Marital Rape SPRF.
IN
Exception:
07
Challenges and
Arguments 22
| Bhamini Rathore
Issue Brief
TABLE OF CONTENTS
1. Abstract 03
2. Introduction 04
3. Understanding Marital Rape Exception
in India 05
4. Marital Rape as a Violation of
Women’s Rights 07
5. Conclusion 08
6. Bibliography 09
If you have any suggestions, or would like to contribute, please write to us at [email protected]
© Social and Political Research FoundationTM
July 2021
ISSUE BRIEF
Marital Rape
Exception:
Challenges and Arguments
| Bhamini Rathore
ABSTRACT
Marital rape refers to the act of sexually assaulting one’s spouse. It is a crime in
most countries except thirty nations including India. Section 375 of the Indian Penal
Code [IPC] defines and criminalises rape but contains an exception clause for when
it happens between a married couple. This exception declares ‘sexual intercourse
by a man with his own wife’ legal in the absence of circumstances like willingness or
consent, listed under Section 375. Such an exception legally absolves the aggres-
sor if sex is demanded or imposed within a marriage. In 2015, a husband raped and
sexually assaulted his wife, leading to her hospitalisation. Despite approaching the
Supreme Court, her petition was dismissed stating that the law cannot be changed
based on one individual’s experience, and her husband was never prosecuted. In
view of this incident and numerous other petitions filed in the court for striking down
the exception clause, the discussion was reopened for hearings on 7th January
2022. A two-judge bench of the Delhi High Court presided over the hearings and
on 11th May 2022, giving a split verdict and shelving the criminalisation of marital
rape under the IPC.
This issue brief asseses the historical challenges in the removal of the marital rape
exception clause of Section 375 of the IPC. In doing so, it also examines the judicial
arguments on the issue of marital rape in light of the recent Delhi High Court ruling.
KEYWORDS: Marital Rape, Sexual Assault, Gender Violence, Dignity, Consent
4 | SPRF INDIA ISSUE BRIEF
INTRODUCTION
According to the World Health Organisation [WHO], one in three women worldwide are victims of
physical or sexual violence during their lifetime (WHO, 2021). More regionally, the National Family
Health Survey reported that 29% of married women experienced physical or sexual abuse from
their husbands (Ministry of Health and Family Welfare, 2021). Violence against women takes var-
ious forms, one of the most prevalent being sexual violence. Between 2009 and 2019, India saw
an increase in recorded rape cases from 21,397 cases in 2009, that is 58 cases per day, to 32,033
cases in 2019, amounting to 90 cases per day (National Crime Records Bureau, 2009, p.81; National
Crime Records Bureau, 2019, p.31). However, marital rape is not reported since it does not qualify
as a crime. On the one hand there is a dearth of laws for protection of the victim. On the other, re-
porting leads to alienation of the victim and the parental family from the larger society, accompanied
with an aggravated threat of violence (Thaplu, 2020). In 2018 Nimeshbhai Bharatbhai Desai case,
the Gujarat High Court told the appealent to file her case under Section 377 (Unnatural offences) and
refused to prosecute the husband under the exception clause of Section 375 (Nimeshbhai Bharat-
bhai Desai v. State of Gujarat, 2018). Such cases are common and discourage marital rape victims
from reporting the crime.
Figure 1: Recorded Rape Cases in India
45,000
38947
40,000 36735
33707 34651
32559 33356
35,000 32033
30,000
24206 24923
25,000 21 397 221 72
20,000
1 5,000
1 0,000
5,000
58 60 66 68 92 1 00 94 1 06 89 91 87
0
2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019
Number of Rape Cases Rape Cases per Day
Source: National Crime Records Bureau (2012, 2014, 2015, 2016, 2017, 2018, 2019)
ISSUE BRIEF MARITAL RAPE EXCEPTION: CHALLENGES AND ARGUMENTS I5
In 2011, the International Men and Gender Equality Survey conducted by the International Center for
Research on Women revealed that one in five men forced their wives into sexual intercourse (Barker
et al., 2011). Taboos existing in society prevent conversations about sexual matters impeding the
transition from traditional conservatism1 to modern sensualism2, and as a result Indian societies and
legal systems fail to recognise marital rape as a crime (Janetius, 2017). Owing to marriage’s cultural
sanctity, viewing a husband as a rapist becomes difficult. It comes in strong conflict with the existing
idea that a rapist is a stranger (Kumar, 2021). Therefore, despite recognising rape as a crime, Sec-
tion 375 of the Indian Penal Code exempts the husband in recognition of an existing marital relation-
ship between the perpetrator and the victim.
Following the state’s failure to address marital rape in the Criminal Law Amendment Act of 2013,
many women’s organisations and human rights groups petitioned the court, vehemently advocating
for the criminalisation of marital rape (Banerjee & Rao, 2022). Most recently, the four petitions filed
in the Delhi High Court challenging the exception to the rape law in the IPC resulted in a split verdict.
UNDERSTANDING MARITAL RAPE EXCEPTION IN INDIA
The rape laws in India date to the 1800’s Coverture Doctrine introduced under the British colonial
rule. Herein, under sexual offences, rape was criminalised as sex without consent and also account-
ed circumstances wherein intercourse happened with consent but under fear of death or under false
pretences. It stated that a woman has no individual rights after marriage and must fulfil her marital
duties to her husband (Kumar, 2021). The basis for this was the belief that before marriage women
belong to the paternal family, and belong to their husband after it. This view postures the husband
as someone who gains ownership of the woman’s body upon marriage (Kallakuru & Soni, 2018).
In 1860, the IPC was introduced, and in 1940, the outdated marital rape exception was updated to
raise the age of married women in the law from 10 to 15 years (Gupta & Gupta, 2013) This was a
result of continued efforts made by lawyers and law makers, between 1920 and 1940, who fought
against the mjority public opinion to prevent child marriages, consummation in marriages where
brides were too young, and prevent child widows (Mahmood, 1980).
Section 375 of the IPC criminalises rape, defining it under four conditions as when a man:
“penetrates his penis, to any extent, into the vagina, mouth, urethra or anus of a woman
or makes her to do so with him or any other person; or inserts, to any extent, any object or
a part of the body, not being the penis, into the vagina, the urethra or anus of a woman or
makes her to do so with him or any other person; or manipulates any part of the body of
a woman so as to cause penetration into the vagina, urethra, anus or any part of body of
such woman or makes her to do so with him or any other person; or applies his mouth to
the vagina, anus, urethra of a woman or makes her to do so with him or any other person,
under circumstances: against her will; or without consent; or consent obtained under threat
or force; or with her consent because she believes that he is another man to whom she is
1
Traditional conservatism emphasises the significance of higher moral principles revealed via natural laws that society
should follow. In this context, traditional conservatism is used to refer to the inability of the wider society to look at sexual
intercourse as anything beyond the means of reproduction and pleasure for the male counterpart.
2
Modern sensualism is the belief that sensations and perception are the most basic forms of real knowledge. In simple
terms, it refers to a philosophy dedicated to the pursuit of physical and sexual pleasure for both men and women.
6 | SPRF INDIA ISSUE BRIEF
or believes herself to be lawfully married; or with her consent with reason of unsoundness
of mind or intoxication or the administration by him personally or through another of any
stupefying or unwholesome substance; or with or without her consent, when she is under
eighteen years of age; or when she is unable to communicate consent.” (Indian Penal
Code, 1860, §375).
However, Exception 2 to Section 375 states, “sexual intercourse or sexual acts by a man with his
own wife, the wife not being under fifteen years of age3, is not rape” (ibid.). This implies that violence
or aggresion against a partner during sexual intercourse or sexual acts between a married couple
do not amount to rape.
As previous ideas about women’s status and role in society became obsolete upon women becom-
ing equal citizens with socio-political and legal rights, there began a shift away from expecting ba-
sic rights to demanding equal opportunities and protection against violence (Katzenstein, 1989). In
1971, the issue of marital rape arose and the 42nd Law Commission Report brought up the issue for
the first time in official legal discourse. It discussed instances of rape within marriage in the course
of separation but failed to implement changes. It stated that “the marriage technically subsists, and
if the husband has sexual intercourse with her against her will or her consent, he cannot be charged
with the offence of rape. This does not appear to be right” (Law Commission of India, 1971). This
suggestion implied that consent differs if a couple lives together or separately. However, changes
were made in the law and under Section 376B of the IPC recently. The development considers
non-consensual sexual intercourse between a husband and wife, during or after their separation,
marital rape. This was a landmark judgment on the matter of marital rape since it protected spouses
undergoing separation or living separately (Criminal Law (Amendment) Act, 2013).
Followed by the acknowledgement of the issue of marital rape as rape during separation, the 172nd
Legislative Commission Report questioned the validity of Exception 2 under Section 375 arguing that
while various forms of violence by husbands against wives are criminalised, marital rape should also
be recognised as a statutory offence. However, this argument was rejected by the law commission
because of concerns that criminalising marital rape would compromise the institution of marriage
(Law Commission of India, 2000). Since marriage is widely considered a personal affair, any dispute
arising in marriage is expected to be solved between the family members. In some cases, the judi-
ciary has even encouraged victims seeking redressal to resolve the matter in their homes (Kallakuru
& Soni, 2018).
With no legal recognition of marital rape several feminist organisations, lawyer groups, and citizens
expressed frustration over poor legal protection. Following this, Justice J. S. Verma Committee pub-
lished the Report of the Committee on Amendments to Criminal Law in 2013. It called for the deletion
of the exception from Section 375 and recommended criminalising marital rape. The report asserted
that marriage alone does not constitute consent and the perpetrator should not be protected by such
a primitive notion (Chhibbar, 2016). Subsequently, the Criminal Law (Amendment) Act (2013), ex-
panded the scope of the term ‘rape’ and replaced it with ‘sexual assault’. Inspite of this, criminalisa-
tion of marital rape was again rejected on the grounds that it would disrupt the Indian family system
and that such an issue can be dealt with under Section 498A of the IPC. The section punishes the
husband or his relative, for ‘wilful conduct which is of such a nature as is likely to drive the woman to
commit suicide or to cause grave injury or danger to life, limb or health (whether mental or physical)
3
Even though this exception states that the married woman must be fifteen years of age, the courts interpret it to
mean 18 years, given that sexual activiy with any minor (with or without consent, married or not) are a crime under the
Protection of Children from Sexual Offences Act, 2012.
ISSUE BRIEF MARITAL RAPE EXCEPTION: CHALLENGES AND ARGUMENTS I7
of the woman; or harassment of the woman where such harassment is with a view to coercing her
or any person related to her to meet any unlawful demand for any property or valuable security or is
on account of failure by her or any person related to her to meet such demand, with imprisonment to
whoever has subjected such cruelty upon a woman. (Indian Penal Code, 1860, §498A).
In 2015, Delhi High Court recieved numerous petitions on the criminalisation of marital rape. Some
even protested the criminalisation to protect men from false allegations or misuse of law and harass-
ment by wives (Wallen & Lateef, 2022). The issue was then raised in Parliament and the Ministry of
Home Affairs responded in stating that “marital rape cannot be appropriately applied in the Indian
context as the mindset of the society is to treat marriage as a sacrament.” (Kallakuru & Soni 2018).
This was followed by an organically renewing focus put on Section 498 of the IPC as resolution by
lawmakers. In 2017, the central government upheld the decision against removal of the exception by
stating that India could not blindly follow the West and restated that criminalising marital rape would
destroy the institution of marriage (PTI, 2017).
On 7 January 2022, the Delhi High Court resumed the final hearings of various petitions. The hear-
ing were with regards to the removal of the exception clause to reassess the validity of the marital
rape exception. Justice Rajiv Shakdher and Justice C. Hari Shankar presided. The Centre filed an
affidavit opposing criminalisation. The affidavit argued that criminalisation would destabilise the in-
stitution of marriage and also be used as a tool to harass husbands and flood litigation. On 11 May
2022, the Delhi High Court delivered a divided verdict on the matter. Justice Rajiv Shakdher allowed
the petition’s plea for criminalisation, stating that the exception violated Article 14 of the Constitution
of India. However, Justice C. Hari Shankar held that the exception was appropriate and that marital
rape should be judged under other offences on a case-by-case basis based on a couple’s history of
violence and abuse (Khushboo Saifi v. Union of India and Anr, 2022).
MARITAL RAPE AS A VIOLATION OF WOMEN’S RIGHTS
While the previous section of the paper outlined the history of debates on marital rape, this one brings
forth the arguments in favour of criminalisation. The argument is based on international laws and
treaties and it also outlines which constitutional provisions get violated by marital rape’s non-crimi-
nalisation.
Violation of International Treaties and Laws
In accordance with the Convention on the Elimination of All Forms of Discrimination Against Women
[CEDAW], India has a responsibility to protect women from “physical, sexual, and psychological vi-
olence occurring in the family including battering…, marital rape…, and violence related to exploita-
tion” and gender-based violence [GBV] (Randall & Venkatesh, 2015). However, the existence of the
marital rape exception and the refusal of the Central government to conform to the ‘standards of the
West’ denies women the right of protection against this violation. Under international human rights
law, it further also infringes a woman’s right to life, liberty, security, equality, well-being and non-dis-
crimination, making it imperative to criminalise marital rape (ibid.)
8 | SPRF INDIA ISSUE BRIEF
Violation of Article 14
Under the Constitution of India, lack of criminalisation of marital rape also violates a woman’s Right
to Equality as Article 14 of the Constitution says, “the state shall not deny to any person equality
before law and equal protection of the law.” This article provides protection to every citizen of India
except for married women in denying them the right to seek redressal against sexual violence within
a marriage. The Centre’s recent stand on the matter stating that deletion of the exception would
result in harassment of husbands also undermines women’s right to equality. It only encourages the
patriarchal mindset which gives precedence to the victimhood of men over women’s.
It’s important to note that the socio-historical context in which Section 375 was drafted was different.
Women’s rights were severely limited in 1860. They were only availed because the rights of women
were merged with their husbands’ since they were viewed as independent legal entities and enjoyed
full legal, social, and political rights (Mishra, 2019). However, while context has changed entirely
with time, what remains is the legal inheritance of Section 375’s exception. Today, a section that
was created in colonial India comes in direct contention with the Indian constitution’s Article 14 as it
disregards women’s right to equal treatment and protection.
Violation of Article 21
Marital rape further violates Article 21 of the Constitution of India which states, “no person shall be
deprived of his life and personal liberty except according to procedure established by law.” Over
the years, the expanse of Article 21 has been elaborated in meaning and effect. As a result, right
to healthy life, privacy, choice in matter of sexual activity has been read by the Supreme Court as
flowing from and protected under Article 21. Recently, the Supreme Court has also recognised the
woman’s right to abstain from sexual intercourse in recognition and protection of her fundamental
right under Article 21 (Makkar, 2022). In marital rape, a married woman’s right to sexual privacy and
bodily integrity are infringed upon. This further violates her right to a healthy dignified life as it affects
her self-esteem, physical health, and mental health directly (Mehta, 2021).
CONCLUSION
The lack of discussion and recognition of marital rape’s grave implications, both within the private
and the public sphere, leads to undermining the impact and consequences of rape inside or outside
marriage. Criminalising marital rape is necessary. The 1860s exception 2 of Section 375 of the IPC
is iniquitous and inapplicable since it fails to uphold the basic constitutional rights of women such as
right to life and liberty. The split verdict suggests that pre-existing ideas against criminalisation based
on the state’s primary duty to protect the sanctity of marriage prevail. Such an outlook assumes con-
sent to sex through marriage, merges woman’s identity with the legal identity of the husband after
marriage. These attitudes need to be challenged and re-evaluated through passing sound legisla-
tions that protect women.
ISSUE BRIEF MARITAL RAPE EXCEPTION: CHALLENGES AND ARGUMENTS I9
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