Understanding the Intersection of Age and Sexual Violence Against Girl Child in India


The author of this blog is Raktim Kundu, a second-year law student at Symbiosis Law School, NOIDA. He has a keen interest in Constitutional Law and Human Rights and can be contacted at raktimk605@gmail.com.

Does Age of a Girl Matter in the Prevention of Sexual Violence?

The famous quote, commonly attributed to Mark Twain, goes, “Age is an issue of mind over matter. If you don’t mind, it doesn’t matter”. According to the following statistics and perspectives of sexual violence, age is and should be kept in mind by both parties involved in the act: victim(s) and perpetrator(s) or actor(s).

Perspectives:

  • Legal

Sexual violence is an act of sexual overture, including the attempt or commission of sexual intercourse with a person of a different sex without consent and may include force. Thus, as per the definition, the key considerations are sex and age, which form part of the mental and physical elements of the act.

  • The above perspective can be analysed from the statutory definition given to sexual offences like rape (s.63(vi) & Exception 2 to s.63 of BNS, 2023), chapter II of POCSO Act, 2012 

  • Social 

For children, society is the victim-centric, whereas, for adolescent girls, it is accused-centric unless there are some aggravating factors besides age. 

Statistics:

  • 1 in 5 of the girls and women present globally have experienced some form of sexual violence, including online sexual abuse. From the perspective of South Asia, the percentage stands at 9%. 

  • From the Indian perspective, crimes against children have increased at a rate of 16.2% since 2020, with sexual offences accounting for 38.1%, according to the NCRB’s 2022 report.

  • From the perspective of age, girls, especially of the age group of 16-18 years, are more vulnerable.

Thus, as per the deduction of the quote, age does matter. 

So, to prevent sexual violence, the intersection between age and sex should be carefully understood not only from a theoretical perspective but also from a practical perspective (by incorporating other intersectional factors).

The legal procedure (as laid down in Rule 12 of the Juvenile Justice (Care and Protection of Children) Rules, 2007) of determining age can be cited as one of the evidentiary marks of age's importance. For example:
  • In the case of Jarnail Singh v. State of Haryana, the Supreme Court upheld that the said rule can be applied in the case of victims of sexual offences under the POCSO Act, 2012.
  • In the case of State v. Varun, the Delhi High Court observed that the legal stance about a case under POCSO is that the juvenility of the victim should be given preference.

Why Should One Be Considerate about Sexual Violence against Girl Children?
Sexual violence is a compilation of acts which go against morality, safety and the right to protection of individuals, including girl children. This perspective is evident from legal provisions like the POCSO Act, 2012; BNS, 2023; IT Act, 2000; and international agencies like the UN.
It is also important to study the issue because the suffering of girl children is accompanied by mental (depression, anxiety and stress) with societal and domestic suffering (not being able to speak up and a lack of support from various agencies).

Is the Age of a Girl Child Given the Thoughtful Consideration It Deserves?
Understanding that age is just the tip (1/10th) of the iceberg is necessary as a girl child has more than one identity, including sociological identities like caste and circumstantial, like ones in digital technology. These identities together make up the causes and outcomes of the act of sexual violence against her.
So, what are the contents of 9/10th of the iceberg?
Caste:

Though the caste system is intrinsic to the base of Indian societies, it is more prevalent in rural areas, like the dominance of upper caste land owners to commit sexual violence against Dalit girls who work as agricultural labourers. The outcomes like dereliction of duty further aggravate the commission of the sexual act. The following two incidents highlight the breach of duty by various enforcement agencies:

  • Sneha:

The local police made every effort not to report the incident of gang rape against Sneha, a 15-year-old Dalit girl, committed by security personnel, including offering a bribe, mental harassment, forge for a medical examination. The police failed at last because she wrote about the incident in her suicide note.

  • Aanya:

The District Child Welfare Commission, after taking note of repeated rapes committed on Aanya, a 14-year-old Dalit girl, answered to it by just keeping her in an observation home. Finally, she died due to this delay in the investigation.

Online:

With the increase in the use of digital devices like smartphones and easy data accessibility, another dimension of sexual violence has opened up. This necessitates a revisit of the existing legal framework regarding the prevention of online sexual abuse.

Offence

Legal Provision

Distribution of live or recorded or forged sexually abusive materials in online platforms and online meetings

IT Act, 2000: sections 67A, B

POCSO Act, 2012: sections 13, 14, 15 (1)

Solicitation of children for sexual favours like photos and videos, which are later used for sextortion and mental harassment

IT Act, 2000: section 67B(e)

POCSO Act, 2012: section 11 (v)

The Ministry of Home Affairs has launched various initiatives and agencies which specifically focus on the enforcement of the legal provisions like:

  • Emergency response support helpline number 112

  • National cyber-crime reporting portal and cyber cells for reporting and investigation of cyber crimes 

  • Indian Cybercrime Coordination Centre

  • National Automated Fingerprint Identification System

The analysis indicates that existing laws are effective during the remedial stage rather than the prevention stage. This issue has been emphasised through the enactment of statutes but not through the development of personnel in enforcement agencies.

Marital Status:
Marriage is a highly positive factor for sexual violence, which has been observed by the Supreme Court. However, the eradication of child marriage is an intricately complex process. The following facts substantiate the above argument:

  • According to NFHS-5, child marriage has decreased to 16.3% in 2019-21 for the age group of women 18-19 years in India (except in states like Manipur). The main causal factors for the occurrence of child marriages are low levels of education and economics. The incidence is more prevalent in communities of Scheduled Tribes.

  • According to the report of UNICEF in 2023, one in four children aged 18 years were married.

Legally, the concept of marriage holds no significance until a woman turns 18, as stated in Exception 2 of Section 65 of the BNS, 2023. This highlights the law's emphasis on age and maturity in personal rights and decisions.

However, the age at which a girl can marry varies widely across cultures and legal systems. While there is a minimum age for enforcing a marriage (18 years as per the Prevention of Child Marriage Act of 2006), personal laws often allow for earlier marriages, prompting essential conversations about children's rights and education.

Religion:

An 8-year-old girl child who belonged to Muslim and nomadic Bakarwal communities was gang raped and murdered by more than 5 persons who were Hindu in Kathua, Jammu & Kashmir on 16 April 2018. To highlight the importance of religion and not sexual violence, party officials and members of the Special Investigation Team tried to allegedly suppress the Muslim community, besides other forms of systemic violence. 

This highlights the blatant violation and oversight of statutory provisions like section 72 BNS, 2023, and section 23 of the POCSO Act, 2012 (which obliges the media not to publicise the victim's identity).

Sex Trafficking:

Sex exploitation, which is one of the acts of sexual violence, is one of the factors involved in child trafficking.

The process generally involves using undue advantage of power or position or inducement against children who belong to an economically poor family background and are illiterate.  The family may treat the girl children, especially those who seem disabled, as a burden. The children also include those who are victims of natural disasters: orphaned and abandoned.


Whom to Blame other than the Accused?
Victim?:
According to various ground reports and academic studies, it is often the first response of society to blame the victim, especially if she is an adolescent girl. One of the reasons is the caste system in society. However, the incidents of sexual violence depict a controversial picture as they sometimes go against normal stereotypes like:
  • Sarita: She was raped when she went to the field to defecate due to lack of proper sanitation. In this incident, the family of the victim was threatened by the accused when he was released on bail. The police warned the accused after taking notice of it. 
  • Masoom: She was raped by a 27-year-old man in the broad daylight. According to her mother, the incident had caused mental distress and anxiety, due to which she fears her father.
So, the victim is not the one to blame in the legal perspective.
Enforcement Agencies:
Though supported by the community to which the accused belongs, law enforcement agencies have been awarded punishment (like section 21 of the POCSO Act, 2012) for their breach of duty. However, generally, they are not afraid of this punishment, as has already been highlighted. One of the reasons for this behaviour is a lack of a board to overview the enforcement agencies on a procedural basis and not merely a statistical basis.

Government and Legislature:
Besides those highlighted above, various initiatives have been undertaken, including various schemes (like the Integrated Child Development Scheme) and the establishment of agencies (like the National Commission for Protection of Child Rights). There remain areas of development, like
  • Specifying women's safety as one of the focal points for smart cities. 
  • Punishment for delinquency on the part of Child Marriage Prevention Officers, similar to that laid down in the POCSO Act, 2012
  • Use of artificial technology in the enforcement of legal provisions and investigation of incidents of sexual violence
  • The laws legislated should not just be a reaction to appease the public sentiment and outcry after a heinous sexual offence but rather should be more reformative and inclusive to inculcate the various dimensions that may arise in the present as well as in the future.
Conclusion: Is there Any Remedy?
Addressing the first question raised, it is crucial to study the factor of age, particularly in girls, to prevent sexual violence against them. The study should necessarily adopt the intersectionality approach, especially in light of the behaviours exhibited by individuals involved in the process, from the commission of the crime to the delivery of justice. This analysis will allow for a holistic and victim-centred approach in the legislation and enforcement of laws aimed at preventing sexual violence against girl children.

References:

Arora, K. (2022, March 11). Crime Against Children Online is evolving and so is the law. Nyaaya. https://nyaaya.org/guest-blog/crime-against-children-online-is-evolving-and-so-is-the-law/

Caste based sexual violence and state impunity (English and Hindi). People’s Archive of Rural India. (2022). https://ruralindiaonline.org/en/library/resource/caste-based-sexual-violence-and-state-impunity-english-and-hindi/

Chachra, S. (2025, January 13). Let us look closer at norms issued by Supreme Court for ending child marriage in india- and its missing links. Down To Earth. https://www.downtoearth.org.in/governance/let-us-look-closer-at-norms-issued-by-supreme-court-for-ending-child-marriage-in-india-and-its-missing-links


Haji, M. (2022, March 18). The illusion of justice offered to children who are sexually abused in India. Nyaaya. https://nyaaya.org/guest-blog/the-illusion-of-justice-offered-to-children-who-are-sexually-abused-in-india/

Jameel, T. (2022, August 30). Crimes against children increases by 16.2%, child sexual abuse cases go up. The News Minute. https://www.thenewsminute.com/news/crimes-against-children-increases-162-child-sexual-abuse-cases-go-167363

Madhukalya, A. (n.d.). Prevalence of online child sexual abuse material rises 87% since 2019, report shows. Deccan Herald. https://www.deccanherald.com/india/prevalence-of-online-child-sexual-abuse-material-online-rises-87-since-2019-report-shows-2737506

Over 370 million girls and women globally subjected to rape or sexual assault as children. UNICEF. (n.d.). https://www.unicef.org/press-releases/over-370-million-girls-and-women-globally-subjected-rape-or-sexual-assault-children

PTI. (2021, October 11). Over 99% crimes registered in 2020 under POCSO act were against girls: NCRB Data. The Hindu. https://www.thehindu.com/news/national/over-99-crimes-registered-in-2020-under-pocso-act-were-against-girls-ncrb-data/article36939365.ece

Salihu, J. T. (2024, March 7). Early marriage and sexual abuse among female children. IntechOpen. https://www.intechopen.com/chapters/1156339

Sasikumar, M. (2023, April 12). Madhu Kishwar’s book on Kathua Rape draws ire: What was the 2018 case about? TheQuint. https://www.thequint.com/explainers/madhu-kishwar-book-on-kathua-rape-case-what-happened

Ritika Sharma

Founder

I am Ritika Sharma, a dedicated researcher with an LL.M. from the prestigious Geneva Academy, Switzerland, where I specialised in International Humanitarian Law and Human Rights. I was honoured with the Henry Dunant Research Prize 2024 for my work exploring the intersection of International Humanitarian Law, Gender and Religion. My journey has taken me to the United Nations Human Rights Council, where I have spoken three times on critical issues like the Myanmar conflict and gender-based violence during my Advocacy internship with Human Rights Now. Currently, as an Advocacy Fellow with Women of the South Speak Out (WOSSO), I am working to amplify voices and create meaningful change by working on a project on the intersectionality of sexual violence against women. Through my platform, HUMAN.DROITS, I address socio-legal challenges while exploring broader human rights and humanitarian issues. My favourite line from the book 'Ignited minds' which mirrors my thoughts is "What actions are most excellent? To gladden the heart of a human being, to feed the hungry, to help the afflicted, to lighten the sorrow of the sorrowful and to remove the wrongs of the injured".

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