Acid attack in India: A study from Victim’s perspective

Shivani Rawat

CHAPTER 1

INTRODUCTION

In layman’s language, the term acid attack can be understood as an act of throwing acid on any person. When we talk legally, there is no such definition of acid attack but the Indian judiciary has interpreted the act of acid attack as “any act of throwing of acid on a person with an intention to cause hurt”. Prior to the Criminal Law Amendment Act, 2013, the wrong acid attack was not incorporated in the Indian Penal Code, 1860. Thus, we could not call the wrong acid attack as an offence.

The victim faces society’s lifelong discrimination. Their social, economic and psychological lives are also affected. The victims are unable to work because of their deformities as a result of an acid attack and it is impossible for them to survive in society. In some cases, they are abandoned by their own family, leading to the victim’s emotional breakdown.

The acid attack’s medical effects are widespread. The latest well-known victims of the acid attack were Kaur and Vinodhini. In 2015, 222 cases of acid attacks were reported, according to the National Crime Records Bureau. The Indian Penal Code did not recognize acid attack as a separate offence until 2013. Sections 326A and 326B were inserted in the Indian Penal Code, 1860 under Criminal Law (Amendment Act) 2013 providing acid attack punishment and attempted acid attack.

The offence is registered under Indian Penal Code section 320, 322, 325, 326 and 307. In the case of Laxmi v UOI[1], SC passed an order to ban the sale of acid in shops. In this case, compensation was given for the first time to the victim of an acid attack.

History of Acid Attack:

The history of acid attack is very small. It all began during the 1800s. During ancient time, acid has been used in metallurgy and for etching. In 1879, 16 cases of vitriol acid attacks were reported as “Crimes of Passion” prevalent predominantly by women against another woman. The use of acid as a weapon began to rise in developing countries, especially in South Asia. The first acid attack which was recorded in South Asia occurred in Bangladesh in 1967, India in 1982, and Cambodia in 1993.[2]

Reasons for acid attack:

There are many reasons which lead to the offence of an acid attack. One of the major reason and the cause of the acid attack is the easy availability of acid in the market. Due to such easy availability, the offence of acid attack rises.

Another reason can be vengeance or rejection of a proposal or any other personal grudge that may lead a person to do such an act to cause such grievous hurt to the other person.

Consequences of an acid attack that the victims have to face[3]:

The long-term effects of acid attack are permanent disfigurement of the body. The acid attack victim’s life changes completely in one day, their loved ones start hating them, they are condemned by society for their horrible appearances. The acid attack makes the person’s life hell and it also affects their opportunities for social, psychological, and work.

Physically:

Throwing acid on a person’s face, it quickly eats eyes, ears, nose, and mouth. Acid can quickly destroy eyesight. The most notable hazard to an acid victim is breathing problem. The depth of injury depends on the strength of the acid and the duration of skin contact. After the acid attack, the acid attack dissolves the bones, the ears, the eyes, etc. The victim’s physical deformities make it difficult to lead a normal life.

Psychological:

Even after recovery, acid attack victim suffers from many mental health problems. Victims of acid attack have higher levels of anxiety due to their appearance, depression.

Medical:

There are extensive medical effects of an acid attack. Since most acid attacks are directed to the face, several articles have thoroughly examined the medical implications for these victims.

Societal:

Most of the victims of acid attacks are ignored by society, relatives, and even members of their family. They feel lonely and isolated. Surviving in society is very difficult for them.

CHAPTER 2

NATURE OF WRONG OF ACID ATTACK

Prior the Criminal Law Amendment Act, 2013.

Before the Criminal Law Amendment Act, 2013, it was difficult for the judges to decide whether such a wrong/ offence would be considered under the Criminal Law or the Tort Law. But due to the nature of the act of acid throwing was more of a criminal in nature rather than tort, thus, by default, the offence of acid attack was always dealt under the criminal law and not under the tort law.

Even though it was considered under criminal law, but there was no specific provision which stated the punishment of such an act or whether such an act was intentionally done or not. Thus, before the Amendment Act of 2013, the cases of the acid attack were dealt under Section 302 and 307 of the Indian Penal Code, 1860. Section 302 provides for the punishment for murder. It states whoever is liable for murder, shall be given capital punishment or imprisonment for life with a fine. This section was applicable only when the victim dies due to acid attack. Section 307 of the Indian Penal Code, 1860 provides for the attempt of murder. The punishment under this section of Indian Penal Code, 1860 can be interpreted in relation to the acid attack as If in the case due to acid attack, the victim survives the attack, then the punishment will be either imprisonment which may extend to 10 years or imprisonment for life and shall be liable for fine as well.

The following cases shall substantiate the above:

1. Morepally Venkatasree Nagesh v.  State of Andhra Pradesh[4]

In this case, the accused was suspicious about the character of his wife. Out of spite, he poured mercuric chloride inside her vagina. The wife later died due to renal failure. The accused was then charged and convicted under Section 302 and Section 307 of the Indian Penal Code, 1860.

• Jahalli Police Station v. Joseph Rodrigues[5]:

In this case, a girl named Hasina was earlier working at the accused officers. Soon she left the office and started working in another firm. The accused first threatened her that if she does not accept his new offer, he might do something. Even then, when she did not accept the offer, the accused threw acid on her. Because of the acid attack, her face’s colour and appearance changed, leaving her blind. The accused was convicted in accordance with IPC Section 307 and sentenced to life imprisonment. Compensation of Rs 2,00,000 was to be paid by the accused to Hasina’s parents in addition to Trial Court fine of Rs 3,00,000.

• Ravinder Singh v.  State of Haryana[6]:

In this case, the husband poured acid on his wife, who refused to grant him a divorce. The accused was in an extramarital affair. The victim suffered multiple acid burns on her face and other parts of her body resulting in her death as a result of the attack. According to IPC Section 302, the accused was charged and convicted. Although the victim had died, life imprisonment was not imposed.

• Syed Shafique Ahmed v. State of Maharashtra[7]:

The main reason behind the husband’s acid attack on his wife and another person was a personal enmity with his wife. This acid attack caused disfiguration on the face of his wife and the other person and the wife lost their right-eye vision. According to section 326 and section 324 of the IPC, the accused was convicted and sentenced to severity.

• Ramesh Dey and Others v. State of West Bengal[8]:

In this case, the accused had previously attempted to throw acid at the victim and succeeded in the second attempt. Revenge was the motive for the crime, as the victim rejected the main accused Ramesh’s openings. Together with two others, the accused went to the house of the victim and threw a bottle of acid outside her house on the victim where she, her mother, her aunt and her little son were sitting. The victim, Padma, died on the neck, chest, breasts, legs, knees, and scalp due to extensive acid burns. The additional sessions Judge granted life imprisonment and a fine under IPC Section 302 and 34 for Rs. 5,000. The appellants were also convicted in accordance with Section 324/34 of the IPC and sentenced to one year’s rigorous imprisonment and a fine of Rs 1,000 each in default to simple imprisonment of 2 months.

After the Criminal Law Amendment Act, 2013:

The Criminal Amendment Act, 2013 finally declared an acid attack as a separate offence under the Indian Penal Code, 1860. The Criminal Law Amendment Act, 2013 brought section 326A and Section 326B which defines the act of acid attack and the punishment for the same. Laxmi v. Union of India[9], is one of the leading cases in which for the first time the court gave compensation to the acid attack victim. In this case, a PIL was filed by Laxmi who is an acid attack victim. In this case, the Apex Court gave the state and UT the direction to regulate acid. The court also dealt with the compensation issue. The Apex Court held that Section 357A of this section provides for the preparation of a compensation scheme for the victim or his dependents who have suffered loss or injury as a result of the crime and who require compensation and rehabilitation.  The Apex Court directs that the victims of acid attacks shall receive compensation of at least Rs. 3 Lacs as the cost of aftercare and rehabilitation from the government / UT concerned.

In Parivartan Kendra v. Union of India[10] , in this case, a petition for the plight of victims of acid attacks such as free medical care, rehabilitation or adequate compensation under Survivor Compensation Schemes- Highlighted the plight of two Dalit girls – victims of acid attacks. In this case, the court also considered that despite the same court’s orders and directions in the Laxmi case, acid is still readily available to most of India’s population. In this landmark judgment, the Supreme Court ruled that the State Governments / UT should discuss and take the matter seriously with all private hospitals in their respective State / UT to the effect that private hospitals should not refuse treatment to victims of acid attack and that full treatment should be given to such victims, including medicines, food, bedding, etc. The Apex Court said there was no need to set up a separate Criminal Injuries Compensation Board, and the Court also clarified that more compensation than Rs. 3Lakh could be given by the government / UT concerned.

State of Maharashtra v. Ankur Panwar[11]: In this case, the accused was convicted of throwing acid at Bandra Station’s Preeti Rathi in 2013 after choosing to pursue her nursing career, declining her marriage proposal. Special Judge Anju S. Shende said “According to the mitigating and aggravating circumstances, the facts of the case and the recent acid attack judgments by the Supreme Court, the accused to death”.  This is one of the cases where the accused was granted capital punishment.

Thus, after the Criminal Law Amendment Act, 2013, the Courts are focusing on the compensation and rehabilitation of the victims and gave stricter punishments to the accused or the convicts of such an offence.

CHAPTER 3

RECOURSE TO THE VICTIMS

Prior to the Criminal Law Amendment Act, 2013:

Criminal Law Amendment Act, 2013 brought some major amendments and these were in the favor of the victims. But prior to the Criminal Law Amendment Act, 2013, the recourse given to the victims were completely in the hands of the judiciary. It was all on the discretion of the judge to provide the proper compensation or rehabilitation to the victims of the offence.

In Bodhisattwa Gautam’s case[12] , The Supreme Court reiterated the above-mentioned decision and further established that the courts have arrived to award interim compensation which should also be provided for in the scheme. A review of acid attack cases again highlights the urgent need for a victim compensation scheme. Victims of acid attacks often have to undergo multiple operations, as stated earlier, costing Lakhs of Rupees. They also need rehabilitation as a matter of urgency because they need financial assistance to survive. Due to the impact of acid attack, it becomes difficult for them to look for a job.

Even in the leading case of Laxmi v. Union of India[13], the judiciary gave directions which would prevent the easy availability of the acid in the market. There were directions that focused on the educational institutions because, in labs, there was the use of acids for experimentation. The directions that were laid down by the judiciary are as follows:

“Apex Court issued guidelines for regulating acid to the territories of the State and the Union. The Court also provided the solution to the acid victim compensation issue”. “The Court held that Section 357A provides for the preparation of a scheme to provide compensation for victims of acid attack or their dependents who have suffered loss or injury”.

Prevention of Offences (Acid) Bill, 2008

Not only the directions but the National Commission for Women came up with the draft of the Prevention of Offences (Acid) Bill, 2008. This bill proposed that there shall be an establishment of the National Acid Attack Victims Assistance Board which will deal and provide assistance to the victims of the acid attack. This assistance would be given by the way of providing medical assistance and psychological counselling so that the victims of the attack can overcome the trauma. This board will also recommend the government to make strategies to control the production and sale of the acid in the market. The bill also suggests that there shall be a National Acid Attack Victims Fund wherein both the Central and State Government can give grants to this fund.  The bill also states that the Board can give the interim relief up to Rs. 1,00,000/- directly to the hospital within a period of 30 days.

Thus prior to the Criminal Amendment Act, 2013 there was no such strong legislation that would actually talk about the compensation or rehabilitation to the acid attack victims. Even the Prevention of Offences (Acid) Bill, 2008 was not passed. Thus, it was completely on the judiciary’s discretion as to what amount shall be compensated to the victims of acid attack. Also, earlier, these cases were focused only to provide punishment to the accused rather than creating a balance between punishments that should be given to the accused and the compensation and rehabilitation that are a right to the victims of this grave offence.

After the Criminal Law Amendment Act, 2013:

The 226^th Law Commission Report:

In the conclusion and the recommendations of the 226^th law commission report that was chaired by Justice A.R. Lakshmanan, there were several recommendations that focused on the acid attack victims. These recommendations are as follows:

• There is a need for a separate section which deals with the acid attack.
• Section 326 which deals with the voluntary causing grievous hurt by dangerous weapons or means is insufficient. The reasons are as follows: First, the definition of grievous hurt is not sufficiently broad to cover the different types of injury inflicted during acid attacks. Second, the section does not address the act of acid administration. Third, the section gives the courts wide discretion with regard to punishment. Cases of acid attacks in India show that in these cases there is normally inadequate punishment. Fourth, if there are no injuries, the I.P.C section will not punish the intentional act of throwing acid. Finally, the section does not specify who is to receive the fine.
• If a person throws or administers the acid to another person, a presumption should be raised against the person who throws or administers the acid that he has done so intentionally.
• Except for commercial and scientific purposes, the distribution and sale of acid should be prohibited. Acid should be a scheduled prohibited chemical that should not be available on the counter. The acid buyer’s details should be recorded.
• Recommend the addition of a new section 326A to the Indian Penal Code.
• The presumption is incorporated in the Indian Evidence Act as Section 114B in the case of an acid attack.
• The government shall enact a law known as the “Criminal Injuries Compensation Act” as a separate law. This law should provide temporary and final monetary compensation for victims of certain acts of violence such as rape, sexual assault, acid attacks, etc. and should cover their medical and other expenses related to rehabilitation, loss of income, etc. While calculating compensation under this Act, any compensation already received by the victim can be taken into account.
• Recommend strict regulation of the distribution and sale of acid and prohibition of the sale of acid through shop counters.

• The Criminal Law Amendment Act, 2013:
• Prior to the Criminal Law Amendment Act, 2013, Acid Attack was not mentioned in the Indian Penal Code, 1860. Thus there was always a difficulty that was faced by the prosecution as a strong case of the acid attack could not be made against the accused. He was previously prosecuted under Section 307 i.e. attempt to murder or under section 302 when the person dies.
• But after the Criminal Law Amendment Act, 2013, Section 326 A was inserted which provides that if there is an offence of acid attack, the offender will be punished with an imprisonment of not less than 10 years which may extend to life imprisonment and fine.
• With the insertion of section 326 B in the Indian Penal Code, 1860, the attempt to throw acid on a person has been made an offence. The punishment under this section is imprisonment of not less than 5 years but which may extend to 7 years and also be liable to fine.
• There was an amendment in Section 100 of the Indian Penal Code, 1860, which provides for the right to private defense. This amendment states that: The right of private defense of the body extends when someone tries to throw acid or throws acid on someone and the person acts in such a way to prevent himself/ herself from such an act.

• NALSA ( Legal Services to victims of acid attacks) Scheme, 2016:

The objectives of this scheme are as follows:

• To strengthen legal aid and representation at the national, state , district and taluka levels for victims of acid attacks in availing the benefits of various legal provisions and schemes for compensation which exist
• To enable the victims of the acid attacks to get access to medical facilities and rehabilitative services.
• To create and spread awareness about the entitlements of the victims of acid attacks through the District Legal Services Authorities, Taluka Legal Services Committees, panel lawyers, Para-legal volunteers and legal services clinics.
• To enhance capacities at all levels of panel lawyers, Para legal volunteers in legal services clinics, government officers tasked with the implementation of various schemes, service providers, police personnel, non- governmental organizations by organizing training, orientation and sensitization programs.
• To undertake research and documentation to study the various schemes, laws etc. to find out the gaps, the needs and to make suggestions to the appropriate authorities.

The plan of action of this scheme is as follows:

• Legal Representation:

All the victims of acid attack and where the acid attack results in death, the heirs of victims of acid attacks shall be provided legal aid on a priority basis in order to enable them to get the benefit of the Victim Compensation Scheme.

SLSAs and DSLAs shall ensure that the victims of acid attacks do not have to face any kind of delay in procedural wrangles and interim compensation is awarded at the earliest.

Support persons and legal representation shall be provided to victims of acid attacks during the recording of their statement under Section 164 of Cr. P.C. giving evidence etc,

Every DLSA Committee shall designate at least one-panel lawyer as Legal Services Officer for the purpose of this Scheme

The DLSA shall also depute a sufficient number of PLVs for the implementation of this Scheme.

The PLVs shall act as the interface between the victims of acid attacks and the Legal Services Institutions. All out endeavour shall be made to reach out to the acid attack victims.

• Legal Services Clinics:

SLSAs shall set up Legal Services Clinics at hospitals having specialized facilities for treatment of burns where victims of acid attacks may be referred for treatment. The PLVs and panel lawyers deputed to such Legal Services Clinics shall be in regular touch with the victims of the acid attacks and their relatives and ensure all possible help to them in securing appropriate medical help and treatment.

The PLVs shall provide assistance and support to the families of victims of acid attacks and where possible counselling for them may be arranged so as to bring them out of trauma occasioned by the incident of attack

The PLVs shall also assist the victims of acid attack in obtaining from the hospital where the victim has first treated a certificate that the individual is a victim of an acid attack which may be utilized by the victim for treatment and reconstructive surgeries or any scheme that the victim may be entitled to with the State Government or the Union Territory.

The PLVs shall ensure that the victims of acid attacks are able to avail of various rehabilitative services that may be available for them.

The Legal Services Clinics shall be communicated to all the Government bodies and departments including the police, NGOs.

The Legal Services Clinics so established shall be governed by the NALSA (Legal Services Clinics) Regulations, 2011 in respect of their functioning, infrastructural facilities, maintenance of records and registers, deputing of PLVs and control over such clinics.[14]

• The Prevention of Acid Attack and Rehabilitation of Acid Attack Victims Bill, 2017:

The objective of this bill is “to provide for the prevention of acid attacks by regulation of sale, supply and use of acid or other measures and rehabilitation of women victims of acid attacks and matters connected therewith or incidental thereto”. Chapter I of the bill provides for the scope and definitions. Section 2 (b) of the Bill defines the acid attack victims. The section defines acid attack victims as: “woman on whom acid has been poured or sprinkled with the intention of causing bodily injury or disfigurement and who, as a consequence of such act, has suffered any bodily injury or disfigurement affected by the chemical action of the acid”.[15]

Chapter II of the Bill provides for the regulation of the sale, supply, and use of acid.  Section 3 provides for the regulation of the production, sale etc. of acid. The section states that there shall be a license in order to produce, sale, import or deliver acid. There shall be proper maintenance of records if the person is having a business wherein the acids are involved. Section 4 of the bill provides that the Central Government shall prescribe the kinds and degree of acids which are to be used for the business.

Chapter III of the Bill provides for the rehabilitation of the acid attack victims. The Section 5 of the bill provides: “Where an acid attack has caused such substantial bodily harm or disfigurement to the victim, as may be prescribed, such victim shall be deemed to be a person with a disability for the purposes of availing benefits under various schemes, including employment under the Central Government, any State Government, any local body, autonomous bodies under any Government or any public sector undertakings.”[16] The Section 6 states: “Where an acid attack victim has suffered such bodily harm or disfigurement in an acid attack that it is likely to impair her chances of obtaining gainful employment or carry on any gainful occupation, the appropriate Government shall pay a monthly allowance to such victim and the amount of such allowance shall not be less than four times the amount of old-age pension payable at the place where the victim ordinarily resides.” 

Chapter IV of the Bill provides for the offences and penalties. Under this chapter if the offender does not comply to provisions of Section 3 and 4, then the penalty shall be simple imprisonment which may extend to six months or fine shall be of Rs. 5,00,000/- or both.  The punishment under Section 326 A of the Indian Penal Code, 1860 the fine is now Rs. 10,00,000/-. Similarly, under Section 326 B, the punishment is now imprisonment for 10 years and fine shall not be less than Rs. 3,00,000/-.

CHAPTER 4

CONCLUSION

Prior to the Criminal Law Amendment Act, 2013, there have been several changes in the Indian Legal System. Earlier the focus was only to prove that whether the accused has committed the offence and what punishment shall be given to the convict. But this amendment did not only bring the Section 326A and 326B in the Indian Penal Code, 1860 but also tried to make the legislation for the victims rather than making it against the accused. Meaning that now compensation and rehabilitation of the victims of acid attack are also considered and not just the punishment that is to be given to the offender.

Laxmi v. Union of India is the landmark case in which the Supreme Court gave directions to curb the practice of sale, production etc. of the acid without license and compensation that has to be given to the victims. The Constitution of India, 1950, under Article 21 provides for the right to life. This fundamental right includes right to live with dignity. The victims of the acid attack suffer a lot of societal hatred and after experiencing such an offence face a lot of difficulty in getting their lives back on track. They have the right to life, but they are not able to enjoy this fundamental right due to such an accident. Thus the Legislators of India have framed various schemes and bills which will help the victims to get their lives back to the track. The Bill of 2017 and the NALSA scheme of 2016 concentrates on the rehabilitation and compensation to the victims of acid attack.

Apart from the efforts of the Legislation, there are various NGOs which are working for the rehabilitation of the acid attack victims. One of the major NGO is Chhanv Foundation. The director of this NGO is Laxmi, who is herself an acid attack survivor. Chhanv Foundation works as a bridge between survivors and the society, as the two come to stand isolated from each other when a girl is attacked with acid. The foundation provides them with urgent and adequate medical and legal aid, and rehabilitate them by finding alternate sources of income. It also connects them with potential donors and supporters for these urgent needs. Most significantly, the organization’s endeavour is to motivate and strengthen the survivors. To reassure them that confidence can be the spring in their step, and faith can fuel their dreams.[17]

Another NGO that works for the rehabilitation of acid attack victims is Make Love Not Scars. This NGOs objective is to provide dignity and independence to acid attack survivors from all walks of life by focusing on their complete medical, legal, education, vocational and psychological rehabilitation. This NGO encourages dreaming big, fighting stereotypes and coming together as a community to ignite the hope for a promising future. Make Love Not Scars offers a safe haven for survivors as a place they can come to for love, guidance, friendships and freedom.[18] This NGO provides rehabilitation in 5 stages. These stages are:

1.     Medical

2.     Legal

3.     Educational

4.     Financial

5.     Psychological

 

Thus, with the recent development in Criminal Law of India, the provisions are now introduced keeping in mind the victims and their compensation and rehabilitation. It is important because it is the victims who have to face the entire society. It becomes very difficult for them to overcome this trauma. Thus we need better rehabilitation facilities and specially government aided so that the poor can also avail rehabilitation facilities. The compensation shall be made a bit more that can cover the medical expenses of the victims because all victims do not belong to an economically sound background. Also, the rehabilitation and compensations shall be made gender neutral because the offence of acid attack can be faced by anyone, not just women.

This change is very much welcomed by the Indian legal system as it brought a major relief to the victims and also gave them a ray of hope in order to get their lives back at track and with dignity. This came very late, but it was essential as there has been an increase in the rate of the reporting of this offence has increased as has been mentioned by the National Crime Report Bureau in State/UT-wise Cases Registered, Cases Chargesheeted, Cases Convicted, Persons Arrested, Persons Chargesheeted and Persons Convicted Attempt to Acid Attack under Crime against Women from 2014 to 2016, which has been disclosed by the Ministry of Home Affairs[19].

BIBLIOGRAPHY

Websites:

• https://data.gov.in/resources/stateut-wise-cases-registered-cases-chargesheeted-cases-convicted-persons-arrested-perso-1. 

• About us, MAKE LOVE NOT SCARS, (Last Visited on 6^th April, 2019, 10:15PM) https://makelovenotscars.org/.7.

• HELP LAXMI BUILD A HOME FOR ACID ATTACK SURVIVORS, (Last visited on 6^th April, 2019, 10:15PM) https://milaap.org/fundraisers/SDU.

• ROZLINA HUSSAIN, The most grievous assault acid attack is common in India, Why, LEGAL SERVICE INDIA (Last visited on 3^rd April, 2019, 8:50 PM) http://www.legalserviceindia.com/legal/article-196-the-most-grievous-assault-acid-attack-is-common-in-india-why.html.

Statutes/ Bill:

• Indian Penal Code, 1860
• Criminal Law Amendment Act, 2013.
• Prevention of Offences (Acid) Bill, 2008.
• The Prevention of Acid Attack and Rehabilitation of Acid Attack Victims Bill, 2017

Report and Schemes:

• 226^th Law Commission Report.
• NALSA ( Legal Services to victims of acid attacks) Scheme, 2016

Case Laws

• Bodhisattwa Gautam v. Shubhra Chakrobarty AIR 1996 SCC 922.
• W.P. (Crl.) No. 129/2006.
• State of Maharashtra v. Ankur Panwar Decided on September 2016.
• (2014) 4 SCC 427.
• 2015 (13) SCALE 325.
• Jahalli Police Station v. Josheph Rodrigues, decided on 22/08/2006.
• AIR 1975 SC 856.
• 2002 Cri Lj 1403(B).
• 2007(3) CHN 775.
• 2002 (1) ALD Cri 905.

WEBSITES REFERRED

• https://www.prsindia.org/report-summaries/justice-verma-committee-report-summary.
• https://www.grin.com/document/307901.
• https://www.usatoday.com/story/news/world/2017/07/27/acid-attacks-women-india-survivors-fight-back/486007001/.
• https://www.huffpost.com/entry/acid-attack-in-india-wher_b_9559790.
• https://slate.com/news-and-politics/2013/02/history-of-acid-violence-when-did-people-start-throwing-vitriol.html.
• https://www.gktoday.in/gk/acid-attacks-in-india-and-preventive-measures/.
• https://blog.ipleaders.in/acid-attack-sentencing-legislation-india/.
• https://blog.ipleaders.in/acid-attack-and-the-law-in-india/.

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[1] (2014) 4 SCC 427.

[2] ROZLINA HUSSAIN, The most grievous assault acid attack is common in India, Why, LEGAL SERVICE INDIA (Last visited on 3^rd April, 2019, 8:50 PM) http://www.legalserviceindia.com/legal/article-196-the-most-grievous-assault-acid-attack-is-common-in-india-why.html.

[3] ROZLINA HUSSAIN, The most grievous assault acid attack is common in India, Why, LEGAL SERVICE INDIA (Last visited on 3^rd April, 2019, 8:50 PM) http://www.legalserviceindia.com/legal/article-196-the-most-grievous-assault-acid-attack-is-common-in-india-why.html.

[4] 2002 (1) ALD Cri 905.

[5] Jahalli Police Station v. Josheph Rodrigues, decided on 22/08/2006.

[6] AIR 1975 SC 856.

[7] 2002 Cri Lj 1403(B).

[8] 2007(3) CHN 775.

[9]  (2014) 4 SCC 427.

[10] 2015 (13) SCALE 325.

[11]  State of Maharashtra v. Ankur Panwar Decided on September 2016.

[12] Bodhisattwa Gautam v. Shubhra Chakrobarty AIR 1996 SCC 922.

[13]  W.P. (Crl.) No. 129/2006.

[14] NALSA ( Legal Services to victims of acid attacks) Scheme, 2016.

[15] §2(b) The Prevention of Acid Attack and Rehabilitation of Acid Attack Victims Bill, 2017.

[16] §5 The Prevention of Acid Attack and Rehabilitation of Acid Attack Victims Bill, 2017.

[17] HELP LAXMI BUILD A HOME FOR ACID ATTACK SURVIVORS, (Last visited on 6^th April, 2019, 10:15PM) https://milaap.org/fundraisers/SDU.

[18] About us, MAKE LOVE NOT SCARS, (Last Visited on 6^th April, 2019, 10:15PM) https://makelovenotscars.org/.

[19] https://data.gov.in/resources/stateut-wise-cases-registered-cases-chargesheeted-cases-convicted-persons-arrested-perso-1.