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Bharati Law Review

Volume VII, Issue 4 (April-June, 2019) PP 44-55


ISSN 2278-6996; e-ISSN 2457-0567
bharatilawreview.com

Child Beggary in India: An Analysis of the Legal


Framework with special reference to Karnataka

Shruthi Prabhakar
(Asst. Prof., Christ Academy Institute of Law, Affiliated to Karnataka State Law University,
Bengaluru)

Abstract: When it comes to begging a state of complete apathy exists in


India. Being a welfare State, India has done little to improve the condition of
beggars. Whether forced by their own families, or as part of begging rackets,
the children are at the receiving end of this apathy with no access to proper
nourishment, health-care, education or even nurturing love. There is no
legislation which comprehensively deals with begging amongst children. One
needs to look at a combination of laws while addressing the issue of child
beggary. About 22 states have enacted legislations prohibiting and punishing
beggary but these laws merely criminalize begging without attacking the root
of the problem and fail to effectively deal with the rehabilitation of children
found begging. Recent past has seen a few PILs filed seeking basic
fundamental rights for beggars and to decriminalize begging. In a country
where poverty and unemployment cripple a large percentage of its population,
it becomes necessary to have laws which can break the vicious circle of
poverty, unemployment and beggary. This paper tries to understand the laws in
India, with special reference to Karnataka, which deal with child beggary,
their implementation and the moral dilemmas of criminalizing begging against
the backdrop of poverty and unemployment.
Keywords: Child Beggary, Poverty, Unemployment, Rehabilitation

I. INTRODUCTION who do not have access to three-


India is a country with a square meals a day and basic
Population of over 121 crores[1]. conditions of life. It is a well-
Out of this, 2011-12 reports known fact that over-population
indicate that approximately 21.9% leads to social evils like poverty,
of the population lives below illiteracy, unemployment, etc. It
poverty line.[2] Even though the quite often becomes difficult even
Government claims that the for a well-educated man to obtain
population living below poverty employment in such a situation, let
line has decreased, in a country alone a person leading an
with such a huge population 21.9% impoverished life. When obtaining
amounts to almost Lakhs of people even the most basic necessities of

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life- food, water, shelter, clothes- various States are a far cry from
becomes a distant dream, man is addressing this alarming situation.
forced to turn to the mercy of other This paper seeks to analyze the
human beings. He starts begging, laws dealing with child beggary
either by his own will or forced by and the moral dilemma of
miscreants who take advantage of criminalizing begging against the
his helplessness. Children, who are backdrop of poverty and
looked upon as a source of unemployment in India.
additional income in these poor
families, become easy targets and II. BEGGARY AMONGST
are pushed into begging. CHILDREN
The Oxford dictionary defines Child exploitation in India is a
beggary as a “…state of extreme result of the macabre family
poverty”. According to Black’s circumstances, social environment,
law dictionary, Beggar is someone poverty, ignorance of family
“…who lives by begging charity, planning and unchecked
or who has no other means of population control, lack of proper
support than solicited alms”. The care and attention, and lack of love
2011 census indicates that there and affection from parents.[5]
are about 4,13,670 beggars in India Beggary is prevalent amongst
with 12,270 being in Karnataka.[3] children owing to a host of factors.
Unconfirmed reports state that as There are children who are forced
many as over 3 lakh children are into begging by the members of
forced to beg across India by their own family in order to
cartels.[4] It will not be surprising provide some income to the
if the actual numbers are even family. There are also those who
bigger than 3 lakhs. Anyone on a kidnap or traffic children and force
short drive across any city in India them into begging for their own
would easily encounter a minimum personal benefits. It would be
of 3-4 children begging at traffic discussed later on in this paper
signals, selling merchandise, how the difference between the
cleaning cars, or being used as an two factors for begging plays an
object by an elder beggar to garner important role in determining the
sympathy for alms. The apathy of kind of response that the
law and its enforcement agencies Government authorities should
towards the plight of these children undertake in dealing with such
is a matter of big concern. There is children.
no legislation at the center which
comprehensively deals with
begging amongst children and
even those which exist in the

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III. LAW REGARDING BEGGING children from the definition of


BY CHILDREN IN INDIA ‘beggar’ and hence does not
The act of begging is prohibited in expressly apply to children found
its entirety within various states in begging.
India. Even though there is no Further, with regard to children
Central act dealing with this, the who are found begging, there are a
matter is one under the State list host of other Acts which become
and about 22 states[6]have enacted applicable. Most of these are
laws against begging so far. Most central legislations applicable
of these acts are based on the throughout India and the States are
Bombay Prevention of Beggary entitled to make rules under the
Act of 1959 (hereinafter referred to acts. An analysis of these is
as ‘Bombay act’) with required necessary to understand the
amendments and additions. position of law regarding children
Section 4 of the Bombay Act found begging.
gives power to the police to arrest One of the most comprehensive
any person found begging and legislations which deal with
produce him or her before court. children in India is the Juvenile
Such a person, after a summary Justice (Care and Protection of
inquiry, may be detained in a Children) Act, 2015 (hereinafter
Certified Institution for up to 3 referred to as ‘JJ Act 2015). Under
years or up to 10 years in case of section 2(14)(ii), the Act defines a
repeat offence and even ‘child in need of care and
imprisoned.[7] In case of a child protection’ as including a child
beggar, the Act provides for the “…who is found working in
child to be produced before a court contravention of labour laws for
established under the Children Act. the time being in force or is found
Hence, in effect the Bombay Act begging, or living on the street”.
criminalizes the act of begging. Section 2 further identifies a child
Similarly, section 3 of the in need of care and protection as a
Karnataka Prohibition of Beggary child whose parent or guardian is
act, 1975 (hereinafter referred to as found to be ‘unfit’ or
the ‘Karnataka act’) prohibits ‘incapacitated’ or one who resides
begging. It makes begging under with a person who has “…injured,
the Act a cognizable offence[8] exploited, abused or neglected the
and bestows upon the Magistrate child…”. Hence the Act considers
power to convict the person so a child who is begging as one in
arrested and detain him in a relief need of care and protection and
centre.[9] It is pertinent to note also declares that such children
here that unlike the Bombay act, should not be treated as children in
the Karnataka Act removes conflict with law.[10] Further, the

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JJ Act 2015 also expressly and are not compelled to otherwise


prohibits employment of children work.[11] Further, on enquiry as to
for begging and punishes the why child beggary was not added
accused with an imprisonment of a within the ambit of Child Labour
term up to 5 years and a fine of Act, the Ministry of Labour
one lakh rupees. The punishment responded that since child
becomes more intensive if the trafficking was already covered by
accused maims or amputates the Section 370 of IPC and a child
child for the purpose of begging. beggar would come within the
The provisions of the Indian purview of a child in need of care
Penal Code, 1860 (hereinafter and protection under the JJ Act,
referred to as ‘IPC’) are also replication under Child Labour Act
attracted in child beggary cases. provisions was unnecessary.[12]
Section 363A of the IPC punishes Children who are found
kidnapping or maiming a child for begging are also citizens of India
the purpose of begging. Section and have access to all the rights
370 of the IPC prohibits anyone which the Constitution of India
indulging in trafficking of persons, bestows upon its citizens. The
including children. This is further fundamental rights of right to
supported by provisions against equality (Art. 14), right against
wrongful confinement, and exploitation (Art. 23), right to life
kidnapping from lawful (Art. 21), right to free and
guardianship. Another section compulsory education till 14 years
which is often used in dealing with of age and right to constitutional
cases of child beggary is section remedies (Art. 32) entitle these
374 of IPC which prohibits children to live a dignified life
compelling any person to labour with access to proper education,
against his will. healthcare, food and protection
With respect to the Child against being made to beg by their
Labour (Prohibition and own parents or any other
Regulation) Act which was exploiters.
amended in 2016, it outright It can be concluded after
prohibits employment of children reading the above laws in harmony
up till 14 years of age in any kind with each other that even though
of occupation and between 14 to begging is a crime as per the
18 years from working in certain specific legislations, inducing or
hazardous industries. This has forcing children to beg is also
been done with a view to ensure prohibited by the law and the law
that all children below the age of calls for protection and
14 years are enrolled in schools rehabilitation of such children.
under the Right to Education Act

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IV. ANALYSIS OF THE LAW WITH completed 18 years of age. Hence,


RESPECT TO THE STATE OF a boy between 16 to 18 years who
KARNATAKA is found begging should also be
Beggary is prohibited in the State considered as a ‘child in need of
of Karnataka under the Karnataka care and protection’ under the JJ
Prohibition of Beggary Act, 1975. Act 2015 and be produced before
Enacted in the year 1975 the the Child Welfare Committee for
Karnataka Act was brought into appropriate steps to be taken rather
force with the aim to “…prohibit than before a Magistrate.
persons from resorting to begging 2.Further, as mentioned earlier,
and to provide for the detention, the Karnataka act bends towards
training and employment of criminalizing beggary rather than
beggars, for the custody, trial and addressing its root cause. In such a
punishment of beggar offenders scenario, it is not clear if a child
and for the relief and rehabilitation between 16 to 18 years found
of such persons in the State of begging should be treated as a
Karnataka…”[13]. The following child in conflict with law rather
are few important observations than a child in need of care and
with respect to this act- protection under the JJ Act 2015.
1.Section 2(4) of the Karnataka 3.Any law enacted by the
Act defines ‘child’ as “…a boy, legislature must uphold the rights
who has not attained the age of guaranteed to every citizen of
sixteen years, or a girl, who has India whether rich or poor. On a
not attained the age of eighteen detailed reading the Karnataka act
years”. Further, section 2(2) seems to grossly violate these
removes a child from the scope of rights of life, livelihood, dignity,
being considered a ‘beggar’ under freedom, etc. It is not in human
the Act. This in effect makes the nature to live a life of indignity.
Karnataka Act inapplicable to the Beggars do not become so out of
cases of children who are found choice. There is room for
begging, other than boys between exception there but a vast majority
the age group of 16yrs to 18yrs. is forced into begging due to
This segregation of boys into various reasons. The Hon’ble High
above and below 16years of age Court of Delhi, while hearing a
can create potential conflict and Revision Petition[14] observed
confusion with the provisions of that a person may beg either
the Juvenile Justice (Care and because he is lazy, or an addict and
Protection of Children) Act, 2015 hence financially burdened, or
(hereinafter referred to as ‘JJ Act being exploited by a beggary
2015’). The JJ Act 2015 defines a mafia, or has no means of
‘child’ as one who has not livelihood and is starving,

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homeless and helpless. When it deprive him of his means of


comes to children, it is often the livelihood to the point of
last two reasons. To traumatize abrogation. That, which alone
children who are already victims makes it possible to live, leave
of such ill fate is violative of their aside what makes life livable, must
fundamental rights. be deemed to be an integral
4.The Karnataka act further component of the right to life.”
prohibits even receiving alms in a 5.There is no provision in the
public place “…whether or not Karnataka act which lays down the
under any pretense such as singing, evidence which needs to
dancing, fortune telling, accompany arrest of a person for
performing tricks, or selling begging. Such a procedural lapse
articles”[15]. Some of these even in the Bombay Act, which
prohibitions are indeed violative of gives arbitrary power to the police
the right to freedom of earning to arrest was the subject matter of
livelihood by legitimate contention in Ram Lakhan v. State
means.[16] It should also be noted where the Delhi High Court set
here that the Child Labour aside the arrest and detention of a
(Prohibition and Regulation) Act, person owing to lack of
1986 as amended in 2016, does not independent witnesses and
prohibit a child aged 16 to 18 years unsatisfactory testimonies of the
from indulging in any of these police officers. When it comes to
either. In a country where there is children between the age of 16 and
dearth of social security schemes 18 years, a lot more procedures
for the poor and no proper and precautions have to be
rehabilitation facilities it becomes undertaken by the authority
a matter of grave concern and making the arrest in light of the
violation of fundamental rights provisions of JJ Act 2015. Being a
when a person is stopped from child in need of care and
earning a livelihood by selling protection, the child must be
knick-knacks in public areas. The produced before a Child Welfare
Supreme Court in the landmark Committee under section 31 of the
Olga Tellis[17] judgment JJ Act 2015 and cannot be taken to
regarding street hawkers stated that the police station. Best practices
“…sweep of right to life conferred prescribe the presence of a social
by Article 21 is wide and far- worker or a lady officer once such
reaching… If the right to a child is picked up. Even if, for
livelihood is not treated as a part of the sake of argument, the child was
the constitutional right to life, the considered a child in conflict with
easiest way of depriving a person law, he should be handled by a
of his right to life would be to child welfare officer or a special

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juvenile police officer and must be case weak. The problem of child
taken immediately before the abuse revolves around the
Juvenile Justice Board and not be complexities of conceptualizing
exposed to a police lock-up or and reporting of the problem, since
jail.[18] the abuser is someone close to the
6.It can be argued that the victim. Further ‘child abuse’
Karnataka act does not apply to includes not just sexual abuse but
children and that these situations also child battering, extreme
would be dealt with under other punishment, hard labour,
laws applicable in Karnataka such emotional abuse and
as the JJ Act 2015 and the IPC. abandonment.[19] The poor
Even then there is a lack of parents of the victims often fear
awareness and sensitization sending their children to testify
amongst the enforcing authorities against the accused. Also,
on what the law states and what prolonged time-period of the trial
protocol and procedure needs to be effects the will of the victims to
followed in the event of the rescue come testify as they become
of a child beggar. Whether the reluctant to go back to the
child should be separated from his harrowing phase of their life.
parents, whether child should be These form a major roadblock in
sent to the custody of individuals bringing the perpetrators to justice.
claiming to be genuine parents, The need of the hour is a complete
authenticity of documents overhaul of the laws which deal
produced, lack of any with beggary among children.
documentation to identify Either the State should remove
relations, shortage of space in children completely from the ambit
shelter homes, etc. are just some of of the Karnataka Act and make
the difficulties which the Child specific rules to deal with such
Welfare Committees face when a cases under the Juvenile Justice
child beggar is produced before Rules or amend the Beggary Act to
them up on rescue. make it beggar-friendly by
7.Further, in cases where decriminalizing beggary and
children have been trafficked to giving focus on bringing down the
beg, the conviction rates have been criminal network involved in cases
very low. One of the factors for of trafficking for beggary.
low conviction rates is lack of
proper procedure laid down in the V. PROHIBITING CHILD
legislation for arrest and BEGGARY: THE MORAL
investigation. A lot of procedural DILEMMA
lapses and weak evidence As discussed previously in this
gathering makes the prosecution’s paper, there are broadly two

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categories of children who beg. rescued? Can the State ensure that
The first includes those who, the child is not sold to or falls into
owing to their poor economic the clutches of such traffickers
condition, are forced to beg either again?
by their own parents or by them The answers to these questions
when they have nobody else to is not as straight forward as it may
fend for them (we will refer to this seem. Article 39 of the
as voluntary begging). The second Constitution of India states that it
category is that of forced begging is the State’s mandate to ensure
by begging mafia or cartels (we that its policies aim towards
will refer to this as involuntary ensuring “…Art. 39(e) that the
begging). strength of workers, men and
1.Voluntary begging: When a women and the children of tender
child is found begging under the age are not abused and that citizens
first category, the law would treat are not forced by economic
the child as a child in need of care necessity to enter an avocation
and protection and the unsuited to their age or
rehabilitation and reintegration strength…”“…Art. 39(f) that
processes as given under the JJ Act children are given opportunities
2015 would follow. Two questions and facilities to develop in a
arise here- a) Is our State healthy manner and in conditions
machinery well equipped to of freedom and dignity and that
effectively rehabilitate and childhood and youth are protected
reintegrate the child into the against moral and material
society or was the child better off abandonment… .”
with his parents or by himself? ‘The right to live with human
and, b) Whether the law should dignity free from exploitation,
punish the poor parents or enshrined in Article 21 derives its
guardians who made the child beg? breath from Directive Principles of
2. Forced begging: A child State Policy and particularly the
rescued from such category of abovementioned clauses and
begging also is a child in need of Articles 41 and 42 of the
care and protection under JJ Act Constitution’.[20] The above two
2015 and even though the local clauses under Article 39 by
Beggary acts do not provide for themselves are enough to point out
stringent punishments, the other the duty and responsibility that the
Acts such as JJ Act, IPC, etc. State has towards its children.
provide for adequate punishment Every hour that a child spends on
to the culprits. In such cases the the road begging or being used to
question that again comes up is beg portrays the failure of the
what next for the child who is entire State machinery towards that

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child. It is the opinion of the The court further called for


researcher that without adequate pragmatic, realistic and
and effective systems in place to constructive steps to be taken to
ensure that the destitute are given ensure that the children belonging
some opportunity to earn to weaker sections of the society
livelihood, the State should not do not lose their childhood and
criminalize the only means of grow into a productive citizen of
livelihood that they have access to. our country.
State must carefully select which If the Supreme Court, in the
type of begging they should above-mentioned cases has
prohibit. allowed employment of children
While considering employment over 14 years in some occupations,
of children below 18 years, the even the Beggary laws should
Hon’ble Supreme Court in a few allow certain type of activities in
cases has observed thus-“…We public places for the children
must concede that having regard to above 14 years to earn some
the prevailing socio-economic livelihood. It is after all the State’s
conditions, it is not possible to mandate under the Constitution to
prohibit child labour altogether and ensure that its children have access
in fact, any such move may not be to basic necessities of life. The
socially or economically State has failed in this front. For
acceptable to large masses of example, even the rehabilitation
people…” [21] homes and certified institutions
Further, in the case of meant for the beggars are not well
BandhuaMuktiMorcha v. Union of equipped to train the inmates for
India (1997)10SCC549 the providing alternative platform for
Hon’ble Supreme Court held that sustenance. In 2010, about 286
the State is obliged to render socio- inmates of the Nirashithara
economic justice to the child and Parihara Kendra (beggars Home),
provide facilities and opportunities Bangalore, died mysteriously
for proper development of his indicating the maladministration of
personality. It observed that the the institutional care and inhuman
employment of children “…either attitude of the personnel engaged
forced or voluntary, is occasioned in the institution.[22]
due to economic necessity; Since the State has failed to
exploitation of their childhood due take care of its own poor citizens,
to poverty, in particular, the poor it cannot shed its responsibility and
and the deprived sections of the criminalize beggary and steal the
society, is detrimental to lives of these children as well.
democracy and social stability, Either it must ensure that there are
unity and integrity of the nation”. adequate and functional homes

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which provide support to all these Section 115 of the said Act and
children or it must at least allow these "beggars" need to be released
them to fend for themselves. from their exploitative clutches. …
persons who are driven to beg for
VI. JUDICIARY ON BEGGARY alms and food as they are starving
LAWS or their families are in hunger…
As things stand, anti-beggary laws beg to survive; to remain alive. For
have invited very less judicial any civilized society to have
attention. The constitutionality of persons belonging to this category
these laws have never been is a disgrace and a failure of the
considered up until recently when State. To subject them to further
two PILs were filed as a result of ignobility and deprivation by
the State of Delhi removing ordering their detention in a
beggars from its streets before the Certified Institution is nothing
Commonwealth games. short of dehumanizing them. It is
In Ram Lakhan v. State here that courts must step in and
(2007)2RCR(Criminal)340, though recognize the defence of necessity.
the constitutional validity of the Judicial notice must be taken of the
Bombay act was not challenged, fact that as the accused are poor
the High Court of Delhi anyways they will not have access to quality
made certain observations legal assistance, if at all. The duty
regarding its legality. The court is therefore cast upon the courts to
was of the opinion that there was satisfy them that the accused did
enough scope for the Act to treat not have a defence of necessity.
different kinds of beggars Prevention of begging is the object
differently. As per the court, while of the said Act. But, one must
professional beggars could be tried realize that embedded in this
and detained, the State must look object are the twin goals-Nobody
at de-addiction for those who beg should beg and nobody should
because of some kind of addiction have to beg.”
to various substances. In 2009, the Government of
“Then there is the third Delhi undertook massive drives to
category of 'beggars' who are gather all the beggars on the streets
exploited and forced into begging of Delhi ahead of the
by other ring leaders. A different Commonwealth Games. It was
approach is required here. … his alleged that these beggars, instead
act of solicitation was not of being rehabilitated in shelter
voluntary but, under duress, the homes, were merely left to fend for
result of exploitation at the hands themselves on the outskirts of the
of others. The ring leaders need to city. The Government justified
be rounded up and penalized under their act under the garb of the

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Bombay Beggary Act which also under the various categories of


extends to Delhi. Writ Petitions offences under JJ Act, IPC, etc.
(W.P.(C) No. 10498/2009[23]and Hence, it is difficult to put this
W.P.(c) No. 117/2000[24] were issue into figures in order to
filed challenging the constitutional understand the depth of the
validity of the Bombay Act in the situation.
Supreme Court of India and also The Ministry itself admits that
the pathetic situation of Beggar’s children, especially ones without
homes in Delhi. The petitioners family, are generally forced to beg
sought for basic human and by traffickers.[25] If this be the
fundamental rights for the beggars case, then why is it that the State is
of Delhi and for decriminalization not able to crack down on these
of begging. The case, along with a trafficking mafias and help the
few other similar PILs was children? There are enough and
transferred by the court to the High more Standard operating
Court of Delhi. As a result of the Procedures which detail out the
petitions the Government brought steps necessary to be undertaken to
out a draft Bill - Persons in rescue children being forced to beg
Destitution (Protection, Care and and identify and arrest the criminal
Rehabilitation) Model Bill, 2016- network. But it is a sad state of
to replace the legislations affairs that most authorities find
governing beggary in India and to themselves at loss about the
provide for decriminalization of procedures which need to be
begging and rehabilitation of followed. Lack of awareness,
beggars. However, the training on the Standard Operating
Government recently withdrew the Procedures can be few reasons but
Bill without giving any adequate lack of will or apathy towards
justification to the Court and thus children from the poorest sections
passed another chance to address of India can also be another
the issue of beggary. reason.
There exists a vicious circle of
VII. CONCLUSION poverty, unemployment and
While researching on this issue, it begging. It is indeed difficult to
was difficult to get consistent address the issue of beggary
official statistics or data regarding through laws without improving
child beggars in India. Even the economic conditions of its
yearly statistical data by the population. There are schemes and
National Crime Records Bureau funds being allocated on poverty
does not have a dedicated chapter alleviation programs but without a
on begging. Offences against these proper strategy and
children perhaps get recorded implementation mechanism in

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place these remain mere lip Madhya Pradesh, Sikkim, Tamil Nadu,
Uttarakhand, Uttar Pradesh, West Bengal,
service. Providing voter identity Punjab, Delhi and Daman & Diu.
cards, BPL cards, scholarships and 7. See Bombay Prevention of Beggary Act,
incentives such as mid-day meal to 1959; § 6.
8. See Bombay Prevention of Beggary Act,
school going children are only few 1959; § 6.
baby steps. The Government needs 9. See Bombay Prevention of Beggary Act,
1959; § 6.
to relook at its strategy be it 10. See Juvenile Justice (Care and Protection of
providing vocation training for Children) Act; § 76(2).
developing skill set for 11. Report on Child Labour (Prohibition and
Regulation) Amendment Bill 2012, Standing
employment, strengthening the Committee on Labour (2013-2014) at
infrastructure of rehabilitation (http://www.prsindia.org/uploads/media/Chil
centers or bringing about d%20Labour/SCRchild%20labour%20bill.p
df.
transparency in government 12. Supra at 31.
expenditure on this issue. 13. Preamble, Karnataka Prohibition of Beggary
Act, 1975, No. 27, Act of Karnataka,
Till the time we do not address 1975(India).
effectively this crippling menace, 14. Ram Lakhan v. State,
through law as well as socio- (2007)2RCR(Criminal)340(India).
15. Karnataka Prohibition of Beggary Act, 1975;
economic policies, the beggars will § 2(2)(a).
remain a constant reminder of how 16. Anugya Jain, Analysis of Beggary in India:
we as a nation failed to ensure to Strategies and Legal Framework, JUS
IMPERATOR (May 13, 2018, 11:44PM),
all the ideals of constitution. http://journal.jusimperator.org/wp-content
/uploads/2017/12/anugya-jain-paper1.pdf.
17. Olga Tellis v. Bombay Municipal
REFERENCE Corporation, AIR 1986 SC 180(India).
1. Census 2011, Government of India. 18. The Juvenile Justice (Care and Protection of
2. Press note on Poverty Estimates 2011-12, Children) Act, 2015; § 10.
Government of India Planning Commission 19. MAMTA RAO, LAW RELATING TO
(July22,2013), WOMEN AND CHILDREN, 591 (3rd ed.
http://planningcommission.nic.in/news/pre_ 2012).
pov2307.pdf. 20. DR. S.C. TRIPATHI & VIBHA ARORA,
3. Minister of Social Justice and Empowerment LAW RELATING TO WOMEN AND
on unstarred Question No.1831 in CHILDREN, 427 (6th ed. 2015).
LokSabha(Mar.8,2016), 21. Salal Hydro Project Labourers v. State of
http://164.100.47.190/loksabhaquestions/ann J&K, (1983) 2 SCC 181(India).
ex/7/AU1831.pdf. 22. DevinaMalaviya and L. Singh,
4. 3,00,000 Children across India are Forced Criminalizing Poverty: Anti Beggary Laws
to Beg by Cartels: Report, DNA INDIA, in India, Indian Socio-Legal Journal, Vol.
(June 1, 2016, 10: 03 PM), XLI Nos.1&2 at 43 (2015).
http://www.dnaindia.com/india/report- 23. Harsh Mander&Anr. V. Union of India
300000-children-across-india-are-forced-to- &Ors.
beg-by-cartels-report- 2218856. 24. KarnikaSawhney v. Union of India &Ors.
5. DR. S.C. TRIPATHI & VIBHA ARORA, 25. See, Report on Child Labour(Prohibition
LAW RELATING TO WOMEN AND and Regulation) Amendment Bill 2012,
CHILDREN, 424 (6th ed. 2015). Standing Committee on Labour(2013-2014)
6. Acts prohibiting or preventing beggary can at 32.
be found in Andhra Pradesh, Assam, Bihar,
Maharashtra, Karnataka, Chhattisgarh, Goa,
Gujarat, Haryana, Jammu & Kashmir,
Himachal Pradesh, Jharkhand, Kerala,

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