Submitted to
Panel on Sex Workers
Constituted by the Honble Supreme Court of India
In the case of Buddhadev Karmaskar v Union of India

In the last eighteen months, there has been an increased spate of attacks by the police
against street-based sex workers in Bangalore. Sex workers have been brutally
assaulted, verbally abused and chased in public, and illegally detained in the police
station. Large sums of money have been extorted from them, and any attempt at
complaining has been met with further violence. The perpetrators of violence are
mainly policemen and women of the police stations in Upparpet, Cottonpet, KG Road
and Market, located in Central Bangalore. Most of these incidents have taken place in
Upparpet, and certain officers of Upparpet Police Station have been particularly active
in targeting sex workers. Many of the women targeted are members of Sadhana Mahila
Sangha, a collective of sex workers based in Upparpete. Sadhana was created in 2002 in
response to a similar series of incidents of police violence in Bangalore. In the twelve
years since their inception, Sadhana has worked towards collectivizing sex workers in
Bangalore, and in combatting violence, whether it be from the police, from clients, or
intimate partners. This present cycle of violence thus comes after a long period of
relative peace.With gradual documentation of these attacks, and conversations with the
police, a pattern emerges. This report of violence against sex workers is an attempt at
documenting some of those incidents, and presenting the possible reasons why sex
workers have again become a target in Upparpet..
This report has been prepared for submission to the Panel on Sex Workers, appointed
by the Honble Supreme Court of India in the case of Buddhadev Karmaskar v. State of
West Bengal.

This report has been prepared by members of following support organizations in

Bangalore, working with Sadhana Mahila Sangha and other sex workers organizations.
Alternative Law Forum
Peoples Union for Civil Liberties Karnataka
Janasahyog, Bangalore,

Upparpet is a busy commercial centre in Central Bangalore. It is close to the busiest
railway station in the city, Bangalore Central Station, and the largest bus terminus,
Kempegowda bus station, also popularly known as Majestic Bus Station. The entire area
is more commonly referred to as Majestic Area. It is one of the oldest and busiest
market areas in Bangalore, and it also serves as a major point of transit for travelers and
traders from different parts of Karnataka and the rest of the country.
Upparpet has been a hub of street-based sex work for many years. Many women travel
to Upparpete from different parts of Bangalore, and even Karnataka, Tamil Nadu and
Andhra Pradesh, to engage in sex work. As is the nature of street-based sex work, these
women work independently, and usually take their clients to nearby lodges or rooms.
Most of these women have families, who are not aware of their identities as sex
workers. Many of them are homeless, and they sleep in bus stands or railway stations.
Street-based sex workers are intimately acquainted with police violence. As selfemployed workers, they lack the protection of a brothel owner.And as a floating labour
workforce comprised primarily of migrants, street-based sex workers can find it
difficult to take collective action. In this context, the efforts of Sadhana Mahila Sangha, a
sex workers collective, are noteworthy. The Sadhana Mahila Sangha, which is a group
of sex workers and former sex workers operating in Upparpete, Cottonpete, KG Road,
Market and other areas, was born in response to police violence in 2002. Since 2002,
Sadhana has been organizing sex workers in the city, and responding to incidents of
police violence against sex workers. Members of Sadhana are now well known to the
Upparpete Police as social workers and activists.

Sadhanas work is unique among other sex workers collectives in Bangalore because of
their focus on the lived realities of sex workers lives. As former and current sex
workers, they recognize the pernicious role that violence on the streets plays in the lives
of these women. Permission to conduct their business in an area is conditional on

favours to the police, which may be monetary or sexual in nature. Sadhanas role has
been in breaking this circle of patronage, and in creating a sense of community in which
sex workers rely upon each other for protection and support. This is achieved through
weekly meetings of sex workers, where they discuss problems and issues faced through
the week. Sadhana also conducts regular night patrols of Upparpete, where members
survey the area to ensure that sex workers are not subjected to violence from clients or
the police, and that they conduct their business in a peaceful manner. Sadhana has also
conducted police sensitization programmes in the area.


Sadhana Mahila Sangha was created in 2002, after an especially brutal cycle of police
violence against sex workers. Geetha, one of the founder- members of Sadhana, came to
Bangalore in 1991 looking for a livelihood. She got into sex work after she was sexually
abused by a policeman. Police violence against sex workers at that time was brutal and
unimaginable. Sex workers would be regularly picked up, detained in police stations,
raped, and given electric shocks. Women would be thrown into the state home for
weeks at an end, where they would not be allowed to contact their families. False cases
would be filed against these women under the Narcotic Drugs and Psychotropic
Susbtances Act, colloquially known as ganja cases. The women were also subject to
horrific acid attacks from local goons and rowdies- on one instance, a woman was
blinded in one eye. However, thepolice would not only refuse t register cases, but they
would also protect the perpetrators of these attacks.
Around this time, in 1993, Samraksha, an HIV-AIDS prevention group, started visiting
the State Home in Bangalore to speak to sex workers about HIV-AIDs prevention.
Subsequently, some of these women started working with Samraksha as peer educators.
However, as peer educators they soon realized that simply talking about HIV-AIDS
prevention does not address the violence felt in the lives of sex workers. At that time,
the police were routinely booking sex workers under Section 8 of the ITPA. In all cases,
the women would be forced to plead guilty and pay a fine, otherwise they would be
subjected to further violence from the police. Whatever little earnings the women made
through sex work would be paid to the police in the form of fines or as extortion money.
When the violence and the harassment became unbearable, in 1999, members of various
civil society organizations, including Peoples Union for Civil Liberties met with sex
workers on the question of police violence. Sex workers spoke about their problems at
this meeting, and it was felt that the only way in which police harassment would stop
was if sex workers stared contesting the cases that were filed against them. However,

the women were warned by the police that if they contested the cases, then they would
be arrested and detained in jail indefinitely. And to discourage sex workers from
contesting cases, the police started arresting women around 4.30 or 5 in the evening,
towards the end of court hours, when the Magistrate would be finishing the days
proceedings. This meant that by the time women were produced, they would be
inevitably remanded to custody for the night. In order to avoid being remanded, most
women chose to not contest the cases, so that they would let off with a fine.
In 1999, just before Dusshera, Salma, one of the sex workers active in organizing women
in Upparpet, was picked up by the Ashoknagar police station in Central Bangalore and
sent to the state home. This was deliberately done right before courts closed for
Dusshera, and Salma was not produced before a magistrate. Members of Peoples
Union for Civil Liberties- Karnataka went to Ashoknagar police station and insisted on
Salmas immediate release. Because of PUCLs insistence, Salma was produced before
the Magistrate at his residence. However, she had to spend an entire week in the State
Home, where she was forced to live with severely mentally ill people. She was
eventually released on a personal bond, and cash surety of Rs. 3,000. A week later,
when courts opened and Salmas case came up, she pleaded not guilty before the
magistrate. The case was eventually dismissed.

This event galvanized sex workers and civil society organisations to take steps towards
combating police violence. Subsequently, weekly meetings discussing police violence
were set up, and sex workers also started organizing area-wise meetings. PUCL-K,
Alternative Law Forum and Vimochana held sessions with them where they were
taught how police procedures worked, how to approach the womens commission, and
how to document cases. The sex workers started a strategy of simultaneously
documenting and contesting cases. However, as they started contesting cases, the
violence escalated.

For example, after Salma won the first case, she contested several others. As a result, the
propriety of each arrest and case came under strict scrutiny by the courts. No lady
police officer would ever be present during an arrest, and this would be exposed during
their cross-examination, when it would be clear thing at the officer being questioned
was actually never present during the arrest. After Salma contested the third such case
filed against her, she was accosted one night by one Shakuntala, who was an officer
who had been cross-examined in court in her case. Shakuntala started beating Salma
brutally, accusing her of deliberately humiliating her in court. Then Shakuntala took out
a gun and held it to Salmas forehead, threatening to kill her. This was done on
Mahatma Gandhi Road, one of the busiest thoroughfares in Bangalore. After beating
Salma senseless, Shakuntala dumped her in a nearby drain and left her. Salma was
rescued by a group of hijras, who took her to their house and helped her recover.
Again, in 2003, Rathna, a sex worker based in Upparpet was picked up by the Upparpet
Police Station. She was beaten up viciously by the police, and left in extreme pain.
Unable to bear the agony and harassment anymore, Rathna crushed her glass bangles
and swallowed the powder. She died in the hospital soon after.
Also in 2003, Lakshmamma was forcibly taken to Upparpete Police Station. Geetha was
summoned to the station by the police, and she was forced to prepare a concoction of
chilies. The concoction was then shoved by the police into Lakshmamma's vagina. This
incident caused a huge uproar, and a case was filed byAdvocate Ravi Varma Kumar in
the Karnataka High Court. The High Court eventually passed a direction that any
officers engaged in such violence will be suspended, and severe action would be taken
against them.
An important strategy that developed around this time is the use of medico-legal
certificates to document police violence. Despite repeated attempts, the police would
refuse to register complaints against their colleagues, and when the sex workers
approached other avenues, such as the State Womens Commission, they were told that
they had no proof of being assaulted. In fact, Philomena Perez, the then chairperson of

the Womens Commission, turned away complainants on the ground that they lacked
any evidence of violence being done to them. After their experience at the Womens
Commission, sex workers started getting medico-legal certificates done at the nearest
government hospital immediately after an episode of violence. They would also take
pictures of bruises and wounds suffered as evidence of injuries.
The contesting of police cases had a visible impact on how courts dealt with sex
workers. Earlier, courts would be satisfied with only a statement that a woman was
caught soliciting. However, courts now started asking for copies of FIRs and
chargesheets made. Also, over time, the amount of money that sex workers had to pay
as surety also reduced, from Rs. 2000 to 3000, to Rs. 500. Eventually, women would be
released only on the surety given by their lawyers.
In 2004, members of Sadhana Mahila Sangha and various civil society organisations met
the Director General and Inspector General of Police. Till then, the women had
documented over 550 cases that were filed against the women. 375 of such cases had
been dismissed, and out of the rest, many women had died or disappeared. In the
discussion with the DG&IGP, he admitted that it was evident from the statistics that
most of these cases were fabricated. Subsequently, a circular was issued from the offices
of the Director General and Inspector General of Police. Circular No. SMS(6)/25/04-05,
dated 30/09/2004, which stated:
Booking of a woman sex worker under Section 8 tantamount to
revictimising the woman when she is already a victim of trafficking and
sexual exploitation. It is, therefore instructed that henceforth no woman
sex worker should be booked u/s 8 of ITP Act unless the women in
question is a "Madam" or a brothel keeper. and further, . I in
future, any cases are booked against women sex workers for "soliciting"
the explanation of the concerned officer should be called and if there is
any lack of bona fides, action should be taken.
4. A large number of complaints have been received from different
places that sex workers are man handled, ill-treated, assaulted and

abused in an inhuman manner by the police personnel. It is also alleged

that the local police is in the habit of extracting money from these sex
workers which itself amounts to extortion and living on their earnings.
Needless to say that this pernicious practice, if true, should be stopped
forthwith and strict disciplinary action should be taken against such

However, after the circular, the police found a new weapon in the Karnataka Police Act,
and started filing cases of nuisance and obstruction of duty against the sex workers.
Three such cases were filed against Geetha, however all three cases were contested and
Another strategy commonly used was to pick up file cases against sex workers under
the provisions of the Karnataka Prohibition of Beggary Act, 1975. The act defines a
beggar as any person other than a child, who having no visible means of subsistence,
wanders about or remains in any public place in such condition or manner as makes it
likely that he exists by soliciting or receiving alms. Sex workers would be picked up
and taken to the Beggars Home. In the Beggars Home, the women were subjected to
constant sexual harassment in the form of propositions and lewd comments from the
Superintendent and the other staff of the home. The women were also forced to live
with mentally ill persons, many of whom were violently ill and in need of medical
treatment. This was extremely traumatizing to the women. Geetha herself was arrested
on beggary charges on several occasions. In the state home, sex workers would be
forced to stay with people who had mental health problems. This was extremely
traumatizing for the women. When PUCL-Karnataka was informed of the conditions in
the beggary home, they approached the State Human Rights Commission, which was
then headed by Justice S.R. Nayak. Justice S.R. Nayak immediately conducted a raid on
the Beggars Home, where he found residents living in inhumane conditions. After this
raid, sex workers were no longer arrested under the Beggary Act.
Over the last twelve years, then police have used a range of strategies to arrest and

detain sex workers. Each strategy has been systematically challenged by sex workers,
and subsequently abandoned. However, as the current cycle of violence shows, misuse
of laws is not the only way in which the police can target sex workers. When all the
laws have been exhausted, physical abuse, arbitrary detention and the forced payment
of fines remain tried and tested methods of harassment and violence. The next section
details specific incidents of violence suffered by sex workers at the hands of police



Since October 2013, several police stations in Central Bangalore, including Cottonpet,
KG Road, Market, and especially Upparpet Police Station have conducted a systematic
campaign of violence against sex workers in that area. Sex workers have been identified
publicly, verbally abused, chased around, and beaten up with sticks. They have been
detained in police stations, and attempts to complain have been met with further
violence. This recent cycle of violence comes after a long period of ten years. The
chronology of events is detailed below:
In January 2013, Sumathi of Sadhana Mahila Sangha was assaulted by a H.V. Gopal
Gowda, an officer of Upparpete Police Station. She was brutally beaten up and verbally
abused, and the officer threatened to put chilli powder in her vagina. She was
accompanied by a Ms. Latha, who was also attacked and abused by the police officer.
In between, we started getting reports of sex workers being identified by the police on
the streets of Upparpete. Police officers would chase women down the streets, and
shout out their names over loudspeakers, thus humiliating the women in public. It
should be noted that many of these women keep their identity as sex workers hidden
from friends and family. The stigma attached to sex work is too great to allow women
to profess their identity and livelihood freely. Therefore, to identify these women in
such a manner is not only denigrating to their dignity, but it also exposes them to the
added dangers of social censure.
On 26.10.2013, Rajamma, a member of Sadhana Mahila Sangha, was accosted by two
policemen dressed in uniform. Rajamma was walking back home in Majestic. When she
was crossing the road near Majestic Theatre, a very busy intersection, two police officers
started chasing her. They abused her, and started beating her up with a stick on her legs
and thighs. Rajamma managed to escape, and contacted members of Sadhana Mahila
Sangha, who then took her to a hospital. Members of Sadhana Mahila Sangha and other
civil society organizations met with the Commissioner, Bangalore City Police, and

submitted a complaint about this incident. The Commissioner spoke to the Deputy
Commissioner of Police, West Division, in front of the assembled activists, and assured
them that the incident would be looked into.
However, these attacks continued unabated. On multiple occasions, sex workers were
identified on the roads, and viciously abused in obscene language. The police would
patrol Upparpet and call out the names of sex workers on megaphones. They would be
threatened and chased with lathis. Many of these women were accosted when they
were on their way home, or were merely running errands in this area. By
indiscriminately targeting women, the police were making it impossible for sex workers
to even access these spaces.
In response to these attacks, Peoples Union for Civil Liberties- Karnataka (PUCL-K)
made a representation dated 11.11.2013 to the Commissioner of Police and to the
Deputy General and Inspector General of Police, Karnataka. This representation
detailed the incidents of violence that had been taking place, and requested the
authorities to conduct enquiries into the violence. A deputation of sex workers, lawyers
and social activists visited the Commissioner and the Deputy-General and InspectorGeneral, and they were assured by both that the violence would be promptly
investigated into.

However, despite repeated assurances from higher officials, these attacks continued
unabated. It must be noted that at this point, the women were still reluctant to file
complaints or make representations about these attacks. In any case it is futile to expect
Upparpete Police Station to accept complaints about their own officers. In fact, past
experience had taught the women that an attempt to complain can often backfire into
more violence. Therefore, while many women approached support organizations and
informed them of the attacks, few wanted to report them.

Moreover, it must be noted that sex workers have for long accepted police violence as a

part of their daily routine. For all the women who approached support groups and
informed them of violence, there are probably many others who simply choose to not
However, the violence and humiliation was proving to be unrelenting, and members of
Sadhana Mahila Sangha and other sex workers collectives and support organizations
had meetings to decide a further course of action. It was then that it was decided that
sex workers would conduct a public protest condemning police violence.
On the 6th of December, sex workers organizations from all over Bangalore, and
organizations such as PUCL-K, Vimochana, Jan Sahyog, Sangama and others assembled
at the Town Hall in Bangalore to protest against police violence. Over 200 protestors
assembled at Town Hall and wore black masks as a sign of protest. The protest was
widely reported in the media. Also, this was the first instance in the history of
Bangalore City that sex workers led a public protest against police violence.
However, even after these meetings, the violence continued unabated. On 02.02.2014,
Roopa, a member of Sadhana Mahila Sangha, was attacked by Inspector Netra kumar of
Upparpet P.S., near Kempegowda Circle. She was hit on her arms and legs with a lathi,
and she sustained severe bruises. She called Geetha, a member of Sadhana, who then
took her to the hospital.

Worried by this increasing spate of attacks, PUCL-K made a representation to the

Assistant Commissioner of Police, West Division, and the Deputy Commissioner of
Police, Chikpet Division. In the meeting with the ACP, he assured us that such
complaints would be enquired into, and he condemned the actions of the policemen.
However, and quite tellingly, he also told the assembled group that perhaps it was a
good idea for the women to not engage in such activities, for their own safety. He also
spoke to the Deputy Commissioner of Police, Chikpet Sub-Division, in the presence of
the group, and asked the group to speak to the DCP about these incidents.

However, in the meeting with the DCP, he denied any wrongdoing on the part of the
police, and repeatedly blamed the sex workers for creating public nuisance. He said that
they were in receipt of public complaints against the sex workers. When it was
suggested that if the sex workers had violated any law, then the police should just file
cases against them, instead of harassing them, the DCP retorted by asking one of the
advocates present in the group if she was aware of any provision that he could book
these women under, thereby implying that because the law did not criminalise these
women, he and his officers had to resort to extra-legal measures. However, the DCP
also assured the group that he would ensure that sex workers were not attacked
However, the next day, on 03.02.2014, Roopa was again attacked at Upparpete. She was
accosted by one Netrakumar, who hit her on her wrists with a lathi, shattering her glass
bangles, which broke on impact and pierced through her skin. On 04.02.2014, another
representation was made by PUCL-Karnataka to the ACP, West Division and the DCP,
Chikpet. On this occasion, the DCP was far more abrasive, and warned the group that
while the violence would cease, he would have to resort to other methods including
the filing of cases, to keep the women off the streets.
On the same day, 04.02.2014, Salma, had gone to Abhinaya Theatre to meet her friend
Sujatha. At Abhinaya, Sujatha and Salma were attacked by a group of police officers
who started beating them up with lathis. Salma sustained severe injuries on her head
and legs, and had to go to a hospital to seek treatment.
As repeated representations to the police had gone unheeded, on 6/02/2014, Peoples
Union for Civil Liberties filed a complaint with the Karnataka State Human Rights
Commission. In H.R.C. No. 668/2014. PUCL detailed incidents of violence, named
perpetrators, and sought an inquiry into these incidents. PUCL made its representation
to Mr. C.G. Hungund, member, State Human Rights Commission.
The SHRC constituted an enquiry into these reports of police violence, and directed the

Deputy Inspector General of Police, State Human Rights Commission to take statements
and enquire into these incidents.
However, during the pendency of the enquiry, on 19.03.2014, Gowramma, a member of
Sadhana, was brutally beaten up in public by an officer of Upparpet Police Station.
When Roopa, who was accompanying Gowramma, tried to intervene, she was pushed
away and abused by the officer. Subsequently, Inspector Prakash of Upparpet Police
Station also joined in and started beating up Gowramma. He kicked Gowramma on her
waist and hit her on her arms and legs. Finally, Gowramma and Roopa managed to
escape. They went to Victoria Hospital, where Gowramma got treated for bruises on her
arms and her legs.
Within a week, on 24.03.2014, Ms. Indra Thimmaiah was attacked. She and her friend
Roopa were at Kempegowda Circle, when Roopa Adagali, an officer of Upparpet Police
Station, ordered a constable to beat them up. Ms. Indra sustained injuries on her hands
and legs, and had to be taken to the hospital. On that day and the next day, around ten
sex workers were attacked in Upparpete. They were chased in public with lathis, and
beaten up mercilessly. Smt. Satyavathi was beaten up brutally in front of Ganesha
temple by policemen at night. When these women protested and said that they had
filed a complaint to the State Human Rights Commission, they were told that the police
were acting on the direct orders of the Commissioner of Police, and unless the woman
produced orders from the commissioner that were to the contrary, the beatings would
Following this incident, PUCL-K made a further representation to the SHRC, requesting
that these incidents be enquired into as well, and the victims be adequately
compensated. This was registered as a separate complaint, as H.R.C. No. 1502/2014.
However, on 4.04.2014, one of the complainants in the above named proceedings before
the SHRC, Ms. Roopa, was illegally detained at around 8 pm in the night by Upparpete
Police Station, by the sub-inspector of Police, Rupa Adagalli. She was told that she is
being detained as she has dared to initiate proceedings with the SHRC. Further, the

police stated that if any of the organization members approach the police, they will file
false cases of theft and robbery against Ms. Roopa and anyone who chooses to
complain. Despite repeated efforts, Ms. Roopa could not be contacted, and she was
untraceable. Support organizations and activists converged the next morning at the
State Human Rights Commission premises, anxious about the whereabouts of Ms.
Roopa. A separate representation was made to the SHRC in this regard. It is only much
later that Ms. Roopa was traced to a friends residence.
After this, Ms. Satyavathi was also attacked on two separate occasions, while she was
sleeping on the pavement at Majestic. She was first attacked by a bystander, who
started hitting her for no reason after she refused to answer his questions. When she
complained to the police, they abused her and hit her further. Satyavathi had to hide
away in her friends house for the next week, and her injuries were so severe that she
could not speak or eat properly.
In spite of pending enquiries before the SHRC, these attacks were continuing, and the
police were acting with complete impunity. Pushed to a corner, sex workers in
Upparpet decided to protest outside Upparpet Police Station on 28.04.2014. Members of
Sadhana Mahila Sangha and various civil society organizations gathered outside the
police station on that day to demand immediate action. However, as soon as the protest
started, the women were surrounded by men, who started violently abusing and
shouting at them. These men, purportedly local residents, were drunk and violent, and
would not let the women speak to the police directly. Finally, the Assistant
Commissioner of Police came out and asked the women to come inside and speak to
him. However, these men who had been abusing and shouting at the women, followed
the group inside the ACPs office, where they continued to scream and threaten the
group. By this time it was clear that these men were present at the behest of the police,
as the ACP made no efforts to control them or ask them to be quiet. Moreover, the ACP
continued to deny that the women had been attacked, and repeatedly stressed on how
their presence was disruptive, and that he had been receiving complaints from locals.

Finally, he agreed to constitute a committee comprising of member of local trader

associations, the police, and civil society organizations, to look into these issues.
However, till date, no meeting has been held in this regard. In fact, on that same
evening, members of Sadhana were informed by some locals that the police had been
aware of this protest, and had paid locals shopkeepers to come and disrupt the
After this, on 24.05.2014, Professor Ramdas Rao, who is a member of Peoples Union for
Civil Liberties, Karnataka, received a letter from the Upparpete Police Station. This
letter stated that all accusations of violence against the police were false and contrived
with an aim of disrupting the police in the discharge of their duties. The letter went on
to state that Upparpet Police station was closing the enquiry into violence against sex
workers. The patently untrue and threatening tone of the letter, and the fact that
Upparpete Police Station felt that they could unilaterally close an enquiry that had been
constituted by the State Human Rights Commission. Subsequently, PUCL-K made
another representation to the State Human Rights Commission, dated 05.05.2014,
requesting the Commission to issue orders in this case, and to also take note of the letter
issued by Upparpet Police Station. On speaking to the Registrar of the Commission, he
expressed surprise that such a letter had been sent, and he gave his assurance that the
enquiry had not been closed.
After the protest on 28.04.2014, no further acts of violence have taken place, however
sex workers continue to be subjected to verbal abuse by police officers. The date of
closing of the inquiry by the Inspector General of Police, State Human Rights
Commission, has been given as 17.7.2014.


There are several factors that this current cycle of violence can be attributed to.
Members of Sadhana have observed that public complaints against sex workers have
increased. A large number of complaints are often from disgruntled clients who do not
want to pay for a sex workers services. Shopkeepers and traders also complain if they
find sex workers roaming around outside their establishments. Moreover, the current
drive against sex workers is similar to the drive against transgenders in Bangalore in
2000, and the corresponding violence that they were subjected to. However, there are
structural questions that underlie the cyclical nature of this violence that must first be
Collective Action as a Threat to Police Oppression
The history of Sadhana Mahila Sangha tells us that while Sadhana was born in response
to violence, its inception also generated violent reprisals. The initial attempts at
contesting cases are what led to an increased spate of attacks, which finally subsided
with the 2004 circular of the DG & IGP. Even now, all of Sadhanas active members
have been systematically targeted by the police.
Over the last twelve years, Sadhana has been instrumental in destroying a system of
patronage between sex workers and the police. Initially, sex workers would have to pay
the police a certain percentage of the money earned from every client. This was known
as a system of roll call. Moreover, sex workers were supposed to provide sexual
services to policemen free of charge whenever asked. This system of free sex, along
with that of daily roll calls, were supposed to act as guarantees against police
However, over the past few years, fewer and fewer sex workers have been paying
money to the police, and allowing them free sex. Sadhanas efforts at collectivizing sex
workers have created a strong-knit community of women who look to each other for

support, and refuse to pay off the police for their protection. As a result, members of
Sadhana have been identified as troublemakers by the police, as through collectivizing
sex workers, Sadhana is upending a well-established and very profitable system. In a
sense, this is almost a textbook state reaction to collective action- the targeting of leaders
to break the union/group/collective/movement.
It has also been observed that each time the inspector in a police station changes, a fresh
round of violence starts against sex workers. The present round of attacks started after
Inspector Prakash R. was appointed as inspector of Upparpet Police station. This
indicates a need for sex workers to constantly negotiate with individual police officers.
This also hints at a larger institutional absence of any understanding of sex work, and
scant respect for civil liberties and human rights. It is unreasonable to expect that sex
workers should have to suffer illegal detentions and brutal beatings just because an
officer is not sensitized to the issues concerned.
The ITPA as a facilitator of violence
The Immoral Traffic Prevention Act does not criminalise sex work per se. However, it
criminalises all activities that facilitate sex work. Therefore, keeping a brothel, living off
the earnings of a prostitute, and soliciting in a public space, are all criminal acts.
However, demanding money in exchange of sexual acts does not per se, constitute a
criminal offence. This distinction stems from a conflation of trafficking and sex work,
and of perceiving all sex workers as necessarily being victims of trafficking. Within this
framework, criminalizing sex workers per se is unacceptable, because it is tantamount
to penalizing the victim, rather than punishing the agents that push her into sex work.
However, as explained earlier, till 2004 in Bangalore, ITPA continued to be used against
sex workers. It was only after the circular of the DG &IGP was issued, that the police
stopped using provisions of the ITPA against sex workers. The language of the circular
is telling- it explicitly states that sex workers are victims, and are to be treated as such,
and only pimps should be booked under provisions of the ITPA. Police officers have

also been quick to adopt this language- in our conversations with higher officials, they
have been particular in insisting that sex workers are victims. However, this
understanding delegitimizes a sex workers choice of livelihood, i.e., it does not
recognise that even within the limited spectrum of choices available to a woman, she
may choose to do sex work because of various factors, including flexible work hours,
and the relative freedom of entry and exit. It further allows the paternalistic state to
make decisions on her behalf, i.e., subjecting her to forceful incarceration in shelter
homes, and proposing rehabilitative measures that are conditional on her leaving sex
However, a lesser known effect of this dichotomy in the law is the creation of a peculiar
morality, where by criminalizing facilitative acts, sex work is implicitly delegitimized,
and hence made to seem immoral, but notillegal. When we have confronted police
officers and asked them why they choose to assault sex workers, they have asked us to
tell them how else this nuisance can be curbed. The ITPA keeps sex work, and
especially street-based sex work, in the penumbra of illegality, and chooses to directly
penalize the sex worker only when she appears in public doing sex work. This means that
while the law overtly tells us that sex workers are victims, it also insidiously implies
that what they do is immoral, and it must be curbed. In the absence of legal provisions,
the police resort to terrorizing and harassing sex workers, especially street-based sex
workers. Which is why, when sex workers start contesting cases and, inevitably
winning them, the police jump from law to law, till there are no more laws left to use,
and violence is the only imperative.
The Changing Nature of the Urban Space
Police raids and attacks against sex workers, street-vendors and the homeless are
typically characterized as raids and clean-up drives, thus implying that these people
have no right to urban public spaces. As Bangalore strives to be a world-class city, such
drives are bound to increase. The Majestic, as one of the oldest and busiest commercial
centres in the city, is rapidly changing, and is the focus of many development projects,

including the Bangalore Metro, and a complete overhaul of the Kempegowda Bus
Station. The recent attacks on sex workers can also be linked to an increasing
gentrification of the neighbourhood. This is made even more obvious when seen in light
of simultaneous drives against street vendors as well. It is yet another symptom of the
exclusivity of neo-liberal models of development- that those identified as undesirable or
unclean elements must be pushed to the fringes of public spaces. These clean-up drives
have a very tangible impact on the safety of sex workers- as these women are pushed
away from urban centres, they are forced to take clients to unsafe, remote areas such as
forests, which puts them in a greater danger of physical harm.


This report is an attempt to document the violence inflicted upon sex workers over the
last eighteen months. Police violence against these women has significantly reduced
since the last protest in front of Upparpete Police Station. However, subsequently, closecircuit cameras have been installed in front of all major commercial areas in Upparpet.
This is an unprecedented development in the police campaign against sex workers, and
only hints at the possibility of future harassment on the basis of video footage. Sex
workers in Upparpet are already migrating to other, less populated and more unsafe
areas to conduct business. The gentrification of the neighbourhood is well under way,
and Sadhana apprehends that the present lull in violence is only temporary, and the
police will soon evolve new techniques to harass and abuse sex workers in Bangalore.

Considering the situation of women in street prostitution in Bangalore, we place before

you, the following demands for consideration and positive action to protect the human
rights of women in street sex work:
1. In environments where many aspects of sex work are criminalised, for instance,
soliciting, living off the earnings of a sex worker (families and children suffer the
most), managers3; sex workers face discrimination and stigma which undermine
their human rights, including to liberty, security of the person, equality, and
health. Hence strict directions to all states to ensure that police work within the
2. When violators are the police themselves, it becomes almost impossible for the
women to seek justice or even to file a complaint, as the police personnel are
protected from within the system at every level. There must be an ombudsman
system (independent of police system) at State and district level to review
complaints against the police department personnel by sex workers and the
action taken.
3. A single window system to ensure entitlements to sex workers without any

stigma attached in the process such as obtaining ration cards, ID cards, old age
pensions, passports, applications to various Government schemes etc
4. A Night shelter for street based homeless women sex workers at selected areas
where large numbers of sex workers spend the nights. These may be managed by
the State with support of NGOs.

This report has been prepared with inputs from members of Peoples Union for Civil Liberties,
Vimochana, Jan Sahyog and Alternative Law Forum.
Dated: 08/07/2014