VICTIM COMPENSATION IN INDIA – AN ANALYSIS

-Vasundhara Saxena
ABSTRACT
Victimology continues to evolve on a daily basis as the court adopts different practices and
guidelines to ensure the dignity of the affected party. But, do we have sufficient support of
the law when it comes to rehabilitating victims into society? Does the state satisfactorily
ensure that victim of various crimes successfully find their way into leading a normal life?
While almost all states have their victim compensation schemes now, this paper seeks to
examine how truly effective and practically implemented are these schemes. The Code of
civil procedure provides for such a compensation to victims under Section 357, which has
further been facilitated and made into a multitude of victim compensation schemes drafted by
state governments for their respective states. This research paper will examine some of these
provisions along with the scheme at large, along with its short comings.
INTRODUCTION
Victim compensation scheme essentially brings us to question the very roots of where the
concept comes from. Victimology is an upcoming branch in India, and the Victim
compensation scheme is one such provision which brings this concept to practical
application. The term victimology was coined by the French lawyer, Benjamin Mendelsohn.
The definition and recognition of the Term Victim has also changed substantially in the past
century, the evolution has moved from being a small branch of victim study under the larger
discipline of criminology to being a separate discipline called ‘victimology’. 1 The focus has
shifted from treating the victim as a subsidiary to giving the victim the importance of being a
‘key player’ in the process of justice.2 It was only after the second world war that the sub
discipline of victimology began to receive objective attention from academicians as a
separate branch of law.3 The Welfare notion of state intervention for the rehabilitation and
the sustenance, readjustment and mixing back into society needed state assistance began to
evolve in those times. One of the first people to suggest the concept of Victim compensation
internationally was Margery Fry, a British prison rights activist who was accompanied by
Professor Jeremy Bentham, who also argued that the state is bound to play a pro-active role
in restoring the victim’s position back to original. As a result of her efforts, Britain set up a
victim compensation scheme in as early as 1964, New Zealand followed suit by setting up
their victim compensation fund in as early as 1963 and then other nations like Canada
followed as well.4 The works of Benjamin Mendelsohn and Hans Von Hentig, who wrote on
the subject as early as 1948 about the need for separate treatment of victims in his book titled
‘The Criminal and His Victim’ are early figures whose work can be seen as the roots of
victimology.5 Victimology has evolved at different paces in different areas, dependent on
various social and political factors. It may be very diverse and exclusive in some nations and
completely non-existent in others. Many countries have transformed their victim schemes,
1
L. Wolhuter, et. al, Victimology : Victimisation and victim’s rights, (Routledge publication, 2008)
2
Ibid.
3
R. Moby and S. Walklate, Critical victimology: International Perspectives (SAGE publication, 1994)
4
Glazebrook, P. (1962). COMPENSATION FOR VICTIMS OF CRIMES OF VIOLENCE. The British Journal
of Criminology, 2(3), 295-299.
5
Booth, T. in ‘Comparitive analysis of the victim policies around the anglo speaking world’ (Routledge
publication, 2007)
with Japan at the leading front and other nations have followed suit. The last 20 years have
specifically brought about phenomenal growth for the subject. These programmes have
grown and developed all over the globe.6 Victim compensation schemes have very well been
hit by the same problems as hundreds of other well-meaning schemes which lack
implementation. Despite having implementation, many of them fail to provide an amount
which really puts the victim in a better position than a person who received a token amount as
mere formality which is barely helpful in really changing the position of the victim. A lot of
victims do not apply for the scheme, fewer receive it. It is even argued by some, that the
gesture is mere token in nature taken by the government to symbolically exhibit their well-
meaning intention for victims of a crime.7
In India, the first steps towards victim compensation have been taken by the Indian Judiciary.
The first few instance include judgement by Justice Krishna Iyer, as in the case of Ratan
Singh vs. state of Punjab, he says “ is a weakness of our jurisprudence that the victims of the
crime, and the distress of the dependents of the prisoner, do not attract the attention of the
law. Indeed, victim reparation is still the vanishing point of our criminal law ! This is a
deficiency in the system which must be rectified by the Legislature.”8
INTERNATIONAL LAWS AND OBLIGATIONS FOR RELIEF OF VICTIMS
The United Nations adopted the ‘Declaration of Basic Principles of Justice for Victims of
Crime and Abuse of Power’, adopted by General Assembly resolution 40/34 of 29
November 1985. This declaration introduced several different concepts like the introducing a
definition as to who qualifies as a ‘victim’ which talks about compensation and giving
reparations as well as strengthening the judiciary’s mechanism. This was followed by the
Declaration on the Protection from Enforced Disappearance adopted by the UNGA in its
resolution passed on 18th December 1992. This was also followed by another resolution on
the same issue passed by the UNGA which was the ‘International Convention for the
Protection of All persons from Enforced disappearance’ which essentially aimed to protect
individuals who were considered to have been arrested, detained, abducted or deprived of any
liberty by the agents of law themselves – this included police brutality and custodial brutality.
Here, in summary, the right to justice, right to information regarding the investigation, and
the right to compensation. Here, the convention includes provisions for restitution,
information satisfaction, restoration of dignity, rehabilitation, compensation. The latest
resolution regarding the subject is the issue of victim protection which was in the form of
guidelines, called the ‘Basic Principles and Guidelines on the Right to a Remedy and
Reparation for Victims of Gross Violations of International Human Rights Law and Serious
Violations of International Humanitarian Law’9 Besides, the Organised Crime convention in
Article 14 and 25 and the Trafficking in Persons Protocol Article 6 (6) make specific
reference to and provide for compensation at an international level.10
INDIAN PROVISIONS FOR COMPENSATION AND ROLE OF JUDICIARY

6
Fattah, E. A. (2000). ‘Victimology: Past, Present and Future’. Journal of Criminologie, 33 (1), 17–46.
https://doi.org/10.7202/004720ar
7
Easton, S. in SENTENCING AND PUNISHMENT,215- 239, (Oxford University press, 2016)
8
1979 SCC (4) 719
9
Romani, C. ‘International law of victims’, 220, Max Planck Yearbook of United nations law, Vol. 14, p.219-
72. (Koninklijke Brill N.V, 2010)
10
United Nations Conference room paper, on National Approaches to compensation of victims of trafficking,
The Indian society has seen cooperation from both the state and the judiciary in terms of
compensating victims. There are provisions in both the Constitution as well as the Code of
Criminal procedure, 1973 which provide for such compensation. However, it must be noted
that the constitution does not have specific provisions for victims, they have to be read into
various human rights provisions.11
I. CONSTITUTIONAL PROVISIONS –
Even though there aren’t directly made schemes for victims in the Constitution, they have
been read into Part III and Part IV of the Constitution. Directive principles of State Policy,
Article 41 and Part V for Fundamental Duties, Article 51A enunciate the duty of the state to
fulfil the right of the public to assistance and to have compassion for all living creatures.
These provisions have been employed by the Judiciary to repeatedly protect and uphold the
rights of individuals to exercise their rights.12 It was all the way back in 1983, the Supreme
court stood up for victim rights in the gruesome case of Rudul shah vs. state of Bihar13, the
court gave orders for granting Rs. 35,000 by way of compensation to the victim after he was
imprisoned without orders of the court for 14 years. There have been multiple cases where
the Supreme court followed this recognition of victim rights and recognised the need to
compensate them. A few cases which compensation has been given were Manju Bhatia v.
N.D.M.C.14, Bhim Singh v. State of Jammu & Kashmir, 15 Dr. Jacob George v. State of Kerala
,16 Paschim Bangal Khet Mazdoor Samity v. State of West Bengal & Ors, 17 People’s Union
for Democratic Rights Thru. Its Secy. v. Police Commissioner, Delhi Police Headquarters 18
People’s Union for Democratic Rights v. State of Bihar 19. in Rohtash Kumar v. State of
Haryana20, the State of Haryana was made to pay Rs. 20 Lakh compensation to the Appellant.
There is no one fixed limit beyond which compensation cannot be paid to the victim, as that
would completely defeat the whole purpose, for every crime does not have the same factual
matrix and one case could require more compensation than another.21
II. PROVISIONS UNDER OTHER LEGISLATIONS-
There are other legislations as well which provide for such compensation in different
scenarios – for eg. Consumer Protection Act, 1986; Fatal Accidents Act, 1855; Indian
Railways Act, 1989; Merchant Shipping Act, 1958; Motor Vehicles Act, 1988; Probation of
Offenders Act, 1958; Protection of Women from Domestic Violence Act, 2005; Sexual
Harassment (Prevention, Protection and Redressal) Act, 2013). Another example could be
that of which Probation of Offenders Act, 1958 which states that while releasing an accused

11
Dube, D. ‘Victim Compensation schemes in India : An Analysis’ 342, International Journal of Criminal
Justice Sciences 13 (1): 339–355 (2018)
12
Sahni, S. et al (2017). Victims’ Assistance in India- Suggesting Legislative Reform (1st ed.). New Delhi:
Anne Books.
13
(1983) 4 SCC 411
14
AIR 1998 SC 223
15
AIR 1986 SC 494
16
1994 SCC (3) 430
17
1996 SCC (4) 37
18
1990 ACJ 192
19
1987 AIR 355
20
 (2013) 14 SCC 434
21
Ibid.
on probation or admonition, the court can give an order for the offender to pay compensation
to the victim under s. 5 of the Act.
III. PROVISIONS UNDER THE CODE OF CIVIL PROCEDURE, 1973 –
The addition of provisions to the Code find their roots in the 41st Report of the Law
Commission of India was submitted in 1969. On such a recommendation, the Code of
Criminal Procedure Bill 1970 was introduced and what was the initial Section 545 was then
revised and re-introduced as Section 357 as it is today. However, this recommendation and
changed format of the section found its way to the code only after the 2008 amendment.
Initially, the amount was only limited to the amount of fine but now that limitation has been
removed. Now the amount of compensation is independent of the amount of fine or even the
very presence or absence of a provision for fine in the first place. Accordingly, the changes
were accommodated.22
The term ‘victim’ itself was introduced in the Code in the year 2008 under S. 2 (wa) which
reads – “ The term ‘Victim’ means a person, who has suffered any loss or injury caused by
reason of the act or omission for which the accused person has been charged and the
expression “victim” includes his or her guardian or legal heir.” The usage of the word
‘charged’ means that the investigation of the offence has been done, accused identified and
the charge has been framed after all that thorough investigation. However, the scheme has a
larger ambit than the definition, for even in cases where the identification of the accused
could not be possible, even then the scheme intends to include them.23
The following provisions were introduced in the Code of Criminal Procedure in 2008 through
an amendment. Section 357, which talks about an order to pay compensation with or without
the order of a fine and Section 358, which talks about payment of compensation to a person
who has been arrested groundlessly along with Section 359 which talks about the payment of
costs in a non-cognisable offence.24 Section 357 specifically talks about empowering the
court to impose a sentence which forms a part of the compensation to be paid to the victim.
But the catch here is that the imposition of such a compensation only happens when a
substantial sentence has been imposed and not in cases of acquittal. – but it must be noted
that the court can impose such an order for compensation even when the sentence itself does
not include the imposition of a fine.25 In Mangi Lal v. State of Madhya Pradesh26, the
supreme court held that it depends on the court’s jurisdiction how the compensation will be
drawn, wholly or partially from the fine that was a part of the sentence or not. It was also
clarified that this is not an ancillary power to add onto the sentence but only an addition
thereto. The ambit of the section has also been explained and explored by various high court
judgments, like State of Madhya Pradesh v. Mangu,27 where the Madhya Pradesh high court
held that the accused can only be directed by the court and not the state to pay compensation
to the victim. The Supreme court has further examined the reasons for the sparing and
22
Mohan, V. REVISITING VICTIM COMPENSATION IN INDIA,
http://docs.manupatra.in/newsline/articles/Upload/6F5E12E5-2A56-49A9-BF1B-CBE1DF4F8726.2-
F__criminal.pdf.
23
Supra note. 11
24
Chakrabarti, N. K., & Dube, D. in ‘R. Deb’s Principles of Criminology, Criminal Law and Investigation’ (4th
ed., Vol. 1 2017).
25
Ibid.
26
2004 CrLJ 880 SC
27
1995 Cr.LJ 3852 (MP)
insufficient usage of the provision by the lower courts in the case of Hari Singh and State of
Haryana v. Sukhbir Singh28 as quoted further below-
“It is an important provision, but courts have seldom invoked it, perhaps due to ignorance of
the object of it. It empowers the court to award compensation to victims while passing
judgment of conviction. In addition to conviction, the Court may order the accused to pay
some amount by way of compensation to victim who has suffered by action of accused. It
may be noted that this power of court to award compensation is not ancillary to other
sentences, but it is in addition thereto. This power was intended to do something to reassure
the victim that he or she is not forgotten in the criminal justice system. It is measure of
responding appropriately to crime as well as reconciling the victim with the offence.”
It was also held in the case of Bodhisattwa Gautam v Shubhra Chakraborty29  that in cases of
rape trials, interim compensation can also be awarded if the court finds it fit for the well
being of the victim.
Section 357 (2) gives the power of deciding the quantum of compensation to the District legal
authority of the area. Section 357(3) gives the power of imposing compensation order in
different cases as per discretion of the court. Section 357 (4) further widens the scope of who
can claim compensation by extending it to victims even in cases where the offender could not
be identified and the victim has been identified. Section 357(5) and (6) talk about providing
first aid or extending any other kind of aid after conducting a preliminary enquiry.
ANALYSIS OF STATE COMPENSATION SCHEMES
Almost all states have victim compensation schemes now. Each state has notified its own
scheme separately, and these amounts provided by these schemes are often drastically
different from one another. These schemes were essentially a mechanism to ensure that the
payment of these amounts to all victims can be done in a more systematic and
institutionalised manner. The VCS is applicable even in cases when no amount of
compensation is payable either due to acquittal or when the accused is not capable of paying
a certain amount. These payments of compensation can also be made upon the
recommendation of the court like in cases of Gang rape (S. 376D, Indian Penal Code), Acid
Attack, (Section 326B, Indian Penal Code) to name a few. The section also aims to cater to
other needs of the victims like that of medical aid. Proceeding charges etc.
There is a division over the whether the legal heirs can or cannot claim benefit under the
scheme. The Punjab and Haryana high court ruled in M/s Tata Steel Ltd. v. M/s Atma Tube
Products30 held that legal heirs can only include people who have been directly affected
whereas the Delhi high court has ruled otherwise in the case of Chattar singh vs. Subhash
and Ors.31.
Most schemes do not define the ambit of what compensation really includes- for example the
term ‘Rehabilitation’. What it can and cannot include has been left to the discretion of the
DSLA, such has been analysed after a brief analysis of the VCS of 12 states. The

28
AIR 1988 SC 2127
29
1996 SCC (1) 490
30
2013 (1) ILR 719 (P&H)
31
176 (2011) DLT 356 
implementation authority at large continues to be the District Legal Services Authority.
However, in some cases, the responsibility of implementing the scheme has also been given
to the State Legal Services Authority, like in the case of the Assam Victim compensation
scheme of 2012, Delhi victims compensation scheme of 2015, Madhya Pradesh Victims
compensation scheme of 2015, Gujarat Victim compensation scheme of 2015.32
Monitoring or Supervising body – In most state, there is no body to supervise the functioning
of the Victim Compensation scheme. Not all states have a separate elaborate mechanism for
ensuring the proper functioning of the scheme. For example, in Bihar, 33 the state law
department takes care of the functioning of this system, whereas in Madhya Pradesh, 34 two
level departments (State level committee and District level committee) have been set up
under the Home department of the State to overlook the implementation of such a scheme.
Eligibility- generally the requirement talks about a ‘substantial’ damage which makes the
victim truly deserving of receiving external aid from the state. For example, in the case of the
Goa scheme, Odisha scheme, Assam scheme to name a few, the damage must be ‘substantial’
and considerable in nature. In Odisha, the requirements include any individual who will find
it difficult to continue and restart their life without compensation and if their personal dignity
has truly been hampered, as stated in cl.7(b) of the Odisha Victim compensation scheme. 35
The Criteria also varies from state as some states set a financial threshold that qualifies the
extent or amount payable to the victim.36
Limitation – the time period for limitation actually varies from state to state. The scheme
itself has to clarify the limitation period for every state. This period generally ranges from six
months to one year or could even have more than one year period like 3 years, as specified
limitation period as in the case of the Gujarat compensation scheme.37
Amount of compensation – There is absolutely no consensus regarding the quantum of
compensation which every state government may give. This question was explored in entirety
by the Supreme court in the case of Tekan Alias Tekram Versus State Of Madhya Pradesh 38
where the court found the VCS of the state of Chattisgarh to be dissatisfactory and hence
proceeded to examine the schemes of other states with regards to victim compensation in the
case of rapes.
The court has stated the following –
“Perusal of the aforesaid victim compensation schemes of different States and the Union
Territories, it is clear that no uniform practice is being followed in providing compensation to
the rape victim for the offence and for her rehabilitation. This practice of giving different
amount ranging from Rs.20,000/- to Rs.10,00,000/- as compensation for the offence of rape
under section 357A needs to be introspected by all the States and the Union Territories. They

32
Supra note 11.
33
Bihar victim compensation scheme, can be accessed at http://bslsa.bih.nic.in/schemes.html
34
Madhya Pradesh crime victim compensation scheme, can be accessed at http://home.mp.gov.in/en/victim-
compensation-scheme-2015
35
Odisha Victim compensation scheme, 2019 can be accessed at https://www.homeodisha.gov.in/odisha-victim
36
Supra note 34.
37
Gujarat victim compensation scheme, 2019 can be accessed at
https://home.gujarat.gov.in/Upload/GUJARAT_VICTIM_COMPENSATION_SCHEME-2019_300519.pdf
38
2016 SCC Online SC 131
should consider and formulate a uniform scheme specially for the rape victims in the light of
the scheme framed in the State of Goa which has decided to give compensation up to
Rs.10,00,000/-.”
The court further went on to issue the following directions –
“All the States and Union Territories shall make all endeavour to formulate a uniform scheme
for providing victim compensation in respect of rape/sexual exploitation with the physically
handicapped women as required under the law taking into consideration the scheme framed
by the State of Goa for rape victim compensation.”
It is clear that while the court agreed that no amount of compensation can truly restore the
dignity and respect of the individual, this aid is crucial in the aftermath and recovery as the
victim tries to ease back into a normal existence.39
THE CENTRAL VICTIM COMPENSATION SCHEME
The central government realised the need for intervention and making a somewhat centralised
system of guaranteeing compensation victims through the Criminal Law (Amendment) Act,
2013 was enacted on 2nd April, 2013, called the Central Victim Compensation scheme
(CVCS) which was also one of the reactions to the Nirbhaya incident. The fund was called
Nirbhaya fund. The Central victim compensation fund (CVCF)40 came to life in 2015. They
even introduced the concept of having ‘One Stop Centres’ controlled by the centre in each
state. This was an initiative by the The Ministry of Women & Child Development where they
will provide medical, legal aid through these centres.41
Even though all states have complied with the mandate by formulating a scheme for
compensation – but the question persists how well availed are these schemes? How
successful are they? How well availed are these schemes? To analyse the same, take a look at
the data of 2018 to 2019 provided by the National legal services Authority which reflects
how aware people are of these schemes and how well utilised they are by the public.

NATIONAL
LEGAL
             
SERVICES
AUTHORITY
STATISTICAL INFORMTION IN R/O VICTIM COMPENSATION SCHEME U/S
   
357-A CR.PC 
    APRIL, 2018 TO MARCH, 2019    
Applications  Applications /  Applications
received orders received
Application Applications Compens
S.NO SLSA directly by marked / including
s Decided  Pending Awarded
Legal Service directed by any Court Orders
Institutions (A) Court (B) (A+B)
 1 Andaman & 0 0 0 0 0
39
Ibid.
40
Central victim compensation scheme, can be accessed at
http://uphome.gov.in/writereaddata/Portal/Images/CVCF.PDF
41
Ibid.
 Nicobar
Islands
Andhra
2 95 33 128 46 75 12374136
Pradesh
Arunachal
3 47 2 49 38 2 7820000
Pradesh
4 Assam 139 423 562 371 547 44770402
5 Bihar 578 243 821 470 18 93785000
6 Chhattisgarh 384 436 820 587 446 38498000
Dadra &
7 Nagar 0 6 6 4 1 650000
 Haveli
Daman &
8 0 0 0 0 0 0
Diu
9 Delhi 916 1698 2614 2284 1372 52192900
10 Goa 0 4 4 0 4 0
11 Gujarat 230 189 419 394 181 73409000
12 Haryana 98 334 432 396 115 77911000
Himachal
13 36 51 87 33 0 1840000
Pradesh
Jammu &
14 26 8 34 19 0 5325000
Kashmir
15 Jharkhand 292 499 791 373 981 59395000
16 Karnataka 1696 559 2255 866 1462 10770727
17 Kerala 114 356 470 150 221 30610000
18 Lakshadweep 0 0 0 0 0 0
Madhya
19 650 484 1134 590 446 54420000
Pradesh
20 Maharashtra 114 43 157 104 211 7770000
21 Manipur 0 26 26 0 38 0
22 Meghalaya 80 24 104 31 6 2345000
23 Mizoram 231 56 287 88 51 25072000
24 Nagaland 11 0 11 0 12 0
25 Odisha 1024 275 1299 783 1419 10007918
26 Puducherry 1 2 3 1 0 300000
27 Punjab 337 61 398 138 236 16552350
28 Rajasthan 1295 777 2072 2170 674 27652375
29 Sikkim 0 0 0 0 0 0
30 Tamil Nadu 757 118 875 425 947 57661540
31 Telengana 20 10 30 13 26 0
32 Tripura 31 22 53 69 28 10820000
U. T.
33 7 12 19 10 10 8200000
Chandigarh
34 Uttar Pradesh 26 0 26 26 0 3625000
35 Uttarakhand 42 54 96 76 36 16280300
36 West Bengal 136 136 272 198 24 28719806
  Grand Total 9413 6941 16354 10753 9589 16843927
42
SOURCE – National legal services authority data, year 2018 to 2019.
The data shows that while some states like Odisha show much awareness about the scheme,
states like Uttar Pradesh have surprisingly low numbers which are a complete mismatch
given the high crime rates. Even though there has been a shift from complete absence of such
schemes to moving onto creating a scheme but there is still a huge difference between the
actual convictions and the number of applications received in a state for such compensation,
which means that a lot of deserving victims go on without aid from the state. Even though the
scheme is a great effort to help out victims, there is still much divergence on the amount to be
given, eligibility criteria by these states.

CONCLUSION AND CRITIQUE

In conclusion, the problem with the scheme lies at levels of drafting as well as
implementation. The very fact that such low number of victims actually received as
compensation as reflected by the data speaks heavily. Schemes are of no use if they
eventually fail to really help the public due to lack of awareness. Distribution of information
regarding this scheme should also be made compulsory for the court/authority. The
coordination between the courts and the legal services authority that is meant to guarantee
these compensations doesn’t seem to be positive according to the figures. In terms of
drafting, the scheme has no uniformity in the entire country. No two states have any
uniformity of the amount to be paid to victims. It has to be taken into account that the cost of
rehabilitating the victim cannot be made uniform across the country, for everything from
living costs, to residence differs from place to place, district to district and state to state.
However, these costs can be considered additional to that of the major compensation that is
given specifically for the crime committed. The District legal services authority really needs
to coordinate with the state to ensure that adequate budget allocation is done for victims,
keeping in mind all these factors. Victims may come from very destitute conditions and may
require regular government support or medical support. News articles have documented
personal experiences of various acid attack victims who have failed to avail the scheme
successfully.4344 Stories of victims with no financial support for basic facilities like last rites,
let alone medical support.45 Besides, there is no clarity of the criteria to be used to allocate
these amounts to the victims, there is no uniformity or even clarity of any eligibility criteria
as to who is and is not entitled to compensation. There is absence of any overviewing or
monitoring body that specifically supervises these functions of the DSLA. There are also
42
NSA statistical archives, can be accessed at https://nalsa.gov.in/statistics/r-o-victim-compensation-schemes-
april-2018-to-march-2019
43
Harsha Raj Gatty, ‘ Supreme Court ruling on financial aid not enough, say acid-attack victims’, July 23, 2013
at 1:21, https://www.deccanherald.com/city/supreme-court-ruling-on-financial-aid-not-enough-say-acid-attack-
victims-336650.html
44
Amit Ganguly, ‘Scarred victims of acid attacks struggle to get their due’, March 7. 2014. Can be accessed at
http://blogs.reuters.com/india/2014/03/07/scarred-victims-of-acid-attacks-struggle-to-get-their-due/
45
PTI, ‘Acid attack victim loses battle for life, father writes to Nitish Kumar to ask for financial aid for last
rites’, July 02, 2017, can be accessed at https://www.firstpost.com/india/acid-attack-victims-father-writes-to-
nitish-kumar-asks-for-financial-aid-for-her-last-rites-3767901.html
multiple concerns raised over the inadequacy of amounts allocated to these victims, and
whether their quantum is sufficient to successfully rehabilitate a victim into the society at
least partially if not completely. To conclude, this scheme can still be said to be in its initial
stages with opaqueness in a lot of areas, which needs to be changed to truly make it effective
and available for all victims.