I.

(A) Personal Details

Role Name Affiliation

Principal Investigator
Paper Coordinator
Content Writer/Author (CW)
Content Reviewer (CR)
Language Editor (LE)
Prof. Sumita Parmar Allahabad University, Allahabad
Prof. Reicha Tanwar Kurukshetra Univesity, Kurukshetra
Dr. Vandana Dave Kurukshetra University, Kurukshetra
Prof. Reicha Tanwar Kurukshetra University
Dr. Sonal Parmar Consultant Editor, New Delhi

(B) Description of Module

Items Description of Module

Subject Name Women’s Studies
Paper Name The Discipline of Women Studies
Module Name/ Title Violence against Women,
Module ID Paper-1, Unit-7, Module-33
Pre-requisites The reader is expected to have an awareness of the
kinds of atrocities against women.
Objectives To make the readers aware about the various forms
of violence against women and the legal provisions
to safeguard them.
Keywords Domestic Violence, Trafficking, Devadasi, Dalit,
Sexual Harassment, Caste Panchayat

II.

1. Introduction
The situation of women in India is paradoxical. While on the one hand they are participating in all
spheres of life and accessing the highest positions in the fields of education, politics, the corporate world, to
name just a few, on the other had they are the victims of extreme forms of violence perpetrated on them both
by their families and by society Although the constitution of India guarantees to all Indian women equality of
opportunity to work, freedom of speech, protection of life and personal liberty and it allows special provisions
to be made by the States in favour of women and also renounces practices derogatory to the dignity of women,
but in reality, a lot of women are not able to access these constitutional rights. Not only are social evils like
female foeticide, child marriage and dowry the barriers, but several other problems like crimes against
women, domestic violence, trafficking of women, sexual harassment at the work place also exist. Gender
based violence, which has become a global issue and concern, cuts the boundaries of regional, social, cultural
and the economic status women. Ironically, in spite of several social legislations in place to provide a safe
environment, women in India feel insecure and threatened.
2. Violence Against Women
In recent years, the issue of violence against women has been recognized as a basic human rights issue
and the elimination of gender based violence has been seen as central to equality, development and peace.
Violence against women includes not only physical violence, but also sexual, psychological and emotional
abuse. Many forms of violence are not even recognized as such and are ignored, condoned or justified by
ascribing them to religious, cultural or traditional beliefs. There is increasing evidence to show that women,
regardless of age, educational level, class, caste, community and family living arrangement are vulnerable to
violence1. The violence against women has increased to the extent that not a single day passes without
newspapers reporting some incident or the other.
The phrase, violence against women, refers to many types of harmful behaviour directed at women
and girls because of their sex. In 1993 the United Nations offered the first official definition of such violence
when the General Assembly adopted the Declaration on the Elimination of Violence against
Women.(CEDAW) According to it, violence against women consists of “any act of gender based violence that
results in, or is likely to result in, physical, sexual or psychological harm or suffering to women, including
threats of such acts, coercion or arbitrary deprivation of liberty, whether occurring in public or private life”.
There is increasing consensus, as reflected in this declaration, that abuse of women and girls,
regardless of where and how it occurs, is best understood within a gender framework because it stems in part
from women’s and girls’ subordinate status in society2. The wide spread violence against women is seen both
as an indicator and means of perpetrating this subordinate status which also manifests itself through various
forms of structural violence such as low health status and lack of access to education and employment. In such
a scenario, wherein women are generally powerless, direct violence against women appears to have the dual
function of at once controlling women and perpetuating their subordinate status3. In other words violence
against women is a manifestation of unequal power relations, which have led to man’s domination over and
discrimination against women. It helps to keep the structure of patriarchy intact.
Violence against women can be divided into two categories4:
a) Physical, sexual and psychological violence occurring within the community, including rape,
sexual abuse and intimidation at work or elsewhere, trafficking of women and forced prostitution.
b) Physical, sexual and psychological violence occurring in the family including battering, sexual
abuse of female children in the household, dowry related violence and other traditional practices
harmful to women and non spousal violence.
As mentioned above, violence includes physical, sexual, emotional, psychological, economic and
some other types of abuses as follows:
- Physical Violence: means hitting, slapping, kicking, beating, pushing or punching.
- Sexual Violence: includes coercive sex, rape, molestation, harassment.
- Emotional Violence: consists of intentional attempt to humiliate and insult the person.
- Psychological Violence: means any threats which are intentionally directed to humiliate or blackmail
or injure the person emotionally.
- Economic Violence: is denying fulfilling economic needs or creating financial dependence.
- Intimidation: It includes making women afraid by using actions, gestures, looks and by any weapon.
- Isolation: It means controlling behaviour like isolating a woman from family and friends, monitoring
her movements and restricting her access to resources.
While the basic reason for violence against women is their inferior status - educationally,
economically, politically and socially - in a male dominated society, there are other factors too. The increasing

1
Goel Aruna, Violence and Protective Measures for Women Development and Empowerment, Deep & Deep,
Publications Pvt. Ltd., New Delhi, 2004, p.2-3.
2
Gour Anuradha, Violence Against Women: A National and International Perspective, M.D. Publications Pvt.
Ltd., New Delhi, 2010.
3
Yadav Sushma & Mishra Anil Dutta, Gender Issues in India, Radha Publications, New Delhi, 2003.
4
Goel Aruna, Violence and Protective Measures for Women Development and Empowerment, Deep & Deep,
Publications Pvt. Ltd., New Delhi, 2004, p.2-3.

2
criminalization of society, media images of violence, poor enforcement of legal provision, unabashed
consumerism and erosion of traditional values have all added to it5.
Listed below are the various forms of violence against women that have been categorized as crimes
under various sections of the Indian Penal Code :
3. Rape
The threat of sexual violence aims at restricting women’s physical mobility and to punish women who
flout social norms. It is a common crime against women which leaves the victim suffering not just physically
but psychologically too, compounded by an additional stigma. Moreover, women are held responsible for any
sexual misconduct which brings shame upon a family. As per the statistics provided by the National Crime
Records Bureau(NCRB), in 2012, Madhya Pradesh was at the top among Indian states with 3,425 incidences
of rape which contributed to 13.74 % of the total number of crimes committed against women. Rajasthan
ranked second with 2049 incidents of rape and West Bengal was at the third position with 2046 incidents.
Nagaland recorded the minimum number of rape case in 2012 i.e. 21 only.
Section 376 of the Indian Penal Code provides the definition and punishment for the offence of rape. It
says that any penetration other than penile penetration is an offence. A man is said to commit rape under the
following seven descriptions:-
i) Against her will
ii) Without her consent
iii) With her consent, when her consent has been obtained by putting her or any person in whom she is
interested missing
iv) With her consent, when the man knows that he is not her husband and that her consent is given
because she believes that he is another man to whom she is or believes herself to be lawfully
married
v) With her consent when, at the time of giving such consent, by reason of unsoundness of mind or
intoxication, she is unable to understand the nature and consequences of that to which she gives
consent
vi) With or without her consent, when she is under eighteen years of age
vii) When she is unable to communicate consent.
The punishment for rape is rigorous imprisonment of either description for a term of not less than
seven years, but which may extend to imprisonment for life and a fine.
4. Kidnapping and Abduction
Kidnapping and abduction of a girl is a common crime pervasive in society. The reason behind
kidnapping is not only money extortion but also sexual assault. Sometimes kidnapping and sexual abuse of a
girl child is done to take revenge from the aggrieved family. Girls are also being kidnapped for the purpose of
forced begging, forced prostitution, blackmailing and other sexual crimes. It was reported by the NCRB(2012)
that West Bengal recorded the highest incidences of kidnapping and abduction with 4168 cases followed by
3789 incidents in Bihar and 3360 in Assam. Mizoram had the least incidences of Kidnapping (only 3).
Sections 363-369 and 371-373 of the Indian Penal Code deal with the crime of kidnapping and abduction. It
says that whoever kidnaps or abducts any woman with intent that she may be compelled to marry someone
against her will or in order to seduce sexually, shall be punished with imprisonment of either description for a
term which may extend to ten years with a fine.
5. Sexual Harassment

5
Goel Aruna, Violence and Protective Measures for Women Development and Empowerment, Deep & Deep,
Publications Pvt. Ltd., New Delhi, 2004, p.2-3.

3
 The threat of sexual harassment follows girls and women throughout their lives. The cases of
molestation, eve teasing, stalking are on an increase and even women in high positions are not exempt from
this menace which cuts across boundaries of caste and class. Section 509 of the Indian Penal Code deals with
offences regarding words, gestures or acts intended to insult a woman and the punishment for this abuse is
imprisonment for a term extendable up to one year, or with fine or with both.
As per the recommendations of the Justice Verma Committee Report constituted after the Nirbhaya
incident of Delhi, the Criminal Law Amendment Act, 2013 came into force. It amended section 354 of the
Indian Penal Code which dealt with molestation of women. Now this section deals with the acts of sexual
harassment in four ways:
Section 354 A says, that Sexual Harassment means a man committing any act of physical contact and
advances involving unwelcome and explicit sexual overtures or a demand or request for sexual favours or
showing pornography against the will of a woman or making sexually coloured remarks. The punishment for
this act is imprisonment for a term extendable to three years or fine or both.
Section 354 B is related to assault or use of criminal force with a woman with intent to disrobe which
means that any man who assaults or uses criminal force with any woman or abets such an act with the
intention of disrobing or compelling her to be naked shall be punished with imprisonment extendable to seven
years or with fine or with both.
Section 354 C deals with the offence of Voyeurism. Any man who watches or captures the image of a
woman engaging in a private act where she would usually have the expectation of not being observed by any
one or disseminates such an image shall be punished with imprisonment extendable to three years on first
offence and on subsequent conviction punishment extendable to seven years and a fine.
Section 354 D is related to stalking. Any man who follows a woman and contacts or attempts to
contact such woman to foster personal interaction repeatedly despite a clear indication of disinterest by such
woman or monitors the use by a woman of the internet, email or any other form of electronic communication
commits the offence of stalking. This offence is liable to three years imprisonment.
As per the NCRB data for the year 2012, the highest percentage of crimes under section 509 of the
Indian Penal Code were recorded in Andhra Pradesh which was 40.49 %, followed by Maharashtra at 14.11 %
of the total crime, while under section 354 of the Indian Penal Code, Madhya Pradesh was at the top with
14.67 % of total crimes and Andhra Pradesh held the second position with 10.62% of the total crime under this
section. The North Eastern states of Meghalaya, Mizoram and Nagaland have the least number of such crimes.
6. Dowry and Dowry Deaths
Dowry is crucially linked to the devaluation of women in society. Perpetuated by the increasingly
materialistic culture of society, it has become a common practice in almost the entire country. Dowry is a
payment in cash or kind given by the bride’s family to the groom’s family. Originally intended to help with
marriage expenses, it has become extravagant and a burden on the girl’s family. If the in-laws are not satisfied
with the dowry, dowry harassment and even murders are committed. This is a manifestation of objectifying
and degrading women. There are no reliable statistics on the number of cases of dowry harassment and deaths
due to non reporting, but according to the records of the NCRB 2012, Andhra Pradesh had the highest number
(2511) of cases registered under the Dowry Prohibition Act, followed by Odisha with 1487 cases. With regard
to cases of cruelty by husband or his relatives West Bengal has the highest percentage (18.65%) followed by
Andhra Pradesh (12.57%) and Rajasthan (12.50%). If we have a look at the figures for dowry deaths, Uttar
Pradesh has the highest incidences i.e. 2244 followed by Bihar, 1275 incidences and Madhya Pradesh 743
incidences. North Eastern states have the smallest number of incidents of dowry deaths.
The Dowry Prohibition Act 1961, defines dowry as any property or valuable security given or agreed
to be given either directly or indirectly by one party to the other party , or by the persons of either party or by
any other person, at or before or any time after the marriage. The person guilty of giving or accepting dowry
may be imprisoned for a minimum of five years and fined not less than Rs. 15,000/- or the amount of the value
of the dowry, whichever is more. Dowry death is death of a woman when it is caused by any burns, injury or

4
occurs otherwise than under normal circumstances within seven years of her marriage and it is shown that
soon before her death she was subjected to cruelty in connection with any demand for dowry. The person
convicted for dowry death can be jailed from seven years to life.
7. Domestic Violence
Another form of violence against women is domestic violence. It is a universal phenomena and also a
method to keep women subordinated in a patriarchal social system. Domestic violence, in its broader sense is
violence among members of a family or members of a household. It implies any type of discrimination or
violence that is inflicted by any member of the family upon another member of the family. Domestic violence
implies the misuse of power in a relationship to control another. The relation could be both natal and nuptial.
A number of causes of domestic violence have been identified in different studies. These causes can be
broadly divided into two categories. The first category is concerned with the individual characteristics of the
abuser and includes individual problems such as unemployment, stress, poverty, being physically challenged
or the lack of material resources. The second category of causes is concerned with the patriarchal control of
men over women. This can be understood by the gender power relation between men and women based on the
ideology of male superiority and dependency of women over men and control of men over social economic
and political resources6. The other reasons may be alcoholism, extra marital affairs, attitudes, not bearing a
son, bringing little dowry and many more.
In the patriarchal societies, girls and women are socialized in such a way that they internalize the
notion of wife beating and feel that it is a right of a man to beat his wife. They do not take it as a breach of
their right to live with dignity. The phenomenon of domestic violence is so widely prevalent that the state had
to intervene in the private life of a woman to provide her with protection from domestic violence. It has now
become an offence under the Protection of Women from Domestic Violence Act 2005. Defining domestic
violence, the act says ‘an act of omission or commission or conduct which harms, injures or endangers the
health, safety, whether mental or physical and includes physical abuse, sexual abuse, verbal and emotional
abuse and economic abuse. It can also be harassment, harm or threat by way of unlawful dowry demand or
related to property or valuable security.
Thus the act covers domestic violence in the following four ways:
Physical violence means beating, battering, slashing, pulling hair, hitting with some object. Sexual
violence includes rape, undressing forcefully or other kinds of sexual abuse. Psychological violence consists of
threat to kill, torture, humiliation, threat to torture children or other family members. Economic violence
includes denial of basic facilities like food, health care, lack of access to resources, not giving money for
maintenance of self and children.
Under this act the magistrate may, after giving the aggrieved women and the respondent an
opportunity of being heard and on being prima facie satisfied that domestic violence has taken place or is
likely to take place, pass the following orders in favour of the aggrieved women.
Protection Order: The Magistrate may pass the protection order to prohibit the respondent from committing
any act of domestic violence, entering the place of employment of the aggrieved women or attempting to
communicate with her in any form.
Residence Order: Residence order may be passed restraining the respondent from dispossessing the
aggrieved women from the shared household or directing the respondent to remove himself from the shared
household.

6
Sultana Ameer, Battered in the Safe Haven: Women and Domestic Violence in Goel Aruna, Kaur Manvinder,
Sultana Ameer (Eds.) Violence Against Women: Issues and Perspectives, Deep and Deep Publications Pvt.
Ltd., Delhi, 2006.

5
Monetary Relief: The Act empowers the Magistrate to pass orders for the grant of monetary relief to the
aggrieved women from the respondent to meet the expenses incurred and losses suffered including, loss of
earnings, medical expenses, loss to property and maintenance of the women and her children.
Custody Order: He may grant temporary custody of children.
Compensation Order: He may pass an order directing the respondent to pay compensation or damage or both
to the women for the injuries including mental torture and emotional distress.
According to the National Family Health Survey III conducted in 2005-06, one third of the women
aged 15-49 years have experienced physical violence and about 1 in 10 have experienced sexual violence. In
total, 35% have experienced physical or sexual violence at the hands of their husbands and other family
members. It was also revealed by the survey that married women are more likely to experience physical or
sexual violence by husbands than by anyone else. Women married to men who get drunk frequently are more
than twice as likely to experience violence as women whose husbands do not drink alcohol. However, alcohol
is not the only factor as 30 percent of women experienced spousal violence whose husbands did not drink.
Spousal violence varies greatly by state. The prevalence of physical or sexual violence ranges from 6
percent in Himachal Pradesh and 13 percent in Jammu & Kashmir and Meghalaya to 46 percent in Madhya
Pradesh and Rajasthan and 59 percent in Bihar. About 54 percent women and 51 percent men agreed that it is
justifiable for a husband to beat his wife under some circumstances, 16 percent of never married women of the
age of 15 years experienced physical violence by a parent, sibling or teacher and 1 percent were sexually
abused. Among sexually abused girls, 27 percent said the perpetrator was a relative7.
All forms of domestic abuse have one purpose to gain and maintain control over the victim. Abuser
uses many tactics to exert power over the victim like domination, humiliation, isolation, denial and blame.
Social learning enforces violence and people learn from observing and imitating others behaviour. If they
observe that the victim accepts the violence silently, then the behaviour is likely to continue. The abuser’s
effort to dominate his partner has also been attributed to low self esteem or feeling of inadequacy and stress of
poverty8.

8. Trafficking of Girls and Women

Trafficking of minor girls and women is a worldwide phenomenon, but more prevalent in poor
countries. Poor families with the desire to earn some money send their daughters to the nearby cities or towns
for employment, through a mediator. These girls are sold by him to earn more money and become victims of
exploitation. Similarly, women are vulnerable to exploitation by traffickers because the poor livelihood
options of the village push them to being trafficked. Trafficking may be defined as ‘the recruitment,
transportation, transfer, harbouring or receipt of persons by means of threat or use of force or other forms of
coercion, of abduction, of fraud, of deception, of the abuse of power or of a position of vulnerability or of the
giving or receiving of payments or benefits to achieve the consent of a person having control over another
person, for the purpose of exploitation’9.
Studies conducted on vulnerability factors indicated that broadly two factors are responsible for this
crime. One is personal circumstances and the other is the socio structural forces10. Personal circumstances
include women with low self esteem, lack of self control, low literacy level or awareness and information,

7
National Family Health Survey-III, 2005-06, International Institute of Population Sciences, Mumbai.
8
Srivastava Hemlata, “Domestic Violence Against Women”, in Subhash Chandra Singh, Gender Violence,
Serials Publications, New Delhi, 2011, p. 30-37.
9
UN Protocol to Prevent, Suppress and Punish Trafficking in Persons, Especially Women and Children 2000,
quoted in Sen Sarkar and Nair P.M., Trafficking in Women and Children in India. Orient Longman Pvt. Ltd.,
2005, p. 1-25.
10
Raymond et al, 2002, quoted in Sen Sarkar and Nair P.M., Trafficking in Women and Children in India.
Orient Longman Pvt. Ltd., 2005, p. 1-25.

6
economic deprivation and disability. The higher the degree of these factors, the greater the risk of
vulnerability. Besides these factors, dysfunctional home environments like marital discord also leads to the
trafficking of women. Socio- structural factors include industrialization, globalization, economic decline or
underdevelopment, privatization and urbanization. Environmental and political factors like immigration
policies etc also have a role to play. Economic crisis, the loss of traditional livelihood or the need for gainful
employment leads to the creation of situations where women easily get into the clutches of the traffickers. The
traffickers are always looking for opportunities to abduct or persuade or kidnap women and girls at places
like bus stops, construction work sites, rehabilitation areas or even within homes. It was seen that the
movement of trafficked people was from less developed areas to more developed regions or from rural to
urban areas. Sometimes trafficking is done within the country and sometimes to neighbouring countries or
even to other continents. In India, Delhi and Mumbai are the main transit zones for international trafficking.
There is a relationship between trafficking of women and commercial sexual exploitation. The girls or women
being trafficked are often used as labourers but mostly for prostitution, pornography, cyber sex and sex
tourism.
According to the NCRB report 2012,11 Tamil Nadu with 500 cases of immoral trafficking was at the
top among the Indian states followed by Andhra Pradesh who has recorded 472 cases, Maharashtra 366 cases
and Karnataka 335 cases.
Section 370 of the Indian Penal Code deals with the crime of trafficking of a person. It says that
whoever for the purpose of exploitation recruits, transports, harbors, transfers or receives a person or persons
by using threats or force or any form of coercion or by adducting or by practicing fraud or abuse of power or
by inducement including giving or receiving of payments shall be punished with rigorous punishment for a
term of seven years extendable to ten years and a fine. Punishment for trafficking of more than one person or a
minor may extend to life imprisonment with a fine.
Besides being forced to work as a domestic labour or as a labourer in a small scale industry or as a sex
worker, women and girls may be trafficked for performing illegal activities like drug peddling, forced
marriages, begging or be sold off through adoption rackets or for organ trading. 12

9 Sexual Harassment at the Workplace

Sexual harassment at the workplace is a growing concern for women who confront it whether working
at lower levels or higher level positions. Women have been subjected to harassment, trauma and victimization
by co-workers or seniors through threats and other pressures. Employers abuse their authority to seek sexual
favours from their female subordinates and sometimes promising promotions or other forms of career
advancement. Women who refuse to give in to such unwanted sexual advances often have the risk of demotion
or dismissal from the workplace. The type of harassment may range from physical to psychological, the most
common among these being making offensive comments. These comments may be about the dressing sense
of the women or their way of behaving or unnecessarily finding out faults in their work thereby harassing them
mentally or psychologically. Physical harassment includes touching, pressing or asking for sexual favours.
Harassment is most often an issue of power, with harassers often holding organizational power or
supervisory authority over those they harass. Harassment is defined as “Unwelcome sexual advances, requests
for sexual favours and other verbal or physical conduct of a sexual nature when submission to or rejection of
this conduct explicitly or implicitly affects an individuals employment, unreasonably interferes with an
individuals work performance or creates an intimidating, hostile or offensive work environment” (U.S. EEOC,
2004). The two types of harassment are, first, quid pro quo harassment, which involves the provision or denial
of favourable job conditions, pay raises, or promotions on the basis of acceptance or rejection of requests for

11
National Crime Records Bureau, 2012, http://www.ncrb.nic.in.
12
Sen Sarkar and Nair P.M., Trafficking in Women and Children in India. Orient Longman Pvt. Ltd., 2005, p. 1-
25.

7
sexual favour, and second, the creation of a hostile environment, which occurs when verbal, physical or
graphic sexual displays are so pervasive that they interfere with work performance or cause an offensive or
intimidating atmosphere in the workplace. Harassment is difficult to address because it usually requires the
less powerful in a work organization to confront the more powerful. It is also often the case that a general
atmosphere or culture in the organization exists in support of the harassing behaviour especially those of the
hostile environment variety and those involving less physical behaviour 13.
Workplace violence - be it physical or psychological has gone global, crossing borders, work settings
and occupational groups. The U.N. System has been taking keen interest in eliminating violence at workplace.
The International Labour Organization, ILO undertook a comprehensive world wide survey of violence at the
workplace and reported that women are particularly vulnerable, some workplaces and occupations have
become high risk and women are concentrated in these high risk occupations- particularly as teachers, social
workers, nurses, bank and shop workers14.
In India the issue of sexual harassment of women at the workplace attracted the attention of people
related to the women’s movement, academicians and the public after the brutal gang rape of a worker of a
Women Development Programme, when she tried to stop a child marriage as a part of her duties. The feudal
patriarchs annoyed by her courage wanted to teach her a lesson. On behalf of that woman,Vishaka a women’s
rights group filed a Public Interest Litigation in the Supreme Court of India. The Supreme Court in 1997 for
the first time acknowledged sexual harassment at the workplace as a human rights violation. Its judgement was
called the Vishaka Guidelines. All the organizations whether public or private had to mandatorily follow the
guidelines and provide violence free environment to women at the workplace.
Subsequently in April 2013 the Sexual Harassment of Women at Workplace (Prevention and
Redressal) Act was passed. It says that sexual harassment results in violation of the fundamental rights of a
woman to equality, her right to life and to live with dignity, right to practice any profession or to carry on any
occupation, trade or business which includes a right to a safe environment free from sexual harassment.
As per the Act, Sexual Harassment includes any contact and advances or a demand or request for
sexual favours or making sexually coloured remarks or showing pornography or any other unwelcome
physical, verbal or non verbal conduct of sexual nature. The workplace means any organized or unorganized,
public or private organization, enterprise, establishment or institution, hospital, sports complex, house or any
place visited by the employee during the course of employment.
Every employer of a workplace is bound by the law to constitute an Internal Complaints Committee to
deal with the complaints of sexual harassment. Besides this, every District Officer has also to constitute a
district level committee called the Local Complaints Committee to receive complaints of sexual harassment
from establishments where the Internal Complaints Committee has not been constituted due to having less than
ten workers or if the complaint is against the employer himself.
Any aggrieved woman may make a complaint of sexual harassment to the police under Section 354A
or to the Internal Complaints Committee or the Local Complaints Committee constituted under the Sexual
Harassment Act

13
Delaat Jacqueline, Gender in the Workplace: A Case Study Approach, Sage Publications, New Delhi, 2007,
p. xxiii
14
Goel Aruna, Violence and Protective Measures for Women Development and Empowerment, Deep & Deep,
Publications Pvt. Ltd., New Delhi, 2004. p. 169-170.