INDIAN LGBTQ+ COMMUNITIES AND PROSPECT OF

SAME-SEX MARRIAGE

SUBMITTED BY-

SANKALP SHANDILY ( SM0121053 )

MANIND MISHRA ( SM0121034 )

DIVYARAJ JAIN ( SM0121021 )

Faculty in charge –

Dr. Thangzakhup Tombing

NATIONAL LAW UNIVERSITY AND JUDICIAL ACADEMY

GUWAHATI, ASSAM

1|Page
TABLE OF CONTENT

❖ INTRODUCTION ..................................................................................................................... 3

o LITERATURE REVIEW ............................................................................................. 3

o SCOPE AND OBJECTIVE .......................................................................................... 4

o RESEARCH METHODOLOGY.................................................................................. 4

❖ 1. GENERAL TRENDS ACROSS THE GLOBE ..................................................................... 4

❖ 2. ARGUMENTS USED BY PROPONENTS AND OPPONENTS OF SAME-SEX

MARRIAGE .............................................................................................................................. 5

❖ 3. FUNDAMENTAL RIGHTS AND SAME-SEX MARRIAGE ............................................. 8

o 3.1 VIOLATION OF ARTICLE 14 OF THE CONSTITUTION................................. 8

o 3.2 VIOLATION OF ARTICLE 15 OF THE CONSTITUTION................................. 9

o 3.3 VIOLATION OF ARTICLE 21 OF THE CONSTITUTION................................. 9

▪ 3.3.1 RIGHT TO SOCIAL JUSTICE AND ECONOMIC

EMPOWERMENT. ......................................................................................... 9

▪ 3.3.2 RIGHT TO SOCIAL SECURITY AND PROTECTION OF FAMILY.

....................................................................................................................... 10

❖ 4. SAME-SEX MARRIAGE AND SPECIAL MARRIAGE ACT ......................................... 10

❖ 5. STANCE OF SOME FOREIGN COUNTRIES ON SAME-SEX MARRIAGE ................ 11

o 5.1 UNIQUE CASE OF AUSTRALIA AND LEGALISATION OF SAME-SEX

MARRIAGE IN AUSTRALIA .................................................................................. 11

o 5.2 SAME-SEX MARRIAGE AND POSITION OF NEPAL. .................................. 11

❖ CONCLUSION ........................................................................................................................ 12

❖ REFERENCES ........................................................................................................................ 13

2|Page
INTRODUCTION

“History owes an apology to the members of this community and their families, for the delay in
providing redressal for the ignominy and ostracism that they have suffered through the centuries. The
members of this community were compelled to live a life full of fear of reprisal and persecution. This
was on account of the ignorance of the majority to recognise that homosexuality is a completely natural
condition, part of arranging of human sexuality”1, Justice Indu Malhotra mentioned this golden line in
the 20th paragraph of her judgement in Navtej Singh Johar vs Union of India but the question is what
about the ignominy and ostracism they are suffering through years as there is no legislation in this
country to permit marriage between two consenting adults of the same sex who want to marry. “Same-
sex Marriage is still not legal in India. “Article 21 of the constitution doesn’t mean mere animal
existence or the mere act of breathing. It guarantees the right to a dignified life2”. Then what about the
dignified life of those consenting adults of this country whose marriage is not legally recognised by any
law? The right to live with dignity means that every person has the inalienable right to live with
dignified life without discrimination, but when two consenting adults of the opposite gender can legally
marry but two consenting adults of the same gender cannot, the question that is begged is how is it not
a violation of the right to live with dignity and hence right to life. Right to life also includes the right to
social justice and economic empowerment, how a society can do justice to a section of society when
that society doesn’t have any law to legalise their marriage and accept it. The right to life also includes
the right to social security and protection of family3 but leave the protection of family lack of laws on
same-sex marriage is not allowing many LGBTQ people to make a family. The lack of law is creating
a lot of problems for those couples as their marriage is not legally recognised so they can’t adopt a child.
They also can’t become a member of clubs whose membership is only open to married couples. The
question is also about discrimination based on sex which they are facing right now.

LITERATURE REVIEW

• "The Shifting Scales of Justice: The Supreme Court in Neo-liberal India" by Mayur
Suresh

Focusing on the Indian Supreme Court, this book analyzes its role and decisions within the
broader context of neoliberalism. It discusses key cases related to LGBTQ+ rights, including
the decriminalization of homosexuality and the potential path towards legalizing same-sex
marriage.

1
Navtej Singh Johar v. Union of India AIR 2018 SC 4321
2
Maneka Gandhi v. Union of India, AIR 1978 SC 597
3
Calcutta Electricity Supply Corporation (India) Ltd. v. Subhash Chandra Bose AIR (1992) SC 573

3|Page
 • "Queer Activism in India: A Story in the Anthropology of Ethics" by Naisargi N.
Dave

This ethnographic study explores queer activism in India, shedding light on the struggles,
strategies, and aspirations of the LGBTQ+ movement. It offers insights into the legal challenges
faced by the community and their efforts towards achieving marriage equality.

• "Gender and Sexualities in Modern India: Issues, Debates, and Contestations" edited
by Sanjay Srivastava and Partha Pratim Basu

This collection of essays examines the complexities of gender and sexuality in modern India.
It covers various aspects of LGBTQ+ rights, including the legal framework, socio-cultural
dynamics, and the impact of judicial decisions, providing a comprehensive understanding of
the context for same-sex marriage debates.

SCOPE AND OBJECTIVE

The scope of this project is limited to understanding of current legal scenario relating to LGBTQ+
community and same sex marriage. This project studies the evolution of the rights of LGBTQ
communities through various judgements of the Supreme court and also discusses the arguments in
favour or against same-sex marriage. This project also tries to focus on the issue of including same-sex
marriage under the special marriage act 1954. This project tries to understand the implication of the
judgement of Justice K.S. Puttaswamy (Retd.) & Anr. vs. Union of India & Ors4and Navtej Singh Johar
v. Union of India5 on same-sex marriage.

RESEARCH METHODOLOGY

The research methods adopted for successful completion of this project entails quantitative techniques
such as secondary data collection and data analyses of existing literature and academic work pieces.
Primarily it has been research driven project whereby analytical skills have been showcased majorly to
reach on to conclusions and standardised opinions.

1. GENERAL TRENDS ACROSS THE GLOBE

Policies and legislation governing marriage and sexual behaviour vary greatly between nations, ranging
from allowing same-sex marriage to imposing the death sentence for same-sex sexual conduct.

4
Justice K.S. Puttaswamy (Retd.) & Anr. vs. Union of India AIR 2017 SC 4161
5
Navtej Singh Johar v. Union of India AIR 2018 SC 4321

4|Page
Furthermore, in many nations, marriage rules and traditions vary significantly by location, province or
state, city, and religion. Same-sex sexual actions by consenting adults engaging in private are permitted
in over 100 nations, accounting for over 60% of the world's population. Many of these nations very
recently decriminalised same-sex sexual conduct by consenting adults, such as England and Wales in
1967, China in 1997, and the 6United States in 2003. In contrast, same-sex sexual actions by consenting
adults are illegal in more than 70 nations (40 percent of the world's population). Some of these nations
impose fines or jail terms (UN News Centre, 2010). In a few nations, the penalty can be more severe,
such as whipping or even death.17 However, several of these nations are revising their laws and may,
as a result, decriminalise same-sex sexual encounters between consenting individuals acting in private.
For example, following the decision in 2009 to decriminalise same-sex sexual acts in New Delhi, which
were formerly punishable by a ten-year jail sentence, India is on the path of evaluating and correcting
its laws against same-sex actions.

In an unusual statement in December 2010, United Nations Secretary-General Ban Ki-Moon called for
the removal of all laws that criminalise homosexuality or allow discrimination based on sexual
orientation or gender identity. In March 2011, a joint statement on behalf of 85 nations before the United
Nations Human Rights Council called on all states to eliminate violence, criminal penalties, and
associated human rights abuses based on sexual orientation and gender identity. Same-sex couples are
legally recognised as domestic registered/unregistered cohabitants in 32 nations, accounting for 15% of
the global population. In these countries, which are primarily Western more developed nations—for
example, Australia, Denmark, France, Germany, and the United Kingdom, as well as most recently
Brazil—same-sex couples are provided with benefits that are similar in many respects to those received
by married opposite-sex couples.

2. ARGUMENTS USED BY PROPONENTS AND OPPONENTS OF SAME-SEX MARRIAGE

One important argument advanced by those in favour of same-sex marriage is that it allows individuals
to exercise what is considered their fundamental human right to marry the person of their choice,
without regard to religion, nationality, ethnicity, race, or sexual orientation. In their opinion, not
allowing SSM is a violation of a fundamental human right. Some have used Article 16 of the United
Nations Universal Declaration of Human Rights in support of this position: "(1) Men and women of

6
Gates, G. J. (2015). Marriage and Family: LGBT Individuals and Same-Sex Couples. The Future of Children,
25(2), 67–87.

5|Page
full age have the right to marry and have children without regard to race, nationality, or religion." They
are entitled to equal rights in marriage, throughout marriage, and after divorce or dissolution."

Of course, whether same-sex marriage adequately represents a core human right is ultimately a legal
question for the courts and the international legal framework to come to grips with. Most countries and
courts that have addressed the issue in the past have dismissed the human rights argument for it,
primarily on the basis of widely held public and historical judicial interpretations of the precise meaning
of marriage—that is, an association between a man and a woman. The equality argument for same-sex
marriage is related to the question of human rights. 7The argument is that same-sex marriage allows
same-sex couples to receive the same state-provided advantages as heterosexual married couples.
Because same-sex couples pay taxes, they should not be denied the various perks, privileges, and rights
afforded to opposite-sex spouses. According to this viewpoint, doing so would be uneven, unjust, and
discriminatory, resulting in lesbians and gays being considered as second-class citizens. Aside from
lower tax rates, opposite-sex marriages receive benefits, privileges, and assistance in the areas of
employment, housing, inheritance, immigration, child adoption, social security, insurance, healthcare,
retirement, pensions, and death and survivorship benefits.

Marriage, in general, is a significant indicator or symbol of social position. Proponents argue that
without it, same-sex couples cannot attain what others regard to be the most desirable type of family
life. Proponents of same-sex marriage argue that it strengthens the connections of committed marriages,
which is intrinsically beneficial to society. The act of marriage offers legal and political
acknowledgement of a couple's commitment to each other, cementing the two people's bond within
society. This was one of the arguments presented in support of legislation in Scandinavian nations,
which were among the first to legalise registered partnerships and eventually same-sex marriage.

Some supporters of same-sex weddings argue that it encourages monogamy and safer sex in addition
to strengthening committed partnerships. This viewpoint holds that it would likely promote norms of
sexual moderation and devotion to a partner or marriage, particularly among homosexual men. If this
is the case, same-sex weddings will almost certainly help to reduce the transmission of sexually
transmitted illnesses. Furthermore, proponents argue that same-sex marriage would be advantageous
because it would contribute to the integration of minority groups, including homosexuals, into
mainstream society.28 Same-sex marriage, it is said, would bring societal legitimacy to homosexual
couples, facilitating acceptance and tolerance of homosexuals and lesbians and reducing exclusion,
prejudice, and violence aimed against them. This outcome would be appreciated not just by same-sex

7
Chamie, J., & Mirkin, B. (2011). Same-Sex Marriage: A New Social Phenomenon. Population and Development
Review, 37(3), 529–551.

6|Page
couples, their families, and other proponents of same-sex marriage, but it is also seen as promoting the
desirable social good of inclusiveness for society as a whole.

One of the main reasons against same-sex marriage is that for much of human history, the primary aim
of marriage was to promote procreation in order to maintain the survival and demographic growth of
the group or society. Marriages were organised in order to produce legitimate kids who would not only
ensure the group's continuing survival, but would also increase the number of productive people within
the society. A similar criticism against same-sex marriage is that it overly broadens the conventional,
long-standing notion of what makes a marriage—seen as the core of a healthy society—to various types
of marital union. Seeking to cover unions between two men or two women would appear to logically
allow future development of this definition in undesired directions. The Netherlands, for example, the
first country to legalise same-sex marriage, now allows polygamous relationships to be registered. The
cities of Amsterdam and Rotterdam record polygamous marriages of Muslim immigrants that occurred
in countries like as Morocco, where having more than one wife is legal. Human reproduction and
parenthood are among the issues raised by opponents of same-sex marriage. It has ramifications and
repercussions for child adoption and assisted reproductive services in particular. Many opponents of
same-sex marriage are concerned that same-sex couples would seek to adopt children, which they
believe is detrimental to both the raising of children and the well-being of society. Others are concerned
that allowing same-sex couples to adopt children could jeopardise adoption by opposite-sex couples
because other nations may refuse to adopt children from residents of countries that have legalised same-
sex marriage.

The topic of same-sex marriage has already affected the larger international community of nations at
the global level, in addition to national and state governments. Spouses and family members of foreign
personnel are entitled to specific benefits at the United Nations, such as dependency allowance, family
travel, education subsidies, and so on. In the face of differing national definitions of marriage and
family, the United Nations typically respects national practises, but limits financial duties, such as
survivor payments, to a single payment shared by co-wives in the event of polygamous partnerships.
mous unions. Following several European countries' recognition of same-sex unions as marriages and
in the face of strong objections and protests by many Member States, the United Nations decided to
recognize such marriages as well as legally recognized domestic same-sex partnerships, again relying
on the long-established principle that matters of personal status are determined by reference to the law
of the nation of the staff member concerned.

7|Page
3. FUNDAMENTAL RIGHTS AND SAME-SEX MARRIAGE

“While reading down Section 377 IPC, the Division Bench of the High Court overlooked that a
minuscule fraction of the country’s population constitutes lesbians, gays, bisexuals or transgenders and
in last more than 150 years less than 200 persons have been prosecuted (as per the reported orders) for
committing an offence under Section 377 IPC and this cannot be made the sound basis for declaring
that section ultra vires the provisions of Articles 14, 15 and 21 of the Constitution”. This was the views
of Supreme court in Suresh Kumar Koushal & Anr vs Naz Foundation & Ors 8 But latter in NALSA vs
Union of India9 Supreme court held that “our Constitution protects non-binary individuals and that the
protections envisaged under Articles 14, 15, 16, 19 and 21 cannot be restricted to the biological sex of
male or female”. After these two decisions come to the landmark judgement of Navtej Singh Johar v.
Union of India10 in which Supreme court seeks apology to this “minuscule” section of the population.
The lack of a law on same-sex marriage violates the fundamental rights of members of the LGBTQ
community mentioned under sections 14, 15 and 21 of the constitution.

3.1 VIOLATION OF ARTICLE 14 OF THE CONSTITUTION

In the Landmark judgement of NALSA vs Union of India11 Supreme court recognised the third gender
Supreme court said in the judgement that “Self-identified gender can be either male or female or a third
gender. Hijras are identified as persons of the third gender and are not identified either as male or
female. Gender identity, as already indicated, refers to a person’s internal sense of being male, female
or transgender.” Article 14 of the constitution of India reads “The State shall not deny to any person
equality before the law or the equal protection of the laws within the territory of India12.” In India, there
is provision for marriage for the other two genders but there is the absence of any law to govern the
marriage of these third genders. Those who want to marry with person of another gender can do so but
what about those who want to marry within the same gender? Their sexual orientation is not a crime
anymore but the lack of laws to govern their marriage and the problem faced by them in taking benefit
of various things such as adoption is a clear violation of article 14 of the constitution. If their sexual
orientation is towards the same sex and they get attracted towards same-sex how they can marry people
of the opposite sex and not providing them with the legal provision to marry is a clear violation of the
Right to Equality between people who are attracted towards people of the opposite sex and those who
got attracted towards the same sex.

8
Suresh Kumar Koushal & Anr vs Naz Foundation & Ors Civil Appeal No. 10972 OF 2013
9
NALSA vs Union of India AIR 2014 SC 1863
10
Navtej Singh Johar v. Union of India AIR 2018 SC 4321
11
NALSA vs Union of India AIR 2014 SC 1863
12
The Constitution of India, 1950, Art. 14.

8|Page
3.2 VIOLATION OF ARTICLE 15 OF THE CONSTITUTION

Article 15(1) of the Indian constitution reads “The State shall not discriminate against any citizen on
grounds only of religion, race, caste, sex, place of birth or any of them”13. Here sex is mentioned and
many people who are not allowed to marry the same sex as they belong to the LGBTQ community are
a clear violation of this article. In the Lok Sabha winter session, one Member of Parliament Sushil
Kumar Modi said that "There should be a debate in Parliament and society. Some Left-liberals and
activists want to imitate the west and impose such laws in the country. I hope the government will
strongly oppose any such move,". "Laws related to adoption, domestic violence, divorce and the right
to stay in marital homes are associated with the institution of marriage between men and women.
Moreover, marriage is an institution wherein both men and women live together and carry forward the
human chain by producing children,"

But honourable MP forgot about the Third gender that exists in our society what about the rights and
liberty of them due to the unavailability of certain laws like adoption, domestic violence, divorce and
the right to stay in marital homes for them those who want to marry in same-sex are facing
discrimination on the ground of sex and it is a clear violation of article 15 of Indian Constitution.

3.3 VIOLATION OF ARTICLE 21 OF THE CONSTITUTION

K.S. Puttaswamy and another v. Union of India14 and others 4 wherein the majority, speaking through
Chandrachud, J., has opined that “sexual orientation is an essential component of rights guaranteed
under the Constitution which are not formulated on majoritarian favour or acceptance.” And this also
become a reason for the judgement of Navtej Singh Johar vs the Union of India. That is a person is
sexually oriented toward a person of the same sex he surely wants to marry with person of the same sex
so the absence of law is a clear violation of his right to life.

Article 21 carries a lot of rights within itself some of those are: -

1) Right to Social Justice and Economic Empowerment.

2) Right to Social Security and Protection of Family.

3.3.1 RIGHT TO SOCIAL JUSTICE AND ECONOMIC EMPOWERMENT.

The right to social justice and economic empowerment is part of article 21 as observed by the Supreme
court but providing legislation for marriage for those who want to marry in same-sex social security
can’t be provided to them.

13
The Constitution of India, 1950, Art. 15(1).
14
Justice K.S. Puttaswamy (Retd.) & Anr. vs. Union of India AIR 2017 SC 4161

9|Page
3.3.2 RIGHT TO SOCIAL SECURITY AND PROTECTION OF FAMILY.

In Calcutta Electricity Supply Corporation (India) Ltd. v. Subhash Chandra Bose,15 it was held that the
Right to life also covers the right to social security and protection of the family. But lack of legislation
on same-sex marriage is not allowing many people to create a family so the lack of legal framework is
a clear violation of the Right to life.

4. SAME-SEX MARRIAGE AND SPECIAL MARRIAGE ACT

None of the marriage act of any religion provided for same-sex marriage also special marriage act 1954
do not provide for same-sex marriage as clause c of section 4 of the Special marriage act reads “the
male has completed the age of twenty-one years and the female the age of eighteen years16” here also
the word male and female are mentioned as in 1954 the voice of these people was very suppressed and
there was not any demand to include same-sex marriage in special marriage act 1954. Now a petition is
filled in the Supreme court of India in the hearing of that senior advocate Mukul Rohatgi submitted that
“ultimately this is a sequel to the judgment in Navtej Singh Johar (wherein the court decriminalised
same-sex relations and Puttaswamy (privacy judgment). These are live issues, not property issues.
People are living, they are getting older and older. The impact is on succession, health…how it will
work”. It is interesting to watch the response of the Central government as the Supreme court seeks the
response of the Central government on it. As intervention with personal laws is a tough task it will be
good to amend the special marriage act 1954 and give the right to these people who were left behind.
In 1954 Special marriage act was introduced as a religious marriage act that doesn’t allow marriage
between intersex and inter-caste consenting adults who want to marry the same situation is prevailing
now as religious laws including the special marriage act don’t allow two people of the same sex to
marry. There is a need for proper legislation or amendment in the special marriage act 1954 to legalise
marriage between two consenting adults. There was a time when there were no laws to govern inter-
caste and intersex marriage and they were introduced later to protect the right of those couples so there
is also a need for a legislation to protect the right of consenting adults who want to marry within the
same sex.

15
Calcutta Electricity Supply Corporation (India) Ltd. v. Subhash Chandra Bose AIR (1992) SC 573
16
The Special Marriage Act ,1954,4(1)(c)

10 | P a g e
5. STANCE OF SOME FOREIGN COUNTRIES ON SAME-SEX MARRIAGE

5.1 UNIQUE CASE OF AUSTRALIA AND LEGALISATION OF SAME-SEX MARRIAGE IN

AUSTRALIA

In 2017 a postal voting survey was conducted by Turnbull Government The question of the survey was
“Should the law be changed to allow same-sex couples to marry” in this survey more than 12.7 million
people took part and 61.7 per cent of people voted yes. After this overwhelming result, Senator Dean
Smith introduced the Marriage Amendment (Definition and Religious Freedoms) Act 2017. It amended
Section 5 of Marriage in Australia as the union of two people”. The bill was enforced after it received
royal assent on 8 December 2017.

5.2 SAME-SEX MARRIAGE AND POSITION OF NEPAL.

• Landmark Judgement of Sunil Babu Pant & Ors. v. Nepal Government17

“The fundamental rights comprised under Part II of the Constitution are enforceable fundamental
human rights guaranteed to the citizens against the State. For this reason, the fundamental rights
stipulated in Part III are the rights similarly vested in the third gender people as human beings.
Homosexuals and third-gender people are also human beings as other men and women are, and they are
the citizens of this country as well... Thus, people other than ‘men’ and ‘women’, including the people
of ‘third gender’ cannot be discriminated against. The State should recognize the existence of all natural
persons including the people of the third gender other than men and women. And it cannot deprive the
people of the third gender of enjoying the fundamental rights provided by Part III of the Constitution.”
But despite this Landmark judgement Nepal still doesn’t recognise same-sex marriage and it is still not
legal in Nepal. They recognise the third gender but not same-sex marriage.

17
Sunil Babu Pant & Ors. v. Nepal Government Writ Petition No. 917 of 2007

11 | P a g e
CONCLUSION

Same-Sex Marriage is one of the most debated and controversial issues regarding LGBTQ rights. The
Argument in support of same-sex marriage says that if two consenting adults of the same sex want to
marry then what is the problem society has with them? There are also various judgements supporting
their demand in one way or other. From K.S. Puttaswamy and another v. Union of India18 to Navtej
Singh Johar vs Union of India, there are various judgements which advocate their rights. This is on the
court to see whether the absence of any legal provision on same-sex marriage is against articles 14,15
and 21 of the Constitution or not. Some people also argue that same-sex marriage is against the social
fabric of Indian society as it is not recognised by any religion but they gave the same argument when
homosexuality was a criminal offence. The petition filed in the supreme court (Supriyo @ Supriya
Chakraborty & Anr. v. Union of India) seeks the inclusion of same-sex marriage in the Special Marriage
Act 1954. Now it is on the supreme court to decide this. Till today 32 countries legalise same-sex
marriage and in the case of Australia they legalised it after a plebiscite. The legalisation of Same-Sex
Marriage if happens will impact the lives of many people from the third gender and those who want to
marry within the same sex. It will ensure basic human rights for those who are left behind. Also, in the
case of Nepal, the supreme court ensures equal treatment in one judgement but not providing same-sex
marriage is violating the concept of equality in one way or another. From Suresh Kumar Koushal &
Anr vs Naz Foundation & Ors 19 to Navtej Singh Johar vs Union of India20 Indian legal system travelled
a long way and by providing provision for Same-Sex Marriage the Indian legal system can ensure total
inclusion of the LGBTQ community. It will also ensure various rights for them.

18
Justice K.S. Puttaswamy (Retd.) & Anr. vs. Union of India AIR 2017 SC 4161
19
Suresh Kumar Koushal & Anr vs Naz Foundation & Ors Civil Appeal No. 10972 OF 2013
20
Navtej Singh Johar v. Union of India AIR 2018 SC 4321

12 | P a g e
REFERENCES

● Eskridge, W. N. (1993). A History of Same-Sex Marriage. Virginia Law Review, 79(7), 1419–
1513.
● Jolly, S., & Vohra, R. (2017). Recognition Of Foreign Same-Sex Marriage In India: A Legal
Exploratory Analysis. Journal of the Indian Law Institute, 59(3), 302–326.
● Vanita, R. (2009). Same-sex weddings, Hindu traditions and modern India</strong>. Feminist
Review, 91, 47–60.

● Chamie, J., & Mirkin, B. (2011). Same-Sex Marriage: A New Social Phenomenon.
Population and Development Review, 37(3), 529–551.
● Gates, G. J. (2015). Marriage and Family: LGBT Individuals and Same-Sex Couples. The Future of
Children, 25(2), 67–87.
● Suresh, Mayur. "The Shifting Scales of Justice: The Supreme Court in Neo-liberal India",
Journal of Law and Social Science,(2020).
● Naisargi N. Dave,"Queer Activism in India: A Story in the Anthropology of Ethics", Indian
Journal of Social Sciences. (2021).

13 | P a g e